&EPA
United States
Environmental Protection
Agency
1200 Pennsylvania Avenue, N.W.
Washington, D.C. 20460
Office of Solid Waste and Emergency Response
December 2014
Support Document for the
Revised National Priorities List
Final Rule - Colorado Smelter
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Support Document for the
Revised National Priorities List
Final Rule
Colorado Smelter
December 2014
Site Assessment and Remedy Decisions Branch
Office of Superfund Remediation and Technology Innovation
Office of Solid Waste and Emergency Response
U.S. Environmental Protection Agency
Washington, DC 20460
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Colorado Smelter Response to Comments NPL Listing Support Document
December 2014
Table of Contents
Executive Summary iii
Introduction iv
Background of the NPL iv
Development of the NPL iv
Hazard Ranking System v
Other Mechanisms for Listing vi
Organization of this Document vi
Glossary vii
1. List of Commenters and Correspondence 1
2. Site Description 3
3. Summary of Comments 9
3.1 General Support for Listing 10
3.2 Conditional Support for EPA Cleanup 10
3.3 Consistency with Data Quality Program 12
3.3.1 Sampling and Analysis Plan 17
3.3.1.1 Conceptual Site Model 18
3.3.1.2 Decision Rules and Acceptable Uncertainty 19
3.3.2 Completion of Data Quality Assessment 20
3.4 Adequacy of Public Docket/Requests for Additional Documents 21
3.4.1 Project-specific QAPP 22
3.4.2 Sampling and Analysis Plan/Data Quality Objectives 23
3.4.3 Project Plan and SOPs 24
3.4.4 SOP-specified Site Diagrams 24
3.4.5 Data Quality Assessment 25
3.4.6 Preliminary Assessment XRF Data 25
3.5 Requests to Extend Comment Period 26
3.6 Risk to Human Health and the Environment 27
3.7 Remediation and Cleanup Levels 28
3.8 Purpose of Listing 29
3.9 Impacts of Listing 30
3.10 Extent of Site 31
3.11 Comments on Reference Material and Factual Errors 31
3.11.1 Number of Aliquots per Multi-increment Sample 31
3.11.2 Number of Locations Sampled 32
3.11.3 Classification of Grab Samples 33
3.11.4 2011 Analytical Results Report Reference List Items 34
3.11.5 QAPP and Appendix H 34
3.12 Identification of Observed Contamination - Soil Collection Technique 35
3.13 Identification of Observed Contamination - Background Level 39
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3.14 Identification of Observed Contamination - Significant Increase Criteria 44
3.15 Identification of Observed Contamination - Contaminated Samples 45
3.16 Attribution 49
3.16.1 Distribution of Lead in Soil - Lack of Concentration Cluster 52
3.16.2 Distribution of Lead in Soil - Variability 59
3.16.3 Arsenic Levels in Soil vs Arsenic Levels in Slag 60
3.16.4 Arsenic/Lead Ratios - Distribution of Arsenic Relative to Lead 61
3.16.5 Comparison of Site-related and Greater Area-related Datasets 62
3.16.6 Other Sources 65
4. Conclusion 67
Attachment 1 March 2000 CDPHE QAPP for Site Assessments Under Superfund
Attachment 2 August 31, 2012 letter from the EPA to the Pueblo City Council
Attachment 3 Excerpt of USGW Open File Report 81-197
Attachment 4 Wilcoxon Rank-Sum Test Calculations
Attachment 5 Colorado Smelter Outreach Timeline
Attachment 6 Figure 4 of Mr. Coomes' Comment Submittal
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Executive Summary
Section 105(a)(8)(B) of CERCLA, as amended by SARA, requires that the EPA prepare a list of national
priorities among the known releases or threatened releases of hazardous substances, pollutants, or contaminants
throughout the United States. An original National Priorities List (NPL) was promulgated on September 8, 1983
(48 FR 40658). CERCLA requires that EPA update the list at least annually.
This document provides responses to public comments received on the Colorado Smelter site, proposed on May
12, 2014 (79 FR 26922). This site is being added to the NPL based on an evaluation under EPA's Hazard Ranking
System (HRS) in a final rule published in the Federal Register in September 2014.
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Colorado Smelter Response to Comments NPL Listing Support Document
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Introduction
This document explains the rationale for adding the Colorado Smelter site in Pueblo, Colorado to the National
Priorities List (NPL) of uncontrolled hazardous waste sites and provides responses to public comments received
on this site listing proposal. The EPA proposed this site to the NPL on May 12, 2014 (79 FR 26922). This site is
being added to the NPL based on an evaluation under the Hazard Ranking System (HRS) in a final rule published
in the Federal Register in December 2014.
Background of the NPL
In 1980, Congress enacted the Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA), 42 U.S.C. Sections 9601 et seq. in response to the dangers of uncontrolled hazardous waste sites.
CERCLA was amended on October 17, 1986, by the Superfund Amendments and Reauthorization Act (SARA),
Public Law No. 99-499, stat., 1613 et seq. To implement CERCLA, EPA promulgated the revised National Oil
and Hazardous Substances Pollution Contingency Plan (NCP), 40 CFR Part 300, on July 16, 1982 (47 FR 31180),
pursuant to CERCLA Section 105 and Executive Order 12316 (46 FR 42237, August 20, 1981). The NCP, further
revised by EPA on September 16, 1985 (50 FR 37624) and November 20, 1985 (50 FR 47912), sets forth
guidelines and procedures needed to respond under CERCLA to releases and threatened releases of hazardous
substances, pollutants, or contaminants. On March 8, 1990 (55 FR 8666), EPA further revised the NCP in
response to SARA.
Section 105(a)(8)(A) of CERCLA, as amended by SARA, requires that the NCP include
criteria for determining priorities among releases or threatened releases throughout the United
States for the purpose of taking remedial action and, to the extent practicable, take into account
the potential urgency of such action, for the purpose of taking removal action.
Removal action involves cleanup or other actions that are taken in response to emergency conditions or on a
short-term or temporary basis (CERCLA Section 101). Remedial action is generally long-term in nature and
involves response actions that are consistent with a permanent remedy for a release (CERCLA Section 101).
Criteria for placing sites on the NPL, which makes them eligible for remedial actions financed by the Trust Fund
established under CERCLA, were included in the HRS. EPA promulgated the HRS as Appendix A of the NCP
(47 FR 31219, July 16, 1982). On December 14, 1990 (56 FR 51532), EPA promulgated revisions to the HRS in
response to SARA, and established the effective date for the HRS revisions as March 15, 1991.
Section 105(a)(8)(B) of CERCLA, as amended, requires that the statutory criteria provided by the HRS be used to
prepare a list of national priorities among the known releases or threatened releases of hazardous substances,
pollutants, or contaminants throughout the United States. The list, which is Appendix B of the NCP, is the NPL.
An original NPL of 406 sites was promulgated on September 8, 1983 (48 FR 40658). At that time, an HRS score
of 28.5 was established as the cutoff for listing because it yielded an initial NPL of at least 400 sites, as suggested
by CERCLA. The NPL has been expanded several times since then, most recently on September 22, 2014 (79 FR
56515). The Agency also has published a number of proposed rulemakings to add sites to the NPL. The most
recent proposal was on September 22, 2014 (79 FR 56538).
Development of the NPL
The primary purpose of the NPL is stated in the legislative history of CERCLA (Report of the Committee on
Environment and Public Works, Senate Report No. 96-848, 96th Cong., 2d Sess. 60 [1980]).
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Colorado Smelter Response to Comments NPL Listing Support Document
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The priority list serves primarily informational purposes, identifying for the States and the public
those facilities and sites or other releases which appear to warrant remedial actions. Inclusion of a
facility or site on the list does not in itself reflect a judgment of the activities of its owner or
operator, it does not require those persons to undertake any action, nor does it assign liability to
any person. Subsequent government actions will be necessary in order to do so, and these actions
will be attended by all appropriate procedural safeguards.
The NPL, therefore, is primarily an informational and management tool. The identification of a site for the NPL is
intended primarily to guide EPA in determining which sites warrant further investigation to assess the nature and
extent of the human health and environmental risks associated with the site and to determine what CERCLA-
financed remedial action(s), if any, may be appropriate. The NPL also serves to notify the public of sites EPA
believes warrant further investigation. Finally, listing a site may, to the extent potentially responsible parties are
identifiable at the time of listing, serve as notice to such parties that the Agency may initiate CERCLA-financed
remedial action.
CERCLA Section 105(a)(8)(B) directs EPA to list priority sites among the known releases or threatened release
of hazardous substances, pollutants, or contaminants, and Section 105(a)(8)(A) directs EPA to consider certain
enumerated and other appropriate factors in doing so. Thus, as a matter of policy, EPA has the discretion not to
use CERCLA to respond to certain types of releases. Where other authorities exist, placing sites on the NPL for
possible remedial action under CERCLA may not be appropriate. Therefore, EPA has chosen not to place certain
types of sites on the NPL even though CERCLA does not exclude such action. If, however, the Agency later
determines that sites not listed as a matter of policy are not being properly responded to, the Agency may consider
placing them on the NPL.
Hazard Ranking System
The HRS is the principle mechanism EPA uses to place uncontrolled waste sites on the NPL. It is a numerically
based screening system that uses information from initial, limited investigationsthe preliminary assessment and
site inspectionto assess the relative potential of sites to pose a threat to human health or the environment. HRS
scores, however, do not determine the sequence in which EPA funds remedial response actions, because the
information collected to develop HRS scores is not sufficient in itself to determine either the extent of
contamination or the appropriate response for a particular site. Moreover, the sites with the highest scores do not
necessarily come to the Agency's attention first, so that addressing sites strictly on the basis of ranking would in
some cases require stopping work at sites where it was already underway. Thus, EPA relies on further, more
detailed studies in the remedial investigation/feasibility study that typically follows listing.
The HRS uses a structured value analysis approach to scoring sites. This approach assigns numerical values to
factors that relate to or indicate risk, based on conditions at the site. The factors are grouped into three categories.
Each category has a maximum value. The categories are:
likelihood that a site has released or has the potential to release hazardous substances into the
environment;
characteristics of the waste (toxicity and waste quantity); and
people or sensitive environments (targets) affected by the release.
Under the HRS, four pathways can be scored for one or more threats as identified below:
Ground Water Migration (Sgw)
- drinking water
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Surface Water Migration (Ssw)
The following threats are evaluated for two separate migration components, overland/flood migration and
ground water to surface water.
- drinking water
- human food chain
- sensitive environments
Soil Exposure (Ss)
- resident population
- nearby population
- sensitive environments
Air Migration (Sa)
- population
- sensitive environments
After scores are calculated for one or more pathways according to prescribed guidelines, they are combined using
the following root-mean-square equation to determine the overall site score (S), which ranges from 0 to 100:
If all pathway scores are low, the HRS score is low. However, the HRS score can be relatively high even if only
one pathway score is high. This is an important requirement for HRS scoring because some extremely dangerous
sites pose threats through only one pathway. For example, buried leaking drums of hazardous substances can
contaminate drinking water wells, butif the drums are buried deep enough and the substances not very
volatilenot surface water or air.
Other Mechanisms for Listing
There are two mechanisms other than the HRS by which sites can be placed on the NPL. The first of these
mechanisms, authorized by the NCP at 40 CFR 300.425(c)(2), allows each State and Territory to designate one
site as its highest priority regardless of score. The last mechanism, authorized by the NCP at 40 CFR
300.425(c)(3), allows listing a site if it meets the following three requirements:
Agency for Toxic Substances and Disease Registry (ATSDR) of the U.S. Public Health Service has
issued a health advisory that recommends dissociation of individuals from the release;
EPA determines the site poses a significant threat to public health; and
EPA anticipates it will be more cost-effective to use its remedial authority than to use its emergency
removal authority to respond to the site.
Organization of this Document
The following section contains EPA responses to site-specific public comments received on the proposal of the
Colorado Smelter site on May 12, 2014 (79 FR 26922). The site discussion begins with a list of commenters,
followed by a site description, a summary of comments, and Agency responses to each comment. A concluding
statement indicates the effect of the comments on the HRS score for the site.
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Glossary
The following acronyms and abbreviations are used throughout the text:
% Percent
Agency U.S. Environmental Protection Agency
AMC Anaconda Minerals Company
AOC Area of Observed Contamination
ARR Analytical Results Report
ASARCO American Smelting and Refining Company
ATSDR Agency for Toxic Substances and Disease Registry
BLL Blood Lead Level
CDC Center for Disease Control and Prevention
CDPHE Colorado Department of Public Health and Environment
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act of 1980, 42
U.S.C. Sections 9601 etseq., also known as Superfund
CF&I Colorado Fuel and Iron Company
CFR Code of Federal Regulations
CLP Contract Laboratory Program
CRP Community Relations Plan
CSM Conceptual Site Model
DQA Data Quality Assessment
DQO Data Quality Objective
EPA U.S. Environmental Protection Agency
FR Federal Register
HRS Hazard Ranking System, Appendix A of the NCP
HRS score Overall site score calculated using the Hazard Ranking System; ranges from 0 to 100
|jg Microgram
|jg/dl Microgram per deciliter
mg/kg Milligram per kilogram
NCP National Oil and Hazardous Substances Pollution Contingency Plan, 40 C.F.R. Part 300
NPL National Priorities List, Appendix B of the NCP
PPM Parts per million
PA Preliminary Assessment
QAPP Quality Assurance Project Plan
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RCRA
Resource Conservation and Recovery Act
Ref.
Reference
RI/FS
Remedial Investigation/Feasibility Study
ROD
Record of Decision
SAP
Sampling and Analysis Plan
SARA
Superfund Amendments and Reauthorization Act
SOP
Standard Operating Procedure
SQL
Sample Quantitation Limit
START
Superfund Technical Assessment and Response Team
SWMU
Solid Waste Management Unit
TSOP
Technical Standard Operating Procedure
UOS
URS Operating Services
USGS
United States Geological Survey
VA
United States Department of Veterans Affairs
XRF
X-ray Fluorescence
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Colorado Smelter Response to Comments NPL Listing Support Document
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1. List of Commenters and Correspondence
EPA-HQ-SFUND-2014-0318-0004
EPA-HQ-SFUND-2014-0318-0005
EPA-HQ-SFUND-2014-0318-0006
Correspondence, dated January 21, 2014, from the Honorable
John W. Hickenlooper, Governor of the State of Colorado to
Shaun McGrath, Regional Administrator, U.S. EPA Region 8.
Correspondence, dated June 11, 2012, from the James B. Martin,
Regional Administrator, U.S. EPA Region 8 to the Honorable
John W. Hickenlooper, Governor of the State of Colorado.
Comment, submitted May 14, 2014, from an anonymous
commenter.
EPA-HQ-SFUND-2014-0318-0007
Comment, submitted May 19, 2014, from an anonymous
commenter.
EPA-HQ-SFUND-2014-0318-0008
Comment, submitted June 13, 2014, from an anonymous
commenter.
EPA-HQ-SFUND-2014-0318-0009
EPA-HQ-SFUND-2014-0318-0010
Comment, submitted July 8, 2014, from Matt Reed,
Conservation Programs Coordinator, Sierra Club, Rocky
Mountain Chapter.
Comment, submitted July 9, 2014, from Joe Kocman and Pam
Kocman.
Comment attachment, dated January 21, 2014, Correspondence
from Governor John W. Hickenlooper, Colorado to Shaun
McGrath, Regional Administrator, U.S. EPA Region 8.
Comment attachment, submitted July 9, 2014, Guidelines for the
Superfund Designation "Letter to the Governor."
Comment attachment, January 10, 2014, Correspondence from
Sandra K. Daff (Pueblo City Councilwoman), Pam Kocman
(Eiler Heights Neighborhood Association), and David C. Balsick
(Bessemer Association for Neighborhood Development) to the
Honorable John W. Hickenlooper, Governor of the State of
Colorado.
Comment attachment, December 31, 2013, Correspondence from
the City Council, City of Pueblo, Colorado and the Board of
County Commissioners, Pueblo County, Colorado, to the
Honorable John W. Hickenlooper, Governor of the State of
Colorado.
EPA-HQ-SFUND-2014-0318-0011
Comment, submitted July 9, 2014, from Joe Kocman and Pam
Kocman.
EPA-HQ-SFUND-2014-0318-0012
Comment, submitted July 9, 2014, from Joe Kocman and Pam
Kocman.
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EPA-HQ-SFUND-2014-0318-0013
Comment, submitted July 9, 2014, from Joe Kocman and Pam
Kocman.
EPA-HQ-SFUND-2014-0318-0014
Comment, submitted July 10, 2014, from Joe Kocman and Pam
Kocman.
EPA-HQ-SFUND-2014-0318-0015
EPA-HQ-SFUND-2014-0318-0016
Comment, dated July 10, 2014, from Eileen Dennis (Board
President, Terry A. Heart (Board Member), Michael J.
Nerenberg (Board Member), Donald Moore (Board Member),
Pueblo City-County Health Department Board of Health.
Comment, dated July 13, 2014, from Velma Campbell, MD,
MPH.
EPA-HQ-SFUND-2014-0318-0017
EPA-HQ-SFUND-2014-0318-0018
EPA-HQ-SFUND-2014-0318-0019
Comment, dated July 8, 2014, from Terry A. Hart,
Commissioner, Board of County Commissioners.
Comment, dated July 11, 2014, from Ross Vincent, Chair,
Sierra Club, Sangre de Cristo Group.
Comment, dated July 11, 2014, from Pam, Don, and Joshua
DiFatta.
EPA-HQ-SFUND-2014-0318-0020
Comment, dated July 11, 2014, from Merril Coomes, including
four figures1 and three tables.
Comment attachment, U.S. EPA, SOP #SRC-OGDEN-02
Surface Soil Sampling.
Comment attachment, Discussion of Particulate Deposition and
Soil Lead Concentration Distribution at the Historic Colorado
Smelter Site.
Comment attachment, Colorado Background Soil Lead.
Comment attachment, EPA Region 8 Conceptual Site Model for
Historic Smelters.
Comment attachment, Analysis of lead concentration vs.
Distance from the Historic Colorado Smelter Site.
1 Note that the figures attached to Mr. Coomes' comment submittal are subject to restricted access via Regulations.gov (the
website providing public users ease of access to federal regulatory content and a way to submit comments on agencies'
regulatory documents published in the Federal Register) due to inclusion of Google Maps-related copyrighted data. The
document can instead be viewed at the USEPA Docket Center (Public Reading Room. Address: USEPA West 1301
Constitution Ave, NW Room 3334 Washington, DC 20004 Telephone: 202-566-1744 Fax: 566-9744 Email: docket-
customerservice@epa.gov), or at the EPA Region 8 docket (contact information for the EPA Region 8 docket: Sabrina
Forrest, Region 8, U.S. EPA, 1595 Wynkoop Street, Mailcode 8EPR-B, Denver, CO 80202-1129; 303/312-6484).
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Comment attachment, Soil Remediation may not Reduce Child
Blood Lead Levels.
2. Site Description
The Colorado Smelter site (the Site) as identified in the HRS documentation record at proposal includes three
areas or sources of contamination: (1) an area of observed contamination (AOC) in residential soils referred to as
AOC A; (2) residual slag material that remains on-site referred to as AOC B; and (3) historic smelter stacks that
emitted particulates that were dispersed to areas surrounding the Site resulting in contamination of the soil in the
neighborhoods located nearby. AOC A involves 176 residences scored as subject to Level I or Level II
concentrations. (See Figure 1 of this support document showing AOCs A and B.)
The Colorado Smelter, also known as the Boston Smelter or the Eilers Smelter, after its builder, Anton Eilers,
operated from 1883 until 1908. The former smelter, located in Pueblo, Colorado, south of the Arkansas River at
the south end of Santa Fe Avenue, was one of five smelters operating in the City of Pueblo and its nearby
subdivisions between the 1880's and the 1920's. These included the Colorado Smelter, the Pueblo Smelter, the
Philadelphia Smelter, the Massachusetts Smelter, and the Blende Smelter. (See Figure 3 of this support document
for these smelter locations.)
The Colorado Smelter facility components changed over the course of its operation. The Colorado Smelter facility
included a blast furnace building that measured 127 feet long, 45 feet wide, and 39 feet high, and housed 4 water-
jacketed blast furnaces with a melting capacity of 168 tons of ore per day. Historical maps, including official city
maps and Sanborn Fire Insurance maps, show the location of the Colorado Smelter and other smelters in Pueblo.
Comparison of Sanborn Maps of 1889 and 1904/05 reveals the smelter underwent considerable expansion to the
south to Mesa Avenue with the addition of several roaster houses and a 200-foot-tall brick chimney and two 125-
foot-tall chimneys in the southern part of the facility. The further addition of two more blast furnaces by 1904/05
increased the capacity of the smelter by fifty percent. Historical photographs of the Colorado Smelter show the
smelter building and smoke stacks with smoke plumes drifting southeast. Some of the slag generated by the
smelter was removed and used as track ballast, although significant amounts of slag remain at the property. In
1923, the smelter stack was demolished and some of the bricks were used to build a school. At present, there are
remnants of destroyed buildings and large slag piles at the Colorado Smelter property.
Several previous investigations have been performed at the Colorado Smelter and at nearby locations by the
Colorado Department of Public Health and Environment (CDPHE) and the United States Environmental
Protection Agency (EPA) including an investigation that was conducted at the Santa Fe Street Bridge, adjacent to
and north of the Colorado Smelter facility. CDPHE performed the first sampling event for the Santa Fe Avenue
Bridge Culvert/Colorado Smelter on April 14, 1992. A sample of the slag pile, SF-SS-3, was found to contain
lead at a concentration of 1,950 milligrams per kilogram (mg/kg) (equivalent to parts per million [ppm]). Two
residential soil samples collected near the smelter, samples SF-SO-02 and SF-SO-03, contained lead at
concentrations of 239 and 336 mg/kg, respectively. Other investigations included a more geographically extensive
sampling by CDPHE in September 1994; an in-situ X-ray Fluorescence (XRF)2 screening investigation of the
Colorado Smelter facility performed by the EPA on May 10, 1995; a detailed investigation of the Colorado
Smelter slag pile performed by the EPA on August 17 and 18, 1995; and a preliminary assessment (PA) report
prepared by CDPHE in 2008.3
2 XRF is an instrumental analytical technique used to determine the elemental composition of a sample by bombarding a
sample with X-rays and measuring the fluoresced X-rays characteristic to each element.
3 See the following references of the HRS documentation record at proposal: Reference 14, describing results from the
September 1994 investigation; Reference 15, describing results from the May 10, 1995 investigation; Reference 16,
describing results from the August 17 and 18, 1995 activities; and Reference 19 for the PA report.
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A study of the metal content of surface soils in Pueblo conducted by affiliates of Colorado State University was
published in 2006 (also referred to in this support document as the Diawara study). A total of 68 soil samples
were collected at 33 locations in a coarsely spaced grid. The average lead concentration was 88 ppm, over 5 times
the average for the conterminous U.S. of 16 ppm and twice the average of 35 ppm reported for soils in the Front
Range Urban Corridor of Colorado. The average arsenic concentration was 12.6 ppm, 2.4 times higher than the
average of 5.2 ppm reported for the conterminous U.S., and 3.6 times higher than the average of 3.5 ppm reported
for soils in the Front Range Urban Corridor.
In 2010, CDPHE prepared a Site Inspection Sampling and Analysis Plan (the CDPHE May 2010 SAP) and
sampling activities were conducted June 21-23, 2010. Soil and waste sample results from this investigation were
used in the HRS documentation record at proposal to establish AOC A and AOC B. Soil samples were collected
from 57 locations including 47 residential properties, 3 vacant lots, 1 road right-of-way, 4 slag piles, and 2
background areas. The results of this CDPHE 2010 site inspection were detailed in a CDPHE June 2011
Analytical Results Report (ARR). Additionally, six surface water samples, including one duplicate, were collected
from on-site, probable points of entry (PPE) to surface water, and the Arkansas River. Four co-located sediment
samples were also collected. All surface water and sediment samples were sent to an analytical laboratory for
analysis of metals through EPA's Contract Laboratory Program (CLP). The samples were submitted to ChemTech
Consulting Group for analysis of total and dissolved metals by ICP-MS (ILM05.4). None of these samples,
however, were submitted for XRF analysis.
The CDPHE 2010 site inspection background soil samples were collected approximately 2 miles northwest of the
Colorado Smelter and outside the area likely to be impacted by emissions from the former smelter. The suitability
of these samples to represent background soil levels of arsenic and lead for this site was corroborated based on: 1)
correspondence with the U.S. Geological Survey (USGS) regarding naturally occurring soil metal levels; 2) the
results of three background soil samples collected on September 29, 1994, for the Santa Fe Avenue Bridge
Culvert ESI; and 3) the results of a 2006 study of arsenic, cadmium, lead and mercury in surface soil in Pueblo.
All of the CDPHE 2010 site inspection soil samples were collected using a multi-incremental sampling technique.
Residential yards with homes were divided into one to four zones, or decision units, including the front yard, back
yard, and side yards. (See Figure 2 of this support document for CDPHE 2010 site inspection soil sample
locations.) The number of zones sampled per residence depended on site-specific conditions such as the size of
the side yards and the extent of paved areas. In each zone, five individual aliquots4 were collected. Based on the
small lot sizes, all of the individual aliquots for all 47 residential properties' samples were collected within 200
feet of the houses. Five individual aliquots were also collected from four vacant lots or road rights-of-way, two
background areas and four slag piles. All samples were collected from the top 2 inches of the ground surface. A
total of 434 individual samples were collected in 1-quart plastic bags.
All of the collected soil samples were analyzed using XRF. Additionally, a subset of the soil samples were
submitted for confirmatory analysis through the EPA's CLP as a quality control (QC) protocol for XRF analysis.
The basis for the Colorado Smelter site score is the CLP data; specifically, CLP analytical results of individual
aliquot samples.
These CLP data were used to establish an area of observed contamination (AOC A) for lead for residential soils.
XRF analyses are also presented to provide additional evidence supporting the background and release sample
concentrations and to provide confirmation that the area between the observed contamination sample locations, as
defined by CLP aliquot samples, is contaminated. Data from this CDPHE 2010 site inspection were also used to
establish an AOC for the slag pile (AOC B) based on CLP aliquot samples. (See Figure 1 of this support
document depicting AOC A and AOC B.)
4 In this context, an aliquot is an individual sample collected for chemical analysis.
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All 434 of the aliquot samples were delivered to URS Operating Services (UOS), EPA's Superfund Technical
Assessment and Response Team (START) laboratory in Denver, Colorado. The samples were analyzed directly in
the bags using the XRF. Subsequently, the samples were composited, dried, sieved, placed in method-specific
polyethylene sample cups per EPA Method SW-846 6200 guidelines, and analyzed with XRF. The 434 aliquot
samples were thus combined into 87 multi-increment samples (also known as composite samples), including 77
residential soil samples (from 47 different properties), 3 vacant lot samples, 1 road right-of-way sample, 2
background samples, and 4 source samples. In summary, a total of 521 samples, including 434 individual aliquots
and 87 composites, were analyzed for metals in soil with XRF using applicable sections of EPA Method 6200.
Fifty-seven samples, representing the full range of lead concentrations of the sample set (and selected based on
XRF analysis results), were submitted for confirmatory analysis through the EPA's CLP as a QC protocol for
XRF analysis. Prepared composite samples (in XRF cups) were sent intact, and aliquot samples were divided
evenly after homogenization and XRF analysis. Eleven composite samples and 46 aliquot samples (including 2
duplicates) for analysis under the CLP were delivered to: Sentinel, Inc., 4733 Commercial Drive, Huntsville,
Alabama 35801via Federal Express. The samples were analyzed for Target Analyte List (TAL) Metals without
mercury by Atomic Emission Spectroscopy-Inductively Coupled Plasma (AES-ICP), by EPA Method CLP
ISM01.2.
Both CLP and XRF data were validated. And, a comparison between XRF and laboratory lead results was
performed using a routine statistical regression analysis. A correlation graph for lead results in the two data sets,
XRF and CLP analyses, is presented in the CDPHE June 2011 ARR and in the March 2012 Data Quality
Assessment (DQA) prepared by UOS, EPA's START 3 contractor. The coefficient of correlation (r2) value for
lead was 0.869, demonstrating there is excellent correlation between the XRF and CLP lab data. Any data sets
demonstrating an r2 value of 0.85 to 1.0 is considered a definitive data quality level, meaning the sets show
statistically similar results.
The HRS documentation record at proposal details that smelter stack emissions contain particulates of heavy
metals, and that in the smelting process, it is not possible to separate all the desired metal from other products
including slag and flue dust. Samples of the slag generated by the Colorado Smelter contain lead and arsenic, and
the ore from the Madonna mine processed at the Colorado Smelter contained 30 percent lead. While the Agency
could not sample flue dust samples from the Colorado Smelter, flue dust samples collected from the Anaconda
Minerals Company (AMC) smelter in Montana contained arsenic and lead at concentrations up to 14,300 ppm and
55,000 ppm, respectively. Slag from the AMC smelter contained arsenic and lead at concentrations of 217 ppm
and 3,120 ppm, respectively. In comparison, the average concentrations of arsenic and lead in slag for the
Colorado Smelter based on 9 CLP aliquot samples are 503 and 10,333 ppm, respectively, further indicating that
stack emissions from the Colorado Smelter also contained arsenic and lead.
Prevailing winds at the Colorado Smelter during the time of operation were out of the north and northwest as
noted on Sanborn Fire Insurance Maps for the years 1883-1904. Wind rose diagrams from a meteorological
station located just south of the Colorado Smelter on the Rocky Mountain Steel Mill for the time periods January
1, 2003 - December 31, 2005, and March 1, 2008 - February 28, 2009, show prevailing winds out of the west-
northwest, supporting this general wind direction. AOC A is located within 1,800 feet of the northern (and most
distant) smoke stack and within 1,663 feet of the southern (and closer) smoke stack (see Figure 1 of this support
document). The proximity of the stacks to AOC A, along with the historic prevailing wind direction, provide
additional evidence that at least a portion of the significant increase in lead and arsenic in AOC A is attributable
to the Colorado Smelter stacks. This attribution is also corroborated by the 1995 ARR for the Santa Fe Avenue
Bridge Culvert study and the study of the metal content of surface soils in Pueblo conducted by affiliates of
Colorado State University and published in 2006 (the Diawara study).
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Colorado Smelter Response to Comments NPL Listing Support Document
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Legend
ฆ Main Stack and Chimney Locations
CDPHE 2010 Slag Pile Samples (CLP Aliquots)
__) Area B Slag Pile
pDPHE 2010 Residential Soil Samples (CLP Aliquots)
Lead
<69 mg/kg (below 3x CLP Aliquot BG)
> 69 mg/kg (above 3x CLP Aliquot BG)
;DPHE 2010 Residential Soil Samples (XRF Composites)
_ead
c 141 mg/kg (below 3* XRF bg)
H > 141 mg/kg (above 3x XRF bg)
Area A Residential Soil
Residential Lots within Area A
_J_FornTe^^ojor3do_Smelte^U|catior^^^^^^^^_
Wv
Sourceof the Aerial Photograph basemap: htfp:/AwM\gisxo.puebto.oo.us/imagery.h/r^(Ref. 3? T
Sourceof the parcel data (lot outline5):http;//www.gis.co.pueblo co.us/landbase.htm (Ref. 36)
Source of the former Colorado Smelter location: Ref. 7 1897 Map of Pueblo compiled from official records
and Ref fid. Sheet 157. Source of CDPHE 2010 Sampling Data: Ref. 22
Source of the Slag Pile Outline: Ref, 27
Source of the Stack and Chimney Locations: Ref. 8c, Sheet 23, Ref. 8d, Sheet 157
Figure*: Deptcang
Area A: Residential Soil and
Area B; Slag Pile
April 4, 2012
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Colorado Smelter Response to Comments NPL Listing Support Document
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Figure 2: CDPHE 2010 site inspection sample locations.
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Colorado Smelter Response to Comments NPL Listing Support Document
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1.000 2,000
4,000
Pueblo Smelter
(former location)
x,i 332
Colorado Smelter
(former location)
Blende Smelter
(former location)
Massachusetts Smelter
(former location)
Rocky Mountain Steel Mills
(formerly Colorado Fuel and Iron)
\ Philadelphia Smelter
;J (former location)
Colorado Smelter Pueblo
Figure 1:
Pueblo former Smelter
Locations
Source of the Aerial Photograph basemap: Ref. 37 NAIP 2009 (National Agricultural Imagery Project;
Source of the former smelter locations: Ref. 7 1897 Map of Pueblo compiled from official records anc
Ftef. 8 Sanbojrn Maps 1883^-2004/05 _
March 27, 2012
Figure 3: Pueblo Former Smelter Locations.
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Colorado Smelter Response to Comments NPL Listing Support Document
December 2014
3. Summary of Comments
The Honorable John Hickenlooper, Governor of Colorado; Terry Hart; the Pueblo City-County Health
Department Board of Health; the City Council, the City of Pueblo; the Board of County Commissioners, Pueblo
County; Velma Campbell; Pam, Don, and Joshua DiFatta; the Sierra Club Rocky Mountain Chapter; and the
Sangre de Cristo Group of the Sierra Club all expressed their support for the placement of the Site on the NPL.
The Honorable John Hickenlooper, Governor of Colorado; Sandra Daff, Pueblo City Councilwoman; Eiler
Heights Neighborhood Association; the Bessemer Association for Neighborhood Development; Joe and Pam
Kocman; and one anonymous public commenter provided support for the placement of the Site on the NPL with
conditions.
Several public commenters opposed the listing of the Colorado Smelter site on the NPL. Two anonymous public
commenters commented that the placement of the Site on the NPL will negatively impact property values because
banks will not provide Federal Housing Administration-insured or U.S. Department of Veterans Affairs (VA)
loans for subsequent purchase of homes in the Site vicinity. Joe and Pam Kocman asserted that homeowners
should not bear the cost associated with testing and abatement. One anonymous public commenter commented
that it was suspicious that the EPA was listing the Colorado Smelter site at this time due to the proposed listing
coinciding with the American Smelting and Refining Company (ASARCO) 2009 bankruptcy settlement. One
anonymous public commenter commented that the EPA had not clarified the extent of the Site.
Two anonymous commenters commented regarding the risk associated with the levels of contaminants detected,
noting that the blood lead levels of arsenic and lead were very low. Mr. Merril Coomes commented that the EPA
Superfund remedial goals for lead levels in residential soil are inconsistent with Center for Disease Control and
Prevention (CDC) recommendations. Joe and Pam Kocman asserted that the EPA should change its blood lead
level to coincide with levels acceptable to the CDC. In addition Mr. Coomes questioned whether the cleanup of
the emissions from the smelter would actually result in the reduction of risk.
Mr. Coomes identified several items that he asserted were either missing from the public docket or not discussed
in the provided documentation and should be provided for review or prepared; these items include a Data Quality
Assessment Report, Quality Assurance Project Plan (QAPP) for the Site, Conceptual Site Model (CSM), Standard
Operating Procedures (SOPs), SOP-specified Site Diagrams, and a complete set of PA XRF data. Mr. Coomes
requested an extension to the comment period to review the several documents requested related to the proposed
listing of the Colorado Smelter site on the NPL.
Mr. Coomes questioned the EPA's adherence to EPA guidance related to quality assurance and data quality. Mr.
Coomes commented that EPA's Guidance was not followed in the preparation of the CDPHE May 2010 SAP. Mr.
Coomes asserted that the EPA did not follow relevant EPA Region 8 guidance for the evaluation of lead at
residential properties, commenting that the quality of the data resulting from the investigation is suspect. Mr.
Coomes further stated that "[s]imply stating that the historic Colorado Smelter released contaminants [is]
insufficient." Mr. Coomes also asserted that a relevant SOP was not followed in sample collection, resulting in
questionable data quality. Mr. Coomes further commented that the sampling logs indicate that the sampling
procedures identified in the SOP were not followed. Mr. Coomes also noted several perceived factual errors in
reports/documents related to the CDPHE 2010 site inspection related to the number and type of samples collected.
Mr. Coomes made several assertions regarding the background lead levels used in HRS documentation record
including:
The background lead levels are inconsistent with a previous Colorado Smelter report.
Lead-based paint or emissions from leaded gasoline are not discussed as possible sources of lead in the
HRS documentation record.
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Colorado Smelter Response to Comments NPL Listing Support Document
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Other studies, specifically the Diawara study and USGS data, provide different background lead levels.
Mr. Coomes asserted that in the comparison of composite sample results versus individual aliquot results, a high
bias is apparent in the composite sample results, and how this bias was introduced has not been explained.
Mr. Coomes commented that attribution of hazardous substances to the Site was questionable, asserting:
The EPA assumed the smelter was the main source of lead contamination.
The attribution of hazardous substances "is based on the fact that other potential lead sources were not
investigated or described."
The collected soil samples and analysis do not support the model of the smelter as the source
contamination based on the ratio of lead to arsenic in the collected soil samples.
A concentration or cluster of locations where lead concentrations exceeded 100 ppm near the Colorado
Smelter site was not present.
An even distribution of lead in soil with distance from the smelter was not present.
There are large differences between the smallest and largest lead concentrations within these sample areas
based on the five aliquot results.
Arsenic/lead ratios in some collected soil samples exceed the highest ratio for slag.
Based on these points, Mr. Coomes concluded that the data support additional lead sources, and the arsenic levels
in soil samples did not result from particulate deposition from the Colorado Smelter.
3.1 General Support for Listing
Comment: The Honorable John Hickenlooper, Governor of Colorado; Terry Hart, Chairman, Board of County
Commissioners; the Pueblo City-County Health Department Board of Health; the City Council, City of Pueblo,
Colorado and the Board of County Commissioners, Pueblo County, Colorado; Velma Campbell; and Pam, Don
and Joshua DiFatta, expressed support for listing the site on the NPL. The Sierra Club Rocky Mountain Chapter,
the Sangre de Cristo Group of the Sierra Club, the Pueblo City-County Health Department Board of Health, and
Velma Campbell supported the placement of the site on the NPL due to public health concerns and the benefits to
people and communities impacted by lead and arsenic contamination. The City Council, City of Pueblo, and the
Board of County Commissioners expressed support for the placement of the site on the NPL due to potential
positive economic impacts, possible federal financing of remediation, and potential boosts to the economic and
potential community improvements as a result of listing the site on the NPL.
Response: The Colorado Smelter site is being added to the NPL. Listing makes a site eligible for remedial action
funding under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), and the
EPA will examine the Site to determine the appropriate response action(s). Actual funding may not necessarily be
undertaken in the precise order of HRS scores, however, and upon more detailed investigation may not be
necessary at all in some cases. The EPA will determine the need for using Superfund monies for remedial
activities will be determined on a site-by-site basis, taking into account the NPL ranking, State priorities, further
site investigation, other response alternatives, and other factors as appropriate.
3.2 Conditional Support for EPA Cleanup
Comment: The Honorable John Hickenlooper, Governor of Colorado; Sandra Daff, Pueblo City Councilwoman;
Eiler Heights Neighborhood Association; the Bessemer Association for Neighborhood Development; Joe and
Pam Kocman; and one anonymous public commenter provided conditional support for EPA cleanup and the
placement of the site on the NPL and submitted multiple conditions for their support for listing. These conditions
include the following.
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Colorado Smelter Response to Comments NPL Listing Support Document
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Governor Hickenlooper requested:
o That "protections are put in place to be responsive to the concerns of the local community" (referring
also to the requests from Councilwoman Daff, the Eiler Heights, and Bessemer community in letters
attached to the Governor's comment), and that EPA address concerns listed by elected officials
(referring to a joint letter from the City Council, City of Pueblo, and Board of County
Commissioners, Pueblo county, also attached to the Governor's comment),
o Community involvement in the Superfund process, specifically noting soil remediation levels and
Superfund liability.
o The funding of the project "through completion without interruption to avoid any delays."
o Notification and use of local businesses for Superfund process contracting opportunities,
o Conducting the cleanup in a "timely, effective and collaborative fashion."
Joe and Pam Kocman and one anonymous public commenter provided support for listing contingent upon
timely clean up occurring within five years and three years following listing, respectively. (The anonymous
public commenter asserted that NPL listing for the Site should stop, but assuming it moves forward, asserted
this condition.)
Joe and Pam Kocman expressed provisional support for listing provided that comprehensive home cleanup be
undertaken, modifications to the EPA testing and remediation models regarding acceptable children's blood
lead levels occur, and Governor Hickenlooper's specifications outlined in his letter of support be fulfilled,
including timely cleanup and addressing the concerns of the community. Joe and Pam Kocman also expressed
that if the EPA cannot guarantee that future costs associated with soil testing and abatement will not be borne
by homeowners, they would not support listing.
Response: As noted in section 3.1, General Support for Listing, of this support document, the Colorado Smelter
site is being added to the NPL. Listing makes a site eligible for remedial action funding under CERCLA, and the
EPA will examine the Site to determine the appropriate response action(s), if any.
Regarding community involvement, the Superfund program offers numerous opportunities for public participation
at NPL sites. The EPA Regional Office develops a Community Relations Plan (CRP) before remedial
investigation and feasibility study (RI/FS) field work begins. The CRP is the "work plan" for community relations
activities that the EPA will conduct during the entire cleanup process. In developing a CRP, Regional staff
interview State and local officials and interested citizens to learn about citizen concerns, site conditions, and local
history. This information is used to formulate a schedule of activities designed to keep citizens apprised and to
keep the EPA aware of community concerns. Typical community relations activities include:
Public meetings at which the EPA presents a summary of technical information regarding the site and citizens
can ask questions or comment.
Small, informal public sessions at which EPA representatives are available to citizens.
Development and distribution of fact sheets to keep citizens up-to-date on site activities.
For each site, an "information repository" is established, usually in a library or town hall, containing reports,
studies, fact sheets, and other documents containing information about the site. The EPA Regional Office
continually updates the repository and must ensure that the facility housing the repository has copying
capabilities.
After the RI/FS is completed and the EPA has recommended a preferred cleanup alternative, the EPA Regional
Office sends to all interested parties a Proposed Plan outlining the cleanup alternatives studied and explaining the
process for selection of the preferred alternative. At this time, the EPA also begins a public comment period
during which citizens are encouraged to submit comments regarding all alternatives. Once the public comment
period ends, the EPA develops a Responsiveness Summary, which contains EPA responses to public comments.
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Colorado Smelter Response to Comments NPL Listing Support Document
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The Responsiveness Summary becomes part of the Record of Decision (ROD), which provides official
documentation of the remedy chosen for the site.
In addition, the EPA makes every attempt to ensure that community relations is a continuing activity designed to
meet the specific needs of the community. Anyone wanting information on a specific site should contact the
Community Relations staff in the appropriate EPA Regional Office. For the Colorado Smelter site, the EPA has
carried out several communications and meetings with members of the public and local officials/leaders. See
Attachment 5, Colorado Smelter Outreach Timeline, of this support document for a brief list. Further, the EPA
and CDPHE have committed staff for this purpose, and hired a neutral facilitator since April 2014 to assist with
monthly meetings to form a community advisory group.
To the extent these comments would condition the listing of the Site on any specific remedial goals, the EPA
notes that it is premature at this stage to discuss what remedial actions, if any, will occur at the Site after it's
placement on the NPL. As discussed in the proposed rule and throughout this final rulemaking, listing makes a
site eligible for CERCLA financed remedial action. What remedies, if any, will be performed at the Site occurs at
a later stage in the Superfund process, i.e., after completion of the remedial investigation/feasibility study.
Regarding remediation timing and remedy selection (as well as funding for remediation), such as those submitted
by Joe and Pam Kocman, and regarding cleanup goals (including health-related goals), see also section 3.7,
Remediation and Cleanup Levels, of this support document.
3.3 Consistency with Data Quality Program
Comment: Mr. Coomes questioned the EPA's adherence to EPA policies and guidance related to quality
assurance and data quality objectives in performing the planning for and collection of the data (and related
documents) used in the site inspection.
Mr. Coomes stated:
EPA has specific Policy and Program Requirements for the Mandatory Agency-Wide Quality
System, CIO 2105.0 (formerly EPA Order 5360.1 A2,) and the applicable Federal regulations
establish a Quality System that applies to all EPA organizations as well as those funded by EPA.
Mr. Coomes also stated:
The listing document does not address quality assurance. The project has not followed the
Mandatory Agency-Wide Quality System, CIO 2105.0 (formerly EPA Order 5360.1 A2,). The
documents supporting the listing do not discuss concepts that support making defensible
decisions.
Mr. Coomes further stated: "there is no discussion/documentation of: 1 .Data Quality Objectives used in planning
the study ... 2. Quality Assessment Project Plan." Mr. Coomes asserted that "[t]he project did not incorporate
EPA's mandatory quality system.
In discussing the CDPHE May 2010 SAP (included as Reference 20 of the HRS documentation record at
proposal), Mr. Coomes noted that the existing data quality objectives section "does not even define the use of the
data (only one example)," and claimed that "EPA's data quality objectives guidance was not followed in planning
or performing this study."
Response: The EPA followed the HRS to place the site on the NPL, and was consistent with all applicable
policies and guidance. None of the comments submitted identify any error in the HRS score or the decision to list
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Colorado Smelter Response to Comments NPL Listing Support Document
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the Site. And, all the documents relied upon in performing the HRS evaluation and showing the policies and
guidances were followed were available to the public. As set out further below:
Purpose of the HRS: The HRS is a screening model that uses limited information and resources to determine
whether a site should be placed on the NPL. Regarding data quality, for an HRS evaluation, the data used
need not be absolutely perfect, as long as the EPA has presented a rational explanation to address the use of
the data in an HRS evaluation.
Data Quality for the CDPHE 2010 Site Inspection: Planning and reporting documents related to the CDPHE
2010 site inspection described data quality objectives and established the quality of the data generated from
site inspection activities. The CDPHE 2010 site investigation was designed to provide data for use in an HRS
evaluation, and the data used to generate an HRS site score for this site is of sufficient quality for determining
that the Site qualifies for listing on the NPL based on an HRS evaluation.
HRS Data Quality Objectives: The HRS itself contains data quality objectives for the purpose of carrying out
an HRS evaluation, and the CDPHE 2010 site inspection analytical results used to score the Site meet these
objectives.
Effect of Comments on HRS Score: Comments asserting EPA has been inconsistent with a particular policy
or guidance document have not documented any defect in any particular HRS scoring factor.
Purpose of the HRS
First, an HRS is a special type of investigation and overarching policies and guidance must be read in context.
The HRS is a screening model that uses limited resources to determine whether a site should be placed on the
NPL for possible Superfund response. The HRS is intended to be a "rough list" of prioritized hazardous sites; a
"first step in a processnothing more, nothing less." Eagle Picher Indus, v. EPA, 759 F.2d 922, 932 (D.C. Cir.
1985) (Eagle Picher II).
As an example of the data quality objectives for an HRS evaluation, and, specifically related to analytical data
quality, the U.S. Court of Appeals for the D.C. Circuit has specifically ruled on the use of analytical data in the
scoring of a site using the HRS when there were possible weaknesses in the laboratory analysis. In the case of
Board of Regents of the University ofWashington v. EPA, 86 F.3d 1214 (DC Cir. 1996), the Court, in response to
the petitioner's challenge regarding the quality of the data being fed into the complex HRS modelspecifically,
when there were issues dealing with the analysisstated that "EPA does not face a standard of absolute
perfection. . . . Rather, it is statutorily required to 'assure to the maximum extent feasible,' that it 'accurately
assesses the relative degree of risk,'" [emphasis in original] and that "[i]t would hardly make sense for the courts
to respond to the resulting evidence by treating a lab's findings as fatally defective whenever it comes up short in
any way." The Court also said that "[i]f there are 'minor contractual deficiencies,' the appropriate response is to
review the deficiencies on a 'case-by-case' basis to determine their impact on the 'usability of the data.'" Also in
this decision, the Court repeated a statement in an earlier NPL HRS case (Eagle-Picher Indus., Inc. v. EPA, 759
F.2d. 905, 921, D.C. Cir. 1985) in explanation of when EPA has met its obligations as: "The EPA has thus
'examined [the] relevant data and . . . articulated a rational explanation for its action.'" [clarification in original]
See also City of Stoughton v. EPA, 858 F.2d 747, 756 (D.C. Cir. 1988) ("It is not necessary that EPA's decisions
as to what sites are included on the NPL be perfect, nor even that they be the best."); CTS Corp. v. EPA, 759 F.3d
52, 61 (D.C. Cir. 2014) (same).
Further, as set out in the HRS documentation and this response to comments document, the data EPA relied on
(including the results of the CDPHE 2010 site inspection) met the standards of the Administrative Procedure Act
by being 'relevant, material, and not repetitious,' see 5 U.S.C. ง 556(d), such that EPA was entitled to weigh it
according to its truthfulness, reasonableness, and credibility. See, e.g., Veg-Mix, Inc. v. U.S. Dept. of Ag., 832
F.2d 601, 606 (D.C. Cir. 1987).
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Colorado Smelter Response to Comments NPL Listing Support Document
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Data Quality for the CDPHE 2010 Site Inspection
Regarding data quality associated with the CDPHE June 2011 ARR and the site inspection activities, the EPA and
the CDPHE followed all relevant policies and guidance related to quality assurance and data quality objectives in
collecting, analyzing, and using the data to perform the HRS evaluation.
First, an HRS evaluation is performed based on information available to characterize a site. In accordance with
the NCP, a site inspection may be carried out to generate data for this purpose (see the NCP at 40 CFR
300.420[c][iii]). In comments directly addressed in this section and other sections of this support document, Mr.
Coomes alleges deficiencies related to several documents such as the March 2000 CDPHE QAPP, CDPHE May
2010 SAP, CDPHE June 2011 ARR, and the March 2012 DQA.5 These are planning/reporting documents for the
CDPHE 2010 site inspection, and the information from this site inspection was included in data used to generate
an HRS score for the Site. However, the exact planning/reporting documentation (as well as other reference
material) used in performing an HRS evaluation is not explicitly specified by the HRS.
Further, the EPA had approval authority and used this authority for the CDPHE Quality Assurance
documentation, which included the March 2000 CDPHE QAPP and the CDPHE May 2010 SAP (included as
Reference 20 of the HRS documentation record at proposal). The March 2000 CDPHE QAPP covers site
assessment activities conducted by the State on behalf of the EPA and was approved by representatives of EPA
Region VIII as shown on page i of that document, included as Attachment 1 of this support document. The
CDPHE May 2010 SAP, specific to the CDPHE 2010 site inspection, was also approved by a representative of
EPA as shown on the cover pages of that document (included as Reference 20 of the HRS documentation record
at proposal). These documents are consistent with CIO 2105.0 (formerly EPA Order 5360.1) and described how
data and information were going to be collected, analyzed, and assessed. The CDPHE May 2010 SAP, in its
Objectives and Decision Rules sections, clarifies that the purpose of the site inspection is to collect data for use in
conducting an HRS evaluation (see pages 1-2, 11-12 of Reference 20 of the HRS documentation record at
proposal). The technical details and procedures for collection and selection of data were also described, and the
data quality indicators of precision, accuracy, representativeness, completeness, comparability and sensitivity
were evaluated. All data was determined usable as qualified (as limited by the analytical data validation and data
quality assessment process).
Analytical precision was demonstrated through the use of duplicate samples. Ten percent of the multi-increment
soil samples analyzed by XRF were sent for laboratory confirmatory analysis. The results generated by both XRF
and Inductively Coupled Plasma-Atomic Emission Spectroscopy (ICP-AES) demonstrated correlation indicating
a definitive data quality level, meaning the sets show statistically similar results. Additionally, the duplicate
sample results were within acceptable criteria for both the XRF and CLP analysis of soil samples. A duplicate
surface water sample was submitted to the CLP lab blind, and results of the analysis were within control limits.
The accuracy of the analytical data was verified through use of several quality control samples, including
standards, blanks, and spikes. See section 3.3.2, Completion of Data Quality Assessment, for more detail on data
5 A QAPP is a document that describes policy, organization, and functional activities, and the data quality objectives and
measures necessary to achieve adequate data for use in site evaluation and HRS activities. A SAP generally documents
procedural/analytical requirements for a site-specific one-time/time-limited project that involves the collection of samples of
water, soil, sediment or other media to characterize areas of potential environmental contamination, and addresses elements
specified in the related QAPP (CDPHE May 2010 SAP is a specific planning document for the CDPHE 2010 site inspection).
The CDPHE June 2011 ARR is a report describing the results from the site inspection activities. The March 2012 DQA is a
report assessing data quality related to the results from the site inspection activities, and is focused on correlation between
soil sample lead XRF results and soil sample CLP laboratory results.
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Colorado Smelter Response to Comments NPL Listing Support Document
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quality control.6 Representativeness was achieved by adherence to technical standard operating procedures
(TSOPs) for sampling procedures, adherence to field and laboratory quality assurance/quality control procedures,
appropriateness of sample location, and achieving the acceptance criteria specified in the CDPHE May 2010 SAP.
A review of the CDPHE May 2010 SAP, field log books, and laboratory data packages reveals no deviations or
failures in the procedures and data that are being used for decision making at the Site (as detailed on pages 38-39
of the CDPHE June 2011 ARR, included as Reference 22 of the HRS documentation record at proposal). As
further explained below, the Colorado Smelter site inspection met project and data quality objectives with regard
to the HRS requirements.
The CDPHE generic QAPP is cited as a reference in the CDPHE June 2011 ARR (the analytical results report for
the CDPHE 2010 site inspection). As stated in the proposed rule (79 FR 26926, Part II) this generic QAPP
reference document has been accessible via the EPA Region 8 Regional Docket. Nonetheless, in response to Mr.
Coomes' comments, the Agency has included the referenced QAPP as Attachment 1 of this response document.
Finally, in Mr. Coomes' comments asserting EPA has not adhered to relevant policy and guidance, he makes
several related claims of deficiencies in documentation related to the planning and reporting for the CDPHE 2010
site inspection. However, as shown in this support document, the CDPHE 2010 site inspection planning and
reporting documentation was sufficient at proposal. (These documents and alleged deficiencies are further
addressed in section 3.3.1, Sampling and Analysis Plan; 3.3.2, Completion of Data Quality Assessment; and 3.4,
Adequacy of Public Docket/Requests for Additional Documents, of this support document).
HRS Data Quality Objectives
In addition to the data quality associated with the CDPHE June 2011 ARR and the site inspection activities, the
HRS states the data quality objectives for the purpose of carrying out an HRS evaluation, including associating
hazardous substances with a source and establishing observed contamination; the HRS evaluation of the Site was
consistent with these HRS objectives. The HRS data quality objectives for associating a substance with a source
based on analytical samples (other than contaminated soil) are detailed in HRS Section 2.2.2, Identify hazardous
substances associated with a source, and specify that the analytical data document the substance to be present in a
sample at a concentration at or above the detection limit. Hence, the analytical data need only be qualitatively
accuratethey must be sufficient to show the presence of a hazardous substance, but need not accurately
determine its exact concentration.
The HRS Section 1.1, Definitions, defines "source" in part as:
[a]ny area where a hazardous substance has been deposited, stored, disposed, or placed, plus
those soils that have become contaminated from migration of a hazardous substance.
For associating a substance with a source, HRS Section 2.2.2, Identify hazardous substances associated with a
source, states:
6 Additionally, the samples used to establish observed contamination for the Site were analyzed under the EPA CLP. This
program was "developed for CERCLA waste site samples to fill the need for legally defensible analytical results supported
by a high level of quality assurance and documentation" (HRS Section 1.1). A key part of the CLP program is to document
the quality of the analytical results through the analysis of quality control samples commensurate with the analysis for field
samples and by tracking the capabilities of the analytical procedures to provide accurate results when analyzing samples with
variable physical properties.
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consider those hazardous substances documented in a source (for example, by sampling, labels,
manifests, oral or written statements) to be associated with that source when evaluating each
pathway.
Thus, to associate a hazardous substance with a source, the substance must be documented to be in an area where
it was deposited, stored, disposed, or placed, or to be soil contaminated through hazardous substance migration.
For sources that are not composed of contaminated soil, any substance that can be documented to be present in the
waste material in the source can be associated with that source. When samples are of waste materials, background
sampling is unnecessary, since the presence of the wastes is evidence that the hazardous substances have been
deposited, stored, disposed, or placed in the source.
The HRS data quality objectives for establishing observed contamination are included in HRS Section 5.0.1,
General considerations, and HRS Table 2-3. The contaminant concentration in the release sample(s) must be
either 1) three times above the background concentration for the media being evaluated, or 2) at or above the
sample quantitation or detection limit if the background level is below the appropriate detection limit. This
involves a quantitative comparison to background, and the data quality objective for establishing observed
contamination is that the concentration of a contaminant must be sufficiently quantitatively accurate to ensure that
one of the two above criteria spelled out in HRS Table 2-3 is met.
HRS Section 5.0.1, General considerations, states in relevant part:
Consider observed contamination to be present at sampling locations where analytic evidence
indicates that:
-A hazardous substance attributable to the site is present at a concentration significantly
above background levels for the site (see table 2-3 in section 2.3 for the criteria for
determining analytical significance), and
-This hazardous substance, if not present at the surface, is covered by 2 feet or less of
cover material (for example, soil), [emphasis added]
HRS Table 2-3, referred to by HRS Section 5.0.1, General considerations, states:
If the background concentration is not detected (or is less than the detection limit), an
observed release is established when the sample measurement equals or exceeds the
sample quantitation limit.
If the background concentration equals or exceeds the detection limit, an observed release
is established when the sample measurement is 3 times or more above the background
concentration, [emphasis added]
Thus, again, the data quality must be of sufficient quantitative accuracy to identify that contaminated sample
results are significantly above background levels (and not an artifact of sampling or analysis variation); and it
must be known that the contaminated sample is within 2 feet of the surface.
As further detailed in section 3.3.2, Completion of Data Quality Assessment, of this support document, an overall
data usability assessment conducted for data generated during the CDPHE 2010 site inspection found all data
usable as qualified (as limited by the data validation and data quality assessment process). Thus, CDPHE 2010
site inspection analytical results presented in the HRS documentation record and used to associate hazardous
substances with sources and establish areas of observed contamination were assessed for qualitative and
quantitative accuracy prior to use in HRS scoring and are sufficient for HRS purposes.
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Effect of Comments on HRS Score
Finally, in many instances specifically addressed in later parts of this support document, Mr. Coomes has claimed
that EPA has been inconsistent with a particular policy or guidance document, but has not explained how such an
inconsistency would affect the HRS Site score or the decision to list the Site on the NPL. However, courts have
held that the "dialogue between administrative agencies and the public is a two-way street." Northside Sanitary
Landfill, Inc. v. Thomas, 849 F.2d 1516, 1520 (D.C. Cir. 1988) (citing Home Box Office, Inc. v. FCC, 567 F.2d 9
(D.C. Cir. 1977)). A commenter "cannot merely state that a particular mistake was made," rather it must show
"why the mistake was of possible significance in the result the agency reaches." See id. at 1519. As explained
further throughout this support document, the methods employed in listing the Site pursuant to the HRS either
satisfied the concerns raised in Mr. Coomes' comments, or the documents he is inquiring about are not applicable
and are not required by the HRS to be presented to the public as part of an HRS evaluation.
This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.
3.3.1 Sampling and Analysis Plan
Comment: Mr. Coomes submitted comments questioning the adequacy of the SAP for the ARR in respect to
EPA's Data Quality Program. He asserted that "[although the Sampling and Analysis Plan (SAP) included a Data
Quality Objectives (DQO) Section 5.0, EPA Data Quality Objectives, EPA's Guidance7 was not followed in
preparation of the Sampling and analysis | sic | Plan." Mr. Coomes pointed to the February 2006 EPA document
Guidance on Systematic Planning Using the Data Quality Objectives Process, EPA QA/G-4 EPA/240/B-06/001.
Mr. Coomes argued that "[s] imply stating that the historic Colorado Smelter released contaminants [is]
insufficient (it says 'trust us')." Mr. Coomes identified several alleged issues that he contended "require additional
input from the EPA to ensure the public understands the rationale of the investigation." Mr. Coomes contended
that this "lack of documented planning results in data quality that does not | v/c | sufficient to support defensible
decision-making." Related to the SAP, Mr. Coomes called into question whether a conceptual site model (CSM)
or decision rules and acceptable uncertainty had been sufficiently considered and conveyed.
Response: The CDPHE May 2010 SAP adequately discusses the CSM and decision rules for the CDPHE 2010
site inspection and for an HRS evaluation, providing CSM details related to identifying sources, hazardous
substances, and exposure routes, and decision rule details such as the problem statement, decision, decision
inputs, defining study boundaries, developing decision rules, and defining tolerance limits on decision rules. The
CSM and decision rules are set out in the CDPHE May 2010 SAP, and are also built into the HRS itself for HRS
scoring purposes, as further detailed in the below subsections.
It is assumed that the SAP referenced by Mr. Coomes in his comments is the CDPHE May 2010 SAP (included as
Reference 20 of the HRS documentation record at proposal). Also, the data quality objectives are addressed in
section 7 (not section 5), Data Quality Objectives Process, of that SAP.
Further, as detailed in section 3.16, Attribution, of this support document, the attribution of hazardous substances
(lead and arsenic) in the residential soil AOC to the Site is properly attributed and consistent with the HRS. The
Colorado Smelter is reasonably documented to have released lead and arsenic contaminants through historical
operations, via smelter stack emissions that were deposited in the AOC surrounding the Colorado Smelter stacks.
Specific comments on the presentation of a CSM and decision rules/acceptable uncertainty are addressed in the
following subsections:
3.3.1.1 Conceptual Site Model
3.3.1.2 Decision Rules and Acceptable Uncertainty
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3.3.1.1 Conceptual Site Model
Comment: Mr. Coomes asserted that "a CSM was not prepared and reported to the public." Mr. Coomes stated:
Therefore, the public has little understanding of release mechanisms, transport pathways, affected
media, and intake routes, because EPA has not explained these concepts and how they apply at
the Colorado Smelter Site. It is not acceptable to expect the public to take EPA's word that
chemicals from the smelter "contaminated" the area without adequate documentation of the
release mechanism, transport mechanism, and intake routes. This information would have been
provided if EPA had followed their DQO guidance.
In discussing a model for the Site, Mr. Coomes referred to a "lead particulate 'rainfall'" concept in Attachment 2
to his comment document. Mr. Coomes requested that if the description in Attachment 2 to his comment
document does not fit EPA's conceptual site model, the EPA "explain how the data support the EPA-proposed
CSM." Mr. Coomes also requested that the CSM to be generated explain how the variability in soil lead
concentrations with distance is consistent with a particulate deposition model.
Response: The EPA followed the HRS in generating an HRS site score, qualifying the Site for the NPL, and none
of the comments have shown that score to be incorrect. The HRS does not require that a CSM be explicitly
described or presented in the HRS documentation record or its supporting references. Furthermore, the CDPHE
May 2010 SAP does discuss the CSM for the CDPHE 2010 site inspection considering that an HRS evaluation
would be performed. The conceptual site model is set out in that document, and is also built into the HRS itself
for HRS scoring purposes.
In general, a CSM is an idealized model of processes at a site which may act as a planning tool for investigating
the site. A CSM can be developed for various stages of a Superfund process (e.g., for a site inspection, a site-
specific risk assessment, for remediation activities, etc.).
The CSM for the HRS evaluation of all possible sites being evaluated includes consideration of such
exposure/risk assessment components as the sources of contaminants and the magnitude of the contamination,
mechanisms by which contaminants may migrate, the fate and transport of contaminants during migration, the
exposure routes into receptors, the identification and quantification of targets (receptors), and finally, the
estimation of the relative risk among sites. The HRS factor values used in determining an HRS score reflect these
factors and the HRS algorithm for combining these factor values into a relative site score links these components
together.
CSMs may take different forms depending on the program or action/activity being planned. However, there is no
HRS requirement that CSMs be developed or explicitly spelled out in the documents supporting the HRS
evaluation (i.e., the HRS documentation record or its supporting references). And, CSMs also need not replicate
the figure provided by the commenter, but could include drawings or narrative descriptions of the site, source
areas, and how site-related contamination could impact target populations. In the CDPHE May 2010 SAP, the
CSM is offered in a narrative format within Section 6.0, Preliminary Pathway Analysis (see pages 4-10 of
Reference 20 of the HRS documentation record at proposal). This text includes several relevant discussions, such
as:
Identifying sources (e.g., waste piles)
Identifying related hazardous substances (various metals)
Potential routes of human exposure (e.g., ingestion of soil)
Consideration of contaminated media within each pathway considered in the SAP, how
contamination may have come to each pathway media, and target populations or environmental
targets potentially affected by each pathway.
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Furthermore, for the purposes of an HRS evaluation, the generic CSM for the entire HRS is also built into the
HRS itself. HRS Section 2.1.3, Common evaluations, lays out evaluations common to all HRS pathways:
Characterizing sources.
-Identifying sources (and, for the soil exposure pathway, areas of observed
contamination [see section 5.0.1]).
-Identifying hazardous substances associated with each source (or area of observed
contamination).
-Identifying hazardous substances available to a pathway.
Scoring likelihood of release (or likelihood of exposure) factor category.
-Scoring observed release (or observed contamination).
-Scoring potential to release when there is no observed release.
Scoring waste characteristics factor category.
-Evaluating toxicity.
-Combining toxicity with mobility, persistence, and/or bioaccumulation (or ecosystem
bioaccumulation) potential, as appropriate to the pathway (or threat).
-Evaluating hazardous waste quantity.
-Combining hazardous waste quantity with the other waste characteristics factors.
-Determining waste characteristics factor category value.
Scoring targets factor category.
-Determining level of contamination for targets.
The sample pathway score sheet shown in HRS Table 2-1 shows how these elements fit into the HRS
scoring approach. And, Figure 8 of the preamble to the HRS shows how scoring elements specific for the
soil exposure pathway fit into the HRS evaluation (including the resident population threat scored for the
Colorado Smelter site), as follows:
Resident Population Ttirsat
UMIkaad tt Eipa>urt X
Waste Characteristics X
Tkrfcts
Otaswrf CoiilmilMfion
Tonicity
tfutudaia Waste Qnutily
Resident ladhridMl
Resident Population
Workers
Resources
TerresaM Sensitive
Environments
+
Nearby Population Tftreat
LBnUnod of Eqpomn X
Hun CknrinWa I
Targets
ArstofOxttiimsauna
Toxicity
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Colorado Smelter Response to Comments NPL Listing Support Document
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(each medium) and the analytical detection limits necessary to support the defined decisions." Mr. Coomes further
asserted that the EPA should describe the specific data and quantity needed to support the acceptable uncertainty,
and noted "the required data, decision statement, and decision criteria are different for various media tested." Mr.
Coomes added that "[e]ven though EPA did not evaluate the HRS for other media, samples of other media were
collected and analyzed and should have been included in the DQO section."
Response: The EPA followed the HRS in generating an HRS site score, qualifying the Site for the NPL, and none
of the comments have shown that score to be incorrect. The HRS does not require that decision rules and
acceptable uncertainty related to screening site investigations be explicitly described in the presentation of the
evaluation to the public (i.e., in the HRS documentation record or its supporting references). Regardless, the
CDPHE May 2010 SAP does adequately address the topics of decision rules and acceptable uncertainty for the
CDPHE 2010 site inspection and for an HRS evaluation, and decision rules for the purposes of an HRS evaluation
are built into the HRS itself.
The CDPHE May 2010 SAP addresses data quality objectives in: section 2.0, Objectives, describing overall site
inspection objectives (on pages 1-2 of Reference 20 of the HRS documentation record at proposal); and section
7.0, Data Quality Objectives Process, discussing the problem statement, decision, decision inputs, defining study
boundaries, developing decision rules, defining tolerance limits on decision rules, and optimizing the sample
design (on pages 10-12 of Reference 20 of the HRS documentation record at proposal). This approach was
consistent with the specifications in the CDPHE generic QAPP included as Attachment 1 of this support
document.
The decision rules for the CDPHE site inspection (e.g., If, Then statements) are present in narrative format and
contained in Step 5 of section 7 of the CDPHE May 2010 SAP. The decision rules consist of comparisons to
background concentrations and relevant health-based benchmarks, consistent with the HRS regulation. As further
discussed in section 3.14, Identification of Observed Contamination - Significant Increase Criteria, of this support
document, the HRS specifies the criteria for identifying a significant increase in hazardous substances and
establishing observed contamination in soil (based on criteria detailed in HRS Sections 5.0.1, General
considerations, 2.3, Likelihood of release, and HRS Table 2-3). Also, these decision rules note that additional
action may be recommended if metals concentrations exceed applicable benchmarks. Additionally, Sections 5.1
and 11.0 of the CDPHE June 2011 ARR discuss the data's acceptability and usability for the HRS evaluation and
listing the site on the NPL (see pages 7-8, 25-39 of Reference 22 of the HRS documentation record at proposal).
This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.
3.3.2 Completion of Data Quality Assessment
Comment: Mr. Coomes commented on the assessment of CDPHE 2010 site inspection data, asserting that "a Data
Quality Assessment Report (that agrees with the EPA guidance for such a document) has not been distributed for
review." Mr. Coomes requested that "[i]f EPA believes this project does not require the suggested analysis, please
provide the support for this decision in terms [of] project quality." Mr. Coomes points to EPA Order CIO 2105.0,
Policy and Program Requirements for the Mandatory Agency-wide Quality System. (Mr. Coomes also referred to
the EPA guidance document Practical Methods for Data Analysis, EPA QA/G-9, QA97 Version, EPA/600/R-
96/084, January 1998.)
Response: The EPA followed the HRS in generating an HRS site score, qualifying the Site for the NPL, and none
of the comments have shown that score to be incorrect. The HRS does not require that any specific data quality
assessment for analytical results generated by site investigations be performed or explicitly described in the HRS
documentation record or its supporting references. However, consistent with EPA policy and guidance, a data
quality assessment was performed and is available in the HRS package at proposal in the CDPHE June 2011 ARR
and March 2012 Data Quality Assessment, and the data was found acceptable for HRS purposes.
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An overall data quality assessment was conducted for data generated during the 2010 CDPHE 2010 site
inspection (summarized on pages 25-39 of the CDPHE June 2011 ARR, Reference 22 of the HRS documentation
record at proposal7); this assessment found that all data are usable as qualified (as limited by the data validation
and data quality assessment process), considering aspects including:
field quality control procedures
data validation and interpretation
data quality indicators (i.e., precision, accuracy/bias, representativeness, completeness,
comparability, sensitivity)
A data quality assessment was also specifically generated for the CDPHE 2010 site inspection XRF results (the
March 2012 Data Quality Assessment, Reference 28 of the HRS documentation record at proposal). This
assessment was primarily concerned with XRF lead results and their correlation/comparability to CLP laboratory
results. This analysis found that lead correlation is definitive between the XRF and CLP data sets, taking into
account the following parameters:
sample preparation
sample analysis
analysis quality assurance/quality control
data validation
data quality indicators (bias, sensitivity, precision, representativeness, completeness, and
comparability)
Regarding the EPA guidance document, Practical Methods for Data Analysis, EPA QA/G-9, QA97 Version,
EPA/600/R-96/084, January 1998, this document was not cited in planning documents used for the 2010 CDPHE
2010 site inspection; more applicable guidance8 as well as the HRS-specific requirements were cited and used in
planning.
This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.
3.4 Adequacy of Public Docket/Requests for Additional Documents
Comment: Mr. Coomes requested that several documents and other information be provided for public review and
to complete his analysis of the proposal to add the Site to the NPL.
Response: The documents and information provided with the HRS package at proposal were sufficient for the
purposes of conducting an HRS evaluation for the Site. Other related documents were available from the EPA
Region 8 docket upon request as instructed in the Federal Register notice of the proposal of the Colorado Smelter
site to the NPL (79 FR 26926). These documents together provide for all data quality program requirements. As
7 During the process of responding to comments a minor error on page 25 of the CDPHE June 2011 ARR (Reference 22 of
the HRS documentation record at proposal) was noted. The sentence on that page stating "[t]here were four types of data
included in the data quality assessment for the Fountain Foundry project. . ." [emphasis added] This sentence should state
instead that "[t]here were four types of data included in the data quality assessment for the Colorado Smelter project. .."
[emphasis added]
8 For example, in the March 2000 CDPHE generic QAPP included as Attachment 1 of this support document, pages 1,13,
and 41 describe relevant policy and guidance documents considered in preparing the QAPP, and Appendix B to that QAPP
includes copies of several standard operating procedure documents. Similarly, pages 1 and 19-20 of the CDPHE 2010 SAP
(Reference 20 of the HRS documentation record at proposal), describe guidance documents and standard operating
procedures considered in preparing the SAP.
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explained below, the documents and information Mr. Coomes requested were either available to him or were not
used in the HRS evaluation of the Colorado Smelter site. Prior to and throughout the comment period for the
proposal of this site to the NPL, EPA Region 8 and the CDPHE received no requests for additional documents or
information. As set out in this support document, the information the Agency provided in the HRS package at
proposal was sufficient to support the HRS evaluation of the Site and provide the public with a meaningful
opportunity to participate in this rulemaking.
Specific documents requested by Mr. Coomes are addressed in the following subsections:
3.4.1 Project-specific QAPP
3.4.2 Sampling and Analysis Plan/Data Quality Objectives
3.4.3 Project Plan and SOPs
3.4.4 SOP-specified Site Diagrams
3.4.5 Data Quality Assessment (DQA)
3.4.6 Preliminary Assessment XRF Data
3.4.1 Project-specific QAPP
Comment: Mr. Coomes requested a copy of the QAPP associated with the CDPHE 2010 site inspection activities.
Mr. Coomes noted that this QAPP is listed as Reference 1 of the CDPHE June 2011 ARR (Reference 22 of the
HRS documentation record at proposal); he commented that the QAPP "cannot be located and is critical to
evaluate the quality of the collected data." If a QAPP is not available, Mr. Coomes requested a project-specific
QAPP be prepared. Mr. Coomes included several other related comments:
"It is important that this QAPP be available for public review before listing the site. Without
the QAPP, documentation of the listing is incomplete."
"A thorough review of documents supporting site listing cannot be completed without this
additional document. Without reviewing this document, the quality of data used to support site
listing is suspect."
[The QAPP] "must be made available in the document repository in order to evaluate whether
or not the data quality are appropriate to support decision-making for decisions that were not
defined in the DQO section of the SAP" [emphasis in original]
"The actual CDPHE QAPP is critical to preparing specific comments on the proposed listing.
Therefore, these comments are not complete and an extension of time is requested to review the
QAPP that was actually used."
"The ARR discusses data quality in terms of precession, accuracy, comparability, and
representativeness, but does not follow more rigorous analysis which is appropriate for
important decisions such as listing a site."
"EPA guidance states that the quality of the data must be related to the decisions identified in the
Data Quality Objectives prepared for the Sampling and Analysis Plan (SAP). The QAPP at the
repository in Pueblo does not address the SAP DQOs and is not acceptable documentation for
the Colorado Smelter Investigation."
Response: As explained above in section 3.3, Consistency with Data Quality Program, of this support document,
the generic QAPP that is cited as a reference in the CDPHE June 2011 ARR (Reference 22 of the HRS
documentation record at proposal) has been available during the comment period of the proposed rulemaking
upon request to the Region 8 EPA docket, as indicated in the Federal Register notice (79 FR 26926), or at
CDPHE's Record Center at 4300 Cherry Creek Drive South, Denver, CO 80246. Although no such request was
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received, EPA is including the generic QAPP as Attachment 1 of this document in response to Mr. Coomes'
comments.
As further discussed in section 3.11.5, QAPP and Appendix H, of this support document, Mr. Coomes discussed a
separate QAPP he located in the Pueblo Rawlins Public Library repository. That QAPP was not attached to Mr.
Coomes comments, and no specific citation to the QAPP was provided by Mr. Coomes. It is thus not clear to
which QAPP Mr. Coomes is referring, or for which site that QAPP was used. However, based on Mr. Coomes'
related assertions, it is clear that the unidentified QAPP is not relevant to the CDPHE 2010 site inspection (and
this QAPP is not the QAPP cited in relevant CDPHE 2010 site inspection planning documents).
This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.
3.4.2 Sampling and Analysis Plan/Data Quality Objectives
Comment: Mr. Coomes requested that the data quality objectives section of the CDPHE May 2010 SAP
(Reference 20 of the HRS documentation record at proposal) be rewritten to address inadequacies, to be
consistent with EPA guidance, to address decision rules and acceptable uncertainty, and to identify specific data
and quantity to support acceptable uncertainty; Mr. Coomes requested this be submitted to the public for review.
Mr. Coomes requested that the EPA "prepare a site-specific CSM that provides a written description of release
mechanisms, chemical transport pathways and exposure intake mechanisms in a manner that the educated lay
public can understand." Mr. Coomes stated that EPA investigative reports must include a CSM, and that this
should be done before the Site is listed. If a CSM is not prepared, Mr. Coomes requested that EPA provide a
rationale for not doing so.
Mr. Coomes further stated: "there is no discussion/documentation of. . . Data Quality Objectives used in planning
the study . . . Please prepare for review an investigation-specific Data Quality Objectives document." Mr. Coomes
commented that "[t]his is actually the first step of Data Quality Assessment11 when the DQOs are not clearly
defined in the SAP."9
Response: The CDPHE May 2010 SAP included as Reference 20 of the HRS documentation record at proposal
was adequate for developing data for an HRS evaluation. Furthermore, Mr. Coomes was mistaken in each of the
alleged deficiencies he described related to the SAP, and the associated topics were sufficiently addressed:
As described in section 3.3.1, Sampling and Analysis Plan, of this support document and its subsections,
although not required by the HRS, the CDPHE May 2010 SAP did provide a discussion of the CSM, decision
rules, and acceptable uncertainty.
As further detailed in section 3.3, Consistency with Data Quality Program, of this support document, the data
quality objectives for the CDPHE 2010 site inspection were documented in the CDPHE May 2010 SAP, as
well as being inherent in the structure of the HRS itself. Provision of additional documentation discussing
data quality objectives is not necessary prior to promulgating the Site to the NPL.
This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.
9 Mr. Coomes cites reference 11 of his comment submittal, EPA Guidance for Data Quality Assessment, Practical Methods
for Data Analysis, EPA QA/G-9, QA97 Version, EPA/600/R-96/084, January 1998.
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3.4.3 Project Plan and SOPs
Comment: Mr. Coomes asserted that the SOP provided to the City of Pueblo for soil collection was not followed.
(Mr. Coomes referred to SOP #SRC-OGDEN-02, Surface Soil Sampling, included as Attachment 1 of his
comment document, docket ID EPA-HQ-SFUND-2014-0318-0020.) Mr. Coomes commented that a project plan
has not been available for public review. Mr. Coomes therefore requested that copies of the project plan and SOP
"actually used in the study" be provided for public review.
Mr. Coomes commented that the SOP provided to the City of Pueblo is not in the Pueblo Rawlins Library
Repository, and should be included for public review.
Mr. Coomes claimed that "a second SOP is cited for the project, but is apparently not available" (pointing to
"Comment 1" of his comment document).
Response: As further described in section 3.12, Identification of Observed Contamination - Soil Collection
Technique, of this support document, the SOP Mr. Coomes cited related to these comments (SOP #SRC-
OGDEN-02, Surface Soil Sampling, included as Attachment 1 of his comment document) was not used during the
CDPHE 2010 site inspection and is not relevant to the data generated during that event. The CDPHE May 2010
SAP used for the CDPHE 2010 site inspection was provided as Reference 20 of the HRS documentation record at
proposal.
Regarding a "second SOP" mentioned as missing by Mr. Coomes, it is unclear to what Mr. Coomes is referring.
Within the context of this assertion, Mr. Coomes points to "Comment 1" of his comment document; however, that
comment appears to discuss the allegedly missing QAPP, not a missing SOP.
This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.
3.4.4 SOP-specified Site Diagrams
Comment: Mr. Coomes commented that site diagrams showing sampling locations at each property are required
by the SOP (referring to SOP #SRC-OGDEN-02, Surface Soil Sampling, included as Attachment 1 of his
comment document). However, Mr. Coomes asserted these diagrams were not available for review, and requested
copies of the diagrams claiming they "are critical to evaluate the potential contributions of lead-based paint to the
soil surrounding houses in this very old neighborhood."
Response: The SOP Mr. Coomes asserted requires that site diagrams showing sampling locations at each property
be generated (SOP #SRC-OGDEN-02, Surface Soil Sampling, included as Attachment 1 of his comment
document) was not used during the CDPHE 2010 site inspection activities and is not cited in relevant planning
documents (e.g., the CDPHE May 2010 Sample and Analysis Plan, included as Reference 20 of the HRS
documentation record at proposal, or the March 2000 CDPHE QAPP for Site Assessments Under Superfund,
included as Attachment 1 of this support document). SOP #SRC-OGDEN-02 and its specifications are not
applicable to the CDPHE 2010 site inspection activities. Figure 3 of the HRS documentation record at proposal
provides the generic soil sampling schematic followed during CDPHE 2010 site inspection activities.
Furthermore, the HRS purpose for which such site diagrams could be used is to show that a given soil sample
establishing observed contamination is within 200 feet of a scored residence in order to evaluate the population
associated with that residence under the resident population threat. However, site diagrams are not needed to
show this for CDPHE 2010 site inspection. As further discussed in section 3.15, Identification of Observed
Contamination - Contaminated Samples, of this support document, page 23 of the HRS documentation record at
proposal pointed out that all of the individual aliquots for all the residential properties sampled during the CDPHE
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2010 site inspection were collected within 200 feet of the residences, as the associated properties are all less than
200 feet in width and length.
This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.
3.4.5 Data Quality Assessment
Comment: Mr. Coomes commented that "a Data Quality Assessment Report (that agrees with the EPA guidance
for such a document) has not been distributed for review," and requested such a document be made available for
review. Mr. Coomes requested that "[i]f EPA believes this project does not require the suggested analysis, please
provide the support for this decision in terms [of] project quality." Mr. Coomes points to EPA Order CIO 2105.0,
Policy and Program Requirements for the Mandatory Agency-wide Quality System.
Mr. Coomes pointed to the EPA guidance document Practical Methods for Data Analysis, EPA QA/G-9, QA97
Version, EPA/600/R-96/084, January 1998. Mr. Coomes requested that EPA prepare a data quality assessment
(DQA) document consistent with this guidance that:
has at least the following steps: (1) Review the Data Quality Objectives (DQOs) and Sampling
Design: (2) Review the DQO outputs to assure that they are still applicable: (3) if DQOs have not
been developed, develop DQOs before evaluating the data (e.g., for environmental decisions for
environmental decision, the following are needed: define the statistical hypothesis and specify
tolerable limits on decision errors; for estimation problems, define an acceptable confidence or
probability interval width). Review the sampling design and data collection documentation for
consistency with the DQOs.
Response: As described in section 3.3.2, Completion of Data Quality Assessment, of this support document, a
data quality assessment was performed for the CDPHE 2010 site inspection data and was available in the docket
at Site proposal. This data quality assessment included an overall data quality assessment that was conducted for
data generated during the 2010 CDPHE 2010 site inspection (in the CDPHE June 2011 ARR, Reference 22 of the
HRS documentation record at proposal), and a data quality assessment specifically generated for the 2010
CDPHE 2010 site inspection XRF results (the March 2012 Data Quality Assessment, Reference 28 of the HRS
documentation record at proposal).
This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.
3.4.6 Preliminary Assessment XRF Data
Comment: Mr. Coomes commented on the CDPHE 2008 PA report (Reference 19 of the HRS documentation
record at proposal), noting that XRF data for several of the sample locations shown in Figure 7 of that report were
not listed in Table 7 of the report. Mr. Coomes asserted XRF data are missing for samples XRF-031, XRF-037,
XRF-039, XRF-040, XRF-041, XRF-042, XRF-043, XRF-044, XRF-045, XRF-046, XRF-047, XRF-048, XRF-
049, XRF-050, XRF-051, and XRF-052. Mr. Coomes concluded the report is incomplete, and requested the
missing data to allow him to complete his analysis of the distribution of contaminants and to complete his
comments.
Response: Analytical results from the CDPHE 2008 PA report were not directly used in the HRS documentation
record at proposal to associate hazardous substances with a source or establish areas of observed contamination
for the Site. However, the CDPHE 2008 PA report (Reference 19 of the HRS documentation record at proposal)
was not incomplete. The CDPHE 2008 PA report provides a summary of previous investigations that are relevant
to the Colorado Smelter site. Regarding the specific sample results mentioned by Mr. Coomes:
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Samples XRF-031 and XRF-037 are contained in Table 7 of the CDPHE 2008 PA report.
Samples XRF-039, XRF-040, XRF-041, XRF-042, XRF-043, XRF-045, XRF-046, XRF-047, XRF-048,
XRF-049, XRF-050, XRF-051, and XRF-052 were collected for a separate investigation of the nearby
Blende Smelter and, although shown on Figure 7 of the CDPHE 2008 PA report, these were not included
in Table 7 because they are not considered relevant to the Colorado Smelter PA.10
Sample XRF-44 was never collected and is not depicted on Figure 7.
This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.
3.5 Requests to Extend Comment Period
Comment: Mr. Coomes noted that he had requested in his comments that the EPA provide additional information,
stating the information "is needed to perform a meaningful review." Mr. Coomes added "[t]his may require
significantly extending the comment period." As detailed in section 3.4, Adequacy of Public Docket/Requests for
Additional Documents, of this support document, Mr. Coomes included in his comments several requests for
documents and information. Specifically regarding the extension of the comment period, he requested the
following:
A copy of the QAPP associated with the CDPHE 2010 site inspection activities. Mr. Coomes asserted
"[t]he actual CDPHE QAPP is critical to preparing specific comments on the proposed listing. Therefore,
these comments are not complete and an extension of time is requested to review the QAPP that was
actually used."
"[A] Data Quality Assessment Report (that agrees with the EPA guidance for such a document)." Mr.
Coomes commented that such a report "has not been distributed for review," and requested such a
document be made available for review, noting this may require a time extension for comments. Mr.
Coomes asserted that "[a] complete review of the proposed listing cannot be made until a DQA report has
been commented upon."
Data that Mr. Coomes asserted is missing from the CDPHE 2008 PA report (Reference 19 of the HRS
documentation record at proposal). Mr. Coomes noted that an extended comment period will be needed to
complete his comments using the additional data.
Response: As explained in the responses provided in sections 3.4, Adequacy of Public Docket/Requests for
Additional Documents, and 3.3, Consistency with Data Quality Program, of this support document, the
information provided in the HRS package at proposal was sufficient to support the HRS evaluation of the Site and
provide the public with a meaningful opportunity to participate in this rulemaking. The 2010 CDPHE 2010 site
inspection was performed as planned; the planning and performance of the investigation was documented; data
obtained were assessed and determined to be appropriate for their intended use as input for an HRS evaluation.
The documents and information relied upon for the HRS evaluation were provided at proposal, and this final
rulemaking does not result in a significant change from the proposed rulemaking. The comment period will not be
re-opened.
This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.
10 The sample results for the Blende Smelter investigation are available from EPA Region 8 on request.
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3.6 Risk to Human Health and the Environment
Comment: Two anonymous public commenters, Joe and Pam Kocman, and Mr. Coomes submitted comments
related to risk posed by the Site and mitigation of that risk.
Two anonymous public commenters presented arguments regarding blood levels of toxins and the associated risk
from the levels detected. Two anonymous public commenters stated that blood levels of both arsenic and lead
were very low and not of significant concern. One anonymous public commenter stated that only 6 of 99
individuals tested had elevated levels of lead in their blood. Another anonymous public commenter commented
that no individual showed elevated blood arsenic levels above 5 micrograms per deciliter (jj.g/dl). These two
anonymous public commenters concluded that the health problems are overstated and that lead-based paint could
be responsible for elevated blood lead levels. Further, one anonymous public commenter questioned that if a
health risk was so great, why it took the EPA two years to begin any action after testing for contaminants.
Joe and Pam Kocman commented that the EPA should change its acceptable blood lead level from 10 jj.g/dl to 5
(ig/dl to be consistent with levels that coincide with current acceptable levels according to the CDC. Joe and Pam
Kocman further commented that children's blood lead levels in the area showed elevated levels above 5 jj.g/dl and
stated that remediation should be undertaken to reduce blood lead levels in children. However, Joe and Pam
Kocman cited a study that was conducted in Baltimore, Maryland11 (that contained similar lead soil level
concentrations as those in homes in the Eilers neighborhood), which found that soil remediation alone did not
reduce blood lead levels in children and commented that soil abatement alone will not significantly reduce the
blood lead levels. Joe and Pam Kocman commented that EPA should work with other Agencies to remediate
more than just neighborhood soil so that blood lead levels can be reduced to below 5 jj.g/dl.
Mr. Coomes submitted several comments discussing health-based cleanup goals and questioned whether such
goals would yield a reduction in risk to the population affected by the Site.
Response: Regarding questions of the level of risk posed by the Site, placing a site on the NPL is not based on a
site-specific risk assessment, nor does listing require that a site-specific risk assessment be performed prior to the
listing. A site-specific risk assessment is performed later in the Superfund process, following more extensive
sampling.
The HRS is not a site-specific risk assessment. A site specific risk assessment quantifies the risk to receptors
actually posed by releases at a site. The HRS is a numerically based screening tool that the Agency uses to assess
the relative degree of risk to human health and the environment posed by a site compared to other sites subject to
review based on a screening level knowledge of site conditions. The HRS score is used to determine whether a
site is eligible for placement on the NPL. The NPL is intended primarily to guide EPA in determining which sites
warrant further investigation to assess the nature and extent of public health and environmental risks associated
with a release of hazardous substances, pollutants or contaminants. See 79 FR 26922 (Proposed Rule, Colorado
Smelter site, May 12, 2014); see also 55 FR 51532 (Final Rule, Hazard Ranking System, December 14, 1990).
CERCLA ง 105(a)(8)(a) requires EPA to determine NPL priorities based on the "relative risk or danger to public
health or welfare, or the environment." The criteria EPA applies to determine this relative risk or danger is
codified in the HRS, and is the Agency's primary tool for deriving a site score based on the factors identified in
CERCLA. The HRS evaluation and score above 28.50 represents EPA's determination that the Site may pose a
relative risk or danger to human health and the environment and warrants further investigation under CERCLA.
The issue at hand is the placement of the Site on the NPL based on an HRS evaluation, not the appropriate levels
of lead or arsenic exposure according to the CDC or other agency, and these comments do not show any error in
the HRS evaluation. As part of the standard Superfund process, once the Site is on the NPL, the investigations
11 Citing to the "Three City Abatement Study" (citation not provided by commenter).
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performed to characterize the Site will be evaluated for completeness, further information will be collected if
deemed necessary to adequately characterize the risks posed by the Site, and based on this information, a risk
assessment decision will be made determining if and what remedial action is necessary to protect human health
and the environment.
This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.
3.7 Remediation and Cleanup Levels
Comment: Mr. Coomes, one anonymous public commenter, the City of Pueblo, the Eiler Heights Neighborhood
Association, the Bessemer Association for Neighborhood Development, and Joe and Pam Kocman submitted
comments related to future remediation and cleanup goals.
Mr. Coomes questioned EPA Superfund lead cleanup levels, and their potential effectiveness at the Colorado
Smelter site. Mr. Coomes asserted that EPA Superfund remedial goals for lead in residential soil are inadequate
based on the CDC recommendations. Mr. Coomes commented that CDC recommendations include reducing the
blood lead level (BLL) to 5 jj.g/dl; but, EPA Superfund guidance instead recommends no more than five percent
of children with BLLs greater than 10 jj.g/dl and no more than one percent of children with BLLs greater than 15
(ig/dl. Mr. Coomes requested that the EPA explain how these goals are protective of children's health. Mr.
Coomes also requested that the EPA explain how the EPA's approach will be protective of children's health for
those living in the Site area. Mr. Coomes stated, "[n]ote that child blood lead tests have not identified that five
percent of the population has BLLs greater than 10 jj.g/dl, which EPA has as a cleanup goal." Mr. Coomes further
requested the EPA "explain how the soil removal to 400 ppm will protect the 0.5 to 4- year olds will be protected
[s/'c] when soil containing "less than" 400 ppm is not remediated."
Mr. Coomes stated:
[T]he EPA cleanup goal for residential properties contaminated with lead is to have no more than
5 percent of the children with blood lead levels greater than 10 jxg/dl and no more than 1 percent
of the children with blood lead levels greater than 15 jxg/dl. None of the children tested in the
proposed Superfund area, or all of Pueblo, have blood lead levels as great as the EPA Superfund
cleanup goal. Please explain how a Superfund soil cleanup will protect children's health. Yes, I
know that EPA does not use blood lead measurements to evaluate a site as clean or contaminated,
but it appears that the position of protecting children's health by remediating soil lead is weak
especially since the 400 ppm "action" level is not protective of all ages of children.
Mr. Coomes asserted that the "most applicable" guidances for the Eilers neighborhood related to soil lead levels
are the U.S. Department of Housing and Urban Development guidance and Toxic Substances Control Act
guidance on the subject.12
Mr. Coomes commented on the results of EPA's 1991 study, Three City Urban Soil-Lead Demonstration
Project, Midterm Project Update, and stated that the results of this study "should be presented to the
Pueblo public" to give them an understanding of the effects of soil remediation on children's blood lead
levels. Mr. Coomes stated "it is not clear that soil remediation would result in a meaningful or even
measurable decrease in Eilers children's BBL [s/'c]."
Mr. Coomes stated:
12 Mr. Coomes cited the April 2001 EPA fact sheet, Identifying Lead Hazards in Residential Properties, EPA 747-F-01-002;
and the U.S. Department of Housing and Urban Development document, Guidelines for the Evaluation and Control of Lead-
Based Paint Hazards in Housing, Office of Healthy Homes and Lead Hazard Control, Second Edition, July 2012.
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In the Eilers area, the average soil lead of all individual residential yard samples is 280 ppm and
yard averages ranged from 48 to 651 ppm. Assuming that EPA's $15 million dollar study was
accurate, replacing Eilers soil would result in an average BLL decrease range of 0.13 to 0.25 |ig
for the average yard.
Mr. Coomes characterized such a reduction as "insignificant."
Mr. Coomes added that the "EPA study of the Eilers neighborhood did not identify or test play areas even
though the Sampling and Analysis plan stated they would."
Mr. Coomes questioned why the Site is being proposed to the NPL, as he asserted that "the evidence does
not support doing so."
Additionally, one anonymous public commenter submitted comments asking how the listing is to proceed. The
City of Pueblo, the Eiler Heights Neighborhood Association, and the Bessemer Association for Neighborhood
Development submitted a list of items that they state EPA should complete before placing the site on the NPL.
The Eiler Heights Neighborhood Association stated that "Nothing less than these 'EXPECTATIONS' is
acceptable since this is the only way to guarantee our children's health." Joe and Pam Kocman commented that if
a comprehensive cleanup cannot be completed in a timely manner (less than 5 years) then EPA should use its
emergency response authority to clean up Eiler neighborhood properties that have been identified as
contaminated.
Response: Remedial actions and site-specific cleanup criteria are developed at a later stage in the Superfund
process, after NPL listing; decisions related to these actions and criteria are not required to be completed prior to
promulgation of a site to the NPL. Consistent with CERCLA, the EPA has in place an orderly procedure for
identifying sites where releases of substances addressed under CERCLA have occurred or may occur, placing
such sites on the NPL, evaluating the nature and extent of the threats at such sites, responding to those threats, and
deleting sites from the NPL. The purpose of the initial two steps (identifying sites where releases of substances
addressed under CERCLA have occurred, or may occur and placing such sites on the NPL) is to develop the NPL,
which identifies for the States and the public those sites that appear to warrant remedial action (56 FR 35842, July
29, 1991). The evaluation or RI/FS phase involves onsite testing to assess the nature and extent of the public
health and environmental risks associated with the site and to determine what CERCLA-funded remedial actions,
if any, may be appropriate; during this process, site-specific conditions, including determination of exposure
scenarios specific to the location, are used to develop site-specific cleanup criteria based on risk. After a period of
public comment, the Agency responds to those threats by issuing a Record of Decision which selects the most
appropriate alternative. The selected remedy is implemented during the remedial design/remedial action phase.
Finally, the site may be deleted from the NPL when the Agency determines that no further response is
appropriate.
None of these comments identified any error in the HRS score. This comment results in no change to the HRS
score and no change in the decision to place the Site on the NPL.
3.8 Purpose of Listing
Comment: One anonymous public commenter expressed suspicion regarding the EPA's motive in listing the Site
at this time, arguing that the Colorado Smelter has not operated in 100 years; the commenter noted that EPA
Superfund funding was reduced in 1994 following revision of the CERCLA tax on chemicals and petroleum, and
characterized it as "curious that the interest in the Eiler's Neighborhood coincides with a | sic] the ASARCO 2009
Bankruptcy settlement, which provided the EPA with $1.79 billion to 'clean up' over 80 sites around the
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country." The same commenter inquired why other sites that appear to be more dangerous in other parts of the
U.S. are not cleaned up first.
Response: Funding-related issues are not considered when determining if a Site qualifies for the NPL, and need
not be made prior to promulgation of the site to the NPL. The EPA's actions to evaluate the Site using the HRS
and list the Site are consistent with the requirements of CERCLA and SARA, and the statutory purpose of the
NPL, which is to inform the public of possible threats and identify those sites which appear to warrant further
investigation and/or remediation.
The primary purpose of the NPL is stated in the legislative history of CERCLA (Report of the Committee on
Environment and Public Works, Senate Report No. 96-848, 96th Cong., 2d Sess. 60 [1980]), as follows (in
relevant part):
The priority list serves primarily informational purposes, identifying for the States and the public
those facilities and sites or other releases which appear to warrant remedial actions.
The EPA has clearly, via this listing, identified for the States and the public both the sources and release (the
smelter stack air emissions, the slag pile, and contaminated soil) that are currently scored using the HRS.
As previously noted in this support document, the selection of remedyif any is found necessaryand any
associated funding is a step carried out at a later stage of the Superfund process.
This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.
3.9 Impacts of Listing
Comment: Two anonymous public commenters and Joe and Pam Kocman submitted comments related to the
impact of listing the Site on the NPL.
Two anonymous public commenters stated that placing the site on the NPL will negatively impact property values
because the homes in the Eiler neighborhood will no longer be marketable. These commenters also stated that
property values are dropping because banks will not provide Federal Housing Administration-insured loans or VA
loans to purchase homes located in the Eiler neighborhood. One of the anonymous public commenters also stated
that because of the loss of value to Eiler neighborhood homes, the commenter considers this listing designation as
an illegal taking of the commenter's property. Joe and Pam Kocman expressed that homeowners should not bear
any future costs of testing and possible abatement.
Response: Indirect economic factors such as those raised by the commenters are generally not considered in the
assessment of whether a site belongs on the NPL. However, even if such factors were considered, the alleged
negative impacts noted by the commenters would be caused by the contamination in the area, not by placing the
site on the NPL. The EPA also notes that there are benefits associated with listing a site, including the potential
for Federally-financed remedial actions; the acceleration of privately financed, voluntary cleanup efforts; and
increased support for state funding responses at particular sites.
The Agency's actions in this rulemaking do not result in any taking of private property in violation of the Fifth
Amendment. This listing does not impose any obligations on any entities. This listing also does not set standards
or a regulatory regime, and imposes no liability or costs. The listing does not interfere with any compensable
property interests of private property owners, and merely reflects the EPA's judgment that a significant release or
threat of release has occurred, and that the Site is a priority for further investigation.
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This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.
3.10 Extent of Site
Comment: One anonymous public commenter noted that the EPA has not defined the extent of the Site
boundaries and is therefore unable to determine the scope of contamination at the Site.
Response: CERCLA Section 105(a)(8)(A) requires the EPA to list national priorities among the known "releases
or threatened releases" of hazardous substances; thus, the focus is on the release, not precisely delineated
boundaries. On March 31, 1989 (54 FR 13298), the EPA stated:
HRS scoring and the subsequent listing of a release merely represent the initial determination that
a certain area may need to be addressed under CERCLA. Accordingly, the EPA contemplates that
the preliminary description of facility boundaries at the time of scoring will need to be refined
and improved as more information is developed as to where the contamination has come to be
located; this refining step generally comes during the RI/FS stage.
The Agency notes however, that the full extent of a "Site" for Superfund purposes is not determined at the time of
listing. Placing a site on the NPL is based on an evaluation, in accordance with the HRS, of a release or threatened
release of hazardous substances, pollutants, or contaminants. That the EPA initially identifies and lists the release
based on a review of contamination at a certain parcel of property does not necessarily mean that the site
boundaries are limited to that parcel.
Until the investigations at the Site are complete and a remedial action (if any) selected, the EPA can neither
estimate the extent of contamination at the site, nor describe the ultimate dimensions of the NPL site. Even during
a remedial action, such as removing contaminated soils or sediments, the EPA may find that the contamination
has spread further than previously estimated, or is not as extensive as estimated.
This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.
3.11 Comments on Reference Material and Factual Errors
Comment: Mr. Coomes submitted several comments regarding the information presented in references and other
perceived factual errors in the HRS package.
Response: The specific comments are addressed in the following sections:
3.11.1 Number of Aliquots per Multi-increment Sample
3.11.2 Number of Locations Sampled
3.11.3 Classification of Grab Samples
3.11.42011 Analytical Results Report Reference List Items
3.11.5 QAPP and Appendix H
3.11.1 Number of Aliquots per Multi-increment Sample
Comment: Mr. Coomes quoted page 23 of the HRS documentation record at proposal as stating that "[i]n each
zone, 5 individual aliquots were collected (Ref. 22, p. 12)" (referring to the soil sampling zones at residential
yards used in the CDPHE 2010 site inspection). However, Mr. Coomes noted that this is incorrect, identifying that
multi-increment sample CO-SO-34-4 contained only four aliquots. Mr. Coomes asserted that "this affects the
'completeness' of the data set and quality analyses should be repeated."
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Response: Mr. Coomes is correct that for sample CO-SO-34-4 results for only 4 out of the 5 aliquots were
available. However, the completeness of the CDPHE 2010 site inspection was found to be sufficient according to
the data quality assessment performed. Furthermore, neither composite results nor individual aliquot results of
multi-increment sample CO-SO-34-4 were used to infer contamination within AOC A or to set AOC boundaries.
Therefore, the number of aliquots collected has no impact on the decision to promulgate the site to the NPL.
Page 8 of Reference 28 of the HRS documentation record at proposal, the March 2012 Data Quality Assessment,
addresses this missing aliquot, stating:
Completeness is a measure of the amount of valid data obtained from a measurement system. The
actual percentage of completeness is less important than the effect of completeness on the data
set. All samples collected by CDPHE were analyzed by XRF as planned, with the exception of
sample C0S0344.2, which was missing from the sample set upon arrival to the EPA warehouse.
All 57 confirmation samples were analyzed by the CLP laboratory as planned.
Thus, five aliquots for CO-SO-34-4 were collected, but one aliquot was lost in shipping; no impact to data quality
was identified.
And, XRF data were presented as additional evidence of contamination within the AOC. As stated on page 24 of
the HRS documentation record at proposal:
[T]he site score is based on CLP data, specifically CLP analytical results of individual aliquot
samples. Within Areas of Observed Contamination (AOCs) based on CLP aliquot samples (Table
3 and Table 5 of this HRS documentation record) XRF multi-increment sample results are also
presented (Table 4 and Table 6 of this HRS documentation record). The HRS allows for inferring
contamination within an AOC for contaminated soil (Ref. 1, p. 51646). XRF analyses are
presented to provide additional evidence supporting the background and release sample
concentrations and to provide additional evidence that the area between the observed
contamination sampling locations is contaminated.
Thus, CLP analyses were used to establish AOC A for scoring purposes, and XRF analyses were presented to
support the inference of contamination within the AOC.
Further, as shown in Table 4: Residential Soil XRF Composites on pages 33-37 of the HRS documentation record
at proposal, multi-increment sample CO-SO-34-4 was not used to infer contamination at that associated property;
CO-SO-34-2 was presented in that table as evidence of contamination at this property (and, as shown on page 22
of Reference 28 of the HRS documentation record at proposal, five aliquots were collected/analyzed for this
zone).
This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.
3.11.2 Number of Locations Sampled
Comment: Mr. Coomes questioned the documentation of the number of samples collected, asserting that:
Appendix G indicates that 8 sample sites were sampled on June 21, 2010 (The sample log book
indicates 16 sites were samples | v/c |). Appendix G indicates that 30 sites were sampled on June
22, 2010 (The sample log book indicates 31 sites were sampled, and Appendix G indicates the 18
sites were sampled on Jun 21, 2010 (the sample log book indicates 20 sample sites were
sampled).
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Mr. Coomes requested that the EPA correct this apparent inconsistency, contending that "[t]his type of reporting
reflects on the overall quality of the investigation and reports."
Response: As shown below, the numbers are consistent with the references and analysis types they are associated
with and there is therefore no impact on the quality of the investigation and reports, or on the HRS evaluation of
the Site.
The EPA assumes that by "Appendix G," Mr. Coomes is referring to Appendix G of Reference 28 of the HRS
documentation record at proposal, the March 2012 Data Quality Assessment. This appendix contains CDPHE
chain-of-custody documents for sampling activities conducted by CDPHE in June 2010. The EPA also assumes
that by "sample log book," Mr. Coomes is referring to the field log book for June 2010 CDPHE sampling
activities included as Reference 21 of the HRS documentation record at proposal.
Regarding samples collected on June 21, 2010, Appendix G of Reference 28 of the HRS documentation record at
proposal is a chain-of-custody for soil and source samples submitted for XRF analysis (8 samples). The sample
locations listed as collected on June 21, 2010, on field log book pages 1-3 of Reference 21 of the HRS
documentation record at proposal additionally include eight surface water and sediment sample locations, which
were not submitted for XRF analysis.
Regarding samples collected on June 22, 2010, Mr. Coomes has miscounted: both the chain-of-custody forms in
Appendix G of Reference 28 of the HRS documentation record at proposal and field log book pages 4-8 of
Reference 21 of the HRS documentation record at proposal list 31 locations sampled.
Regarding samples collected on June 23, 2010, again, chain-of-custody forms in Appendix G of Reference 28 of
the HRS documentation record at proposal list the 18 locations from which samples were submitted for XRF
analysis. Field log book pages 4-8 of Reference 21 of the HRS documentation record at proposal include those
sample locations plus an additional two samples (a surface water sample and a sediment sample) that were not
submitted for XRF analysis.
This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.
3.11.3 Classification of Grab Samples
Comment: Mr. Coomes commented that the data quality assessment report refers to residential aliquot samples as
grab samples. However, Mr. Coomes stated that:
The only grab samples identified in the May 10, Sampling and Analysis Plan (CON000802700)
are for 1. A sample of water collected by the county (p 7), background (p 13), waste pile (pi 3)
and soil on the banks of the river (p 15). She | sic | residential soil samples were collected based on
Figure 3 of the SAP.
Mr. Coomes requested that the EPA correct one of those documents (the SAP or the data quality
assessment report) and "provide a description of the actual sample collection type, so there is agreement."
Response: Both the March 2012 Data Quality Assessment and the May 2010 Sampling and Analysis Plan
(References 28 and 20 of the HRS documentation record at proposal, respectively) are correct in identifying the
type of samples collected. All of the samples collected during the CDPHE June 2010 site inspection activities
(including individual soil aliquots collected for a multi-increment sample) may be considered grab samples in the
sense that there was no field compositing of the samples. (In discussing residential soil sampling, page 15 of
Reference 20 of the HRS documentation record at proposal, the CDPHE May 2010 SAP, notes that "[n]o
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compositing, drying, or sieving of the samples will occur in the field, [emphasis added]" Page 12 of Reference 22
of the HRS documentation record at proposal, the associated analytical results report, confirms that following
collection, the samples "were brought back to Denver and delivered to URS Operating Services (UOS)" and then
"[l]ater, UOS combined the samples into 88 multi-increment samples".) Furthermore, whether a sample is
classified as an "aliquot" sample or a "grab" sample is not relevant to an HRS evaluation; rather, for HRS
purposes it is only relevant whether or not the sample represents the contamination in the environment.13
This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.
3.11.4 2011 Analytical Results Report Reference List Items
Comment: Mr. Coomes pointed to the reference list included in the CDPHE June 2011 ARR, Reference 22 of the
HRS documentation record at proposal, questioning whether entries 58 and 59 in that report are intended to refer
to the same document or different documents. (Both reference list entries name the Sampling and Analysis Plan
for the Colorado Smelter Site, May 2010.) If different, Mr. Coomes requested that both copies be supplied for
review.
Response: The References list on pages 42-45 of Reference 22 of the HRS documentation record at proposal is an
endnote-style list, with an entry for each citation to a reference within the body of the report text. Reference list
entries 58 and 59as well as entries 3 and 61refer to the same document, the May 2010 Sampling and Analysis
Plan for the Colorado Smelter Site.
This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.
3.11.5 QAPP and Appendix H
Comment: In several instances, Mr. Coomes refers to a QAPP "provided in the Pueblo Rawlins Public Library"
and an "Appendix H" that was "provided by EPA," and makes comments on these documents.
Regarding the QAPP "provided in the Pueblo Rawlins Public Library," Mr. Coomes made the following
comments:
"The QAPP that is provided in the Pueblo Rawlins Public Library was written by an unknown
organization and not the CDPHE who had sample collecting responsibility."
"EPA guidance states that the quality of the data must be related to the decisions identified in the Data
Quality Objectives prepared for the Sampling and Analysis Plan (SAP). The QAPP at the repository in
Pueblo does not address the SAP DQOs and is not acceptable documentation for the Colorado Smelter
Investigation."
Mr. Coomes noted this QAPP "appears to be generic and not related to the Colorado Smelter site
Investigation," and "was written by an unknown organization and not the CDPHE who had sample
collecting responsibility."
Regarding "Appendix H," Mr. Coomes made the following comments:
"Appendix H provided by EPA appears to be from an unrelated investigation "Gowanus Canal Remedial
Investigation, Brooklyn, New York", as indicated in Table 3' (of that document): Screening Level
Comparison to Nondetects."
13 See also section 3.12, Identification of Observed Contamination - Soil Collection Technique, of this support document,
which further explains HRS requirements for establishing observed contamination.
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"Appendix H is a Data Quality Assessment that only evaluates the quality of the data after the samples
are collected and analyzed. That document mentions a project-specific QAPP three times as the UFP-
QAPP. UFP is not defined in the document. The importance of a project-specific QAPP is implied in
Appendix H. Appendix H obviously does not apply to the Colorado Smelter, since the word "smelter" is
not even in the document."
Response: The QAPP and "Appendix H" documents referred to by Mr. Coomes in his comments appear to be
unrelated to the Colorado Smelter site, and thus comments based on these documents are not relevant to the
decision to list the Site on the NPL.
Regarding the QAPP found by Mr. Coomes at the local public library, this QAPP was not attached to Mr. Coomes
comments, and therefore not available for inspection by the EPA. However, based on Mr. Coomes' related
assertions, such as that the QAPP in question was not generated by CDPHE, it is clear that this QAPP was not
used in planning the CDPHE 2010 site inspection and is not cited in relevant planning documents (e.g., the
CDPHE May 2010 Sample and Analysis Plan, included as Reference 20 of the HRS documentation record at
proposal). The CDPHE generic QAPP actually used in planning the CDPHE 2010 site inspection is cited as a
reference in the CDPHE June 2011 ARR. This generic QAPP is included as Attachment 1 of this response
document. Therefore, Mr. Coomes' comments related to the QAPP he found at the public library are not relevant
to the CDPHE 2010 site inspection activities or the NPL listing of the Site.
Similarly, regarding the "Appendix H" document mentioned by Mr. Coomes, Mr. Coomes has not provided a
copy of this document or clarified what overarching document to which it is appended. Based on some of Mr.
Coomes comments, the "Appendix H" document he is referring to appears to be an appendix to the Gowanus
Canal Remedial Investigation reportan EPA document generated for a separate Superfund site in New York.14
Comments related to this document are not relevant to the CDPHE 2010 site inspection activities or the NPL
listing of the Site.
This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.
3.12 Identification of Observed Contamination - Soil Collection Technique
Comment: Mr. Coomes called into question the usability, comparability, and representativeness of the soil
samples results presented in the HRS documentation record and used in the HRS evaluation based on claimed
issues with the sampling technique used and asserted inconsistency with an SOP Mr. Coomes stated was provided
to the City of Pueblo by the EPA.
Mr. Coomes asserted that "[r]eview of that the Standard Operating Procedure (SOP) provided to the City of
Pueblo demonstrates that the SOP was not followed, resulting in questionable data quality from the study." (Mr.
Coomes refers to SOP #SRC-OGDEN-02, Surface Soil Sampling, included as Attachment 1 of his comment
submittal, docket ID EPA-HQ-SFUND-2014-0318-0020.) Mr. Coomes commented that the "actual procedures
used to collect samples yield [s/'c] analytical data have not been made available," and concluded "the collected
data are not sufficient to support defensible decision-making."
Mr. Coomes commented that the SOP instructed that:
the soil samples be collected with Shelby tubes,
new gloves be used at each sample point, and
a sample location diagram be generated before sample collection.
14 Copies of the remedial investigation report for the Gowanus Canal site, including the "Appendix H" to which Mr. Coomes
appears to be referring are available at http://www.epa.gov/region2/superfund/npl/gowanus/ri docs.html.
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However, Mr. Coomes asserted that sampling logs show that "samples were collected very rapidly, without
sufficient time to follow the SOP provided to the City of Pueblo." Mr. Coomes commented:
The sampling log book shows that Samples CO-SO-38 through CO-SO-45, 80 individual samples
at 8 properties, were collected in an average time of 1 minute and 23 seconds per sample. That is
insufficient time to change gloves between each sampling location to prevent cross
contamination, use Shelby tubes for sample collection, make a sketch of the sample locations in
the yard, and use decontamination procedures. . . . Other sample collection times include: 5
properties; CO-SO-29, 30, 31, 32, and 33, collected 80 samples at 1 minute and 47 seconds for
each sample. Another series of samples for four properties; CO-SO-13, 14, 15, and 16 collected
60 samples at 1 minute and 43 seconds each. This analysis clearly demonstrates that the SOP was
not followed.
Mr. Coomes noted that related to soil samples used to establish AOC A, page 23 of the HRS documentation
record states, "All samples were collected from the top 2-inches of the ground surface (Ref. 22, p. 12)." However,
Mr. Coomes also claimed that inappropriate soil sampling equipment different from that specified in the SOP was
used, stating:
The photo documentation supporting the investigation clearly shows the sampling equipment to
be a small folding shovel. This sampling equipment is shown in the photo documentation section
of the report. It is not clear how a specific 0 to 2-inch soil horizon can be accurately sampled
using this crude sampling equipment. ... if a small shovel was used (no plastic scoops as shown
in earlier reports) [p]lease document how the 0 to 2-inch soil horizon was accurately sampled.
Mr. Coomes requested that the EPA "provide documentation that supports using a shovel to collect soil samples
to consistently collect the same sample horizon is an accurate methodology" and "[e]xplain how the potential
variability affects the data analysis and the 'comparability' and 'representiveness' of the sample data when Shelby
tubes are not used to sample a specific soil horizon." Mr. Coomes further stated that:
Since field duplicate samples were not collected for the Colorado Smelter Study, the potential
variation in data resulting from the undocumented sampling method (which is not described in the
SOP supplied to the City of Pueblo) is of unknown quality and is of uncertain used | v/c | to
support listing the site.
Mr. Coomes requested that the EPA "discuss this critical issue and how it affects decision-making."
Separately, Mr. Coomes asserted that the EPA did not follow relevant EPA Region 8 guidance for the evaluation
of lead at residential properties. Mr. Coomes cited the EPA April 2000 document, Region VIII Superfund
Program Residential Soil Lead Sampling Guidance. Mr. Coomes alleged this guidance was not referenced or
followed in the site investigation, and therefore "the quality of the collected data is suspect and cannot be used to
support defensible decision-making." Mr. Coomes commented, "a conceptual site model (CSM) was not included
or discussed, although EPA Region 8 guidance provides an example, specifically for historic smelting
operations." Mr. Coomes asserted there should have been a discussion of release mechanisms, transport pathways,
and receptor populations for each chemical of concern. Mr. Coomes asserted this omission results in a lack of
understanding by the public regarding the problems at the Site and what EPA is attempting to do, thus failing one
of the objectives of EPA investigative reports.
Response: The SOP cited by Mr. Coomes was not used in planning the CDPHE 2010 site inspection. All of the
soil and source samples used in the HRS evaluation for the Site were collected from the top two inches of the soil
surface using dedicated, disposable plastic scoops, and a separate plastic scoop was used for each individual
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sample, consistent with the CDPHE May 2010 SAP developed for the CDPHE 2010 site inspection.15 And, as
explained below, soil sample results used in scoring the Site met data quality objectives specific to the HRS,
which are those relevant to listing (e.g., the objectives related to the collection of data of sufficient quality to
determine whether the site qualifies for NPL listing via an HRS evaluation).
First, the SOP Mr. Coomes cited related to his comments (SOP #SRC-OGDEN-02, Surface Soil Sampling,
included as Attachment 1 of his comment document) was not used during the CDPHE 2010 site inspection and is
not cited in relevant planning documents (e.g., the CDPHE May 2010 Sample and Analysis Plan, included as
Reference 20 of the HRS documentation record at proposal, or the March 2000 CDPHE QAPP for Site
Assessments Under Superfund, included as Attachment 1 of this support document). Mr. Coomes did not indicate
in his comments why he believes this SOP is connected to the CDPHE 2010 site inspection. SOP #SRC-OGDEN-
02 and its specifications are not relevant to the CDPHE 2010 site inspection activities, and therefore not relevant
to the data used for the HRS evaluation of the Site.
The HRS requires in identifying observed contamination for an HRS evaluation that the contamination be within
the top two feet of soil (an HRS data quality objective). HRS Section 5.0.1, General considerations, states in
relevant part:
Consider observed contamination to be present at sampling locations where analytic evidence
indicates that:
-A hazardous substance attributable to the site is present at a concentration significantly
above background levels for the site (see table 2-3 in section 2.3 for the criteria for
determining analytical significance), and
-This hazardous substance, if not present at the surface, is covered by 2 feet or less of
cover material (for example, soil).
There is no HRS requirement that evidence of observed contamination be limited to the top two inches of soil;
however, a sample from the top two inches meets this data quality objective.
On the subject of soil samples used to identify the residential soil area of observed contamination, page 23 of the
HRS documentation record at proposal notes that "[a]ll samples were collected from the top 2-inches of the
ground surface (Ref. 22, p. 12)."
Page 12 of Reference 22 of the HRS documentation record at proposal (the CDPHE June 2011 ARR) cited above,
also notes soil collection within the top two inches. And, page 25 of that ARR notes that "[a]ll Technical Standard
Operating Procedures (TSOPs) for field activities as specified in the Approved58 SAP were followed" (referring to
the CDPHE May 2010 SAP).
Page 15 of the CDPHE May 2010 SAP (Reference 20 of the HRS documentation record at proposal) states:
Samples will be collected from 0-2" or slightly deeper depending on landscaping including grass
cover. Where grass is present the sod will be peeled back to allow for sample collection and
immediately replaced. The samples will be collected with decontaminated stainless steel spoons
or disposable plastic scoops.
15 Note that, an SOP is generally an established Regional, State, or contractor procedure to address non-site specific
investigation activities and issues. These procedures may cover topics such as sampling protocols, chain-of-custody
requirements, and quality assurance sampling requirements. In contrast, a SAP generally documents procedural/analytical
requirements for a site-specific one-time/time-limited project that involves the collection of samples of water, soil, sediment
or other media to characterize areas of potential environmental contamination, and addresses elements specified in the related
quality assurance project plan.
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As shown in the photolog of the ARR (pages 60-75 of Reference 22 of the HRS documentation record at
proposal) the CDPHE sampling crew carried a small shovel in case it was necessary to peel back sod to allow for
soil sampling; however this was not necessary for any of the yards sampled as dry loose dirt was always available.
A shovel was not used to collect any samples.
Regarding the timing of sample collection, all collected source, background, and residential soil samples were
placed into zip-top polypropylene bags (see page 26 of Reference 22 of the HRS documentation record at
proposal) using the dedicated scoops; and, no additional soil sample treatment/compositing or analysis was
performed in the field. Therefore, very little time was needed to collect each sample.
Regarding duplicate samples, CDPHE followed procedures described in the CDPHE May 2010 SAP to guide
field sampling. The SAP did not call for the collection of field duplicate soil samples because of the typical
heterogeneity expected in grab soil samples.
Regarding the EPA Region 8 Superfund Program Residential Soil Lead Sampling Guidance, this guidance
document is not required to be followed for an HRS evaluation.16 Additionally, page 1 of this guidance document
notes that it "is not intended to replace other guidance documents relating to Program specific activities, SOPs,
QAPPs, etc." It also notes that its purpose is to "[d]efine the nature and extent of contamination and determine
where elevated concentrations of lead are present at levels posing an unacceptable risk to humans." However, as
further explained in section 3.6, Risk to Human Health and the Environment, of this support document, an HRS
evaluation is not based on a site-specific risk assessment; instead, the HRS is a numerically based screening tool
that the EPA uses to assess the relative degree of risk to human health and the environment posed by a site
compared to other sites subject to review (a site-specific risk assessment is part of a later step in the Superfund
process).
While the CDPHE did not cite the EPA Region 8 Superfund Program Residential Soil Lead Sampling Guidance
in the CDPHE May 2010 SAP, it has become common practice for residential soil sampling to include various
concepts and procedures described in that guidance, while also following EPA's site inspection guidance, which
helps direct sample collection for proper application of the HRS.17 For the Colorado Smelter site, the site
inspection program staff collected more than one aliquot or increment from multiple decision units at each
property sampled during the site inspection. All of the samples collected for the site inspection were collected as
grab samples (i.e., there was no field-compositing of any samples), which is typical of CERCLA site inspections.
These procedures were correctly performed by CDPHE and are described in Section 8.2.3 of the CDPHE May
2010 SAP, included as Reference 20 of the HRS documentation record at proposal (see Reference 20, pages 14-
15 and Figure 3).
Furthermore, as explained in section 3.3, Consistency with Data Quality Program, of this support document, soil
sample results used in scoring the Site met data quality objectives specific to the HRS, which are those relevant to
listing.
Regarding the CSM, as further detailed in section 3.3.1.1, Conceptual Site Model, of this support document,
although the HRS does not require that a CSM be generated or explicitly described to the public (in the HRS
documentation record or its supporting references), such a model was included in the CDPHE May 2010 SAP in a
16 The Region 8 sampling guidance document referred to by Mr. Coomes is available at
http://www2.epa.gov/region8/residential-soil-lead-sampling-guidance-document.
17 See also page 1 of CDPHE 2010 SAP, included as Reference 20 of the HRS documentation record at proposal, which notes
that the SAP was prepared in accordance with the EPA "Guidance for Performing Site Inspections Under CERCLA", Interim
Final, September 1992, the "Region 8 Supplement to Guidance for Performing Site Inspections Under CERCLA," and the
CDPHE Generic Quality Assurance Project Plan (QAPP) (CDPHE HMWMD 2000).
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narrative format; and, for the purposes of an HRS evaluation, a CSM used for the relative evaluation of all sites is
also built into the HRS itself.
This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.
3.13 Identification of Observed Contamination - Background Level
Comment: Mr. Coomes submitted several comments asserting that the lead background levels used to establish
observed contamination in the HRS documentation record at proposal were low and available data instead support
a greater background lead level of around 100 mg/kg.
Mr. Coomes stated:
The background lead concentrations (two samples) identified in the Colorado Smelter Site
Inspection Analytical Results Report8 June 22, 20118 were 47 and 22 mg/kg. Those data are in
conflict with the background soil lead in an earlier Colorado Smelter report [Citing Sample
Report Santa Fe Avenue Bridge Culvert Pueblo, Colorado COD #98257252513, February 22,
1994.] That report identified a background soil lead concentration of 111 mg/kg (Sample SF-SO-
1, -Table 4 of reference 8).
In discussing background lead concentrations, Mr. Coomes also commented that the EPA has not discussed lead-
based paint or emissions from leaded gasoline as significant sources in the HRS documentation record. Mr.
Coomes pointed to previous EPA studies18 on other areas of the country, noting that urban area soil lead levels
found in those studies were "much greater than those found in the Eilers neighborhood" and the "EPA should not
consider the Eilers soil lead levels as out of the ordinary."
Mr. Coomes also pointed to the results from two other studies19 asserting the results support a background level of
100 ppm and requested EPA provide a detailed discussion why they do not support that value, as follows:
Please review the Diawara1 and USGS13 data and explain why specific samples that were
collected in undeveloped areas cannot represent background soil lead concentration, which could
approach approximately 100 ppm. The USGS data also support background soil lead
concentrations of this magnitude. If EPA considers it not logical to consider those data as
representative of background please provide a detailed discussion to support that position.
From the Diawara study, Mr. Coomes specifically mentions two sample locations (Diawara sites 8A and 8B) as
being 4.3 miles upwind of the Colorado Smelter site, distant from urban areas and residential
development/commercial activity; Mr. Coomes contends that these samples exhibit lead concentrations of
approximately 100 ppm and represent background lead soil levels.20 Mr. Coomes commented that such
background levels are supported by the USGS study data (noting 72 soil sample results from that document
18 Mr. Coomes cites the EPA 1991 document, Three City Urban Soil-Lead Demonstration Project, Midterm Project Update,
and the EPA January 1998 document, Guidance for Data Quality Assessment, Practical Methods for Data Analysis,
EPA QA/G-9, QA97 Version, EPA/600/R-96/084.
19 Mr. Coomes cites two studies: (1) Diawara, Moussa M., et al. 2006. Arsenic, Cadmium, Lead, and Mercury in Surface
Soils, Pueblo, Colorado: Implications for Population Health Risk. Environmental Geochemistry and Health, 28:297-315. This
document (hereafter referred to as the 2006 Diawara study) is included as Reference 11 of the HRS documentation record at
proposal. (2) Schaklett et al Element Concentrations in Soils and Other Surficial Materials of the Conterminous United
States, USGS paper 1270, 1984.
20 Mr. Coomes points to Figure 3 of his comment submittal, on which he has plotted the locations of Diawara sample
locations 8A and 8B. The Diawara study sample locations and lead concentrations may also be found on pages 300 and 302-
303 of Reference 11 of the HRS documentation record at proposal.
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summarized in Attachment 3 to his comment document on discussion and presentation of USGS data). Mr.
Coomes stated "[t]wenty percent (15 of 72) of the county soil lead concentrations were 50 ppm or greater. More
than five percent (4 of 72) were 100 ppm lead."
Response: The background samples and associated background lead concentrations used in establishing observed
contamination for lead concentrations in the HRS documentation record were selected appropriately and
consistently with the HRS. And, the HRS documentation record at proposal presented substantial information to
show their suitability to set background levels for the purpose of establishing observed contamination.
The HRS does not contain instructions on or define conditions for establishing background levels of
contaminants; background samples should be suitable for comparison to observed contamination samples to
establish that the identified significant increase evaluated is not the result of the sampling and analysis methods
employed. For the soil exposure pathway, the HRS addresses background only in the context of identifying
observed contamination. HRS Section 5.0.1, General considerations, states:
Evaluate the soil exposure pathway based on areas of observed contamination:
Consider observed contamination to be present at sampling locations where analytic evidence
indicates that:
-A hazardous substance attributable to the site is present at a concentration significantly
above background levels for the site (see table 2-3 in section 2.3 for the criteria for
determining analytical significance), and
-This hazardous substance, if not present at the surface, is covered by 2 feet or less of
cover material (for example, soil).
HRS Section 2.3, Likelihood of Release, states in part, "[t]he criteria in table 2-3 are also used in establishing
observed contamination for the soil exposure pathway."
The portions of HRS Table 2-3 used to establish observed contamination and the AOC are cited as follows:
Sample Measurement > Sample Quantitation Limit3
An observed release is established as follows:
If the background concentration is not detected (or is less than the detection limit), an
observed release is established when the sample measurement equals or exceeds the sample
quantitation limit3.
If the background concentration equals or exceeds the detection limit, an observed release is
established when the sample measurement is 3 times or more above the background
concentration.
Thus, background levels are used for the purpose of identifying a significant increase in hazardous substances.
The HRS uses background levels to show that a hazardous substance is present at concentrations significantly
above background levels for a site. The background sample locations used to determine the significant increase
from the release from the Colorado Smelter sources are representative of the level that would be present if the
release from the Colorado Smelter sources were not present. And, the sampling methods employed for
background and observed contamination samples would have minimized effects of other sources, such as lead-
based paint on houses and emissions from leaded gasoline.
The HRS documentation record at proposal presents support for the suitability of the background soil samples
used in establishing observed contamination. Page 23 of the HRS documentation record at proposal discusses
background samples, stating:
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CDPHE performed a Site Inspection on the Colorado Smelter in 2010 (Ref. 22). Sampling
activities were conducted from June 21 - 23, 2010 (Ref. 21). Samples were collected from 57
locations including 47 residential properties, 3 vacant lots, 1 road right-of-way, 4 slag pile
samples, and 2 background samples (Ref. 22, pp. 12, 21). Background soil samples were
collected from an open field approximately 2 miles northwest of the Colorado Smelter and
outside the area likely to be impacted by emissions from the former smelter (Ref. 22, p. 21).
Page 23 of the HRS documentation record at proposal also notes the soil samples were collected using the same
multi-incremental sampling technique, and that:
Five individual aliquots were also collected for each of the vacant lots, road right-of-way,
background and slag pile samples. All samples were collected from the top 2-inches of the ground
surface (Ref. 22, p. 12).
Pages 23-24 of the HRS documentation record at proposal further discuss that background and contaminated soil
samples were subjected to the same analytical process, including XRF aliquot/composite sample analysis and
CLP confirmatory aliquot/composite analysis for a subset of the contaminated samples and one background
sample. And, results from CLP and XRF analyses were validated.
On strategy for background sample location, page 25 of the HRS documentation record at proposal states:
The background locations were selected to obtain soil samples that were sufficiently far enough
away that they were unlikely to be impacted by aerial deposition from the stacks. A map of the
surficial geology of the Pueblo area by the United States Geologic Survey (USGS) (Ref. 23 and
Ref. 24) was used to compare background and release samples. The map shapefiles were
downloaded from the USGS webpage [a copy of the USGS surficial geology of the Pueblo area
map is available online21] and imported into ArcMap. A map (Ref. 25) was created and shows
that the background samples were collected in a Holocene-age unit designated as "xci" and
described as a sandy clay disintegration residuum (Ref. 24, p. 13). In comparison, the release
samples collected from areas surrounding the former smelter were collected in a Holocene-age
unit designated as "es" and described as an eolian sand (Ref. 24, p. 8).
And, page 25 of the HRS documentation record at proposal addresses the possible influence of naturally occurring
arsenic and lead levels, stating:
The suitability of the background samples for comparison to release samples for metals
concentrations for the purpose of determining if a release sample is greater than three-times the
background concentration is supported by correspondence on February 27, 2012 from the USGS
(Ref. 33). Regarding naturally occurring arsenic and lead levels in the surficial units from which
samples were collected, the USGS states that the "xci" unit is formed from in-situ weathering of
the Pierre Shale, known to be enriched in trace elements including arsenic and, less so, lead. In
comparison, the "es" unit would be expected to have lower concentrations of naturally occurring
arsenic and lead (Ref. 33). Therefore, the surficial geologic unit "xci" from which the background
samples were collected would, if anything, be expected to be biased high relative to the release
samples collected from within the "es" unit.
21 See http://pubs.usgs.gov/mf/2002/mf-2388/mf-2388 print.pdf
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Page 26 of the HRS documentation record at proposal presents the background concentrations for CLP aliquot
sample CO-BG-02 1.5 as 15.8 mg/kg22 lead and 9.5 mg/kg arsenic; these results are used in setting background
levels for the identification of CLP aliquot samples meeting observed contamination criteria and establishing the
boundaries of AOC A. Page 27 of the HRS documentation record at proposal presents the background
concentrations from XRF composite samples CO-SO-BG-Ol and CO-SO-BG-02 as 47 mg/kg lead/16 mg/kg
arsenic, and 22 mg/kg lead/13.5 mg/kg arsenic, respectively; these results are used in setting background levels
for the identification of XRF composite samples meeting observed contamination criteria and to provide
additional evidence of contamination within AOC A.
Finally, page 25 of the HRS documentation record at proposal offers additional evidence substantiating the soil
background concentrations of arsenic and lead used in establishing observed contamination.
Three background soil samples collected on September 29, 1994 (Refs. 14b, pp. 10-14; 14c, p.2)
for the Santa Fe Avenue Bridge Culvert Expanded Site Investigation (Ref. 14) corroborate arsenic
and lead background soil concentrations presented in Tables 1 and 2 of this HRS documentation
record. Background soil samples SOI, S02, and S03 for the Santa Fe Avenue Bridge Culvert
Expanded Site Investigation were collected from three locations located several miles from the
Colorado Smelter (Ref. 14b, pp. 13, 14). Arsenic concentrations for these samples ranged from
5.0 ppm to 6.1 ppm and lead concentrations ranged from 13.9 ppm to 32.5 ppm (Ref. 14, p. 18, p.
40; Ref 14c, pp. 18-20).
A study of arsenic, cadmium, lead and mercury in surface soils in Pueblo (Ref. 11) also
corroborate background arsenic and lead concentrations presented in Tables 1 and 2 of this HRS
documentation record. A local map of lead concentrations (Ref. 11, p. 305, Figure 3) in Pueblo
indicates soil samples collected at sites 31A/3 IB in the northern portion of the study area (Ref.
11, Figure 1) should best represent background conditions. At sites 31A and 3 IB arsenic
concentrations are 13.2 ppm and 14.7 ppm, and lead concentrations are 18 ppm and 30 ppm,
respectively (Ref. 11, Table 1, p. 303).
Regarding the lead result of 111 mg/kg for sample SF-SO-1 pointed to by Mr. Coomes and shown in CDPHE
1994 Sample Report, Santa Fe Avenue Bridge Culvert (Reference 13 of the HRS documentation at proposal), this
is likely not a viable representation of background levels for the Site because of the sample's proximity to the
Colorado Smelter. SF-SO-1 is located approximately 0.7 mile west of the Colorado Smelter (see Figure 9 of
Reference 13 of the HRS documentation record at proposal) and is expected to be within the area impacted by
aerial deposition from the stacks due to its close proximity to the Colorado Smelter and area known to be
contaminated by aerial deposition. Background samples CO-BG-01 and CO-BG-02 used in the HRS
documentation record at proposal in the identification of observed contamination, were from approximately 2
miles northwest of the Colorado Smelter.
Regarding the Diawara study samples, Mr. Coomes suggests using Diawara samples 8A and 8B for background
with lead levels of 99 and 100 ppm, respectively, as shown on page 302 of Reference 11 of the HRS
documentation record at proposal. However, there is no indication that these locations are more appropriate than
other Diawara study sample locations that might be considered as background samples within that study,
including Diawara samples 9A/9B, 10A/10B, 11A/1 IB, 29A/29, or 31A/3 IB, all of which show lead
concentrations comparable to the CDPHE 2010 site inspection background samples with lead levels of 48, 36, 22,
22 On page 26 of the HRS documentation record at proposal, this result is noted as being qualified as estimated during data
validation, and is adjusted per the EPA Fact Sheet, "Using Qualified Data to Document an Observed Release and Observed
Contamination," (Reference 48 of the HRS documentation record at proposal) to provide an estimated maximum possible
concentration of 22.75 mg/kg lead prior to use in evaluation of contaminated samples for meeting HRS observed
contamination criteria.
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28, 53, 30, 38, 23, 18 and 30, respectively, as shown on page 303 of Reference 11 of the HRS documentation
record at proposal. (For sample locations, see also Figure 1 of the Diawara study on page 300 of Reference 11 of
the HRS documentation record at proposal.) Also, the Diawara study sample locations may not be as
representative of background levels, due to less screening out of other sources and proximity to other smelters in
the area. As quoted above, the HRS documentation record at proposal does mention Diawara study samples
31 A/3 IB as supporting the concentrations found in background samples CO-BG-01 and CO-BG-02.
Additionally, it appears that the Diawara study samples were prepared for analysis using a different procedure that
could impact the lead analysis results: they were sieved prior to analysis. Page 299 of Reference 11 of the HRS
documentation record at proposal states that:
Samples were taken from the top 5-cm of soil and placed in freezer bags. For each sample a
subset was sieved to particles less than 2 mm in diameter and stored in glass containers for
chemical analysis.
It is not clear that the results from the sieved portions of soil samples analyzed for the Diawara study would be
directly comparable to the results from the CDPHE 2010 site inspection CLP aliquot soil samples used in
establishing AOC A, which were not sieved. Of the soil particle size fractions, it is possible that lead tends to
associate more with one fraction than another; therefore, the smaller particle size fraction included in Diawara
studies may be skewed relative to the CDPHE 2010 site inspection samples (e.g., flue dust from the Colorado
Smelter stacks would likely exist in smaller particle size, and sieving would tend to select for those particles,
impacting comparability). And, the analytical method used to generate Diawara study results is not specified;
again, based on a possible difference in analyses, it is uncertain whether these Diawara study results would be
either directly comparable to those from the CDPHE 2010 site inspection CLP aliquot soil samples used to
establish AOC A, which were generated via CLP methodology, or directly comparable to XRF-analyzed
composite sample results presented as additional evidence of contamination within AOC A (i.e., it is possible that
differences in sample preparation, digest procedures, analytical precision/accuracy, etc., between the
methodologies do not yield directly comparable results).
On the subject of the USGS study data cited by Mr. Coomes, the EPA cannot replicate or verify the analysis or
assertions made by Mr. Coomes regarding the background soil lead levels. In response to this comment, the EPA
has reviewed Attachment 3 of Mr. Coomes comment document, and the USGS Professional Paper 127023 cited by
Mr. Coomes as the source of his tabular and graphical data presented in his Attachment 3, based on the samples
and sample characteristic data presented. However, these data do not appear to be derived from that particular
USGS paper. It appears that the tabular data presented in Mr. Coomes Attachment 3 may be derived instead from
USGS Open-File Report 81-19724, although this reference is not cited by Mr. Coomes. Regardless of these issues,
from the pool of data in USGS Open-File Report 81-197, the two USGS soil samples from Pueblo County listed
exhibited lead concentrations of 20 ppm and 30 ppm (mg/kg); these concentrations are supportive of the
background lead levels used in the HRS documentation record at proposal. Additionally, according to page 2 of
the USGS Open-File Report 81-197, soil samples were pulverized and sieved and the minus-2 millimeter fraction
used for analysis, and the analysis employed was a semi-quantitative six-step emission spectrographic method.
Similar to the Diawara study results, it is not clear that results from these sieved samples would be directly
comparable to CDPHE 2010 site inspection CLP aliquot soil sample results used to establish AOC A. And it is
uncertain whether these USGS study results would be either directly comparable to those from the CDPHE 2010
site inspection CLP aliquot soil samples used to establish AOC A, which were generated via CLP methodology,
or directly comparable to XRF-analyzed composite sample results presented as additional evidence of
contamination within AOC A.
23 A complete copy of USGS Professional Paper 1270 is available at http://pubs.usgs.gov/pp/1270/.
24 A complete copy of USGW Open File Report 81-197 is available at http://pubs.er.usgs. gov/publication/ofr81197. An
excerpt of this report is included as Attachment 3 of this support document.
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Regarding the 1991 EPA document, Three City Urban Soil-Lead Demonstration Project, Midterm Project Update,
referred to by Mr. Coomes, the data collected for this study are not representative of background levels for the
Colorado Smelter site. While the EPA study identified lead levels in urban areas, specifically three different
citiesBoston, MA; Baltimore, MD; and Cincinnati, OHthe identified lead concentrations within the study are
applicable to the three cities evaluated and the industries and other contamination sources specific to those cities;
these levels are not representative of site-specific factors that may be influencing background lead levels at the
Colorado Smelter site. Further, the study areas selected in each city for that study were intentionally areas with
elevated soil lead levels (not randomly chosen areas), and were not meant to be representative of lead
concentrations in each city.25 Hence, the data included in the EPA study on urban soil lead levels are not relevant
to establishing site-specific background levels for the Colorado Smelter site.
Finally, even if the highest lead concentration Mr. Coomes proposes as a reasonable background concentration
111 mg/kg leadwere used to set the lead background level, many of the sample results used to establish
observed contamination based on lead would still meet observed contamination criteria. The lead sample results
would exceed three times that number333 mg/kg (20 out of the 31 CLP aliquot sample lead results shown in
Table 3 of the HRS documentation record at proposal). Although the resulting hypothetical AOC A based on only
the samples with concentrations greater than 333 mg/kg would shrink based on that exercise, the sample locations
still documenting observed contamination established via arsenic concentrations and the related Level I targets
scored based on those locations would not change. And, the Site score would not change even if the targets score
were based solely on those points of arsenic observed contamination and Level I targets.26
This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.
3.14 Identification of Observed Contamination - Significant Increase Criteria
Comment: Mr. Coomes called into question the criteria used to identify a significant increase in hazardous
substances over background levels in samples used to document the presence, location, and level of observed
contamination. Mr. Coomes stated:
EPA compared three times the background concentration of lead to identify a need for
investigation. This criterion is generally used to determine whether there has been a release from
a source, and are [s/'c] not criteria used to list a site on Superfund.
Response: The criteria used to establish observed contamination in the HRS documentation record at proposal are
consistent with the HRS and are criteria specifically used in evaluating a site for NPL listing. Using a hazardous
substance in a contaminated sample exhibiting concentrations three times or more the background level to
establish observed contamination is part of HRS-specified criteria.
HRS Section 5.0.1, General considerations, identifies the significant increase criteria, and states in relevant part:
25 See page 3 of the 1991 EPA document, Three City Urban Soil-Lead Demonstration Project, Midterm Project Update,
available online at http://nepis.epa.gov/Exe/ZvPDF.cgi/20000LHH.PDF?Dockev=2000QLHH.PDF.
26 The waste characteristics factor category value would remain unchanged as well since the hazardous substances scored
would still include arsenic and lead. And, even though AOC A might shrink in the hypothetical scenario, the waste quantity
AOC A contributes to the score is minimal compared to that contributed by the slag pile AOC B. Therefore, considering a
likelihood of exposure value of 550, a waste characteristics factor category value of 100, and a resident population targets
factor category value of 205 (based solely on the Level I concentrations score of 155 established by arsenic points of
observed contamination and the resulting resident individual score of 50), the soil exposure pathway score would remain
100.00 and the Site score would remain 50.00 in this hypothetical scoring.
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Consider observed contamination to be present at sampling locations where analytic evidence
indicates that:
-A hazardous substance attributable to the site is present at a concentration significantly
above background levels for the site (see table 2-3 in section 2.3 for the criteria for
determining analytical significance), and
-This hazardous substance, if not present at the surface, is covered by 2 feet or less of
cover material (for example, soil), [emphasis added]
HRS Section 2.3, Likelihood of release, introduces Table 2-3 which is used to identify observed releases in the
ground water, surface water, and air pathways and observed contamination in the soil exposure pathwaythe
pathway evaluated for this site. HRS Section 2.3 states in part to "[u]se the criteria in table 2-3 as the standard for
determining analytical significance. (The criteria in table 2-3 are also used in establishing observed contamination
for the soil exposure pathway, see section 5.0.1.)"
HRS Table 2-3 is contained in HRS Section 2.3, Likelihood of release, referred to by HRS Section 5.0.1, General
considerations, and establishes the mathematical requirements for establishing observed contamination or
observed releases; it states in relevant part:
If the background concentration is not detected (or is less than the detection limit), an
observed release is established when the sample measurement equals or exceeds the
sample quantitation limit.
If the background concentration equals or exceeds the detection limit, an observed release
is established when the sample measurement is 3 times or more above the background
concentration, [emphasis added]
Tables 3 and 4 on pages 29-36 of the HRS documentation record at proposal present three-times-background for
each analyte (in a column labeled "3xBG/SQL") to show that the related contaminated soil sample results meet
HRS criteria for establishing observed contamination, consistent with the HRS.
This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.
3.15 Identification of Observed Contamination - Contaminated Samples
Comment: Mr. Coomes asserted that, in the comparison of composite sample results versus individual aliquot
results, a high bias is apparent in the composite sample results. Mr. Coomes noted this "is after EPA made a
correction for one of the composite lead values, (CO-SO-20-3)." Mr. Coomes points to Figure 4 of his comment
document, stating, "Figure 4 compares the difference between the average lead for the aliquots and lead
concentration of the composite sample. The average difference is 43.3 ppm, a value that is greater than the EPA's
identified "background" concentration (37.5ppm)."27
Mr. Coomes commented that the composite results were "19 percent larger than the mathematically combined
amounts from the five individual samples. EPA has not explained how this bias was introduced, but places the
quality of the data is in question."
Response: The samples used to establish observed contamination and the AOC meet all HRS data quality
objectives for identifying contaminated samples for the purposes of the HRS evaluation. Despite any tendency for
composite sample XRF results to be greater than related aliquot sample XRF results, they still met the HRS
significant increase criteria for establishing observed contamination by showing a significant increase above the
27 Figure 4 of Mr. Coomes' comment submittal is included as Attachment 6 of this support document.
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background levels established using the same type of sample. Further, the difference between composite results
and aliquot results is expected given the different sample treatment.
As explained below, CLP aliquot sample results were used to establish the boundaries of observed contamination
in residential soils associated with AOC A. XRF composite sample results (the subject of Mr. Coomes' bias
arguments) were only used to provide additional evidence of the extent of contamination within AOC A.
Furthermore, composite samples are not required by the HRS; any individual aliquot result within 200 feet of a
residence meeting observed contamination criteria is sufficient to establish observed contamination and score the
residence under the HRS resident population threat.
HRS Section 5.0.1, General considerations, describes how to document observed contamination and an AOC,
stating in relevant part:
Consider observed contamination to be present at sampling locations where analytic evidence
indicates that:
-A hazardous substance attributable to the site is present at a concentration significantly
above background levels for the site (see table 2-3 in section 2.3 for the criteria for
determining analytical significance), and
-This hazardous substance, if not present at the surface, is covered by 2 feet or less of
cover material (for example, soil).
Establish areas of observed contamination based on sampling locations at which there is
observed contamination as follows:
-For all sources except contaminated soil, if observed contamination from the site is
present at any sampling location within the source, consider that entire source to be an
area of observed contamination.
-For contaminated soil, consider both the sampling location(s) with observed
contamination from the site and the area lying between such locations to be an area of
observed contamination, unless available information indicates otherwise.
If an area of observed contamination (or portion of such an area) is covered by a permanent,
or otherwise maintained, essentially impenetrable material (for example, asphalt) that is not
more than 2 feet thick, exclude that area (or portion of the area) in evaluating the soil
exposure pathway.
For an area of observed contamination, consider only those hazardous substances that meet
the criteria for observed contamination for that area to be associated with that area in
evaluating the soil exposure pathway (see section 2.2.2).
If there is observed contamination, assign scores for the resident population threat and the
nearby population threat, as specified in sections 5.1 and 5.2. If there is no observed
contamination, assign the soil exposure pathway a score of 0.
HRS Section 5.1, Resident Population Threat, states:
Evaluate the resident population threat only if there is an area of observed contamination in one
or more of the following locations:
Within the property boundary of a residence, school, or day care center and within 200 feet of
the respective residence, school, or day care center, or
Within a workplace property boundary and within 200 feet of a workplace area, or
Within the boundaries of a resource specified in section 5.1.3.4, or
Within the boundaries of a terrestrial sensitive environment specified in section 5.1.3.5.
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If not, assign the resident population threat a value of 0, enter this value in table 5-1, and proceed
to the nearby population threat (section 5.2).
There is no requirement that composite samples be used and no detailed requirements for any specific sample
type. Therefore, any aliquot soil sample within 200 feet of a scored residence meeting observed contamination
criteria is sufficient to identify observed contamination and evaluate the population associated with that residence
under the resident population threat of the HRS. As noted on page 23 of the HRS documentation record at
proposal, all the individual aliquots for all the residential properties sampled during the CDPHE 2010 site
inspection were collected within 200 feet of the houses, as the associated properties are all less than 200 feet in
width and length (this was not contested by commenters).
Regarding XRF composite sample results, page 24 of the HRS documentation record at proposal states that the
CLP results from aliquot samples were used to establish AOC A, and that XRF results from composite samples
were only used as additional evidence of contamination; it states:
In this HRS documentation record the site score is based on CLP data, specifically CLP analytical
results of individual aliquot samples. Within Areas of Observed Contamination (AOCs) based on
CLP aliquot samples (Table 3 and Table 5 of this HRS documentation record) XRF multi-
increment sample results are also presented (Table 4 and Table 6 of this HRS documentation
record). The HRS allows for inferring contamination within an AOC for contaminated soil (Ref.
1, p. 51646). XRF analyses are presented to provide additional evidence supporting the
background and release sample concentrations and to provide additional evidence that the area
between the observed contamination sampling locations is contaminated.
Those CLP aliquot contaminated sample results and XRF composite contaminated sample results are shown in
Tables 3 and 4 on pages 29-36 of the HRS documentation record at proposal.
Page 24 of the HRS documentation record at proposal notes that these results are supported by the XRF results
from aliquot samples:
It should be noted that the XRF aliquot data comprises a larger, and therefore more robust, data
set than either the laboratory data or the XRF composite data and that the XRF aliquot data set
corroborates the HRS score derived and presented in this documentation record. All data obtained
during the June 21-23, 2010 sampling event are presented in the ARR (Ref. 22) and DQA (Ref.
28). XRF composites and aliquot sample lead concentrations are illustrated on Figures 6 and 7
contained as References 32a and 32b to this HRS documentation record.
Thus, as explained above, the observed contamination present in AOC A was established using samples that met
all HRS data quality objectives.
Furthermore, the difference between composite sample lead results and aliquot sample lead results is expected
given the different sample preparation for each sample type. Pages 23-24 of the HRS documentation record at
proposal state that:
A total of 434 individual samples were collected into 1-quart plastic bags. All 434 of the sample
aliquots were delivered to URS Operating Services (UOS), EPA's Superfund Technical
Assessment and Response Team (START) laboratory in Denver, Colorado (Ref. 22, p. 4;Ref.
22b; Ref. 28, Appendix G) where they were analyzed using an Innov-X model Omega X-Ray
Fluorescence analyzer (XRF) (Ref. 28 p. 2). The samples were analyzed directly in the bags using
the XRF (Refs. 22, p. 12; 28, p. 1). Subsequently, the samples were composited, dried, sieved,
placed in method specific polyethylene sample cups per EPA Method SW-846 6200 guidelines
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(Ref. 29, pp. 19, 20), and analyzed with the XRF (Ref. 28, p. 1). The 434 aliquots were thus
combined into 87 multi-increment samples (also known as composite samples) . . .
Therefore, as part of sample processing per analytical method specifications, composite samples were sieved and
dried (aliquot samples were not). This processing would be expected to increase measured lead concentrations,
and can explain the "bias" calculated by Mr. Coomes, for two reasons. First, moisture can be a negative
interference for XRF analysis, and thus more moist samples (the aliquot samples) will tend to yield lower analyte
measurements than drier samples (the composite samples)2S. And second, a sieved sample (the composite sample)
will contain a greater proportion of smaller particles than a non-sieved sample (an aliquot sample); as the lead-
bearing material deposited from the Colorado Smelter was likely composed of fine-grained flue dust, a sieved
sample would likely exhibit a greater lead concentration than a non-sieved sample. However, these differences did
not introduce an inaccuracy in the comparison between background and release samples presented in the HRS
documentation record, because CLP aliquot release samples were compared to CLP aliquot background samples
and XRF composite release samples were compared to XRF composite background samples (within each
background/release sample set, compared samples were subject to the same sample preparation techniques and
same resulting effects on lead concentrations).
Regarding Mr. Coomes statement that the "average difference is 43.3 ppm, a value that is greater than the EPA's
identified 'background' concentration (37.5ppm)," this is not the background lead level that was used in the HRS
documentation record at proposal. Page 26 of the HRS documentation record at proposal presents the lead
concentration from CLP aliquot background sample CO-BG-02 1.5 as 15.8 mg/kg lead; this result is used in
setting background levels for the identification of CLP aliquot samples meeting observed contamination criteria
and establishing the boundaries of AOC A. Page 27 of the HRS documentation record at proposal presents the
lead concentrations from XRF composite background samples CO-SO-BG-Ol and CO-SO-BG-02 as 47 mg/kg
lead and 22 mg/kg lead, respectively; these results are used in setting background levels for the identification of
XRF composite samples meeting observed contamination criteria and to provide additional evidence of
contamination within AOC A. A value of 37.5 was not used as a background concentration in the HRS
documentation record at proposal.
Additionally, if the purpose of Mr. Coomes' statement was to call into question the background levels used in the
HRS documentation record at proposal by comparing the magnitude of the background levels to the average
difference value he calculated, such a comparison is not statistically appropriate and does not negate the validity
of those background levels. That is, as described above, the average difference between the composite sample
results and the aliquot sample results represents the difference between two different sample preparation
processes. Because the two sets of data are developed in different ways, it is inappropriate and not meaningful to
compare this average difference value to results generated by either individual sample preparation process (the
aliquot samples results or the composite sample results).
Regarding the correction of one of the composite lead values, in sample CO-SO-20-3, it was explained in
Reference 22a of the HRS documentation record at proposal that:
The error appears on page 19 (in-text Table 8) of the Analytical Results Report where the lead
concentration for sample SO-20-3 is incorrectly reported to be 632 part per million (ppm). The
correct lead concentration for this sample is 362 ppm. The error is also contained in Figure 6. The
rest of the ARR is correct, including the summary table at the end of the ARR.
And, SO-20-3 was not used in establishing observed contamination at the Site.
28 For example, see page 6200-5 of Reference 29 of the HRS documentation record at proposal (EPA Method 6200). See also
page 7 of the EPA Region 4 Science and Ecosystem Support Division Operating Procedure SESDPROC-107-R2, Field X-
Ray Fluorescence Measurement, available at http://www.epa. eov/region4/sesd/fbqstp/Field-XRF-Measurement.pdf.
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This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.
3.16 Attribution
Comment: Mr. Coomes submitted comments calling into question the attribution of hazardous substances to the
Site based on his review of data cited by EPA. Mr. Coomes asserted that the EPA "assumes that the smelter was
the primary, or only, source of lead contamination" and that "[t]his conclusion is based on the fact that other
potential lead sources were not investigated or described."
Mr. Coomes commented that particulate from stack emissions should deposit "uniformly in the area and be more
concentrated downwind of the stack, but generally decreasing with distance from the source." Mr. Coomes argued
that the distribution of lead concentrations "does not support a particulate deposition model from a point source."
Based on the EPA's model of the Site, Mr. Coomes contended that:
Assuming that the smelter is the source of contamination, the ratio of lead to arsenic should be
uniform over the 'contaminated' area and decrease in concentration with distance from the
source. The collected soil samples and analysis do not support this Conceptual Site Model
concept.
Further, Mr. Coomes commented that the data quality objective guidance calls for a site-specific CSM to be
prepared and claims that one is not present; Mr. Coomes therefore asserts that the "release mechanisms, transport
pathways, affected media, and intake routes" are not explained and the attribution of hazardous substances to the
Site cannot be made.
Response: The attribution of hazardous substances (lead and arsenic) in the residential soil AOC to the Site is
properly established consistent with the HRS. The Colorado Smelter is reasonably documented to have released
lead and arsenic contaminants through historical operations via smelter stack emissions that were deposited in the
AOC surrounding the Colorado Smelter stacks.
HRS Section 5.0.1, General considerations, states:
Evaluate the soil exposure pathway based on areas of observed contamination:
Consider observed contamination to be present at sampling locations where analytic evidence
indicates that:
-A hazardous substance attributable to the site [emphasis added] is present at a
concentration significantly above background levels for the site (see Table 2-3 in section
2.3 for the criteria for determining analytical significance), and
-This hazardous substance, if not present at the surface, is covered by 2 feet or less of
cover material (for example, soil).
Establish areas of observed contamination based on sampling locations at which there is observed
contamination as follows:
-For contaminated soil, consider both the sampling location(s) with observed
contamination from the site and the area lying between such locations to be an area of
observed contamination, unless available information indicates otherwise.
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If an area of observed contamination (or portion of such an area) is covered by a permanent, or
otherwise maintained, essentially impenetrable material (for example, asphalt) that is not more
than 2 feet thick, exclude that area (or portion of the area) in evaluating the soil exposure
pathway.
For an area of observed contamination, consider only those hazardous substances that meet the
criteria for observed contamination for that area to be associated with that area in evaluating the
soil exposure pathway (see section 2.2.2).
Page 21 of the HRS documentation record at proposal discusses hazardous substances that are associated
with the Site sources:
It has been documented that smelter stack emissions contain particulates of heavy metals (Ref.
42, pp. 53, 55; Ref. 43, p. 170). Samples of the slag generated by the Colorado Smelter contain
lead and arsenic (Ref. 22, pp. 58, 59) and it is reasonable to conclude that particulate emissions
from the Colorado Smelter stacks also contained lead and arsenic. In addition, the ore from the
Madonna mine processed at the Colorado Smelter contained 30 percent lead (Ref. 4, p.34, Ref.
5). In the smelting process, it is not possible to separate all the desired metal from other products
including slag and flue dust (Ref. 44, p. 92). Flue dust samples collected from the Anaconda
Minerals Company (AMC) smelter in Montana contain arsenic and lead at concentrations up to
14,300 ppm and 55,000 ppm, respectively (Ref. 45, pp. 38, 98, 106). Slag from the AMC smelter
contains arsenic and lead at concentrations of 217 ppm and 3,120 ppm, respectively (Sample AM-
SO-06) (Ref. 50, Table 2, p. 46). In comparison, the average concentration of arsenic and lead in
slag for the Colorado Smelter based on nine CLP aliquot samples is 503 ppm and 10,333 ppm,
respectively (Ref. 28, Table 1, p. 14) further indicating that stack emissions from the Colorado
Smelter also contained arsenic and lead.
Pages 38-39 of the HRS documentation record at proposal further discuss the attribution of hazardous
substances identified in the AOC to the Site in the attribution section:
Between the 1880's and the 1920's, five smelters operated in the City of Pueblo and its nearby
subdivisions. These included the Colorado Smelter, the Pueblo Smelter, the Philadelphia Smelter,
the Massachusetts Smelter, and the Blende Smelter (Ref. 4, pp. 1-5; Figure 1 of this HRS
documentation record). In addition to the smelters, the Colorado Fuel and Iron Co. (CF&I)
located south of the Colorado Smelter (Figure 1) began operations in Pueblo in the late 1800s
processing pig iron to make steel and iron products (Ref. 11, p. 298). This facility continues in
operation under the name Rocky Mountain Steel Mills. The facility is an active Resource
Conservation and Recovery Act (RCRA) facility with dozens of solid waste management units
(SWMUs) in various stages of assessment and cleanup. The mill continues to operate under a
state Resource Conservation and Recovery Act permit (CO-05-09-29-01) and a Clean Air Act
Title V Operating Permit (95OPPB086) (Ref. 19, p. 3).
Historical photographs (Ref. 4, p. 32, Ref. 9) of the Colorado Smelter show plumes of smoke
carried by wind being dispersed away from the stacks to the southeast. Sanborn Fire Insurance
maps (Ref. 8) show drawings of the Colorado Smelter and note the height of the main smoke
stack as 135 feet and a 200-foot-tall brick chimney for the roaster house as well as several other
stacks (Ref. 8c, Sheet 23, Ref. 8d, Sheet 157).
Prevailing winds at the Colorado Smelter during the time of operation were out of the north and
northwest as noted on Sanborn Fire Insurance Maps for the years 1883-1904 (Refs. 8a, p.l; 8b, p.
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1; 8c, p. 1; 8d, p. 1). Wind rose diagrams from a meteorological station located just south of the
Colorado Smelter on the Rocky Mountain Steel Mill for the time period January 1, 2003 -
December 31, 2005 and March 1, 2008 - February 28, 2009 show prevailing winds out of the
west-northwest (Ref. 46, pp. 1-3).
The area of area of | v/c | observed contamination as shown on Figure 4 of this HRS
documentation record is located within 1800 feet of the northern (and most distal) smoke stack
depicted and within 1663 feet of the southern (and more proximal) smoke stack depicted. The
proximity of the stacks to the area of observed contamination along with the historic prevailing
wind direction is evidence that at least a portion of the significant increase in lead and arsenic in
AOC A is attributable to the Colorado Smelter stacks.
The map (Ref. 14a) from the 1995 ARR for the Santa Fe Avenue Bridge Culvert (Ref. 14) shows
the spatial distribution of arsenic and lead contamination in soils surrounding the five smelters
that were operating in Pueblo from 1878 (Ref. 4, p. 13) until 1921 (Ref. 4, pp. 114-115). The map
shows a pattern that indicates a significant increase in lead and arsenic levels adjacent to the
Colorado Smelter.
The study of the metal content of surface soils in Pueblo conducted by affiliates of Colorado State
University published in 2006 (Ref. 11) also show an increase in lead concentration near the
Colorado Smelter. Sites 19A/19B and 20A/20B located southeast of the Colorado Smelter
indicate lead concentrations ranging from 149 ppm to 287 ppm (Ref. 11, Figure 1 and Table 1;
Ref. 47).
The increase in lead soil concentrations in residential areas proximal to the Colorado Smelter
based on data from the Colorado Smelter Site Inspection ARR (Ref. 22) is illustrated by Figures 6
and 7 (Refs. 32a and 32b). These maps present the lead soil concentration using graduated
symbols that graphically depict lead concentrations which are hence easily observed to be higher
in the residential areas immediately south and east of the Colorado Smelter.
For the area of observed contamination comprising 176 residential properties a portion of the
significant increase is attributable to the Colorado Smelter. The presence of lead and arsenic soil
contaminated to levels meeting HRS Table 2-3 criteria indicate lead and arsenic were emitted
from the smelter's smoke stacks and deposited on nearby soil.
As presented in the HRS documentation record and references cited therein, arsenic and lead are associated with
emissions from the Site sources. The HRS documentation record at proposal explains that historical photographs
show plumes of smoke travelling away from the stacks to the southeast. Further, it explains that because the slag
generated by the Colorado Smelter during the refining process contains lead and arsenic, it is reasonable to
conclude that emissions from the Colorado Smelter stacks also contained lead and arsenic. This is consistent with
similar current smelter operations that are known to emit the same substances present in their slag and flue dust.
Therefore, the arsenic and lead identified in the local residential soils as being significantly above background
sample concentrations was correctly identified as observed contamination and was correctly attributed to the Site,
consistent with the HRS; and, it is reasonable to conclude that emissions from Site Source 3, Smelter Stack air
emissions, which contain arsenic and lead resulting from operations at the site, caused the significant increase of
hazardous substances in the AOC.
Regarding Mr. Coomes comments on data quality objectives and the CSM, while the HRS documentation record
does not specifically refer to a CSM, as quoted above, the Source and Attribution sections of the HRS
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documentation record identify the hazardous substances (lead and arsenic), the process that released
contamination (the smelting process), the method of transport (Smelter emissions and plumes of smoke), and the
affected media (contaminated soil). As outlined in section 3.3, Consistency with Data Quality Program, of this
support document, and further demonstrated in this section of this support document and its subsections, the data
used to establish observed contamination at the Site are sufficient to support the attribution of lead and arsenic in
the residential soil to releases of lead and arsenic from the Colorado Smelter facility.
The following subsections of this support document address specific assertions regarding the attribution of
hazardous substances to the facility:
3.16.1 Attribution - Distribution of Lead in Soil - Lack of Concentration Cluster
3.16.2 Attribution - Distribution of Lead in Soil - Variability
3.16.3 Attribution - Arsenic Levels in Soil vs Arsenic Levels in Slag
3.16.4 Attribution - Arsenic/Lead Ratios - Distribution of Arsenic Relative to Lead
3.16.5 Attribution - Comparison of Site-related and Greater Area-related Datasets
3.16.6 Attribution - Other Sources
3.16.1 Distribution of Lead in Soil - Lack of Concentration Cluster
Comment: Mr. Coomes commented that based on his review of analytical data there was no lead concentration
cluster near the Colorado Smelter. Mr. Coomes inspected results in the 2006 Diawara study (Reference 11 of the
HRS documentation record at proposal) and plotted on a map locations where the lead concentrations exceeded
100 ppm (this plot is included as Figure 2 of Mr. Coomes comment submission29, docket ID EPA-HQ-SFUND-
2014-0318-0020). Mr. Coomes asserted that:
There is no not | sic | a concentration (or cluster) of these locations near the Historic Colorado
Smelter Site. In fact, the "high" lead soils are distributed over the entire investigative area (all of
Pueblo), except the far Northern portion of that investigation, which has only recently been
(sparsely) developed for residential use. Site 19A (177 ppm lead) is adjacent to Eilers, on the
South side of Northern Avenue. That location may be suspect because it is adjacent to the
existing Steel Mill and across Northern Avenue from the site. This suspicion is confirmed by
examining the relatively high lead in sample 20B (149 ppm), which is located South East of the
Steel Mill operation, and is close to the commercial metal operation.
Mr. Coomes requested that the EPA "explain how the Colorado Smelter emitted lead-containing particulate, but
high (greater than 100 ppm) soil lead concentrations are not located or concentrated immediately surrounding the
Historic Colorado Smelter site." Mr. Coomes stated that the "collected data do not support the EPA assumption
that soil lead concentrations decrease with increased distance from the Historic Colorado Smelter" and requested
this be addressed in the "Listing Document and supporting documentation."30
Response: Regarding Mr. Coomes' assertion that there is no support that lead concentrations are highest clustered
around the facility and decrease with distance from the historic Colorado Smelter, this assertion is incorrect. The
data presented in the HRS documentation record (specifically the data presented in figures shown in References
29 Mr. Coomes plotted on Figure 2 of his comment submittal locations where the Diawara study sample lead concentrations
exceeded 100 ppm. All of the Diawara study sample locations and lead concentrations may also be found on pages 300 and
302-303 of Reference 11 of the HRS documentation record at proposal.
30 Mr. Coomes pointed to Figure 1 of his comment submittal, noting it is a reproduction of Figure 7 from Reference 17 of the
HRS documentation record at proposal. (However, he cites instead to Reference 19, which appears to contain the figure that
is the basis for his Figure 1; this figure shows sample locations from 1994/1995 CDPHE soil collection activities.) Mr.
Coomes explains he added 0.5, 1.0, and 1.5 distance rings to his Figure 1.
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Colorado Smelter Response to Comments NPL Listing Support Document
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14, 32a, and 32b of the HRS documentation record at proposal) illustrate this decreasing gradient to be present
there is a concentration cluster near the historic Colorado Smelter. (See Figures 4, 5, and 6, of this support
document below based on these references. Additionally, Figures 5a and 5b of this support document represent
the CDPHE 2010 site inspection composite sample XRF lead results, focusing on soil samples, and varying plot
size and color based on concentration.) The EPA does not claim that this gradient extends throughout the city or
region as the commenter may be asserting, but rather that in the immediate vicinity of the smelter facility, the soil
lead concentrations decrease as the distance from the historic smelter stack increases. Additionally, several of the
residential soil samples in AOC A near the Colorado Smelter contain lead concentrations well above 100 mg/kg
(the level Mr. Coomes' equated with "high" concentrations). See Figures 5 and 6 of this support document31.
31 See also pages 51-59 of Reference 22 of the HRS documentation record at proposal for a full list of CDPHE 2010 site
inspection soil sample results.
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Colorado Smelter Response to Comments NPL Listing Support Document December 2014
Boston
Colora
Smeltei
ฆjo r"
Ph iladelphia
Sn elter .
Legend Excerpt
SOURCE SAMPLES
As levels less ihan
RESIDENTIAL SAMPLES
As levels less (ban
18.0
As levels greater than
or equal lo 18.0
Figure 4: CDH 1995 expanded site inspection report results. (Modified figure from Reference 14a of the HRS
documentation record at proposal: cropped, and legend excerpted.)
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Colorado Smelter Response to Comments NPL Listing Support Document
N
A
Colorado Smelter, Pueblo
HRS doc. record Ref. 32a
Figure 6: Colorado Smelter
2010 XRF Lead Results
for Mulitincrement Composite Samples
CDPHE
February 27, 2012
Source of the Aerial Photograph basemap: Ref, 37 NAIP 2009 (National Agricultural Imagery Project)
Source of the former Colorado SmeKer location:
Ref 7 1897 Map of Pueblo compiled from official records
and Ref 8d Sheet 157
Source of the CDPHE Sampling Data Ref 22
December 2014
Legend
CDPHE 2010 XRF Composite Results
Lead (mg/kg)
ฆ 22 - 94
95-180
181-253
254 - 308
309 - 379
380 - 473
474 - 581
582 - 785
786 - 1468
1469-8066
Historic Smelter Locations
1-25
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*
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413448
+
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61S 742
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375
750
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1,500
Figure 5: CDPHE 2010 site inspection composite sample XRF lead results. (Figure from Reference 32a of the HRS documentation record at proposal.
Cropped.)
55
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Colorado Smelter Response to Comments NPL Listing Support Document
December 2014
Legend
XRF COMPOSITE SLAG SAMPLES
Stack Locations
94
Source of the Aerial Photograph basemap: Ref. 37 NAIP 2009 (National Agricultural Imagery Project)
Source of the former Colorado Smelter location:
Ref 7 1897 Map of Pueblo compiled from official records
and Ref. 8d, Sheet 157
Source of the CDPHE Sampling Data: Ref. 22
Historic Smelter Locations
ฆ<' // ? /'/&"
-ป cm
Colorado Smelter, Pueblo
Response to Comments
Figure 6A (Modified): Colorado Smelter
2010 XRF Lead Results
for Mulitincrement Composite Soil Samples
Graduated Symbols (6 Divisions)
(lead concentrations in ppm)
CDPHE
October 14, 2014
Figure 5a: CDPHE 2010 site inspection composite sample XRF lead results, focused on soil results. (Figure from Reference 32a of the HRS
documentation record at proposal. Cropped. Plot point size varied by concentration only for soil results).
56
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Colorado Smelter Response to Comments NPL Listing Support Document
December 2014
Colorado Smelter, Pueblo
Response to Comments
Figure 6B (Modified): Colorado Smelter
2010 XRF Lead Results
for Mulitincrement Composite Soil Samples
Graduated Colors (6 Divisions)
(lead concentrations in ppm)
CDPHE
October 14, 2014
N
A
Source of the Aerial Photograph basemap: Ref. 37 NAIP 2009 (National Agricultural Imagery Prompt)
Source of the former Colorado Smelter location: q
Ref. 7 1897 Map of Pueblo compiled from official records
and Ref. 8d, Sheet 157
Source of the CDPHE Sampling Data: Ref. 22
O
o5e
!63
329
Arka.
Legend
A XRF COMPOSITE SLAG SAMPLES
ฆ Stack Locations
Lead
O 63-151
O 152-236
O 237 - 321
O 322 - 441
O 442 - 581
O 582 - 785
Historic Smelter Locations
cr
O,
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Figure 5b: CDPHE 2010 site inspection composite sample XRF lead results, focused on soil results. (Figure from Reference 32a of the HRS
documentation record at proposal. Cropped. Plot point color varied by concentration only for soil results).
57
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Colorado Smelter Response to Comments NPL Listing Support Document
Colorado Smelter, Pueblo
HRS doc. record Ref. 32b
Figure 7: Colorado Smelter
2010 XRF Lead Results
for Aliquot Samples
CDPHE
February 27, 2012
N
A
ฑ3*195
source of the Aerial Photoaraph basemap: Ret 37 NAIP 2009 {National Agricultural Imagery Project)
Source of the former Colorado Smelter location:
Ref 7 1897 Map of Pueblo compiled from official records
and Ref 8d, Sheet 1S7
Source of the CDPHE Sampling Daia Ref 22 ซvป
w*
\
375 750
ฆBleet
1.S0D '
December 2014
Legend
CDPHE 2010 Soil Aliquot Results
Lead
o
0- 115
o
116-224
O
225 - 330
o
331 - 453
O
454 - 624
O
625- 1053
o
1054-2243
o
2244 - 3765
O
3766 - 7852
O
7853- 11928
Historic Smelter Locations
Figure 6: CDPHE 2010 site inspection aliquot sample XRF lead results. (Figure from Reference 32a of the HRS documentation record at proposal.
Cropped.)
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Colorado Smelter Response to Comments NPL Listing Support Document
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This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.
3.16.2 Distribution of Lead in Soil - Variability
Comment: Mr. Coomes commented that if the Colorado Smelter was the source of the lead soil contamination, the
lead "should have been quite evenly distributed over the Eilers area" with some "relatively small differences."
But, Mr. Coomes asserted the EPA's data do not support this and commented that lead is not evenly distributed
over the Eilers neighborhood area.
On the individual residential property scale, Mr. Coomes contended that vacant lots sampled exhibited on average
only 53% of the lead concentrations found at residential lots. Mr. Coomes also noted that soil collected from
roadways had lower lead concentrations than residential yard samples. Mr. Coomes argued that such "uneven or
spotty" distribution is not consistent with EPA's model of the Site.
On the scale of the composite sample zones32 on each sampled property within the AOC, Mr. Coomes asserted
that, because the sample areas within each yard are small, the amount of lead deposited "in the individual sample
areas, where five separate samples were collected, should be very similar, based on the assumed EPA model."
But, Mr. Coomes contended "there are large differences" between the smallest and largest lead concentrations
within these sample areas based on the five aliquot results. As evidence, Mr. Coomes commented that:
Background sample areas showed a maximum difference of 25 ppm lead
Vacant lots showed a maximum difference of 51 ppm
Eight residential yard areas showed a maximum difference of 51 ppm or less
Thirty-three residential yard areas showed a maximum difference between 51 to 200 ppm
Eighteen residential yard areas showed a maximum difference between 200 to 300 ppm
Sixteen residential yard areas showed a maximum difference greater than 300 ppm
One residential yard zone showed a maximum difference of 1,287 ppm.
Mr. Coomes stated "[t]hese large concentration differences in such small areas are inconsistent with EPA's
assumption the smelter emissions are the major soil lead contamination source in Eilers."
Mr. Coomes also requested EPA explain why arsenic is "concentrated in very small areas of the Site soil, rather
than in a more even concentration distribution as expected from fugitive or stack particulate deposition."
Response: Regarding Mr. Coomes assertion that if the Colorado Smelter was the source of the lead soil
contamination, the lead "should have been quite evenly distributed over the Eilers area" with some "relatively
small differences" and that the lack of this even distribution disproves the EPA's model of the Site, this is
incorrect. As discussed below, there are multiple reasons why lead and arsenic levels might spatially vary from
property to property, and even within a single property, but still exhibit an overall decrease with distance.
A substantial amount of the contamination from the Colorado Smelter operations would have been emitted during
operation of the facility, which took place more than a century ago. Over that time period, it is likely that the lead
and arsenic concentrations deposited as a result of Colorado Smelter operations have been affected by many
processes (e.g., weathering, addition of fresh soil/removal of contaminated soil during landscaping/yard work)
and therefore the remaining contamination would be expected to exhibit some spatial variation. Furthermore, soil
is not a homogeneous matrix, and therefore some variability is introduced by the matrix itself. However evenly
the deposition of contaminants originally occurred, it is expected that some variability would be introduced over
32 Composite sample zones refer to the 5-point multi-increment zones illustrated on Figure 3 of the HRS documentation
record at proposal.
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Colorado Smelter Response to Comments NPL Listing Support Document
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time on the very small scale (within a sampling zone in a portion of a yard), on the small scale on each individual
property (between sampling zones), and on the larger scale between properties and blocks in the city. Examples of
variables that could impact variation in the concentration gradient include: landscaping (soil/plant addition or
removal), property shapes (wind shadows), vegetation types on different properties (wind shadows, erosion), road
paving/utility work, and other factors. Such variability does not negate the overall concentration gradient within
the nearby vicinity of the Colorado Smelter facility.
Regarding the CDPHE 2010 site inspection vacant lot and roadway samples, the fact that the average of the lead
results from these samples is lower compared to the overall average for the CDPHE 2010 site inspection
residential soil samples is not inconsistent with EPA's model of the Site. The range of the CDPHE 2010 site
inspection residential soil samples XRF composite lead results is 63-785. The XRF composite lead results for
vacant lot samples CO-SO-12-1, CO-SO-49-1, and CO-SO-50-1 are 166, 216, and 94 mg/kg, respectively. The
roadway sample (which is not from a vacant lot but rather located near the road on a lot with a house) CO-SO-08-
1 XRF composite lead result is 263. These results are within the mid-low end of the range of the other soil results.
This is expected, given that these samples are generally upwind of the Colorado Smelter based on prevailing wind
direction (see Figure 2 of this support document for sample locations), and given the distance of these locations
from the Colorado smelter.33
This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.
3.16.3 Arsenic Levels in Soil vs Arsenic Levels in Slag
Comment: Mr. Coomes questioned the source of the arsenic in the AOC. Mr. Coomes cited the CDPHE 1994
Sample Report, Santa Fe Avenue Bridge Culvert (Reference 13 of the HRS documentation at proposal) and
specifically commented that arsenic levels in soil were greater than those in slag, and quoted a portion of page 19
of the 1994 Sample Report, which states:
It should be noted that the arsenic concentrations in the contaminated soils are higher than the
arsenic found in either the slag, seep or culvert discharge. This points to perhaps another source in
the area or long term atmospheric deposition.
Response: It appears that the basis of Mr. Coomes' comment was a comparison of a single slag sample and five
soil samples which, given the variation in concentrations that Mr. Coomes comments on in section 3.16.2,
Distribution of Lead in Soil - Variability, of this support document, is likely too few samples on which to draw a
definitive conclusion. In fact, based on a larger sample set, the concentration of arsenic is higher in the slag pile
than in residential soils.
Mr. Coomes' concentration values are based on the results from the CDPHE 1994 Sample Report, Santa Fe
Avenue Bridge Culvert (Reference 13 of the HRS documentation at proposal); that study was more limited than
the CDPHE 2010 site inspection. The 1994 Sample Report discusses one slag pile sample and five soil samples.
During the CDPHE 2010 site inspection, soil samples were collected from 47 residential lots, 3 vacant lots, and 1
road frontage (each lot included multiple zones that were sampled; each zone usually included 3 to 5 discrete
samples). Additionally, four waste pile locations (slag piles) were sampled as part of this CDPHE 2010 site
inspection, with each location again consisting of several multi-increment samples. As can be seen from the
results of this much more extensive sampling, Table 3 of the HRS documentation record at proposal shows
CDPHE 2010 site inspection AOC A residential soil samples with arsenic results up to 343 mg/kg. Table 5 of the
33 See also Figure 5 of this support document showing the relevant composite sample lead results plotted, and pages 51-59 of
Reference 22 of the HRS documentation record at proposal for a full list of CDPHE 2010 site inspection soil sample
results.
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HRS documentation record at proposal shows CDPHE 2010 site inspection slag pile samples with arsenic results
up to 1,740 mg/kg. Thus, the levels of arsenic are actually higher in slag samples than residential soil samples.
Additionally, the arsenic contained in the slag does not represent the total arsenic that may have been emitted or
blown from the facility. As explained in quoted text from the HRS documentation record above, historical data
from another smelting operationan AMC smelter in Montanashowed that much more arsenic and lead may
be contained in the flue dust than in the slag. Therefore, it is possible that soils affected by flue dust emissions
could appear lead/arsenic enriched relative to slag.
This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.
3.16.4 Arsenic/Lead Ratios - Distribution of Arsenic Relative to Lead
Comment: Mr. Coomes suggested that the arsenic/lead ratios should be the same throughout the AOC if the
contamination resulted from aerial deposition. Mr. Coomes commented that, based on EPA's assertion that lead
and arsenic contamination in soil is the result of smelter emissions, a long-term deposition of arsenic-containing
particulate would be accompanied by a parallel deposition of lead-containing particulate. Mr. Coomes contended
that therefore the ratio of arsenic concentrations to lead concentrations "should be constant over the investigative
area." However, Mr. Coomes commented that these ratios are "not consistent and the variation is very large."
Mr. Coomes examined available data and made several points:
Based on sample data included in the EPA 1995 ARR (Reference 15 of the HRS documentation record at
proposal), Mr. Coomes calculated that the ratio of arsenic/lead in slag ranges from 0.007 to 0.029.34
Based on soil sample XRF data included in Table 8 of the CDPHE June 2011 ARR (Reference 22 of the HRS
documentation record at proposal), Mr. Coomes calculated the ratio of arsenic/lead in soil ranges from 0.057
to 0.44, with an average of 0.125.
Mr. Coomes listed several of these soil samples with arsenic/lead ratios that exceeded the highest ratio for
slag, 0.029.
Mr. Coomes asserted the data "supports the position that there are additional and significant lead sources
unrelated to the smelter operation or arsenic" and that "smelter emissions were not the major contributor to soil
lead and arsenic." Mr. Coomes also stated that "[i]t is clear that the arsenic did not result from deposition of
particulate from the Historic Colorado Smelter" and noted, "other sources of arsenic . . . were not evaluated by
EPA."
Response: Mr. Coomes is incorrect in asserting that arsenic/lead ratios do not support the attribution of soil lead
and arsenic levels to the Colorado Smelter. It is unlikely that a constant ratio of arsenic to lead would be found at
this site. Given that releases were documented from an operation that closed more than 100 years ago, there are
many different, naturally occurring physical and chemical reactions that may act on the two substances differently
because lead and arsenic have different physical and chemical properties (e.g., physical and chemical weathering).
Additionally, it is incorrect to assume that the various sources at the Site (stack emissions, slag, and fugitive dust)
would contain uniform ratios of lead and arsenic throughout the facility's operation.
Mr. Coomes bases many of his arguments on the assertion that the ratio of arsenic concentrations to lead
concentrations "should be constant over the investigative area;" this assumption is likely incorrect for various
reasons. First, changes in the facility processes (differences in input ore, process efficiency, etc.) over time would
34 Mr. Coomes notes that some of the arsenic values he used in his calculations were "J"-qualified, but were used in his
analysis without modification.
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introduce variability in the arsenic/lead ratio being emitted from the facility and, coupled with the variation in
wind direction during each specific process timeframe, would introduce some variability into the arsenic/lead
ratio detected in soils. Second, as previously mentioned, a substantial amount of the contamination from the
Colorado Smelter operations would have been emitted during operation of the facility more than a century ago.
From the end of facility operations to present day, it is likely that the lead and arsenic concentrations deposited as
a result of Colorado Smelter operations have been affected by many processes such as weathering, addition of
fresh soil/removal of contaminated soil during landscaping/yard work, etc. And, it is possible that weathering of
the arsenic over the last century did not evenly affect arsenic and lead in the soil (e.g., extraction of these two
metals from soil via rainwater may take place at different rates). Finally, soil is not a homogeneous matrix, and
therefore some variability is introduced by the matrix itself. Therefore, there is no reason to expect that the ratio
of arsenic to lead from emitted from smelter activities over such a long period would remain constant in the
environment.
Mr. Coomes' direct comparison of arsenic/lead ratios found in slag to those found in soils is also likely faulty. Of
the contributions of arsenic and lead in soil from the Colorado Smelter, a significant portion may have come from
the stack emissions including flue dust (as opposed to dust derived from slag). As described above, the arsenic
and lead levels found in flue dust may vary greatly from those found in slag. There is therefore no reason to
expect the arsenic/lead ratios found in soil to match those found in slag.
Specifically regarding Mr. Coomes' comment on other sources allegedly not evaluated, see section 3.16.6, Other
Sources, of this support document.
This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.
3.16.5 Comparison of Site-related and Greater Area-related Datasets
Comment: Mr. Coomes questioned that contaminant concentrations actually decreased with distance from the
Colorado Smelter. Mr. Coomes performed analysis of contaminant concentration data for samples near the Site
and compared them to samples located farther from the Site (less affected by the Site), and asserted that, based on
a statistical analysis, the "data sets are from the same population," calling into question the Colorado Smelter as a
significant contributor of arsenic to soils at the Site.
Mr. Coomes examined the arsenic concentrations identified in "all arsenic concentrations identified in the
ARR9 [see footnote on citation35]", and arsenic concentrations identified in the 2006 Diawara study (Reference 11
of the HRS documentation record at proposal), and applied the Wilcoxon Rank Sum Test36. Mr. Coomes
presented the results in Table 3 of his comment document. Mr. Coomes asserted that "[t]he analysis demonstrated
that the two arsenic data sets are from the same population at a 1 percent significance level." Mr. Coomes
commented that the Diawara samples were from residential and rural areas, and "many so distant that the area was
not affected by the historic smelter operations." Mr. Coomes concluded that this shows "the Historic Smelter did
not contribute significant arsenic to the Site soil."
Mr. Coomes requested that "analyses reportedly performed16 by EPA that demonstrated results contrary to those
presented in Table 3 be made available for public review" (referring to reference 16 of his comment submittal, a
35 Mr. Coomes cites to entry 9 of the reference list in his comment document, which refers to the CDPHE 1994 Sample
Report, Santa Fe Avenue Bridge Culvert (Reference 13 of the HRS documentation at proposal). But, based on the
investigation results included in Table 3 of his comment document, it would appear the values he compared to the Diawara
study results are actually XRF composite soil sample results from the CDPHE June 2011 ARR (Reference 22 of the HRS
documentation record at proposal), which is entry number 8 in the reference list of his comment document.
36 Mr. Coomes asserts that use of the Wilcoxon rank sum test to compare populations of data is supported by an EPA
OSWER directive (EPA 540-R-01-003 OSWER 9285.7-41 September 2002).
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"[v]erbal response to question at an EPA Public meeting in Pueblo"). Mr. Coomes requested that EPA provide
"any analyses EPA performed on the data that demonstrate the site arsenic concentrations are different than those
reported by Daiawara. | v/c |"
Response: Mr. Coomes' statistical comparison of the Diawara Study data to the CDPHE 2010 site inspection data
does not demonstrate that lead concentrations remain uniform with distance in the immediate vicinity of the
Colorado Smelter. Mr. Coomes is incorrect in his assertion that the Diawara Study soil lead dataset (including
sampling locations less affected by the Site) is statistically similar to the CDPHE 2010 site inspection soil lead
dataset. And, Mr. Coomes applied a statistical test that is less than ideal for the data and comparison he was
attempting to make. Mr. Coomes' conclusions regarding the data are incorrect.
Mr. Coomes presented a statistical comparison of the CDPHE 2010 site inspection composite soil sample XRF
arsenic results to those previously published by Diawara using the Wilcoxon Rank-Sum test (an unpaired two-
sample comparison of medians). Mr. Coomes' results indicated that there was no statistically significant
difference between the two datasets at the 1% significance level. The EPA could not reproduce the results of Mr.
Coomes' analysis, even using the data set he presented. If anything, the EPA's analysis using the same testing
process, the results indicated a distinct difference between the two datasets because they have distinctly different
mean values. 37
Furthermore, the purpose of the Wilcoxon Rank-Sum test (an unpaired two-sample comparison of medians) is to
compare the medians of two distinct data sets to determine whether they come from the same sample. However,
the Diawara study included data from multiple distinct sites, and the purpose of this effort was never to make
conclusions about a single population. As such, using these data to represent a single "background" population is
misleading, and comparing them to the CDPHE 2010 site inspection soil results using the Wilcoxon Rank-Sum
(or any other two-sample comparison test) does not make sense. Additionally, focusing on the median of a set of
data has little meaning in this context, as the CDPHE 2010 site inspection soil data were designed to identify hot
spots, i.e., determine locations where high concentrations are occurring. Therefore, the commenter's comparison
of the midpoint of the distribution (using the median) rather than the upper percentiles of the distribution again
does not provide evidence contradicting that the soil contamination scored as observed contamination is
attributable to the Colorado Smelter.
And, the EPA has also previously explained, when Mr. Coomes brought this issue up at a prior public hearing
regarding the Site, that Mr. Coomes' conclusions are erroneous on this matter, as documented in an August 31,
2012, letter from the EPA to the Pueblo City Council, included as Attachment 2 of this support document:
Mr. Coomes' assertion that arsenic concentrations identified in Eilers area samples are identical to
those characterized during the 2006 "Pueblo-wide" soil study [the Diawara study] is simply not
correct. EPA technical staff including Charles Partridge, PhD, EPA toxicologist, and Robert
37 EPA reviewed Mr. Coomes' submitted calculations, and could not reproduce them using the submitted data. However,
EPA performed the Wilcoxon Rank-Sum test using two different software applications, and using the dataset values as
provided in Table 3 of Mr. Coomes' comment submission, in the columns labeled "BKGRD RESULTS" and "INVEST
RESULTS"; each application calculation indicated that the median concentration was statistically significantly higher in the
CDPHE 2010 site inspection dataset compared to the Diawara dataset at the 1% significance level. Therefore, EPA disagrees
that the submitted analysis provided evidence contradicting that the soil contamination scored as observed contamination is
attributable to the Colorado Smelter. These calculations are shown in Attachment 4, Wilcoxon Rank-Sum Test Calculations,
of this support document. The two software applications used were SAS Version 9.2 (PROC NPAR1WAY procedure) and
NCSS Version 9 Statistical Software. For both applications, a one-sided Wilcoxon Rank-Sum test was performed to
determine whether the median concentration was significantly higher in the ARR dataset compared to the background
dataset. As shown in Attachment 4 of this support document, the Z-statistic generated by the test using both applications was
Z = -9.2332, with a p-value < 0.0001, indicating that one can conclude at the 1% significance level that the ARR median
concentration is significantly greater than the background median concentration.
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Edgar, PhD, EPA statistician, reviewed the data from the 2006 Colorado State University-Pueblo
(CSU-Pueblo) - "Pueblo-wide" soil study and compared it to the data collected in the Eilers
neighborhood in support of listing the Colorado Smelter site. Based on rigorous analysis using five
different statistical tests, EPA determined that the soil arsenic data collected from the Eilers
neighborhood are indeed statistically significantly higher when compared to the soil arsenic
data from the 2006 CSU-Pueblo study, [emphasis added]
The 2012 EPA letter provides a figure comparing the Diawara study soil arsenic data to CDPHE 2010 site
inspection soil arsenic data. The letter states:
[T]he average concentration of 12.4 milligrams per kilogram (mg/kg) for the CSU-Pueblo
samples is much lower than the EPA/CDPHE study's average concentration of 55.4 mg/kg
samples. Additionally all 66 of the CSU-Pueblo samples contained less than 70 mg/kg arsenic
and approximately 92 percent of the CSU-Pueblo samples contained 20 mg/kg or less of arsenic.
None of the CSU -Pueblo samples contained greater than 70 mg/kg of arsenic; whereas there were
samples with arsenic concentrations exceeding 70 mg/kg and as high as 210 mg/kg in the
EPA/CDPHE study's samples. This figure dramatically illustrates the increased levels of arsenic
in the soils surrounding the Colorado Smelter site when compared to those levels of arsenic found
in soils across the City of Pueblo.
The figure from the 2012 EPA letter is shown below:
50
,*12.4 mg/kg
Average *55 4
Average
o wm
10 20 30 40 60 50 70 80 90 100 110 120 130 140 150 160 170 180 190 200 210
Level of Arsenic in Soil (mg/kg)
EPA Neighborhood Soil Data 9 CSU-Pueblo 2006 Soil Data
Figure 7: Comparison of Diawara study soil arsenic data to CDPHE 2010 site inspection soil arsenic data.
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Thus, the datasets are statistically different, and Mr. Coomes' related conclusion that his analysis shows that the
Colorado Smelter did not contribute significant arsenic to the Site soil is invalid.
Regarding the reference 16 of Mr. Coomes' comment submittal, a "[v]erbal response to question at an EPA Public
meeting in Pueblo," it is not clear to what public meeting verbal response Mr. Coomes is referring, and therefore
the EPA cannot respond specifically to this element of Mr. Coomes' comment.
This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.
3.16.6 Other Sources
Comment: Mr. Coomes challenged whether other sources of lead and arsenic were properly considered in
establishing attribution of the contaminant increase to the Colorado Smelter operations. Regarding lead sources,
he asserted that the EPA has not discussed lead-based paint or emissions from leaded gasoline as significant
sources in the HRS documentation record. Mr. Coomes pointed to previous EPA studies38 on other areas of the
country, noting that urban area soil lead levels found in those studies were "much greater than those found in the
Eilers neighborhood" and the "EPA should not consider the Eilers soil lead levels as out of the ordinary." Mr.
Coomes offered several reasons to attribute lead levels to lead-based paint:
Based on historical housing data, Mr. Coomes commented that "half of the homes in Pueblo were built before
1971 and were likely [s/'c] have lead-based-paint," and that "[t]he Pueblo Chieftain reported November 24,
2012 that 23.8 % ofhomes in the city of Pueblo were built prior to 1940 (definitely lead-based-paint)." Mr.
Coomes contended "this information should be discussed in the listing document."
Mr. Coomes noted based on his arguments related to the "large concentration differences" within the small
composite sampling zones, that "logical conclusion, based on analysis of the EPA data, is that another source
of lead (likely lead-based paint - some of the homes were built before smelter operation stopped) is
contributing significantly greater amounts of lead to soil than historic smelter emissions." Mr. Coomes
pointed to the analysis he performed in Attachment 2 to his comment document.
Mr. Coomes noted the likelihood of lead-based paint in neighborhood housing, contending that "the
concentration of soil lead does not decrease with distance from the Historic smelter site [pointing to his
analysis in Attachment 5 to his comment document]," and therefore concluded that "the primary source of
lead is lead-based paint."
Mr. Coomes stated that "[o]nly four of the 279 aliquots had lead content greater than 1200ppm. Because the
homes in this area are old and have lead-based paint. . . there does not appear to be a significant soil lead
hazard."
Mr. Coomes commented that "[a] significant source of arsenic for residential yards is the historic application of
pesticides." Mr. Coomes pointed to lead arsenatecommonly used as a pesticide until the 1950sand noted its
arsenic/lead ratio is 0.241, and that the average ratio he calculated for CDPHE June 2011 ARR soil samples is
0.125. Mr. Coomes stated, "[i]t is clear that other sources of arsenic (for example arsenic-containing pesticides)
were not evaluated by EPA." Mr. Coomes requested it be explained why pesticides were not considered by the
EPA as a source of arsenic. Mr. Coomes requested that the EPA "include an evaluation of other probable arsenic
sources in the documentation supporting the listing."
38 Mr. Coomes cites the EPA 1991 document, Three City Urban Soil-Lead Demonstration Project, Midterm Project Update,
and the EPA January 1998 document, Guidance for Data Quality Assessment, Practical Methods for Data Analysis, EPA
QA/G-9, QA97 Version, EPA/600/R-96/084.
65
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Colorado Smelter Response to Comments NPL Listing Support Document
December 2014
Mr. Coomes also commented that "high soil lead concentration was identified at a historic blacksmith's shop.
EPA did not discuss previous land use in their reports."
Mr. Coomes asserted that another source not discussed by EPA is fugitive dust emissions from materials handling
operations, which would have larger particle sizes that settle over shorter distances from the origin compared to
stack emissions.
Response: As required by the HRS, the EPA determined that at least a portion of the significant increase in
contaminants identified in observed contamination in the Eilers neighborhood is attributable to the Colorado
Smelter based on information including the proximity of the Colorado Smelter to AOC A, predominant wind
direction, and the distribution of contaminants showing a concentration pattern indicating a significant increase in
lead and arsenic levels adjacent to the Colorado Smelter (as shown in Figures 4, 5, 5a, 5b, and 6, of this support
document). While there may be other possible non-site sources of lead and arsenic, as described in HRS
documentation record text quoted above in section 3.16, Attribution, of this support document, the EPA did
consider the effects of such sources (i.e., four other historical smelters in the city and CF&I/Rocky Mountain
Steel Mills facility), and none of the other identified alternative sources of lead and arsenic could explain the
significant increase in contamination in the AOC. Nor does the presence of these alternative sources demonstrate
EPA's attribution rationale is incorrect. And, these other sources/facilities pointed to by Mr. Coomes do not
explain the soil lead concentration gradient present in the neighborhood around Colorado Smelter.
Regarding lead-based paint, soil sampling procedures employed during the CDPHE 2010 site inspection would
have mitigated any related effects. Reference 39 of the HRS documentation record at proposal, a CDPHE
memorandum describing the residential soil sampling methodology for the CDPHE 2010 site inspection, states
that:
The sampling team collected all samples from open, exposed dirt areas at least 10 feet away from
the house away from roof drip lines to minimize the potential for soil contamination sourced by
lead-based paint.
Regarding leaded gasoline, Mr. Coomes offers no specific information indicating that the observed contamination
of lead in Site soils would be attributable to historical leaded gasoline emissions. In fact, Mr. Coomes comments
that soil collected from a roadway contained lower lead concentrations than residential yard samples.
Additionally, several of the samples used to establish observed contamination are from the back yard of
residential lots (zone 4)39. In general, these sample locations are farther from roads and would be less affected by
historical leaded gasoline emissions from nearby roadways, and yet they still exhibit observed contamination
levels of lead. Additionally, as shown in Table 4 of the HRS documentation record, many of the XRF zone 4
composite sample lead levels in these samples (ranging from 339-742 mg/kg) exceed the road frontage sample
CO-SO-08 XRF composite result (263 mg/kg) (this sample was collected at a location on a residential lot closer
to the road). The fact that road frontage sample CO-SO-08 was from a property to the west of the Colorado
Smelter (upwind based on the prevailing wind direction) and that the zone 4 locations mentioned are all
downwind of the Colorado Smelter supports the scenario in which the historical emissions from the Colorado
Smelter are the dominant factor influencing AOC A soil lead levels.
Furthermore, any contributions from lead-based paint or historical leaded gasoline emissions to soil
contamination would not explain the soil lead concentration gradient near the Colorado Smelter described in the
HRS documentation record and references at proposal.
39 Reference 39 of the HRS documentation record at proposal explains that in the CDPHE 2010 site inspection sample
naming convention, "zone 4" at a residential lot represented the back yard. As shown in Table 3 of the HRS documentation
record, the following zone 4 samples met observed contamination criteria: CO-SO-18 4.5, CO-SO-28 4.3, CO-SO-31 4.5,
CO-SO-32 4.4, CO-SO-40 4.1, CO-SO-40 4.2, CO-SO-40 4.3, CO-SO-43 4.1, CO-SO-43 4.3, and CO-SO-43 4.4.
66
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Colorado Smelter Response to Comments NPL Listing Support Document
December 2014
Regarding Mr. Coomes' assertion that the EPA has not considered pesticide application as a possible source of
arsenic, such a claim is speculative and not supported by the available evidence or by any site-specific
documentation provided by Mr. Coomes. As explained above, EPA has offered substantial information attributing
lead and arsenic in Site soils to the Colorado Smelter. Mr. Coomes noted that the arsenic/lead ratios in the soil are
more similar to the ratio in lead arsenate pesticides than those in slag. But, as previously explained, the
arsenic/lead ratios in soileven at the time of depositionwould not necessarily be expected to match that in
slag; and the currently existing arsenic/lead ratios in soil may have changed significantly since the original
smelter-related deposition occurred a century ago; therefore, direct comparisons to ratios in slag or ratios in
pesticides are not relevant to this site-specific attribution discussion. Further, the EPA presented a concentration
gradient for arsenic from the smelter to local residential soils that showed decreasing concentrations with distance
from the smelter (see Figures 5, 5a, and 5b of this support document); if the arsenic contamination were due to
pesticide application there would be no decreasing concentration gradient with increased distance from the
smelter as pesticide applications would be more uniformly distributed in the local neighborhoods.
Similarly, regarding the blacksmith's shop, Mr. Coomes offers no information indicating that the observed
contamination of lead in Site soils would be attributable to the blacksmith's shop instead of the Colorado Smelter,
and provides no information showing the location of the blacksmith's shop or analytical evidence to explain why
it should be considered as contributing to the contamination at the Site.
Regarding possible fugitive dust emissions contributions from the Colorado Smelter facility to AOC A soils,
again Mr. Coomes provides no specific evidence to support this; while such contributions could have occurred,
they remain speculation. Even if fugitive dust emission contributions were considered, they would be attributable
to the Colorado Smelter facility.
This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.
4. Conclusion
The original HRS score for the Colorado Smelter site was 50.00. Based on the above responses to public
comments, the final scores for the Colorado Smelter site are:
Ground Water: Not scored
Surface Water: Not scored
Soil Exposure:
Air Pathway:
HRS Score:
100.00
Not scored
50.00
67
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Attachment 1
March 2000 CDPHE QAPP for Site Assessments Under
Superfund
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COLORADO DEPARTMENT OF PUBLIC HEALTH
AND ENVIRONMENT
HAZARDOUS MATERIALS AND WASTE MANAGEMENT DIVISION
QUALITY ASSURANCE PROJECT PLAN
FOR SITE ASSESSMENTS UNDER SUPERFIJND
REVISION 01
MARCH, 2000
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CDPHE QAPP
Signature Page
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Date: 03/2000
Page i of v
COLORADO DEPARTMENT OF PUBLIC HEALTH
AND ENVIRONMENT
HAZARDOUS MATERIALS AND WASTE MANAGEMENT DIVISION
QUALITY ASSURANCE PROJECT PLAN rn
TB
FOR SITE ASSESSMENT UNDER SUPEREUND
APR ] 4 2000
ANDWAgTFMAMAftnupjvr
Approved:
Pat Smith, Site Assessment Manager, EPA Region VIII
Date:
s/f
'n/oo
Approved:
Tony Medrano, Quality Assurance Officer, EPA Region VIII
Date:
3 Ji{->! A
Approved:
Joseph Vranka, Superfund Unit Leader, CDPHE
Date: iD 2aGr>
Approved:
Date: ~OQ
Martin O'Grady, Quality Assurance Officer, CDPHE
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Table of Contents
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TABLE OF CONTENTS
Page #
TITLE PAGE AND APPROVALS i
DISTRIBUTION LIST ii
TABLE OF CONTENTS iii
ABBREVIATIONS AND ACRONYMS v
1.0 INTRODUCTION 1
2.0 PROJECT/TASK ORGANIZATION (Element A4) 4
2.1 EPA Site Assessment Manager 4
2.2 EPA Quality Assurance Officer 5
2.3 CDPHE Quality Assurance Officer 6
2.4 Superfund PA/SI Unit Leader 7
2.5 Project Leader 7
2.6 Field Staff 9
2.7 Subcontractors 9
3.0 PROBLEM DEFINITION/BACKGROUND (Element A5) 9
4.0 PROJECT/TASK DESCRIPTION (Element A6) 10
5.0 DATA QUALITY OBJECTIVES AND CRITERIA FOR MEASUREMENT
DATA (Element A7) 10
5.1 Data Categories 13
5.1.1 Screening Data 13
5.1.2 Screening Data with 10% Definitive Confirmation 13
5.1.3 Definitive Data 14
5.2 Data Assessment Parameters 18
6.0 SAMPLING PROCESS DESIGN (Element Bl) 19.
"7.0 SAMPLING METHODS (Element B2) 20
7.1 Standard Operating Procedures 20
7.2 Record Keeping And Document Control 23
8.0 SAMPLE HANDLING AND CUSTODY (Element B3) 23
9.0 ANALYTICAL METHODS (Element B4) 24
10.0 QUALITY CONTROL (Element B5) 24
10.1 Field Quality Control 25
10.2 Laboratory Quality Control 26
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11.0 INSTRUMENT/EQUIPMENT CALIBRATION AND FREQUENCY (Element B7) .. . . 26
11.1 Calibration Procedures 26
11.2 Preventive Maintenance 27
11.3 Calibration And Maintenance Records 27
12.0 ASSESSMENT AND RESPONSE ACTIONS (Element CI) 27
12.1 Responsibility For Assessments 27
12.2 Implementation of Assessments 28
12.3 Mechanisms For Assessment 29
12.3.1 Management System Review 29
12.3.2 Audits and Surveillances 29
12.3.3 Independent Technical Review and Peer Review 31
12.3.4 Readiness Review 32
12.3.5 Data Reduction Assessment 32
12.3.6 Data Quality Assessment 33
12.4 Response to Assessments 34
12.5 Non-conformance And Corrective Action 35
13.0 DATA REVIEW, VERIFICATION AND VALIDATION (Elements D1 and D2) 36
13.1 Field Data Validation 36
13.2 QC Review And Analytical Data Validation 36
14.0 RECONCILIATION WITH USER REQUIREMENTS (Element D3) 38
14.1 Precision 38
14.2 Accuracy 39
14.3 Completeness 39
14.4 Representativeness 40
14.5 Comparability ; 40
15.0 LIST OF REFERENCES 41
FIGURES
Figure 2-1 QA Project Organization
.Figure 5-1 The Data Quality Objectives Process
TABLES
Table 1-1 Use Category Chart
Table 5-1 Superfund Data Categories
APPENDICES
Appendix A Environmental and Quality Control Sample Collection and Laboratory Analysis
Specifications
Appendix B Standard Operating Procedures
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Abbreviations and Acronyms
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ABBREVIATIONS AND ACRONYMS
AA
Atomic absorption
ASC
Analytical Services Coordinator
ASQC
American Society for Quality Control
ASTM
American Society for Testing and Materials
CDPHE
Colorado Department of Public Health and Environment
CLP
Contract Laboratory Program
DLs
Detection limits
DQO
Data quality objective
EPA
U.S. Environmental Protection Agency
ERP
Emergency Response Program
FSP
Field Sampling Plan
GC/MS
Gas chromatography/mass spectrometry
HRS
Hazard Ranking System
IC
Ion chromatography
ICP
Inductively coupled plasma
IR
Infrared spectroscopy
PCB
Polychlorinated biphenyls
QA
Quality assurance
QAO
Quality Assurance Officer
QAPP
Quality Assurance Project Plan
QC
Quality control
RPD
Relative percent difference
RSD
Relative standard deviation
SAP
Sampling and Analysis Plan
SHSP
Site Health and Safety Plan
SOP
Standard operating procedure
SOW
Statement of work
SUL
Superfund PA/SI Unit Leader
XRF
X-ray fluorescence
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1.0 INTRODUCTION
Quality Assurance (QA) is an integrated system of management activities involving
planning, implementation, assessment, reporting, and quality improvement to ensure that
a process, item, or service is of the type and quality needed and expected by the customer.
Quality Control (QC) is the overall system of technical activities that measures the attributes
and performance of a process, item or service against defined standards to verify that they
meet the stated requirements established by the customer; the QC system includes
operational techniques and activities that are used to fulfill requirements for quality.
This Quality Assurance Project Plan (QAPP) was prepared by the Colorado Department of Public Health and
Environment (CDPHE) for the U.S. Environmental Protection Agency (EPA) Region VIII. EPA Order
5360.1, Change 1, "Policy and Program Requirements for the Mandatory Agency-Wide Quality System"
(U.S. Environmental Protection Agency (EPA) 1998) requires that all environmental data collection activities
that are performed by or on behalf of the EPA, be supported by an approved QAPP prior to the start of data
collection activities, except as specified by Region VIII emergency response/time-critical removal policies.
This QAPP was prepared in accordance with the EPA guidance documents entitled, "EPA Requirements for
Quality Assurance Project Plans, Interim Final EPA QA/R-5" (EPA 1999), "Quality Assurance/Quality
Control Guidance for Removal Activities" and EPA Region VIII "Minimum Requirements for Field
Sampling Activities" (EPA 1996).
Data collection requirements are often determined by the Hazard Ranking System (HRS). Regional and
National Preliminary Assessment and Site Inspection (PASI) guidances offer strategies and common
guidelines on scope of effort for Site Assessment Investigations relative to the HRS.
This QAPP presents elements common to many environmental data collection activities. The purpose of this
QAPP is to:
Describe how the CDPHE Site Assessment (SA) program Quality System will be applied to a
specific project;
. Justify proposed environmental data operations;
"<> Integrate all technical quality aspects of environmental data operations for a specific project;
Provide project- or task-specific blueprints for how QA and QC are to be applied to obtain the type
and quality of data needed for a specific decision or use; and
Identify and document limitations on the use of the data.
The QAPP, a project-specific Sampling and Analysis Plan (SAP), a Site Health and Safety Plan (SHSP), and
Standard Operating Procedures (SOPs) collectively form the set of plans for individual projects.
The level of detail and the QA/QC specified in the project plans are based on the scope of work, cost,
technical requirements, site-specific conditions and the intended use of the data. The EPA has defined four
categories that vary the level of detail and content requirements for QAPPs. Table 1-1 illustrates these
Category requirements. The CDPHE SA program primarily incorporates the requirements of Category III,
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Interim Studies, which include projects with environmental data operations performed as interim steps in a
larger group of operations. Such projects include work producing results that are used to evaluate and select
options for preliminary assessments, site inspections, and Hazard Ranking System (HRS) Packages of
potential Superfund site listings.
SOPs are used for all activities affecting the quality of data or measurements conducted for a project. SOPs
provide standardized and written guidelines for field, laboratory and reporting operations. SOPs are
consistent with current regulations and guidelines, are clear and concise, and contain directions that can be
followed in a stepwise manner. The EPA encourages the use of SOPs as attachments to project documents
to reduce the size of the document and the time required to prepare it. CDPHE has prepared SOPs, "Standard
Operating Procedures." The SOPs cover sampling protocols and technical operations.
EPA QA/R-5 requires that a QAPP address 25 topics or elements in four subject areas. Region VIII requires
that 16 of these 25 elements be addressed. The elements contained within this QAPP are grouped to reflect
the general processes of:
Project Management - Sections 1 through 5;
Measurement/Data Acquisition - Sections 6 through 11;
Assessment/Oversight - Section 12; and
Data Validation and Usability - Sections 13 and 14.
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TABLE 1-1
Use Category Chart
Category
Description
Element
Project Management
Title and Approval Sheet
A1
Table of Contents
A2
Distribution List
A3
Project/Task Organization
A4
Problem Definition/Background
A5
Project/Task Description
A6
Quality Objectives and Criteria for
Measurement Data
A7
Special Training
Requirements/Certification
A8
Documentation and Records
A9
Measurement/
Sampling Process Design
B1
Data Aquisition
Sampling Methods
B2
Sample Handling and Custody
B3
Analytical Methods
B4
Quality Control
B5
Instrument/Equipment Testing,
Inspection, and Maintenance
B6
Instrument/Equipment Calibration
and Frequency
B7
-
Non-direct Measurements
B9
Data Management
B10
Assessment/
Oversight
Assessments and Response Actions
CI
Reports to Management
C2
Data Validation
and Usability
Data Review, Verification and
Validation
D1
Verification and Validation
D2
Reconciliation with User
Requirements
D3
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2.0 PROJECT/TASK ORGANIZATION (Element A4~>
Figure 2-1 presents a typical project-specific organization. This figure shows key positions along with lines
of authority and lines of communication and coordination. Descriptions of the responsibilities and authorities
for the key positions as they relate to project QA and QC are provided below. It is essential that all
individuals have defined responsibilities for their functional areas and are clearly aware of the entire project
organization and interrelationships. As this is a project organization, senior officials, managers, and
administrators, whose positions are not functionally involved with data generation, data use, or decision-
making, are not included. Also to be noted that to some degree, one person may fulfill multiple positions
described herein.
QA personnel have sufficient authority, access to work areas, and organizational freedom to identify quality
problems; to initiate, recommend or provide solutions to problems through established channels; and to verify
solution implementation. Such personnel ensure that all work, including any processing of information,
delivery of products, and installation or use of equipment, is reviewed in accordance with QC objectives and
that all deficiencies and nonconformances are corrected. QA personnel have direct access to senior
management, so that the required authority is provided where needed, to carry out QA duties.
2.1 EPA SITE ASSESSMENT MANAGER
The EPA-assigned Site Assessment Manager (SAM) is responsible for coordinating all project-
related activities on behalf of the EPA. A major component of this position involves coordinating
with the CDPHE Project Leader in the execution of the work and the submission of deliverables as
scheduled, in accordance with the project assignment. Specific responsibilities of the SAM are as
follows:
Provide oversight of all project activities;
Review and approve project plans (including SAPs) and coordinate review within EPA as
necessary. Initiate the Data Quality Objective (DQO) process as appropriate, providing
DQO framework;
Review and approve the QAPP;
Ensure that the QAPP and associated reports are transmitted to the EPA Quality Assurance
Officer (QAO);
Transmit comments on QA from the EPA to the Project Leader regarding QA plans and
laboratory performance;
Ensure that the Project Leader addresses EPA review comments and takes appropriate
action;
Transmit program-wide quality issues to EPA QAO; and
Initiate conductance of field and laboratory audits and management system reviews.
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2.2 EPA QUALITY ASSURANCE OFFICER
The EPA QAO or designee is responsible for ensuring that the project has an appropriate QA
program. Specific responsibilities of this position are as follows:
Support the EPA SAM on QA issues.
FIGURE 2-1
QA Project Organization
= lines of communication
= lines of authority
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2.3 CDPHE QUALITY ASSURANCE OFFICER
The QAO is responsible for the development, implementation and maintenance of the comprehensive
Quality System. Responsibilities of this position include communicating with all levels of program
and project management to ensure that a quality product is produced for delivery. Project-specific
responsibilities of the QAO or designee are as follows:
Serve as the official contact with EPA for all QA matters;
Respond to QA needs, resolve problems, and answer requests for guidance or assistance;
Prepare the QAPP, and revise as necessary; provide guidance to the Project Leaders in the
development of project-specific SAPs;
Review and approve the project-specific SAPs;
Assign competent, qualified independent reviewers to review the technical adequacy of
deliverables;
Track the progress and completion of the review and approval process;
Ensure that EPA protocols and procedures, as well as CDPHE SOPs, are being followed;
Review the implementation of selected SAPs and the adequacy of the data or products
generated based on quality objectives;
Initiate conductance of field and laboratory audits and management system reviews, as
appropriate;
Maintain a current list of all approved QAPPs, SAPs, and SOPs to be used for auditing
purposes;
Authorize, coordinate, and conduct internal and subcontractor audits of selected projects for -
adherence to the project plans.
Submit notice of any laboratory and field systems audits prior to their occurrence and in a
timely manner to the EPA QAO who has the option to attend;
Review audit and nonconformance reports to determine areas of poor quality or failure to
adhere to established procedures;
Confer with the audited entity on the steps to be taken for corrective actions and track
nonconformance until it has been corrected; evaluate the adequacy and completeness of the
action taken; confer with the Project Leader to resolve an inadequate corrective action;
confirm the adequacy and the implementation of the response action;
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Suspend or stop work with the concurrence of the Unit Leader and EPA, upon detection and
identification of an immediate adverse condition affecting the quality of results;
Provide training on QA policies, procedures, and methodology;
2.4 CDPHE SUPERFUND PA/SI UNIT LEADER
The Superfund PA/SI Unit Leader (SUL) is responsible for providing senior leadership and expertise
to individual Proj ect Leaders, and for maintaining a broad perspective of EPA and CDPHE priorities.
Responsibilities of the SUL are to:
Identify the need and expectations of services to be provided and when necessary, negotiate
acceptable scopes of work;
Provide senior level input and technical expertise to Project Leaders on developing or
establishing project objectives, data quality objectives, sampling rationale, regulatory
requirements, and data assessment methods;
Ensure that the best available technology is being applied to reduce potential waste and
inefficiencies, and that the best known processes are in use;
Provide senior level coordination, review, and approval of project documents;
Assess completion of work in accordance with EPA and regulatory requirements; and
Provide full assistance to the QAO and audit team during the planning, scheduling, and
management of project-specific QA audits and surveillances; review assessment findings;
and ensure that required corrective actions are completed.
2.5 CDPHE PROJECT LEADER
The Project Leaders report to and obtain technical direction and assistance from the EPA SAM and
the CDPHE SUL and are responsible for monitoring and documenting the quality of all work
produced by the project team, which includes the field staff and subcontractors. The fundamental
goal of this position is to produce a quality work product within the allotted schedule and budget.
Duties include executing all phases of the project and efficiently applying the full resources of the
project team in accordance with the project plans. The Project Leader is responsible for managing
any project task involving the specialized chemical expertise and the assessment and reporting of
related analytical data. Specific responsibilities of a Project Leader are as follows:
Assist the SAM in determining DQOs;
Prepare and implement the project SAPs (which incorporate applicable QAPP elements) and
reports for each project, as appropriate;
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Ensure that SOPs are available and in use for activities that affect product quality and that
assigned staff have been trained in their implementation;
Inspect and accept supplies and consumables;
Ensure that appropriate sampling, testing and analysis procedures are followed and that
correct lab QC checks are implemented;
Monitor sample preservation, handling, transport and custody throughout the project;
Coordinate the appropriate disposition of investigation-derived waste;
Ensure that the proper number and type of environmental and control samples are collected,
identified, tracked, and sent to the laboratory for analysis;
Coordinate and schedule sample shipment to analytical laboratories to meet holding times
and analytical procedures specifications;
Monitor subcontractors for compliance with both project and data quality requirements
records, costs, and progress of the work; replan and reschedule work tasks as appropriate;
Review and approve calculations to ensure that data reduction is performed in a manner that
produces quality products;
Verify data quality, test results, equipment calibrations, and QC documentation; maintain
and regularly review all QC records;
Ensure that all project deliverables are subjected to independent technical review by
qualified personnel within the time frame of the project schedule;
Plan and schedule assessments in conjunction with the QAO;
Provide full assistance to the audit team during the conduct of project-specific QA audits. -
Review and respond to assessment findings; determine the root cause for the non-
conformance; confer with the QAO on the steps to be taken for correction; and ensure that
procedures are modified to reflect the corrective action and that they are distributed to all
field personnel, including subcontractors;
Report QA problems to the QAO;
Prepare and send notice of sampling to the Region VIII Sample Broker.
Qualify and procure laboratories for analysis of samples for projects not handled by the
Region VIII Sample Broker;
Coordinate data collection activities to be consistent with information requirements;
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Oversee evaluation of data received from the laboratory in accordance with the project
requirements;
Coordinate the assessment of data based upon criteria established in DQOs;
Supervise the compilation of field data and laboratory analytical results;
Assure that data are correctly reported; and
Prepare or oversee the preparation of portions of the final report that summarize data results
and present conclusions.
2.6 FIELD STAFF
Under the direction of the Project Leader, the Field Staff are responsible for the planning,
coordinating, performing, and reporting of specific technical tasks. Responsibilities of the Field Staff
are as follows:
Implement the QAPP and project-specific SAP;
Develop and maintain technical activity files and log books; and
Implement technical procedures applicable to tasks.
2.7 SUBCONTRACTORS
CDPHE personnel may delegate to others the responsibility of planning and executing certain
portions of the project activities. When subcontractors are involved in activities covered by the
requirements of the QAPP, the responsibility and authority of each subcontractor must be clearly
established and documented. Project Leaders are responsible for monitoring subcontractors for
compliance with both project and data quality requirements.
3.0 PROBLEM DEFIMTION/BACKGROUND (Element A51
The problem definition and background are included in the proj ect-specific SAP. The problem definition and -
background address the following points:
Contamination problem to be solved or decision to be made; why this investigation is being
conducted;
Site location and description;
Source and location of contamination, including any physical or chemical characteristics of the site
that could cause a release, historical information or existing data that provided this information, and
data gaps that exist and will be filled during this investigation;
Maps of the project vicinity and areal extent of the contamination problem;
Regulatory objectives and basis for the sampling effort;
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Action levels for contaminants, including levels used for data evaluation;
The intended use and users of the data, including decisions/decision makers.
4.0 PROJECT/TASK DESCRIPTION (Element A6^>
The project or task description is included in the project-specific SAP. The project or task description
addresses the following points:
Description of the work involved and how the planned activities will resolve the problem or question;
Applicable technical, regulatory, or project-specific quality objectives that must be met;
Project schedule and task durations, including audits;
Project constraints such as time, access or funding;
Expected measurements and field and analytical data that will be collected;
Project records required, including reports and field records;
Special personnel, equipment, or analytical requirements commensurate with the complexity of the
project;
QA Assessment tools as required by the QAPP that will be implemented during the course of the
project (e.g., technical reviews, peer reviews, and technical audits).
5.0 QUALITY OBJECTIVES AND CRITERA FOR MEASUREMENT DATA (Element A7>
Project-specific quality objectives and measurement performance criteria are included in each project SAP.
It is the goal of EPA and the regulated community to collect data of sufficient quantity and quality to support
defensible decision making. At the same time, it is necessary to minimize expenditures related to data
collection by eliminating unnecessary, duplicative, or overly precise data. The most efficient way to -
accomplish both of these goals is to begin each project by defining project quality objectives and
"measurement performance criteria.
The EPA supports the implementation of the DQO Process to ascertain the type, quality, and quantity of data
necessary to address site-specific problems ("Data Quality Objectives Process for Hazardous Waste Site
Investigations, EPA QA/G-4HW," EPA 2000). It is the responsibility of the Project Leader, in conjunction
with the QAO, to implement the DQO process as part of the project planning activities. In those cases in
which the DQO process is not used, it is still necessary to state the project quality objectives and
measurement performance criteria in the project-specific SAP.
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The QA requirements, identified as a result of the DQO Process, will be used at three stages in a project, as
follows:
Project inception - to present the plans for project execution from a QA viewpoint.
During the project - to act as a guide for QA implementation, review and audits, and as the
specifications for assessing the quality of data generated.
Project completion - to serve as a basis for determining whether the project has attained established
goals.
Figure 5-1 summarizes the DQO Process.
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FIGURE 5-1
The Data Quality Objectives Process
State the Problem
I
Identify the Decision
I
Identify Inputs to the Decision
I
Define the Study Boundaries
i
Develop a Decision Rule
I
Specify Limits on Uncertainly
n
Optimize the Design for Obtaining Data
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5.1 DATA CATEGORIES
Descriptive data categories (definitive data and screening data with definitive confirmation) have
been developed by the Superfund program. According to EPA "Data Quality Objectives Process for
Superfund, Interim Final Guidance," these two categories are associated with specific QA and QC
elements, and may be generated using a wide range of analytical methods (EPA 1993). The goal is
to ensure that all data produced by field activities are of known quality and can thus be used for more
general purposes than originally intended.
Table 5-1 describes data categories from both references and provides general descriptions of the
QA levels and specific QA/QC requirements for various common analyses. The particular type of
data to be generated depends on the qualitative and quantitative DQOs developed during application
of the DQO process. The data categories, as excerpted from the EPA documents, are:
5.1.1 Screening Data
Screening data are generated by rapid, less precise methods of analysis and less rigorous
sample preparation. Sample preparation steps may be restricted to simple procedures such
as dilution with a solvent, instead of elaborate extraction/digestion and cleanup. Screening
data provide analyte identification and quantification, although the quantification may be
relatively imprecise. Screening data without associated confirmation data are not considered
to be data of known quality. QA/QC elements for screening data are:
Sample documentation (location, date and time collected, batch, etc.);
Chain of custody (when appropriate);
Sampling design approach (systematic, simple or stratified random, judgmental, etc.);
Initial and continuing calibration; and
Determination and documentation of detection limits.
5.1.2 Screening Data with 10% Definitive Confirmation
This category requires that at least 10% of the screening data be confirmed using analytical
methods and QA/QC procedures and criteria associated with definitive data. As a minimum,
at least three screening samples reported above the action level (if any) and three screening
samples reported below the action level (or as non-detects) should be randomly selected
from the appropriate group and confirmed. Analytical error determination (i.e., screening
sample replicates) is required unless total measurement error (collocated samples) is
determined during the confirmation analyses. Analytical error is the measurement of the
precision of the analytical method; total measurement error is the measurement of overall
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precision of the measurement system from sample acquisition through analysis. QA/QC
elements for screening data with 10% definitive confirmation are:
Sample documentation (location, date and time collected, batch, etc.);
Chain of custody (when appropriate);
Sampling design approach (systematic, simple or stratified random, judgmental, etc.);
Initial and continuing calibration;
Determination and documentation of detection limits;
Analyte(s) identification;
Analyte(s) quantification;
Analytical error determination (This procedure measures the precision of the analytical
method, and is required when total measurement error is not determined under the
confirmation step. Refer to Section 5.2); and
Definitive confirmation: at least 10% of the screening data must be confirmed with
definitive data as described below. As a minimum, at least three screening samples
reported above the action level (if any) and three screening samples reported below the
action level (or as non-detects) should be randomly selected from the appropriate group
and confirmed.
5.1.3 Definitive Data
Definitive data are generated using rigorous analytical methods, such as approved EPA
reference methods. Data are analyte-specific, with confirmation of analyte identity and
concentration. Methods produce tangible raw data (e.g., chromatograms, spectra, digital
values) in the form of paper printouts or computer-generated electronic files. Data may be
generated at the site or at an off-site location, as long as the QA/QC requirements are
satisfied. For the data to be definitive, either analytical or total measurement error must be
determined. QA/QC elements for definitive data are:
Sample documentation (location, date and time collected, batch, etc.);
Chain of custody (when appropriate);
Sampling design approach (systematic, simple or stratified random, judgmental, etc.); -
Initial and continuing calibration;
Determination and documentation of detection limits;
Analyte(s) identification;
Analyte(s) quantification;
QC blanks (trip, method, rinsate);
Matrix spike recoveries;
Performance Evaluation (PE) samples (when specified); and
Analytical error determination or total measurement error determination. (Refer to
Section 5.2.)
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TABLE 5-1
Superfund Data Categories
QA/QC Levels
Screening
Screening Data with 10%
Definitive Confirmation
Definitive
Data Uses
Data useful only for immediate
situation; and to afford a quick,
preliminary assessment of site
contamination.
Data useful for site assessment
and decision making at SAM
discretion
Data useful for enforcement,
litigation, risk assessment,
and most other uses
Typical Uses
Preliminary health and
safety assessment
Preliminary identification
and quantitation of
pollutants
Non-critical decisions
Emergency situations
Waste profiling
Site characterization
Waste characterization
Clean-up confirmation
Verification of health and
safety assessment
Verification of critical
samples
Enforcement
Litigation
Risk assessment
Quality
Assurance Type
Data of unknown quality
Data of known quality
Data of known quality
Quality
Assurance
Elements
Logged quality control
checks provided in methods
or SOPs
Qualified analyst
ฆ Identification
Quantification
Confirmation of 10% of the
samples by a definitive
method
Error determination1
Definitive identification
Definitive quantification
ฆ Error determination
Validation
None
QC Review2
Validation of 10% of the
results in each of the samples,
calibrations, and QC analyses
Quality Control
Elements
Instrument QC
Field QC (Field blanks and
collocated samples are
optional)
Analyst training
Document DLs
Instrument QC
Field QC
Analyst training
QC within method
parameters
Document DLs
Instrument QC
Field QC
Analyst training
QC within method
parameters
Document DLs
'Error determination: screening data with 10% definitive confirmation requires measurement of analytical error (screening sample replicates)
unless total measurement error (collocated samples) is determined during the confirmation analyses. The site-specific SAP may state that error
determination is not necessary if it can be qualitatively shown that the DQOs do not require it, e.g., concentrations in the percent range are expected
to be found, yet the action level is in the parts per billion (ppb) range.
2QC review is required for all samples analyzed under screening data with 10% definitive confirmation. Data validation is required for 10% of
the results in each of the samples, calibrations, and QC analyses for the definitive confirmation data.
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TABLE 5-1
Superfund Data Categories
continued)
QA/QC
Levels'
Screening
Screening Data with 10%
Definitive Confirmation
Definitive
Sampling Plan
Optional
Mandatory
Mandatory
Typical Volatile
Analyses
Field GC
(e.g., Sentex field GC with
single column and detector)
Field GC with 10% of
samples being confirmed by
GC/MS with full QA/QC
deliverables; duplicates and
blanks.
EPA Method 8240 or
8260; data report;
replicates; blanks and
spikes
GC method with 10% of
samples being confirmed by
GC/MS with full QA/QC
deliverables; duplicates and
blanks.
EPA Method 8010/8020
with second column
confirmation; data report
replicate, blanks, and
spikes.
Typical Non-
volatile Analyses
Immunoassay kits
Immunoassay with 10% of
samples being confirmed by
GC/MS with full QA/QC
deliverables; duplicates and
blanks.
EPA Method 8270; data
report; replicates, blanks,
and spikes.
GC method with 10% of
samples being confirmed by
GC/MS with full QA/QC
deliverables; duplicates and
blanks.
EPA Method 8100/8120
with second column
confirmation; data report;
replicate, blanks, and
spikes.
Typical Metal
Analyses
Field XRF
Field XRF with 10% of
samples being confirmed by
ICP or AA with full
QA/QC deliverables;
duplicates and blanks.
EPA Method 6010; data
report; replicates, blanks,
and spikes.
AA, ICP, IC, or wet
chemistry methods with
10% of samples being
confirmed by ICP or AA
with full QA/QC
deliverables; duplicates and
blanks.
EPA methods for AA
(7000s); data report;
replicate, blanks, and
spikes.
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TABLE 5-1
Superfund Data Categories
(continued)
QA/QC
Levels1
Screening
Screening Data with 10%
Definitive Confirmation
Definitive
Typical PCB/
Pesticide
Analyses
Immunoassay Kits
Immunoassay kits with
10% of samples being
confirmed by GC/MS with
full QA/QC deliverables;
duplicates and blanks.
EPA Method 8140-
Pesticides; data report;
replicates, blanks, and
spikes.
GC method with 10% of
samples being confirmed by
GC on a second column
with full QA/QC
deliverables; duplicates and
blanks.
EPA Method 8080 with
second column
confirmation; data report;
replicate, blanks, and
spikes.
Typical
Petroleum
Hydrocarbon
Analyses
Immunoassay kits
Chem test kits (HANBY)
IR (EPA 413 and 418)
methods
Immunoassay3 IR, and
chemical analysis with 10%
of samples being confirmed
by GC/MS or EPA Method
8015 (modified) with
second column
confirmation with full
QA/QC deliverables;
duplicates and blanks.
EPA Method 8015
(modified) with second
column confirmation; data
report; replicate, blanks,
and spikes.
GC method with 10% of
samples being confirmed by
GC/MS or GC on two
columns with full QA/QC
deliverables; duplicates and
blanks.
Testing for physical parameters is not analyte specific. Therefore, by strict definition, any physical test would
have to be considered non-definitive. However, the testing methods may be definitive if approved methodology is
- followed.
Physical
Parameters (pH,
flash point, etc.)
Field testing equipment
ฆ Testing equipment with QC
samples, duplicates, and
blanks.
Testing equipment; data
report; and QC samples,
duplicates, and blanks.
GC
Gas chromatograph
GC/MS =
Gas chromatography/mass spectrometry
ICP
Inductively coupled plasma
AA
Atomic absorption
IC
Ion chromatography
XRF
X-ray fluorescence
IR
Infrared spectroscopy
DLs
Detection Limits
3 Immunoassay kits used to generate data must be capable of generating calibration, blank, duplicate, and estimation of error data.
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5.2 DATA ASSESSMENT PARAMETERS
Data acceptance criteria are established in the project-specific SAP for each of the five data
assessment parameters identified by the EPA. These objectives are expressed as quantitative and
qualitative statements concerning the type of data needed to support a decision, based on a specified
level of uncertainty. Table 3 in Appendix A, or an equivalent table, is used in the SAP to present
three of the five data assessment parameters (precision, accuracy, completeness). Criteria for
comparability and representativeness are described below. Table 3 also defines the required
analytical detection limits.
Data are reconciled in the Analytical Results Report (ARR) with stated DQOs by determination of
precision (analytical and/or total measurement error determination), accuracy, and completeness, and
statements on representativeness and comparability.
The data assessment parameters are:
Precision is a measure of agreement among replicate (or between duplicate) or collocated sample
measurements of the same analyte. The closer the numerical values of the measurements are to each
other, the more precise the measurement. Precision is determined through calculation of analytical
and/or total measurement error.
Analytical error (required for screening with 10% definitive confirmation data unless total
measurement error is determined during confirmation analyses) is determined by taking an
appropriate number of replicate aliquots from one thoroughly homogenized screening sample. The
replicate samples are analyzed and standard laboratory QC parameters (such as variance, mean, and
coefficient of variation) are calculated and compared to method-specific performance criteria. Total
measurement error (required for definitive confirmation data if analytical error is not determined)
is calculated using an appropriate number of collocated samples for each matrix under investigation,
independently collected from the same location and analyzed. Standard laboratory QC parameters
such as variance, mean, and coefficient of variation are calculated and compared to established
measurement error goals. For data to be definitive, either analytical or total measurement error must
be determined. (EPA 1993).
For some sampling events, determination of precision may not be required. For example, when it
is expected that all sample analyte concentrations will be far greater than site action levels, rigorous
error determination may not be necessary. When this is the case, the site-specific SAP QC
requirements should reflect the program needs.
Accuracy is a measure of bias in a measurement system. The closer the value of the measurement
agrees with the true value, the more accurate the measurement. Accuracy is expressed as the percent
recovery of the surrogate or spike analyte from a sample or standard. Accuracy is dependent on
traceability of instrumentation, standards, samples, and data; methodology; reference or spiked
samples; performance samples; and equipment calibration.
Completeness is a measure of the number of valid measurements obtained in relation to the total
number of measurements planned. The closer the numbers are, the more complete the measurement
process. Completeness is expressed as the percentage of valid-to-planned measurements. A
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sufficient volume of sample material is collected to complete the required analyses, so that samples
represent all possible contaminant situations under investigation as well as background and control
areas. Completeness is influenced by environmental conditions, potential for change with respect
to time and location, equipment maintenance, data records, sampling location, sample volume, QC
samples, and sample representativeness. In general, a completeness greater than 90% will fulfill the
data quality objectives.
Comparability is a qualitative parameter expressing the confidence with which one data set can be
compared to another. The comparability goal is achieved through the use of SOPs to collect and
analyze representative samples, by reporting analytical results in appropriate and consistent units and
by maintaining consistency in sampling conditions, selection of sampling procedures, sample
preservation methods, and analytical methods.
Representativeness is a qualitative parameter that expresses the degree to which sample data
accurately and precisely represent a characteristic of a population, parameter variations at a sampling
point, or an environmental condition. The design of and rationale for the sampling program (in terms
of the purpose for sampling, selection of sampling locations, the number of samples to be collected,
the ambient conditions for sample collection, the frequencies and timing for sampling, and the
sampling techniques) ensure that environmental conditions have been sufficiently represented.
6.0 SAMPLING PROCESS DESIGN (Element Bl)
The project-specific SAP describes the sampling design by presenting project objectives in terms of specific
operational parameters. The design identifies sampling locations, sample types and matrices, frequency of
collection and sample numbers, measurement/text parameters and sensitivity needed for decision making.
The sampling design should also generate data that are representative of the conditions at the site within
resource limitations.
The project-specific SAP presents the rationale for sample selection, including justification for the frequency
of collection of each sample matrix at each sample collection site. Elimination of unnecessary, duplicative
or overly precise data minimizes expenditures and response time related to sample collection and analysis.
However, sufficient data must be collected to support defensible decision making.
When field screening and/or field analyses are to be used, the SAP describes the criteria for sample selection
'and the required quality objectives. The SAP may also include other information such as specific selection
criteria, techniques, rationale or guidelines used to establish sample point locations, measurement criticality,
well installation design, selection of sample collection equipment, etc. Examples of the types of site-specific
factors that may be discussed in the SAP include: site accessibility, climate, potential hazards, media of
concern, and site heterogeneity. Information that can be used to support the design often includes site maps,
geological information, disposal records, and historical data. Method validation for unusual sample matrices
and situations may also be included to support the decision for their inclusion in the design.
Table 1 in Appendix A, or a table containing equivalent information, is used in the SAP to present the
quantities of both environmental and QC samples to be collected and analyzed for each matrix to be
investigated. Each type of QC sample is described in detail in Section 10.0 of this plan.
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7.0 SAMPLING METHODS (Element B21
The quality of data collected in an environmental study depends on the quality and thoroughness of field
sampling activities. Due to the sensitivity of analytical methods and the extremely low levels of detection
specified for sample analysis, the sampling process becomes integral to the integrity of data generated. As
a result, general field operations and practices and specific sample collection and inventory must be well
planned and carefully implemented.
The project-specific SAP provides detailed descriptions of the sampling program and sampling procedures.
The sampling-related topics described in the SAP include the following:
Identification of all methods used, including method number, date and regulatory citation, when
available;
Procedures for sample collection;
Required sampling equipment;
Required support facilities;
Performance requirements for sampling methods;
Use of field screening;
Field measurements;
Field preparation of samples including filtration and preservation procedures;
Required sample containers, sample volumes, and sample holding times;
Corrective action to be taken when sampling or measurement systems fail; appropriate alternative
methods;
Decontamination procedures and materials; and
Disposal of investigation-derived wastes.
The Project Leader at times is required to adjust the field program and deviate from the project-specific SAP
to accommodate site-specific needs, for example, adding or deleting a sampling location, using less inert
sampling devices, or collecting smaller sample volumes. When it becomes necessary to modify a program,
the Project Leader documents and implements the necessary changes. The designated EPA official is notified
if the change is determined to be a significant one.
7.1 STANDARD OPERATING PROCEDURES
SOPs have been developed for use on sampling and related data-gathering activities The purpose
of these procedures is to obtain samples that represent the environment and contamination under
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investigation. These SOPs provide consistency in data collection activities and decrease the time
needed for SAP preparation and review. Proposed project-specific modifications to the SOPs along
with their justification are clearly documented in the project SAP and in the project reports. SOPs
are included in the project-specific SAP as attachments or by reference.
For non-standard operations, unusual sample matrices or unusual sampling conditions, validation of
procedures may be required to confirm that project quality criteria can be met. These validations
must be developed before project sampling begins and must be documented in the project reports.
SOPs (SOPs) for sample collection are briefly described below.
SOP 1 - General Field Operation - describes the overall field organization in support of
sample collection, sample identification, record keeping, field measurements, and data
collection.
SOP 2 - Sample Containers, Preservation and Maximum Holding Times - describes the
methods used to place samples in appropriate containers to preserve specific samples, and
the maximum time a sample can be held before it is analyzed.
SOP 3 - Chain of Custody - outlines the documentation necessary to trace sample
possession.
SOP 4 - Sample Identification, Labeling, and Packaging - specifies the methods for sample
identification and labeling. Sample packing and shipment methods are also outlined.
SOP 5 - Sample Location Documentation - outlines the methods for documentation of all
sample locations.
SOP 6 - Use and Maintenance of Field Log Books - outlines the proper documentation of
information in field log books during data collection activities.
SOP 7 - Hazardous Waste Characterization - outlines the methods for characterization of
unknown materials for disposal, bulking, recycling, grouping and classification purposes. .
SOP 8 - Investigation Derived Waste Management - outlines the management of wastes
generated during environmental field operations.
SOP 9 - Monitor Well Installation - describes the methods for monitoring well installation,
including design, construction procedures, and materials.
SOP 10 - Monitor Well Development - describes the methods for monitoring well
development, including data recording formats.
SOP 11 - Equipment Decontamination - describes the techniques used to decontaminate
equipment prior to sample collection or data measurement.
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SOP 12 - Groundwater Sampling - establishes the methods for monitoring well purging,
sample collection, and equipment use when sampling.
SOP 12A - Groundwater Sampling for Low Flow Purge - describes equipment and
operations for sampling groundwater monitor wells using a pump to obtain samples with a
minimum of turbidity.
SOP 13 - Water Level Measurement - describes the methods used to record water levels at
surface water locations and in groundwater monitoring wells.
SOP 14 - Water Sample Field Measurements - describes the measurement techniques and
data requirements associated with the collection of either a groundwater or surface water
sample.
SOP 15 - Flow Measurements - describes the methods for conducting flow measurements
during surface water sampling.
SOP 16 - Surface and Shallow Depth Soil Sampling - establishes the methods for sample
collection using a variety of sampling devices. Techniques for avoiding sample and
equipment cross-contamination are also discussed.
SOP 17 - Sediment Sampling - establishes the methods for sample collection using a variety
of sampling devices. Techniques for avoiding sample and equipment cross-contamination
are also discussed.
SOP 18 - Surface Water Sampling - establishes the methods for sample collection and
equipment use at a variety of surface water locations. Techniques for avoiding water body
and sample cross-contamination are also discussed.
SOP 19 - Soil Gas Sampling - outlines the methods for decontamination and soil gas
sampling for routine field operations.
SOP 20 - Drum and Container Sampling - describes methods for safe and effective sampling.
of drums and containers less than 120 gallons.
SOP 21 - Tank Sampling - describes the measurement techniques used in sampling
aboveground storage tanks.
SOP 22 - Aquifer Slug Testing - establishes the methods and data recording formats for
conducting slug tests in groundwater monitoring wells.
SOP 23 - Aquifer Pump Testing - establishes the methods and data recording formats for
conducting pump tests in groundwater extraction and monitoring wells.
SOP 24 - Geological Borehole Logging - describes the information and observations to be
recorded for the identification, logging, and sampling of a borehole. Sampling methods and
data collection formats are also presented.
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SOP 25 - Residential Dust Sampling - describes the methods for collecting composite dust
samples in a residential community.
SOP 26 - Chip, Wipe and Sweep Sampling - describes the equipment and methods required
for obtaining a representative chip, wipe or sweep sample to monitor potential surface
contamination.
7.2 RECORD KEEPING AND DOCUMENT CONTROL
Project activities are documented in the project plans and project reports and are supported by field
activities records and laboratory data reports. Applicable field forms as described in SOPs may be
included as attachments to the project-specific SAP. When references are used in project documents,
or when attachments are added to these documents, they must be specific so that the reviewer can
readily find the appropriate sections and pages containing the pertinent information. Laboratory
documentation requirements are delineated in the laboratory contracts and include specifications for
data report composition, report format, turnaround time, and records retention. Laboratory data are
recorded in a format that includes sample identification, analysis date, parameter values, and
detection limits. Both laboratory and field data are combined and summarized in final tables and
graphs that are appropriate to the type of data and convey information to support the findings of the
data collection program. In all cases, data are clearly tabulated and presented in a consistent manner
to support comparison of common sets of data. Finally, data are presented so as to logically lead to
and substantiate the conclusions and recommendations provided by the final report.
8.0 SAMPLE HANDLING AND CUSTODY (Element B3^>
Written documentation of sample custody from the time of sample collection through the generation of data
by analysis of that sample is recognized as a vital aspect of an environmental study. The chain of custody
of the physical sample and its corresponding documentation are maintained throughout the handling of the
sample. All samples must be identified, labeled, logged onto a Chain-of-Custody form, and recorded in a
sample tracking log or field log book as a part of the procedure to ensure the integrity of the resulting data.
The record of the physical sample (location and time of sampling) is joined with the analytical results through
accurate accounting of the sample custody. Sample custody applies to both field and laboratory operations.
SOPs and data collection forms have been developed for sample custody, sample labeling, analysis requests,
"and shipping and tracking procedures. These SOPs are included in the project-specific SAP by reference.
Analytical laboratory sample custody procedures are included in the laboratory QA plan, which identifies the
roles of both the sample custodian and the laboratory coordinator.
SOPs for sample handling are briefly described below.
SOP 3 - Chain of Custody - describes the EPA forms, forms completion instructions, and the record
keeping requirements and formats associated with sample custody. Additionally, this SOP outlines
the steps to be followed in order to maintain a continuous chain of custody from sample collection
to data generation and the communications and information transfer that will occur between field
personnel, sample coordinators, and EPA personnel;
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SOP 4 - Sample Identification, Labeling and Packaging - outlines the steps involved with sample
labeling and packing at the point of collection for distribution to the analytical laboratory; and
SOP 5 - Sample Location Documentation - outlines the necessary descriptions and information to
be recorded for each physical location where sampling is conducted.
9.0 ANALYTICAL METHODS (Element B41
To ensure that the DQOs established in the project-specific SAP can be achieved, the analytical criteria that
are to be used for data generation by laboratory analysis must be clearly identified. Analytical methods for
sample analyses are selected on the basis of the required detection limits, known contaminants existing in the
study area, and the range of analytes to be determined. The project-specific SAP identifies the analytical
methods for the samples collected during the project activities. Table 2 provided in Appendix A, Table 4
provided in Appendix A, or a table containing equivalent information, is used in the SAP to present method
numbers, reference guidance, sample container, sample volume requirements, sample preservatives, sample
holding times, and contaminant specific benchmarks for each sample matrix and analyte.
Analysis of samples collected at CDPHE are performed by laboratories that have established laboratory QA
plans in compliance with the EPA's QA guidance for sampling and chemical analysis. Prior to sample
analysis, the laboratory is provided with the following directions.
Number and matrices of the samples to be analyzed;
Required analysis turnaround time;
Identification of analytical methods and equipment;
Description of sample preparation procedures;
Identification of digestion/extraction methods;
Frequency and type of QC analyses;
Precision and accuracy criteria;
Data reporting limits and units; and
Laboratory documentation and reporting requirements.
If the Project Leader, in conjunction with the Analytical Services Coordinator and the Quality Assurance
Officer find the analytical data to be unreliable or incomplete, the laboratory is responsible for correcting the.
errors. If the laboratory can not provide data of adequate accuracy and precision, the samples may need to
"be recollected.
10.0 QUALITY CONTROL (Element B51
The project-specific SAP identifies the QC procedures needed for each sampling, analysis or measurement
technique applicable to the project and states or references the required control limits for each QC check.
The number and type of QC samples collected are determined by the type of data to be collected as identified
during the DQO process. QC checks of both field sampling and laboratory sample analysis are used to assess
and document data quality and to identify discrepancies in the measurement process that need correction.
QC samples are used to determine the representativeness of the environmental samples, the precision of
sample collection and handling procedures, the thoroughness of the field decontamination procedures, and
the accuracy of the laboratory analysis.
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Table 1 in Appendix A, or a table containing equivalent information, is used in the SAP to present the
quantities of field and laboratory QC samples to be collected and analyzed for each matrix to be investigated.
10.1 FIELD QUALITY CONTROL
The following sections describe the types of field QC samples that are collected:
Field blanks are used to indicate the presence of external contaminants that may have been
introduced into the samples during collection. These blanks may also become contaminated during
transport, but this condition is assessed by the use of trip blanks, as discussed below. Field blanks
are prepared on site during the sampling event by pouring ASTM Type I organic-free water into
randomly selected sample containers.
Trip blanks are used to assess contamination introduced into the sample containers by volatile
organics through diffusion during sample transport and storage. One trip blank is prepared off-site
and is included in each shipping container with samples scheduled only for analysis of volatile
organic compounds regardless of environmental medium. When sample bottles are provided by the
laboratory, trip blanks are prepared at the laboratory using ASTM Type I organic-free water,
transported to the sampling site with the other sample containers, and returned to the testing
laboratory for analysis along with the samples collected during the sampling event. The trip blanks
remain unopened throughout the transportation and storage processes and are analyzed along with
the associated environmental samples. Trip blanks are analyzed and reported as water samples even
though the associated environmental samples may be from a medium such as soil, tissue, product,
etc.
Equipment blanks (equipment decontamination rinsates) are used to assess the adequacy of
practices to prevent cross-contamination between sampling locations and samples. Rinsate samples
are collected daily only for sampling equipment used repetitively to collect environmental samples
and not for dedicated sampling equipment or drilling equipment. Rinsate water is collected following
the final decontamination rinse of sampling equipment (such as a bailer, sampling pump, or mixing
bowl) and then dispensed into sample containers. Specified sample containers and sample volumes
are collected for each type of analysis to be conducted by the laboratory. The equipment
decontamination rinsates are handled and analyzed in the same manner as all environmental samples.
Field replicates (or duplicates) are collected at selected locations to provide estimates of the total
sampling and analytical precision. At least one replicate sample is analyzed from each group of 20
samples of a similar matrix type and concentration. The field replicates are handled and analyzed
in the same manner as all environmental samples.
Standard reference samples are used to assess the accuracy of the analytical methods specified and
to assess the performance of the laboratory sample analysis. These samples are prepared with a
known composition and analyte concentration by an independent laboratory and submitted to the
analytical laboratory as unknown samples. The samples contain specific analytes at concentrations
anticipated to be measured in the various environmental media and are analyzed in the same manner
as all environmental samples.
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10.2 LABORATORY QUALITY CONTROL
The analytical laboratory uses a series of QC samples specified in each standard analytical method
to assess laboratory performance. Analyses of laboratory QC samples are performed for samples
of similar matrix type and concentration and for each sample batch. The types of laboratory QC
samples are method blank, laboratory control standard, duplicate, matrix spike and matrix spike
duplicate. Other technical QC requirements may be project-specific, for example second column
confirmation for a gas chromatography analysis of pesticides.
The analytical laboratory will also report out-of-control occurrences such as poor analysis
replication, poor spike recovery, instrument calibration problems, blank contamination, etc.
Corrective action is taken at any time during the analytical process when deemed necessary based
on analytical judgment or when QC data indicate a need for action. Corrective actions include, but
are not limited to:
Re-analysis;
Re-calculation;
Instrument recalibration;
Preparation of new standards/blanks;
Re-extraction/digestion;
Dilution;
Application of another analysis method; and
Additional training of analysts.
Out-of-control incidents are documented so that corrective action may be taken to set the system
back "in control." These incidents constitute a corrective action report, and are signed by the
laboratory director and the laboratory QA contact:
Where the out-of-control incident occurred;
When the incident occurred and was corrected;
Who discovered the out-of-control incident;
Who verified the incident;
Who corrected the problem; and
Who verified the correction.
11.0 INSTRUMENT/EQUIPMENT CALIBRATION AND FREQUENCY (Element B71
11.1 CALIBRATION PROCEDURES
The project-specific SAP identifies the field sampling, measuring and testing equipment to be used
for data collection activities. All equipment used on the project is calibrated and adjusted to operate
within manufacturers' specifications. Equipment and instrumentation calibration ensures that
accurate and reliable measurements are obtained. The procedures for calibration and maintenance
used by the analytical laboratories are included in their laboratory QA Plans and analytical methods.
All calibration standards are traceable to the National Institute of Standards and Technology or other
primary standards. Methods and intervals of calibration are based on the type of equipment, stability
characteristics, required accuracy, intended use, and environmental conditions.
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11.2 PREVENTIVE MAINTENANCE
Preventive maintenance is implemented on a scheduled basis to minimize downtime and to ensure
accurate measurements from both field and laboratory equipment. This program is designed to
achieve results commensurate with the specified capabilities of equipment operation, thus generating
data of known quality. Maintenance is conducted by trained technicians using service manuals or
through service agreements with qualified maintenance contractors. In addition, backup equipment
and critical spare parts are maintained to quickly correct equipment malfunction.
11.3 CALIBRATION AND MAINTENANCE RECORDS
Calibration and maintenance records are maintained for equipment in project specific logbooks.
12.0 ASSESSMENT AND RESPONSE ACTIONS (Element CD
Assessments are utilized to increase the user's understanding of the activity being assessed and to provide
a basis for improving that activity. Assessments may be conducted by CDPHE staff or independent
subcontractors. All assessments are planned and documented based on the project requirements. Both self-
assessments and independent assessments utilize one or more assessment tools such as reviews, surveillances,
formal audits and technical documentation reviews. The project-specific SAP identifies the number,
frequency, and type of assessment activities needed for the project. Assessment responsibilities, planning,
tools and responses are summarized below.
12.1 RESPONSIBILITY FOR ASSESSMENTS
QA/R-5 requires that assessments be conducted by personnel who have sufficient authority, access
to work areas, and organizational freedom to:
Identify quality problems;
Identify and cite practices that may be shared with others to improve the quality of their
operations and products;
Propose recommendations for resolving quality problems;
Independently confirm implementation and effectiveness of solutions;
Provide documented assurance to line management that, when problems are identified,
further work performed is monitored carefully until the problems are suitably resolved; and
Suspend or stop work with the concurrence of the SUL and EPA, upon detection and
identification of an immediate adverse condition affecting the quality of results.
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12.2 IMPLEMENTATION OF ASSESSMENTS
Approaches used for the assessments vary with the objectives of the assessment and the status of the
project, but are of two basic types:
Management and technical self-assessment: the qualitative assessment of a management or
technical system by those immediately responsible for overseeing and/or performing the
work.
Management and technical independent assessment: the qualitative assessment of
management or technical system by someone other than the group performing the work.
Assessments are scheduled by the QAO in consultation with the Project Leader but may be requested
by the SUL or EPA. The schedule for either management or technical assessments is based on the
status, risk, and activities in progress and is documented in project-specific plans. In addition to
scheduled assessments, technical personnel conduct routine, informal assessments of their work and
may request a formal assessment to clarify or document unusual or complex activities.
The planning process for assessments includes one or more of the following:
Reviewing project-specific requirements identified within project plans;
Defining acceptance criteria;
Developing an outline or check list of critical technical functions and procedural
requirements;
Defining the responsibility and authority of the person(s) conducting the assessment; and
Assuring that the personnel scheduled to conduct the assessment have adequate training and
experience. The capability of personnel conducting assessments is determined by review
of their training, certification, and experience with the program, project, or system being
assessed. Assessor qualifications must be equivalent to or higher than the individual whose
activity is to be assessed. Independent assessments must have no real or perceived conflict
of interest.
Assessment findings, recommendations, and corrective actions are documented in reports that
contain some or all of the following:
Names of the parties responsible for the assessment;
A copy of guidelines developed for the assessment;
Brief description of the activity assessed;
Description of any quality problems;
Recommendations for resolving any quality problems; and
Suggestions for sharing and noteworthy practices.
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12.3 MECHANISMS FOR ASSESSMENT
The tools for assessment include:
Management system reviews;
Audits and surveillances;
Independent technical reviews and peer reviews;
Readiness reviews;
Data reduction assessment; and
Data quality assessments.
12.3.1 Management System Review
Management system reviews evaluate the ability of project management to meet
programmatic requirements or to meet specified data and information collection DQOs.
Normally this type of review will not be scheduled. However, if substantial
nonconformances are identified from the other scheduled audits or the quality of data and
related documentation are of project concern, this form of review will be employed under
the direction of the QAO.
The management system is reviewed to ensure:
Effectiveness of the system of management controls that are established to achieve
and ensure quality;
Adequacy of resources and personnel provided to achieve and ensure quality in all
activities;
The effectiveness of training and audits; and
Applicability of DQOs and software.
12.3.2 Audits and surveillances
Systems and performance audits and surveillances are conducted as the principal means to
determine compliance with the project-specific documents. Audits and surveillances are
used to formally review individual projects during their course and across all levels of
management. The QAO has the primary responsibility for conducting audits and
surveillances, portions of which may be delegated to an auditing team comprised of senior
technical specialists.
Copies of the audit reports and surveillance memoranda are maintained in the QA
administrative files and in the project files and are transmitted to the EPA with the final
report for a project, or when requested by the EPA. Technical specialists must be familiar
with the technical and procedural requirements of both field and laboratory operations, and
the associated QA plans. In addition, auditors may not be directly involved with the actual
tasks themselves, so as not to introduce bias in the auditing process. Several factors are
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taken into consideration for determining the scope and frequency for audits and surveillances
as follows:
Complexity of the task order;
Applicable regulations;
Program guidance;
Project or task scope and duration;
Data quality objectives;
Deliverable requirements;
Subcontractor participation;
Emergency conditions;
Criticality of data collection; and
Potential for or frequency of nonconformances.
Surveillances are less formal than audits, but generally they follow the same procedures as
an audit. Surveillances may be initiated by line management or the QAO when a need for
such is determined.
An audit or surveillance may be initiated prior to the award of a subcontract to determine the
capability of a potential subcontractor; when reorganization or maj or revision has been made
to the project-specific SAP; when scheduled audits are established by the project planning
documents; at any time a nonconformance is suspected; or to verify that corrective actions
for nonconformance have been implemented.
The QAO submits notice of any laboratory or field system audits prior to their occurrence
and in a timely manner to EPA. Audits are scheduled such that an EPA representative may
attend and observe the audit. Two types of audits are as follows:
Performance Audits are used to determine the status and effectiveness of both field and
laboratory measurement systems and provide a quantitative measure of the quality of data
generated. For laboratories, this involves the use of standard reference samples or
performance evaluation samples. These samples have known concentrations of constituents
that are analyzed as unknowns in the laboratory. Results of the laboratory analyses are
calculated and compared for accuracy against the known concentrations of the samples and
evaluated in relation to the project DQOs. Field performance is evaluated using field blanks,
trip blanks, equipment decontamination rinsates, field replicates, and collocated samples.
Technical System Audits are used to confirm the adequacy of the data collection (field
operation) and data generation (laboratory operation) systems. The on-site audits are
conducted to determine whether the QAPP, project-specific SAP, and field and laboratory
SOPs are being properly implemented.
A systems audit of field procedures assesses and documents at a minimum, prefield
activities, sampling methods (including collection, containers, and preservation),
equipment decontamination, chain of custody, sample tracking and shipment
documentation, sample labeling, QC methodology, equipment maintenance and
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calibration, sampling documentation and other field activity logs, field team
debriefing, post-field activities, and equipment check-in and recalibration.
A systems audit of laboratory procedures assesses and documents at a minimum,
methods for data qualification, analytical data generation, chain-of-custody
documentation and protocol, instrument calibration and maintenance, data reporting,
QC methods and QC criteria, and nonconformance corrective action procedures.
12.3.3 Independent Technical Review and Peer Review
An independent technical review is a documented critical review of work of a substantive
nature or identified as a deliverable. A peer review is a documented critical review of work,
generally beyond the state of the art or characterized by the existence of potential
uncertainty. These reviews are conducted by experienced and qualified personnel to ensure
the quality and integrity of tasks and products by allowing the work and/or deliverable to
undergo objective, critical scrutiny. The QAO, SUL, and Project Leader are responsible for
ensuring that reviewers are independent from actual work or decision-making on the tasks
or activities being reviewed, and possess technical qualifications sufficient for conducting
the in-depth review. A written record of the review and resolution of the review findings is
incorporated into the project files.
The independent technical review and peer review process is used as a management tool to
assess the following:
Soundness of a technical approach or result;
Application of complicated problem-solving techniques;
Changes in the scope of a project;
Transition between phases of a sampling event;
Problems identified in a project or report;
Major decisions made at the planning stage or during the course of a project;
Potential for erroneous assumptions, data, calculations, methods, or conclusions;
and
Basis of design criteria and calculations.
Independent technical reviews and peer reviews are conducted for (but are not limited to)
all:
Work Plans;
SAPs;
Reports of site inspections;
Draft and final project reports; and
SOPs.
As needed, based on project DQOs, independent technical reviews and peer reviews may
be conducted for:
Technical approaches;
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Technical memoranda;
Studies and investigations;
Cost estimates;
Plans and specifications; and
Subcontract scopes of work.
12.3.4 Readiness Review
A readiness review is a systematic, documented review of the readiness for the start up or
continued use of a facility, process, or activity. Readiness reviews are typically conducted
before proceeding beyond project milestones and prior to initiation of a major phase of work.
Readiness reviews are performed by the SUL as needed during key successive phases of a
project.
12.3.5 Data Reduction Assessment
The following section outlines the procedures for verifying the accuracy of the data
reduction process, the methods used to ensure that data transfer is error-free (or has an
admissible error rate), that no information is lost in the transfer process, and that the output
is completely recoverable from the input. In order to reduce the risks associated with data
transfer, this process is kept to a minimum. Data are reduced either manually on calculation
sheets or by computer on formatted print-outs. The following responsibilities are delegated
in the data reduction process:
Technical personnel document and review their own work and are accountable for
its correctness;
Major calculations receive both a method and an arithmetic check by an
independent checker. The checker is accountable for the correctness of the
checking process;
An Independent Technical Review is conducted to ensure the consistency and
defensibility of the concepts, methods, assumptions, calculations, etc., as scheduled
by the Project Leader; and
The Project Leader is responsible for ensuring that data reduction is performed in
a manner that produces quality data through review and approval of calculations.
Hand Calculations must be legibly recorded on calculation sheets and in logical progression
with sufficient descriptions. Major calculations are checked by a staff member. After
completing the check, the checker signs and dates the calculation sheet immediately below
the originator. Both the originator and checker are responsible for the correctness of
calculations. A calculation sheet contains the following, at a minimum:
Project title and brief description of the task;
Task number and date performed;
Signature of person who performed the calculation;
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Basis for calculation;
Assumptions made or inherent in the calculation;
Complete reference for each source of input data;
Methods used for calculations; and
Results of calculations, clearly annotated.
Computer Analysis includes the use of models, programs, data management systems, etc.
For published software with existing documentation, test case runs are periodically
performed to verify that the software is performing correctly. Both systematic and random
error analysis are investigated and appropriate corrective action measures taken.
Documentation for project specific in-house developed models and programs is reviewed
by the SUL prior to use. This documentation is prepared in accordance with computer
program verification procedures and contains at a minimum:
Description of methodology and engineering basis;
Major mathematical operations;
Flow chart presenting the organization of the model or program; and
Test case(s), sufficiently comprehensive to test all model or program operations.
QC procedures for checking models (or programs) involves reviewing the documentation,
running the test case, and manually checking selected mathematical operations. Each
computer run has a unique number, date, and time associated with it appearing on the
printout. All QC measures are documented as referenced in applicable procedures.
12.3.6 Data Quality Assessment
Data Quality Assessments are prepared to document the overall quality of data collected in
terms of the established DQOs. The data assessment parameters calculated from the results
of the field measurements and laboratory analyses are reviewed to ensure that all data used
in subsequent evaluations are scientifically valid, of known and documented quality, and,
where appropriate, legally defensible. In addition, the performance of the overall
measurement system is evaluated in terms of the completeness of the project plans,
effectiveness of field measurement and data collection procedures, and relevance of
laboratory analytical methods used to generate data as planned. Finally, the goal of the data
quality assessment is to present the findings in terms of data usability.
The major components of a data quality assessment are presented below and show the
logical progression of the assessment leading to determination of data usability:
Summary of the individual data validation reports for all sample delivery groups by
analytical method. Systematic problems, data generation trends, general conditions
of the data, and reasons for data qualification are presented;
Description of the procedures used to further qualify data caused by dilution,
reanalysis, and duplicate analysis of samples. Examples of the decision logic are
provided to illustrate the methods by which qualifiers are applied;
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Evaluation of QC samples such as, field blanks, trip blanks, equipment rinsates,
field replicates and laboratory control samples to assess the quality of the field
activities and laboratory procedures;
Assessment of the quality of data measured and generated in terms of accuracy,
precision, and completeness through the examination of laboratory and field control
samples in relation to objectives established and correct application of statistical
methods. A further discussion of the evaluation of DQOs is presented in Section
14.0.
Summary of the usability of data, based upon the assessment of data conducted
during the previous four steps. Sample results for each analytical method are
qualified as acceptable, rejected, estimated, biased high, or biased low.
12.4 RESPONSE TO ASSESSMENTS
The SUL and Project Leaders review and respond to assessment findings in a timely manner. This
response will depend upon the potential impact and/or time-critical nature of the quality problem.
In all cases, it is the responsibility of the QAO to confirm the implementation and effectiveness of
the response action.
Time-Critical, Significant Impact. Example: A field audit finds that a subcontractor is
using an inappropriate analytical procedure. The assessor notifies the Project Leader and
QAO from the field, discusses alternatives; attempts to take immediate corrective action;
and, if necessary, stops work with concurrence of the Project Leader, SUL and EPA.
Time-Critical, Minor Impact. Example: A field audit finds that sample labels are messy
but information is useable. The assessor notifies the Project Leader and documents the
finding.
Not Time-Critical, Possible Major Impact. Example: A management assessment
determines that a procedure for sampling is in error. The assessor incorporates a description
and recommendation into a report to the SUL, and QAO. The SUL establishes a schedule
for corrective action, designates a responsible person, and determines what documentation
of the corrective action is required; the QAO follows up to confirm that the corrective action
has been implemented.
Not Time-Critical, Minor Impact. Example: A management assessment determines that
the numbering system for the procedures is obsolete. The assessor describes the problem;
discusses a solution with the responsible person; and reports to the Project Leader that the
issue has been resolved; the QAO follows up to confirm that the corrective action has been
implemented.
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12.5 NON-CONFORMANCE AND CORRECTIVE ACTION
Management and technical staff follow project plans, supplementary procedures, SOPs, and training
plans and procedures during the course of any CDPHE activity, however, on occasion, non-
conformances do occur. Each nonconformance is documented by CDPHE personnel or a
subcontractor employee observing the nonconformance. Examples of nonconforming work include:
Items that do not meet the contractual requirements by a subcontractor supplier;
Errors made in following work instruction or improper work instruction;
Unforeseen or unplanned circumstances that result in services that do not meet
quality/contractual/technical requirements;
Unapproved or unwarranted deviations from established procedures;
Errors in craftsmanship or trade skills;
Non-validated or verified computer programs;
Sample Chain-of-Custody missing or deficient; and
Data falling outside established DQO criteria.
Results of QA reviews and audits typically identify the requirement for a corrective action. The
QAO is responsible for reviewing all audit and nonconformance reports to determine areas of poor
quality or failure to adhere to established procedures. Nonconformances are formally reported by
the QAO to the Project Leader. The Project Leader is responsible for evaluating all reported
nonconformances, determining the root cause, conferring with the QAO on the steps to be taken for
correction, and executing the corrective action as developed and scheduled. Corrective action
measures are selected to prevent or reduce the likelihood of future occurrences and address the root
causes to the extent identifiable. Selected measures are appropriate to the seriousness of the
nonconformance and are realistic in terms of the resources required for implementation.
In summary, corrective action involves the following steps:
Discovery of a nonconformance;
Identification of the responsible party;
Determination of root causes;
Plan and schedule of corrective/preventive action;
Review of the corrective action taken; and
Confirmation that the desired results were produced.
Upon completion of the corrective action, the QAO evaluates the adequacy and completeness of the
action taken. If the action is found to be inadequate, the QAO and Project Leader confer to resolve
the problem and determine any further actions. Implementation of any further action is scheduled
by the Project Leader. The QAO will issue a suspend or stop work notice with the concurrence of
the SUL and EPA in cases where significant problems continue to occur or a critical situation
requires work to prevent further discrepancies, loss of data, or other problems. When the corrective
action is found to be adequate, the QAO notifies the Project Leader of the completion of the audit.
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The QAO maintains a log of nonconformances in order to track their disposition until correction and
for trend analysis as necessary. All documentation associated with a nonconformance is entered into
the project files and QA administrative files.
13.0 DATA REVIEW. VERIFICATION AND VALIDATION (Elements D1 and D2)
At a minimum, all analytical data are reviewed. The SAP indicates if data validation is also required based
on the project DQOs. When applicable, the SAP presents project-specific criteria used to accept, reject or
qualify data.
The purpose of the validation process is to eliminate unacceptable analytical data and to designate a data
qualifier for any data quality limitation discovered. In some instances, the analytical data may be used only
for approximation purposes. Data validation criteria are discussed below for both field and laboratory data.
13.1 FIELD DATA VALIDATION
Field Data Validation is conducted to eliminate data that are not collected or documented in
accordance with specified protocols outlined in the QAPP and SAP and listed below. In some
instances, the field data are used only for approximation purposes and do not require validation. In
all cases, validation of field data is performed on two separate levels. First, all field data are
validated at the time of collection reviewing the procedures outlined in the SOPs. Second, the
Project Leader reviews the field data documentation to identify discrepancies or unclear entries.
Field data documentation are validated against the following criteria:
Sample location and adherence to the plan;
Field instrumentation calibration;
Sample collection protocol;
Sample volume;
Sample preservation;
Blanks collected and submitted with each respective sample set;
Duplicates collected and submitted with each respective sample set;
Sample documentation protocols;
Chain-of-Custody protocol; and
Sample handling and shipment.
13.2 QC REVIEW AND ANALYTICAL DATA VALIDATION
13.2.1 OC Review
QC Review consists of a review of the data summary forms that are generated for a set of
data. At a minimum, Chain-of-Custody records, the case narrative, and the summary results
for samples and QC analyses are reviewed. The raw data are reviewed for completeness
only. The Reviewer assumes that the information presented in the data summary forms is
correct as presented. Information that is not contained in the data summary forms is not used
in the review process. (Note: Raw data may be reviewed if the data summary forms reveal
a discrepancy or error that cannot be resolved through a review of the data summary forms.)
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13.2.2 Data Validation
The Site Assessment Program requires that data be validatable but does not require
validation of each data set for decision making. Data is routinely validated. Exceptions are
at the descretion of the EPA Site Assessment Manager, in consultation with the CDPHE
Project Leader.
Analytical Data Validation is conducted by a specialty contractor not involved with the
actual generation of data. All data generated are recorded on standard Contract Laboratory
Program (CLP) Statement of Work (SOW) forms, or their equivalent. This requirement
includes both CLP and non-CLP analyses such as standard EPA analytical methods not
specifically covered by the CLP. The data report is then validated in accordance with the
criteria contained in EPA guidance documents modified for the analytical method used (EPA
1994a; EPA 1994b). Data validation reports are filed with the data and describe the usability
of the data for further technical interpretations.
The validation report provides a list of all samples being validated, a narrative summarizing
each validation topic (e.g., calibration, hold times, etc.), flagged form Is, worksheets, and
any data resubmitted by the laboratory at the request of the validator. The requirements for
data validation relate to the QA/QC elements summarized in Table 5-las follows:
Screening Data: Data need only be evaluated for calibration and detection limits criteria.
Screening Data with 10% Definitive Confirmation: Data validation of 10% of the results
reported in each of the samples, calibrations, and QC analyses is required for screening data
with definitive confirmation (of the definitive confirmation data only). The results are
evaluated for all of the QA elements listed in Section 5.1.2 and in Table 5-1.
Definitive Data: Data validation of 10% of the results reported in each of the samples,
calibrations, and QC analyses is required for definitive data. The results are evaluated for
all of the QA elements listed in Section 5.1.3 and in Table 5-1.
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14.0 RECONCILIATION WITH DATA USER REQUIREMENTS (Element D3)
In the final report for each project, all data generated for the project are reconciled with the DQOs presented
in the project-specific SAP. The final report describes initial project DQOs and summarizes all changes made
to the DQOs as the project progressed. The rationale for the changes is discussed along with any
consequences of these changes. The report describes how issues were resolved and limitations on the use
of the data. The report also summarizes procedures used to define data usability, i.e., data reviews or
validation reports, and the results of these procedures (see also Section 12.3.6).
Analytical data are assessed for accuracy, precision, completeness, representativeness, and comparability.
The data assessment criteria for each of these parameters are described in Section 5.2 of this QAPP. This
section establishes the methods for calculating accuracy, precision, and completeness and for evaluating
representativeness and comparability using the methods described by EPA guidance. Generally, data that
do not meet the established acceptance criteria are cause for resampling and reanalysis. However, in some
cases data that do not meet acceptance criteria are usable with specified limitations. Data that are indicated
as usable with limitations are included in the project reports, but are clearly indicated as having limited
usability. Indicators of data limitations include data qualifiers, quantitative evaluations, and narrative
statements regarding potential bias.
14.1 PRECISION
Precision examines the spread of data about their mean. The spread presents how different the
individual reported values are from the average reported values. Precision is thus a measure of the
magnitude of errors and will be expressed as the relative percent difference (RPD) or the relative
standard deviation (RSD). The lower these values are, the more precise that data. These quantities
are defined as follows:
RPD (%) = 100 x \S " D\
(S + D)/2
RSDj *) . igฐ x - *1
p. (S + D)
where S = Analyte concentration in a sample
D = Analyte concentration in a duplicate sample
or
RSD (%) = 100 (1)
where s = Standard deviation of replicate measurements
X = Mean of replicate measurements
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CDPHE QAPP
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Page 39 of 41
14.2 ACCURACY
Accuracy measures the average or systematic error of an analytical method. This measure is defined
as the difference between the average of reported values and the actual value. Accuracy will be
expressed as the percent bias for standard reference samples. The closer this value is to zero, the
more accurate the data. This quantity is defined as follows:
Bias (%)
MC - KC
KC
x 100
where KC = Known analyte concentration
MC = Measured analyte concentration
In cases where accuracy is determined from spiked samples, accuracy will be expressed as the
percent recovery. The closer these values are to 100, the more accurate the data. Surrogate recovery
will be calculated as follows:
Mi
Recovery (%) = x 100
SC
where SC = Spiked concentration
MC = Measured concentration
Matrix spike percent recovery will be calculated as follows:
Recovery (%) = x 100
iSC
where: SC = Spiked concentration
MC = Measured concentration
USC = Unspiked sample concentration
In instances where data can be adjusted to correct for systematic errors before data evaluation, the
correction factor and rationale for correction will be fully documented and presented in the report
that summarizes the data.
14.3 COMPLETENESS
Completeness establishes whether a sufficient number of valid measurements were obtained. The
closer this value is to 100, the more complete the measurement process. This quantity will be
calculated as follows:
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v
Completeness (%) = x 100
where V = Number of valid measurements
P = Number of planned measurements
14.4 REPRESENTATIVENESS
Representativeness expresses the degree to which data accurately and precisely represent the
environmental condition. Following a determination of precision, a statement on representativeness
will be prepared noting the degree to which data represent the environmental and contaminant
conditions under investigation.
14.5 COMPARABILITY
Comparability expresses the confidence with which one set of data can be compared to another.
Following the determination of both precision and accuracy, a statement on comparability will be
prepared citing the acceptance criteria established in relation to use of the data sets in further
evaluations and modeling of the environmental and contaminant conditions under investigation. A
statement on comparability will also be prepared when the data collected are used with data reported
from another or previous study.
CDPHE QAPP
Revision: 01
Date: 03/2000
Page 40 of 41
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CDPHE QAPP
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Date: 03/2000
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15.0 LIST OF REFERENCES
U.S. Environmental Protection Agency (EPA). 1990. Quality Assurance/Quality Control Guidance for
Removal Activities: Sampling QA/QC Plan and Data Validation Procedures. EPA/540/G-90-004 (4/90).
U.S. Environmental Protection Agency (EPA). 1993. Data Quality Objectives Process for Superfund,
Interim Final Guidance. EPA 540-R-93-071 (9/93).
U.S. Environmental Protection Agency (EPA). 1994a. U.S. Environmental Protection Agency CLP National
Functional Guidelines for Organic Data Review, EPA 540/R - 94/012, (2/94).
U.S. Environmental Protection Agency (EPA). 1994b. U.S. Environmental Protection Agency CLP National
Functional Guidelines for Inorganic Data Review, EPA 540/R - 94/013 (2/94).
U.S. Environmental Protection Agency (EPA). 2000. Data Quality Objectives Process for Hazardous Waste
Site Investigations. EPA QA/G-4HW. (2000).
U.S. Environmental Protection Agency (EPA). 1996. U.S. Environmental Protection Agency Region VIII
Minimum Requirements for Field Sampling Activities (9/96).
U.S. Environmental Protection Agency (EPA). 1999. EPA Requirements for Quality Assurance Project
Plans, Interim Final. EPA QA/R-5 (11/99).
U.S. Environmental Protection Agency (EPA). 1998. EPA Order 5360.1, Change 1, Policy and Program
Requirements for the Mandatory Agency-Wide Quality System (7/98).
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APPENDIX A
Environmental and Quality Control Sample Collection
and Laboratory Analysis Specifications
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CDPHE QAPP - Appendix A
Revision: 0
Date: 01/2000
TABLE 1
Environmental and Quality Control Sample Quantities for Environmental Analyses
Sample ID /
Location
Analysis
Quality Control Samples
Lab QA/QC
Field QA/QC
Total Samples
Standard
Reference
Samples
MS/MSI)
Other...
Field
Replicates
Trip
Blanks
Field
Blank
F.quipnienl
Rinsnte
Total Samples
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CDPHE QAPP - Appendix A
Revision: 0
Date: 01/2000
TABLE 2
Environmental Sample Collection and Laboratory Analysis Specifications
Analysis
Analytical
Method
Reference
Container-1
Required
Volume
Preservation1"
Holding Time'
a Container types: AGV = amber glass vial; HDPE = high-density polyethylene bottle and cap; AGB = amber glass bottle.
b Sample preservation will be performed by the sampler immediately upon sample collection. Preservatives will be added to filtered samples following
filtration. Containers used for volatile organic samples will be completely filled, permitting no head space,
c Holding times begin from the time of sample collection in the field. Two holding times indicate the maximum holding time until sample extraction
and the maximum holding time.
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CDPHE QAPP - Appendix A
Revision: 0
Date: 01/2000
TABLE3
Quality Assurance Objectives for Environmental Samples
Analysis
(for each matrix)
Analytical
Method
Data Type
Units
Required
Detection
Limits
Accuracy
%
Precision
ฑ%
Note: The complete list of analytes determined from laboratory sample analysis is published in each reference document listed for the specified analytical method. Detection limit, accuracy, and precision values
are presented in this table as ranges, but are assigned to each individual analyte as published in each reference document.
Data type refers to the following: Accuracy is determined by use of field blind QC samples and laboratory matrix spikes.
S = Screening; Precision is determined by use of field duplicates, laboratory duplicates, and laboratory matrix spike duplicates.
S/D = Screening with 10% Definitive Confirmation;
D = Definitive data
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Table 4
A Comparison of CLP Detection Limits with Superfund Chemical Data Matrix Benchmarks and ICP / Mass Spec Limits for ULSA Request
Sorted by Alphabetical Order
Substance Name
CLP Limits
ICP/MS Limits
Ground Water Pathway
Drinking Water
Food Chain
Environmental
Soil Pathway
Water
me/L
Soil
me/ke
Water mg/1
Soil
me/lcfl
MCL/MCLG
mtrfl.
Reference
Dose
Screening
Cone.
me/L
Cancer Risk
Screen Cone
mp/L
MCL/MCLG
me/L
Reference
Dose
Screening
Cone.
me/L
Cancer Risk
Screen Cone
me/L
Reference
Dose
Screening
Cone,
me/ke
Cancer Risk
Screen Cone
me/ke
AWQC/
AALAC
Freshwater
ma/L
AWQC/
AALAC
Saitwater
me/L
Reference
Dose
Screening
Cone.
Cancer Risk Screen Cone
Inorganic
Aluminum
2.0E-01
4.0E+01
5.0E-03
5.0E-01
Antimony
6.0E-02
1.2E+01
1.0E-04
1.0E-02
6.0E-03
1.5E-02
6.0E-03
1.5E-02
5.4E-01
3.1E+01
Arsenic
1.0E-02
2.0E+00
5.0E-04
5.0E-02
5.0E-02
1.1E-02
UUIHIHIHUIUII
5.0E-02
1.1E-02
HBBEH
4. ir-oi
msms
2.3E+01
4.3E-01
Barium
2.0E-01
4.0E+01
1.0E-04
1.0E-02
2.0E+00
2.6E+00
2.0E+00
2.6E+00
9.5E+01
5.5E+03
Beryllium
5.0E-03
1.0E+00
1.0E-04
1.0E-02
ฆt.oi.-in
1.8E-01
_
man
4 i,i-m
1.8E-01
_
ฆmm
6.8E+00
mam
3.9E+02
1.5E-0I
Cadmium
5.0E-03
1.0E+00
1.0E-04
1.0E-02
5.0E-03
1.8E-02
5.0E-03
1.8E-02
6.8F.-0I
1 11'-03
1.1E-03
3.9E+01
Calcium
5.0E+00j
1.0E+03
5.0E-03
5.0E-01
Chromium
1.0E-02
2.0E+00
1.0E-04
1.0E-02
1.0E-01
1.0E-01
Cobalt
5.0E-02
1.0E+01
1.0E-04
1.0E-02
Copper
2.5E-02
5.0E+00
1.0E-04
1.0E-02
1.3E+00
1.3E+00
1.2L-0J.
1.2E-02
Iron
1.0E-01
2.0E+01
5.0E-03
5.0E-01
1.0E+00
1.0E+00
Lead
3.0E-03
6.0E-01
1.0E-04
1.0E-02
1.5E-02
1.5E-02
3.2E-03
3.2E-03
Magnesium
5.0E+00
1.0E+03
5.0E-03
5.0E-01
Manganese
1.5E-02
3.0E+00
1.0E-04
1.0E-02
1.8E-01
1.8E-01
6.8E+00
3.9E+02
Mercury *
2.0E-04
4.0E-02
2.0E-04
2.0E-02
2.0E-03
1.1E-02
2.0E-03
1.1E-02
4.1E-01
2.3E+01
Molybdenum
na
na
1.0E-04
1.0E-02
1.8E-01
1 81-01
J..SF-1'J
Nickel
4.0E-02
8.0E+00
1.0E-04
1.0E-02
7.3E-01
1.6E+03
Potassium
5.0E+00
1.0E+03
5.0E-03
5.0E-01
Selenium
5.0E-03
1.0E+00
1.0E-03
1.0E-01
5.0E-03
l.SE-01
5.0E-02
1.8E-01
6.8E+00
5.0E-03
5.0E-03
3.9E+02
Silver
1.0E-02
2.0E+00
1.0E-04
1.0E-02
1.8E-01
1.8E-01
6.8E+00
2 3E-ป.S
2.3I-.-H!
3.9E+02
Sodium
5.0E+00
1.0E+03
5.0E-03
5.0E-01
Thallium
1.0E-02
2.0E+00
1.0E-04
1.0E-02
5.0E-04
5 01.-0-1
Vanadium
5.0E-02
1.0E+01
1.0E-04
1.0E-02
2.6E-01
2.6E-01
9.5E+00
5.5E+02
Zinc
2.0E-02
4.0E+00
5.0E-04
5.0E-02
1.1E+01
1.1E+01
4.1E+02
1.2E-01
1.2E-01
2.3E+04
Cyanide
1.0E-02
2.0E+00
2.0E-01
7.3E-01
2.0E-01
7.3E-01
2.7E+01
5.2E-03
5.2E-03
1.6E+03
Lower than CLP RAS DL
m Lower than normal ICP/MS DL
* - Mercury limits are cold vapor atomic absorption limits, not ICP/MS.
-------
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Table 4
A Comparison of CLP Detection Limits with Superfund Chemical Data Matrix Benchmarks 1
Sorted by Alphabetical Order |
Substance Name
| CLP Limits
| Ground Water Pathway
| Drinking Water
| Food Chain
j Environmental
| Soil Pathway |
Low Cone
SOW
Water
hb/L
Soil
MCL/MCLG
Reference
Dose
Screening
Cone.
Cancer Risk
Screen Cone
MCL/MCL
0
Reference
Dose
Screening
Cone.
Cancer Risk
Screen Cone
Reference
Dose
Saeening
Cone.
Cancer Risk
Screen Cone
AWQC/
AALAC
Freshwater
AWQC/
AALAC
Saltwater
Reference
Dose
Screening
Cone.
ue/ke
Cancer Risk Screen Cone
. ue/ke
| Volatile Organic |
Chloromethane
1.0E+00
1.0E+01
l.OE+Ol
I 6.6E+00
| 6.6E+00
2.4E+02
4.9E+04
Bromomethane
1.0E+00
1.0E+01
l.OE+Ol
5.1E+OI
5.1E+01
.
1.9E+03
1.1E+05
Vinyl chloride
I.0E+00
1.0E+01
l.OE+Ol
2.0E+00
2 OE+OO
Pflgfrlgf
3.4E+02
Chloroethane
l.OE+OO
1.0E+01
l.OE+Ol
Methylene chloride
2.0E+00
l.OE+Ol
l.OE+Ol
5 0E+00
2.2E+03
1.1E+01
5.0E+00
2.2E+03
1.1E+01
8.1E+02
4.2E+02
4.7E+06
8.5E+04
Acetone
5.0E+00
1.0E+01
l.OE+Ol
3.7E+03
3.7E+03
1.4E+05
7.8E+06
Carbon disulfide
1.0E+00
l.OE+Ol
l.OE+Ol
3.7E+03
3.7E+03
1.4E+05
7.8E+06
Dichloroethene, 1,1-
1.0E+00
l.OE+Ol
l.OE+Ol
7.0E+00
3.3E+02
MMMI
7.0E+00
3.3E+02 fpiipipil
I.2E+04
7.0E+05
1.1E+03
Dichloroethane, 1,1-
1.OE+OO
l.OE+Ol
l.OE+Ol
3.7E+03
3.7E+03
1.4E+05
7.8E+06
Dichloroethene, 1,2- cis
1.0E+00
l.OE+Ol
l.OE+Ol
7.8E+02
Dichloroethene, 1,2-tran
1.0E+00
l.OE+Ol
l.OE+Ol
1.6E+03
Chloroform
1.0E+Q0
l.OE+Ol
l.OE+Ol
1.0E+02
3.7E+02
1.4E+01
1.0E+02
3.7E+02
1.4E+01
1.4E+02
5.2E+02
7.8E+05
1.0E+05
Dichloroethane, 1,2-
1.0E+00
l.OE+Ol
l.OE+Ol
5.0E+00
r ฆ* fiB+00
3.5E+01
7.0E+03
2-Butanone
5.0E+00
l.OE+Ol
l.OE+Ol
2.2E+04
2.2E+04
8.1E+05
4.7E+07
Bromochloromethane
1.0E+00
na
na
Trichloroethane, 1,1,1-
1.0E+00
l.OE+Ol
l.OE+Ol
2.0E+02
Carbon tetrachloride
1.0E+00
l.OE+Ol
l.OE+Ol
5 0E+00
2.6E+01
5.0E+00
2.6E+01
n
9.5E+02
2.4E+01
5.5E+04
4.9E+03
Bromodichloromethane
l.OE+OO
l.OE+Ol
l.OE+Ol
1.0E+02
7.3E+02
1.0E+02
7.3E+02
1 4E+00
2.7E+04
5.1E+01
1.6E+06
1.0E+04
Dichloropropane, 1,2-
1.OE+OO
l.OE+Ol
l.OE+Ol
5.0E+00
1.3E+00
5.0E+00
1.3E+00
4.6E+01
9.4E+03
Dichloropropene, cis-1,3-
l.OE+OO
l.OE+Ol
l.OE+Ol
Trichloroethene
l.OE+OO
l.OE+Ol
l.OE+Ol
ฆ 5.0E+00
7 7E+00
5 OE+OO
7 7E+00
2.9E+02
5.8E+04
Dibromochloromethane
l.OE+OO
l.OE+Ol
l.OE+Ol
6.0E+01
7.3E+02
l.OE+OO
6.0E+01
7.3E+02
l.OE+OO
2.7E+04
3.8E+01
1.6E+06
7.6E+03
Trichloroethane, 1,1,2-
1.1E+01
l.OE+Ol
l.OE+Ol
3.0H+00
1.5E+02
1.5E+00
3.0E+00
1.5E+02
1.5E+00
5.4E+03
5.5E+01
3.1E+05
1.1E+04
Benzene
l.OE+OO
l.OE+Ol
l.OE+Ol
5.0E+ 00
2.9E 100
5.0E-IO0
2.9E+00
1.1E+02
2.2E+04
Dichloropropene, trans-1,
31 .OE+OO
l.OE+Ol
l.OE+Ol
Bromoform
l.OE+OO
l.OE+Ol
l.OE+Ol
1.0E+O2
7.3E+02
1.1E+01
1.0E+02
7.3E+02
1.1E+01
2.7E+02
4.0E+02
1.6E+06
8.1E+04
4-Methyl-2-pentanone
5.0E+00
l.OE+Ol
l.OE+Ol
2.9E+03
2.9E+03
1.1E+05
6.3E+06
Hexanone, 2-
5.0E+00
l.OE+Ol
l.OE+Ol
Tetrachloroethene
l.OE+OO
l.OE+Ol
l.OE+Ol
5.0E+00
3.7E+02
ฃfc5E+0Q>
3.7E+02
)
1.4E+04
6.1E+01
|
7.8E+05
1.2E+04
Tetrachloroethane 1,1,2,2
l.OE+OO
l.OE+Ol
l.OE+Ol
. |
4 ilrOM
1.6E+01
3.2E+03
1,2-Dibromoethane
l.OE+OO
na
na
smmmmmm
1 OTlrOSf
7.5E+00
Toluene
l.OE+OO
l.OE+Ol
: i.OE+oi
1.0E+03
7.3E+03
1.0E+03
7.3E+03
2.7E+05
1.6E+07
Chlorobenzene
l.OE+OO
I.OE+OI
; l.OE+Ol
1.0E+02
7.3E+02
1.0E+02
7.3E+03
2.7E+04
1.6E+06
Ethyl benzene
l.OE+OO
l.OE+Ol
l.OE+Ol
7.0E+02
3.7E+03
7.0E+02
3.7E+03
1.4E+05
7.8E+06
Styrene
l.OE+OO
l.OE+Ol
l.OE+Ol
1.0E+02
7.3E+03
1.0E+02
7.3E+03
2.7E+05
1.4E+07
Xylenes (total)
l.OE+OO
l.OE+Ol
l.OE+Ol
1,3-Dichlorobenzene
l.OE+OO
na
na
6.0E+02
1,4-Dichlorobenzene
l.OE+OO
na
na
7.5E+01
3 6E+00
7.5E+01
3.6E+00
1.3E+02
2.7E+04
1,2-Dichlorobenzene
1.0E+00
na
na
6.0E+02
3.3E+03
3.3E+03
1.2E+05
7.0E+O6
1,2-Dibromo-3-ch!oropr
ooane
l.OE+OO
na
na
7SM-
1 M
IM
: ฆ
4.6E+02
CLP multi-media SOW limits are not low enough.
CLP low concentration limits are not low enough.
This table assists in determining whether CLP labs can provide adequate DL's.
It is subject to update as risk-based benchmarks are updated, and as CLP contracts are re-negotiated.
-------
-------
Tabic 4
A Comparison of CLP Detection Limits with Superfund Chemical Data Matrix Benchmarks
Sorted by Alphabetical Order
Substance Name
CLP Limits
Groundwater Pathway
Drinking Water
Food Chain
Environmental
Soil Pathway
Low Cone
SOW
Water
Limits
Water
Soil
MCL/MCLG
Reference
Dose
Screening
Cone.
Cancer Bisk
Screen Cone
MCL/MCL
G
Reference
Dose
Screening
Cone.
Cancer Risk
Screen Cone
Reference
Dose
Screening
Cone.
Cancer Risk
Screen Cone
AWQC/
AALAC
Freshwater
AWQC/
AALAC
Saltwater
Reference
Dose
Screening
Cone.
Cancer Risk Screen Cone
Semivolatile Organic
Acenaphthene
5.0E+00
1.0E+01
3.3E+02
2.2E+03
2.2E+03
8.1E+04
4.7E+06
Dinitrophenol, 2,4-
2.0E+01
2.5E+01
8.3E+02
7.3E+01
7.3E+01
2.7E+03
1.6E+05
Nitrophenol, 4-
2.0E+CI
2.5E+01
8.3E+02
Dibenzofuran
5.0E+00
l.OE+Ol
3.3E+02
Dim'trotoluene, 2,4-
5.OE+C0
I.0E+01
3.3E+02
7.3E+01
7.3E+01
2.7E+04
1.6E+05
Diethvl phthalate
5.0E+00
l.OE+Ol
3.3E+02
2.9E+04
2.9E+04
1.1E+06
6.3E+07
Chlorophenyl-pheny] etht
5.0E+00
I.0E+01
3.3E+02
Flourene
5.0E+00
l.OE+Ol
3.3E+02
I.5E+03
1.5E+03
5.4E+04
3.1E+06
4-Nitroaniline
2.0E+01
2.5E+01
8.3E+02
1.1E+05
Dinitro-2-methvlephenol,
2.0E+01
2.5E+01
8.3E+02
Nitrosodiphenylamine, N
5.0E+00
l.OE+Ol
3.3E+02
Bromophenyl-phenylethe
S.OE+OO
l.OE+OI
3.3E+02
Hexachlorobenzene
5.0E+00
l.OE+Ol
3.3E+02
2.9E+01
2.9E+01
WBSm
1.1E+03
2.0E+0Q
6.3E+04
4.0E+02
Pentachlorophenol
5.0E+00
2.5E+01
8.3E+02
1.1E+03
1.1E+03
4.IE+04
2.6E+01
1.3E+01
1.3E+01
2.3E+06
5.3E+03
Phenanthrene
5.0E+00
l.OE+Ol
3.3E+02
Anthracene
5.0E+00
l.OE+Ol
3.3E+02
1.1E+01
ฆ1
l.IE+04
4.IE+05
2.3E+07
Carbazole
na
l.OE+Ol
3.3E+02
t 6EH)2
3.2E+04
Di-n-buty! phthalate
5.0E+00
l.OE+Ol
3.3E+02
3.7E+03
3.7E+03
1.4E+05
7.8E+06
Flouranihene
5.0E+00
l.OE+Ol
3.3E+02
1.5E+03
1.5E+03
5.4E+04
3.1E+06
Pyrene
5.0E+00
l.OE+Ol
3.3E+02
1.1E+03
1.1E+03
4.1E+04
2.3E+06
Butylbenzyt phthalate
5.0E+00
l.OE+OI
3.3E+02
7.3E+03
7.3E+03
2.7E+05
1.6E+07
Dichlorobenzidine, 3,3-
5.0E+00
l.OE+OI
3.3E+02
^OE+OOI
1.4E+03
Benz(a)anthracene
5.0E+00
l.OE+Ol
3.3E+02
i4i3EฑQ0
8.8E+02
Chrysene
5.0E+00
l.OE+Ol
3.3E+02
1.2E+01
1.2E+01
4.3E+02
8.8E+04
Bis(2-ethylhexyl) phthala
5.0E+00
l.OE+Ol
3.3E+02
6.0E+00
7.3E+02
61E+00
6 3E+00
7.3E+02
>2^7E+02:
23E+02
I.6E+06
4.6E+04
Di-a-octyl phthalate
5.0E+00
l.OE+Ol
3.3E+02
7.3E+02
7.3E+02
2.7E+04
1.6E+06
Benzo(b)flouranthene
5.0E+00
l.OE+Ol
3.3E+02
ฆ
4 3E+00
8.8E+02
Bcnzo(k)flouranthene
5.0E+00
l.OE+Ol
3.3E+02
4 3E+01
8.8E+03
Benzo(a)pyrene
5.0E+00
l.OE+Ol
3.3E+02
mt
4 0E-01
8.8E+01
Ideno( 1,2,3-cd)pyrene
5.0E+00
l.OE+Ol
3.3E+02
8.8E+02
Dibenz(a,h)anthracene
5.0E-HJ0
l.OE+Ol
3.3E+02
4 3E-01
8.8E+01
Benzo(fi,hTi)perylene
5.0E+00
l.OE+Ol
3.3E+02
CLP low concentration SOW limits are not low enough
CLP multi-media SOW limits are not low enough
-------
-------
Table 4
A Comparison of CLP Detection Limits with Superfund Chemical Data Matrix Benchmarks
Sorted by Alphabetical Order
Substance Name
CLP Limits
Ground Water Pathway
Drinking Water
Food Chain
Environmental
Soil Pathway
Low Cone
SOW
Water
Limits
Water
Soil
MCL/MCLG
Reference
Dose
Screening
Cone.
Cancer Risk
Screen Cone
MCL/MCL
G
Reference
Dose
Screening
Cone.
Cancer Risk
Screes Cone
Reference
Dose
Screening
Cone.
Cancer Risk
Screen Cone
AWQC/
AALAC
Freshwater
AWQC/
AALAC
Saltwater
Reference
Dose
Screening
Cone.
Cancer Risk Screen Cone
Semivolatile Organic
Phenol
5.0E+00
I.0E+01
3.3E+02
2.2E+04
2.2E+03
8.1E+05
4.7E+07
Bis(2-chloroethyl)ether
5.0E+00
1.0E+01
3.3E+02
5.8E+02
Chlorophenol,2-
5.0E+00
1.0E+01
3.3E+02
1.8E+02
1.8E+02
6.8E+03
3.9E+05
Dichlorobenzene, 1,3-
na
1.0E+01
3.3E+02
6.0E+02
Dichlorobenzene, 1,4-
na
1.0E+01
3.3E+02
7.5E+01
7.5E+01
E+02
2.7E+04
Dichlorobenzene, 1,2-
na
1.0E+01
3.3E+02
6.0E+02
3.3E+03
6.0E-01
3.3E+03
1.2E+05
7.0E+06
2-Methylphenol
5.0E+00
1.0E+01
3.3E+02
1.8E+03
lftlE+00:
1.8E+03
6 E+OO
6.8E+04
3.9E+06
2,2-Oxybis(l-Chloroprop
t5.0E+00
l.OE+OI
3.3E+02
1.5E+03
1.5E+03
5.4E+04
4JE+0U
3.0E+06
9.1E+03
4-MethyIphenol
5.0E+00
1.0E+01
3.3E+02
1.8E+02
1.8E+02
6.8E+03
3.9E+05
N-nitro-di-n-propylamtne
5.0E+00
1.0E+01
3.3E+02
f4aE^Jw
9.1E+01
Hexachlorocthane
5.0E+00
l.OE+OI
3.3E+02
3.7E+01
3.7E+0I
1.4E+03
: "1 * t>
7.8E+04
4.6E+04
Nitrobenzene
5.0E+00
I.OE+Ol
3.3E+02
Isophorone
5.0E+00
1.0E+0I
3.3E+02
7.3E+03
9.0E+0I
7.3E+03
9.0E+0I
2.7E+05
3.3E+03
I.6E+07
6.7E+05
Nitrophenoi, 2-
5.0E+00
1.0E+01
3.3E+02
Dimethvl phenol, 2,4-
5.0E+00
I.OE+Oi
3.3E+02
7.3E+02
7.3E+02
2.7E+04
I.6E+06
Bis(2-chloroethoxv)meth
5.0E+00
I.OE+Oi
3.3E+02
Dichlorophenol, 2,4-
5.0E+00
I.OE+OI
3.3E+02
1.0E+02
1.1E+02
4.1E+03
2.3E+05
Trichlorlobenzene, 1,2,4-
5.0E+00
l.OE+OI
3.3E+02
7.0E+01
3.7E+02
7.0E-02
3.7E+02
1.4E+04
7.8E+05
Napthalene
5.0E+00
I.OE+OI
3.3E+02
Chloroaniline, p-
5.0E+00
l.OE+OI
3.3E+02
I.5E+02
1.5E+02
5.4E+03
3.1E+05
Hexachlorobutadiene
5.0E+00
l.OE+OI
3.3E+02
;7;3E+00
2.7E+02
^OE+Ollt
1.6E+04
8.2E+03
Chloro-3-methylpheno!,4
5.0E+00
l.OE+OI
3.3E+02
7.3E+04
7.3E+04
2.7E+06
1.6E+08
Melhylnapthalene, 2-
5.0E+00
1.0E+01
3.3E+02
Hexachlorocyclopentadie
5.0E+00
l.OE+OI
3.3E+02
5.0E+0I
2.6E+02
5.0E+01
2.6E+02
9.5E+03
5.5E+05
Trichlorophenol, 2,4,6-
5.0E+00
1.0E+01
3.3E+02
7E+00
;j7i7E+00X
29E 02
5.8E+04
Trichlorophenol, 2,4,5-
2.0E+01
2.5E+01
8.3E+02
3.7E+03
3.7E+03
1.4E+04
7.8E+06
Chloronapthalene, 2-
5.0E+00
l.OE+OI
3.3E+02
2.9E+03
2.9E+03
1.1E+05
6.3E+06
Nitroaliline, 2-
2.0E+01
2.5E+OI
8.3E+02
Dimethyl phthalate
5.0E+00
l.OE+OI
3.3E+02
3.7E+05
3.7E+05
I.4E+07
7.8E+07
Acenaphthylene
5.0E+00
1.0E+01
3.3E+02
Dinitrotoluene, 2,6-
5.0E+00
l.OE+OI
3.3E+02
3.7E+01
3.7E+01
I.4E+03
7.8E+04
Nitroaliline, 3-
2.0E+01
2.5E+01
8.3E+02
-------
-------
Table 4
CLP multi-media RAS limits are not low enough
CLP low concentration limits are not low enough
-------
-------
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
COLORADO DEPARTMENT OF PUBLIC HEALTH
AND ENVIRONMENT
HAZARDOUS MATERIALS AND WASTE MANAGEMENT DIVISION
- QUALITY ASSURANCE PROJECT PLAN
APPENDIX B
STANDARD OPERATING PROCEDURES
CONTENTS
General Field Operation
Sample Containers, Preservation and Maximum Holding Times
Chain of Custody
Sample Identification, Labeling, and Packaging
Sample Location documentation
Use and Maintenance of Field Log Books
Hazardous Waste Categorization
Investigation Derived Waste
Monitor Well Installation
Monitor Well Development
Equipment Decontamination
Groundwater Sampling
Groundwater Sampling for Low Flow Purge
Water Sample Field Measurements
Flow Measurements
Surface and Shallow Depth Soil Sampling
Sediment Sampling
Surface Water Sampling
Soil Gas Sampling
Drum and Container Sampling
Tank Sampling
Aquifer Slug Testing
Aquifer Pump Testing
Geologic Borehole Logging
Residential Dust Sampling
Chip, Wipe and Sweep Sampling
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 1
Revision No.: 0
Date: 01/2000
Page 1 of9
STANDARD OPERATING PROCEDURE - 1
GENERAL FIELD OPERATION
1.0 PURPOSE
This procedure outlines the general field organization as well as the field structure of sample collection,
sample identification, record keeping, field measurements, and data collection. These guidelines are followed
to ensure that the activities used to document sampling and field operations provide standardized background
information and identifications. Site-specific deviations from the methods presented herein must be approved
by the Project Leader (PL) and Quality Assurance Manager (QAM).
2.0 DEFINITIONS AND ABBREVIATIONS
2.1 Definitions
Project Plans: Includes all documents or plans related to an individual site. Project Plans include
the Health and Safety Plan, Sampling Plan, and others.
2.2 Abbreviations
ASC Analytical Services Coordinator
EM Equipment Manager
PL Project Leader
PPs Project Plans
QA Quality Assurance
QAC Quality Assurance Coordinator
QAM Quality Assurance Manager
QAO Quality Assurance Officer
QC Quality Control
SHSC Site Health and Safety Coordinator
SAM Site Assessment Manager (EPA employee)
TDMT Technical Data Management Team
SOP Standard Operating Procedures
3.0 RESPONSIBILITIES
The PL is the primary point of contact with the SAM or CDPHE Project Manager and, in some cases, the role
of PL and CDPHE Project Manager may be filled by one person. The CDPHE Proj ect Manager, when onsite,
has the ultimate responsibility for decisions concerning the project/site and if working in conjunction with
EPA, may consult the SAM on decision critical matters. If the CDPHE Project Manager or SAM is not on
site, the PL has ultimate responsibility for project/site decisions. The PL is responsible for development and
completion of the Sampling Quality Assurance/Quality Control (QA/QC) Plan, project team organization,
I:\QAPP\SOP\SOP Ol.wpd
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 1
Revision No.: 0
Date: 01/2000
Page 2 of9
ensuring that appropriate sampling, testing and analysis procedures are followed; coordinating subcontracting
and procurement activities; and reporting to the CDPHE Project Manager or SAM on project progress. The
CDPHE Project Manager or SAM is responsible for all public relations efforts.
The PL interacts with the field team members to obtain appropriate field equipment, oversee the
implementation of the Project Plans (PPs) in the field, and interacts with the OSC on problems relating to
instrumentation, sampling, and field methodologies. The PL oversees all equipment calibration and
maintenance in the field, and ensures that decontamination procedures are correctly instituted in the field.
The PL reviews and signs all field forms before they are routed to the Technical Data Management Team
(TDMT), and also assists the project Quality Assurance Coordinator (QAC) in improving existing field
methods and developing new methods when necessary.
The QAC ensures the implementation of all QA program requirements for the project. The QAC informs
the PL when new or improved technical and QA procedures are needed; provides QA indoctrination and
training to project staff; and interacts with the QAM and PL on technical problems related to methods and
instrumentation. The QAM ensures that data collection activities are consistent with the information
requirements and that data are correctly and completely reported.
The Analytical Services Coordinator (ASC) ensures that the proper sample containers are sent to the field.
The ASC maintains close contact with the PL regarding the number of samples and types of analyses to be
preformed. The information that the ASC needs pertaining to planned and altered sample shipments is
contained in CDPHE Standard Operating Procedure (SOP) 3, Chain of Custody.
The designated Site Health and Safety Coordinator (SHSC) or the PL is responsible for writing the Site
Health and Safety Plan prior to mobilization, conducting daily on-site safety meetings, and ensuring project
personnel are in compliance with health and safety protocols. The SAM is not required to be in compliance
with CDPHE Health and Safety protocols. CDPHE subcontractors will abide by guidelines set forth in the
Site Health and Safety Plan unless they opt not to follow the guidelines. If this option is exercised,an
alternative Site Health and Safety Plan will be prepared by the respective subcontractor and subsequently
reviewed for approval by the SHSC. Instances under these options will be dealt on by a case by case basis.
The SHSC will ensure that proj ect personnel are equipped with proper safety equipment. The SHSC interacts
with the PL on environmental monitoring programs and decontamination processes.
-Field personnel are responsible for performing site duties as instructed by the PL. The PL is also responsible
for collecting and organizing the field data entry forms (Exhibits) and reviewing SOPs prior to performing
site activities.
4.0 PROCEDURE
4.1 Mobilization/Demobilization
The PL will write applicable PPs, if required, and have them approved by the CDPHE Project
Manager or SAM. The PL will then assign personnel to review the plans and field equipment
checklist (provided in Exhibit 1-1). Specific items required for field activities will be identified and
acquired.
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 1
Revision No.: 0
Date: 01/2000
Page 3 of9
All equipment to be used will be checked by the PL to verify that it is operational and calibrated
before leaving the program support office. Calibration will also be performed, as directed by the PL,
when the equipment reaches the site.
The PL will obtain copies of the appropriate SOPs and PPs that will be taken into the field. SOPs
brought to the field will contain current versions of procedures and respective exhibits used for the
applicable field method. These SOPs will be revised and updated by appropriate staff members as
needed.
Upon return from the site, all equipment will returned clean and orderly to the equipment room. If
any problems occurred on site with any equipment, the problems should be noted in detail in the field
log book and any applicable field form (if used). This information will be written down in a note or
memo format and attached to the equipment in question. Defective equipment should be repaired as
soon as field personnel identify a problem. Immediate repair will assist future PLs with site
preparations.
4.2 Shipping
If sensitive field equipment is to be shipped to the site, proper care must be taken to ensure that
damage will not be incurred enroute, including the packaging of individual items in separate
containers filled with protective packaging material (e.g., foam pellets). If possible, equipment with
carrying cases will be packed in the respective case and placed inside a foam pellet-filled container.
Non-sensitive field equipment can be combined in protective pellet-filled boxes.
All boxes containing equipment shall be labeled with the following items:
Receiving company name, address and telephone;
Attention (person receiving items in field);
Return company name, address and telephone; and
Return attention.
4.3 Serialization
All non-disposable equipment purchased will be permanently labeled with serial numbers. Any
equipment purchased by an outside agency for use on a project will be tagged with the agency serial
number.
A permanent inventory of equipment will be maintained, and will include at a minimum: serial
numbers, types of equipment, initial costs, service records, and warranty information.
All field forms and field log books will be kept in the project files when returned from the field. Log
books will be assigned to project personnel for the duration of the field activities.
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Procedure No. 1
Revision No.: 0
Date: 01/2000
Page 4 of 9
4.4 Field Organization
4.4.1 Chain-of-Command
Standard Operating Procedures
Colorado Department of
Public Health and Environment
Chain-of-Command protocols will be defined by the CDPHE Quality Management Plan and
implemented by the PL. These protocols will be strictly followed while performing field
tasks. All decisions concerning sampling, equipment problems and changes in strategy will
be made by the CDPHE Project Manager and/or the PL or an approved appointee. Public
relations problems will be addressed by the CDPHE Project Manager or SAM only. The PL
or an approved designee shall conduct a daily "tailgate meeting" prior to field activities,
during which individual roles will be delineated and safety issues discussed.
4.4.2 Field Documentation
All project activities will be recorded each day in the field log book. These methods are
outlined in CDPHE SOP 6, Use and Maintenance of Field Log Books. On occasion, non-
routine field activities will be recorded on special field forms if the CDPHE Quality
Assurance Officer (QAO) and PL approve.
4.4.3 Sampling Organization
The PL shall ensure that the sampling design, outlined in the applicable PPs and TSOPs, is
followed during all phases of sampling activities at the site. For each sampling activity, field
personnel shall record the information required by the applicable SOPs on the Exhibits
provided.
Survey personnel shall identify and locate the monitoring and sampling stations described
in the applicable PPs. Benchmarks located on the site and nearby shall be located and used
as permanent reference markers. All sample locations shall be clearly marked, labeled and
photographed according to the methods outlined in CDPHE SOP 5, Sample Location
Documentation.
4.5 Review
The PL or an approved designee shall check field log books, daily logs, and all other documents
(Exhibits) that result from field operations for completeness and accuracy. Any discrepancies on
these documents will be noted and returned to the originator for correction. The reviewer will
acknowledge that review comments have been incorporated by signing and dating the applicable
reviewed documents.
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 1
Revision No.: 0
Date: 01/2000
Page 5 of9
5.0 REFERENCES
CPDHE. 2000. Standard Operating Procedure 3, "Chain of Custody." Standard Operating Procedures.
CDPHE. 2000. Standard Operating Procedure 5, "Sample Location Documentation." Standard Operating
Procedures.
CDPHE. 2000. Standard Operating Procedure 6, "Use and Maintenance of Field Log Books." Standard
Operating Procedures.
I:\QAPP\SOP\SOP Ol.wpd
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
6.0 EXHIBITS
1-1 Field Equipment Checklist
Procedure No. 1
Revision No.: 0
Date: 01/2000
Page 6 of 9
I:\QAPP\SOP\SOP Ol.wpd
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Standard Operating Procedures Procedure No. 1
Colorado Department of Revision No.: 0
Public Health and Environment Date: 01/2000
Page 7 of9
General
EXHIBIT 1-1
Field Equipment Checklist
1.
Health and Safety Plan
2.
Site base map
3.
Hand calculator
4.
Brunton compass
5.
Personal clothing and equipment
_ 6.
Personal Protective Equipment
7.
Field Sample Plan
Environmental Monitoring Equipment
_ 1.
Shovels
2.
Keys to well caps
3.
pH meter (with calibrating solutions)
__ 4.
pH paper
5.
Thermometer
6.
Conductivity meter (with calibrating solution)
7.
Organic vapor analyzer or photoionization detector with calibration gas
8.
H2S, 02, combustible gas indicator
Sampling Equipment
1.
Tool box with assorted tools (pipe wrenches, screwdrivers, socket set and driver, open and
box end wrenches, hacksaw, hammer, vice grips)
2.
Geologic hammer
3.
Trowel
4.
Stainless steel and/or Teflonฎ spatula
5.
Hand auger
6.
Engineer's tape
7.
Steel tape
8.
Electric water level sounder
9.
Petroleum Interface Probe
10.
Batteries
11.
Bailers (Teflonฎ, stainless steel, acrylic, PYC)
12.
Slug test water displacement tube
13.
Vacuum hand pump
14.
Electric vacuum pump
15.
Displacement hand pump
16.
Mechanical pump (centrifugal, submersible, bladder)
17.
Portable generator
18.
Gasoline for generator
19.
Hose
20.
Calibrated buckets
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Standard Operating Procedures Procedure No. 1
Colorado Department of Revision No.: 0
Public Health and Environment Date: 01/2000
Page 8 of9
EXHIBIT 1-1 (Continued)
21.
Stop watch
22.
Orifice plate or equivalent flow meter
23.
Data logger and pressure transducers
24.
Strip chart recorders
25.
Sample bottles
26.
0.45-micron filters (prepackaged in holders)
27.
Sample preservatives (nitric, hydrochloric, sulfuric acid/sodium hydroxide)
28.
Heavy-duty aluminum foil
29.
Coolers
30.
Ice packs
31.
Large "Ziploc" bags
32.
Heavy-duty garbage bags
33.
Duct tape
34.
Strapping tape
35.
Paper towels
36.
"Bubble" pack, foam pellets, or shredded paper
37.
Verxniculite
38.
Stainless steel bowls
39.
SW scoop
40.
Peristaltic pump/tubing
41.
Sample tags
42.
TSOPs
Decontamination Equipment
1. Non-phosphate detergent (alconox or liquinox)
2. Selected high purity, contaminant free solvents
3. Long-handled brushes
4. Drop cloths (plastic sheeting)
5. Trash container
6. Galvanized tubs or equivalent (e.g., baby pools)
7. Tap Water
8. Contaminant free distilled/deionized water
9. Metal/plastic container for storage and disposal of contaminated wash solutions
10. Pressurized sprayers, H20
11. Pressurized sprayers, solvents
12. Aluminum foil
13. Sample containers
14. Emergency eyewash bottle
Documentation Supplies
1. Field Log Books
2. Daily Drilling Report forms
I:\QAPP\SOP\SOP Ol.wpd
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 1
Revision No.: 0
Date: 01/2000
Page 9 of9
EXHIBIT 1-1 (Continued)
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
Field Borehole Log forms
Monitoring Well Installation Log forms
Well Development Data forms
Groundwater Sampling Log forms
Aquifer Test Data forms
Sample Chain-of-Custody forms
Custody seals
Cooler labels ("This Side Up," "Hazardous Material," "Fragile")
Federal Express/DHL labels
Communication Record forms
Documentation of Change forms
Camera and film
Paper
Pens/pencils
Felt tip markers (indelible ink)
I:\QAPP\SOP\SOP Ol.wpd
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-------
Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 2
Revision No.: 0
Date: 01/2000
Page 1 of 15
- STANDARD OPERATING PROCEDURE 2
SAMPLE CONTAINERS, PRESERVATION,
AND MAXIMUM HOLDING TIMES
1.0 PURPOSE
The purpose of this procedure is to list acceptable sample containers and describe sample preservation and
maximum holding times to be used during all hazardous waste investigations for low-, medium-, or high-
concentration samples of liquid, sediment and sludge matrices.
This procedure provides guidance for routine field operations on environmental projects. Site-specific
deviations from the methods described herein must be approved by the Project Leader (PL), the Colorado
Department of Public Health and Environment. (CDPHE) Quality Assurance Officer, and the Analytical
Services Coordinator.
2.0 DEFINITIONS AND ABBREVIATIONS
2.1 Definitions
Low-Concentration Sample: In general, the contaminant of highest concentration is present at a level
less than 10 parts per million (ppm). Examples include background environmental samples,
perimeter, and lagoon samples.
Medium-Concentration Sample: In general, the contaminant of highest concentration is present at
a level greater than 10 ppm and less than 15 percent by volume (150,000 ppm). Examples include
weathered material.
High-Concentration Sample: In general, at least one contaminant is present at a level greater than
15 percent by volume. Samples from drums and tanks are assumed to be high concentration unless
information indicates otherwise.
Routine Analytical Services (RAS): Analysis for low concentration soil or water samples using
specific methods on a 30- to 45-day turnaround time through the Contract Laboratory Program
Unique Laboratory Sample Analyses (ULSA): Analysis of various matrices using a wide variety of
U.S. Environmental Protection Agency (EPA) approved methods for low, medium, or high
concentration samples on a normal or rush turnaround schedule through the CLP.
2.2 Abbreviations
APHA American Public Health Association
(CLP).
75.50906.00
I:\QAPP\SOP\SOP 02.wpd:bas
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 2
Revision No.: 0
Date: 01/2000
Page 2 of 15
CLP
EPA
HC1
ml
NaOH
NWWA
PL
PPm
PPs
QC
RAS
SAS
ULSA
VOA
Mgl
/j,m
BOD
CDPHE
Biochemical Oxygen Demand
Colorado Department of Public Health and Environment
Contract Laboratory Program
U.S. Environmental Protection Agency
Hydrochloric acid
milliliter
Sodium hydroxide
National Water Well Association
Project Leader
Parts per million
Project Plans
Quality Control
Routine Analytical Services
Special Analytical Services
Unique Laboratory Sample Analyses
Volatile organic analysis
micrograms per liter
micrometer, micron
3.0 RESPONSIBILITIES
Sampling personnel (samplers) are responsible for performing the applicable tasks outlined in this procedure.
The PL or an approved designee is responsible for checking all work performance and verifying that the work
satisfies the applicable tasks required by this procedure. This will be accomplished by reviewing all
documents (Exhibits) and data produced during work performance. All activities and data collected shall be
recorded in the field log book.
4.0 PROCEDURE
The sampling and analysis program for START assignments must comply with the analytical procedures
outlined by the EPA CLP (EPA 1988) or an equivalent procedure acceptable to EPA.
The purpose of sample preservation is to prevent or retard the degradation and modification of chemicals or
to retard biological activity in samples during transit and storage. Efforts to preserve the integrity of the
samples must be initiated as soon as possible after the time of sampling and continue until analyses are
performed. Preservatives must be added to the sample container as soon as possible after the time of sample
collection. The recommended procedure is to take pre-measured volumes of the preservatives in sealed
ampules to the field.
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 2
Revision No.: 0
Date: 01/2000
Page 3 of 15
Complete and unequivocal preservation of samples, domestic sewage, industrial wastes, or natural waters,
is impossible in practice. Regardless of the nature of the sample, complete stability for every constituent is
not likely to be achieved. At best, preservation techniques can retard the chemical and biological changes
that inevitably continue after the sample is removed from the parent source. Degradation of the sample
ceases only if it is preserved at a temperature of absolute zero (-273 ฐC). However, freezing of a sample to
extend hold times is not permitted. Therefore, as a general rule, it is best to analyze the samples as soon as
possible after collection. This is especially true when the analyte concentration is expected to be in the low
microgram per liter Oug/1) range.
Methods of preservation are relatively limited and are intended generally to perform the following:
Retard biological action;
Retard hydrolysis of chemical compounds and complexes;
Reduce volatility of constituents; and
Reduce absorption'effects.
Preservation methods are generally limited to:
pH control;
Chemical addition; and
Refrigeration.
The recommended preservative for various constituents is given in Exhibits 2-2 and 2-3. Preservation
techniques for some analyses requiring more than simple refrigeration or filtering are discussed in Section
4.2. Exhibits 2-2 and 2-3 also provide the estimated volume of sample required for the analysis, the
suggested type of container, and the maximum recommended holding times for samples to be properly
preserved.
When selecting preservation techniques and sample container type, always refer to the guidance
provided in the documentation of the analytical methods to be used.
4.1 Sample Containers
Select sample containers based on the analytical parameters of interest. Use containers made of
materials that are nonreactive. Glass and polyethylene containers are the most commonly accepted,
and both are used when sampling many constituents. When metals are the analytes of interest,
however, polyethylene containers with teflonฎ-lined caps are preferred. When organics are the
analytes of interest, use amber glass containers with Teflonฎ-lined caps.
Refer to Exhibit 2-3 for sample container requirements for common analyses.
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 2
Revision No.: 0
Date: 01/2000
Page 4 of 15
4.2 Sample Preservation
Perform appropriate chemical preservation in the field for various analytical parameters as soon as
possible after the time of sample collection. When appropriate, cool samples after collection and
during shipment. All samples should be kept out of direct sunlight and stored in the dark (e.g., in a
cooler). Regardless of the method of preservation, perform analyses as soon after sampling as is
possible.
In some instances, the optimal method for sample preservation may be inappropriate due to the
restrictions placed on the transport of certain chemicals by shippers. When shipping restrictions
prevent the use of some reagents for sample preservation, use the most appropriate and permissible
technique.
Refer to Exhibit 2-3 for preservation requirements for common analyses.
4.3 MaximumHoIding Time
Complete and unequivocal preservation of a sample for an extended period of time is a practical
impossibility. Regardless of the nature of the sample, complete stability for every constituent is not
likely to be achieved. Maximum holding times are assigned to each analyte and are designed for
quality assurance purposes to minimize degradation effects on the analysis. Therefore, as a rule, it
is better to analyze the sample as soon as possible after collection. This is especially true when low
contaminant concentrations are expected. Suggested maximum holding times for some of the more
common analytes are listed in Exhibits 2-2 and 2-3.
4.4 Review
The Site Manager or an approved designee shall check all sample control documentation to ensure
that the samples, transport, and analysis events have met the criteria outlined in this Standard
Operating Procedure (SOP). Any discrepancies shall be noted and the documentation will be
returned to the originator for correction. The reviewer will acknowledge that corrections have been
incorporated by signing and dating each reviewed document.
5.0 REFERENCE
American Public Health Association (APHA). 1983. "Standard Methods for the Examination of
Water and Wastewater." 14th ed.
U.S. Environmental Protection Agency (EPA)/National Water Well Association (NWWA). 1981.
"Manual of Groundwater Sampling Procedures." EPA/NWWA Series.
U.S. Environmental Protection Agency (EPA). 1983. "Methods forthe Chemical Analysis of Water
and Wastes." EPA-600./4-79-020. March 1983.
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 2
Revision No.: 0
Date: 01/2000
Page 5 of 15
U.S. Environmental Protection Agency (EPA). 1983. "RCRA Permit Writer's Manual:
Groundwater Protection" (40 CFR Part 264, Subpart F), Geotrans Inc., EPA Contract No. 68-01-
6464.
U.S. Environmental Protection Agency (EPA). 1984. Federal Register Part VIII, 40 CFRPart 136,
October 26, 1984.
U.S. Environmental Protection Agency (EPA). 1986. "Test Methods for Evaluating Solid Waste."
SW-846.
U.S. Environmental Protection Agency (EPA). 1988. "Users Guide to the Contract Laboratory
Program." 9240.0-1, December 1988.
6.0 EXHIBITS
Exhibit 2-1 EPA Sample Container Requirements Including Laboratory QC for CLP Analyses
Exhibit 2-2 Preservation Requirements for RAS Analyses
Exhibit 2-3 Recommended Sample Containers, Preservation, and Maximum Holding Times
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Standard Operating Procedures Procedure No. 2
Colorado Department of Revision No.: 0
Public Health and Environment Date: 01/2000
Page 6 of 15
EXHIBIT 2-1
EPA Sample Container
Requirements Including Laboratory QC for CLP Analysis
Suggested Sampling Bottles Including Laboratory QC
VOLATILES
WATER
SAMPLE
2 X 40- ml. Amber Glass Vials
MS/MSD
2 X 40- ml. Amber Glass Vials
SOIL
n
SAMPLE M 1 X 4 - oz. Wide Mouth Glass Jar
MS/MSD
n
1 X 4 - oz. Wide Mouth Glass Jar
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Standard Operating Procedures Procedure No. 2
Colorado Department of Revision No.: 0
Public Health and Environment Date: 01/2000
Page 7 of 15
EXHIBIT 2.1 (continued)
EPA Sample Container
Requirements Including Laboratory QC for CLP Analysis
Suggested Sampling Bottles Including Laboratory QC
EXTRACTABLE ORGANICS
WATER
A
A
SAMPLE
2 x 1-Liter Amber
Glass Bottles
MS/MSD
2 x 1-Liter Amber
Glass Bottles
A
A
SOIL
SAMPLE
1 x 8 oz. WIDE MOUTH
GLASS JAR
MS/MSD
1 x 8 oz. WIDE MOUTH
GLASS JAR
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Standard Operating Procedures Procedure No. 2
Colorado Department of Revision No.: 0
Public Health and Environment Date: 01/2000
Page 8 of 15
EXHIBIT 2.1 (continued)
EPA Sample Container
Requirements Including Laboratory QC for CLP Analysis
Suggested Sampling Bottles Including Laboratory QC
METALS
WATER
TOTAL
SAMPLE
1X1- Liter
Polyethylene Bottle
SPIKE/DUPLICATE
1X1- Liter
Polyethylene Bottle
WATER
DISSOLVED
SAMPLE
1X1- Liter
Polyethylene Bottle
SPIKE/DUPLICATE
1X1- Liter
Polyethylene Bottle
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Standard Operating Procedures Procedure No. 2
Colorado Department of Revision No.: 0
Public Health and Environment Date: 01/2000
Page 9 of 15
EXHIBIT 2.1 (continued)
EPA Sample Container
Requirements Including Laboratory QC for CLP Analysis
Suggested Sampling Bottles Including Laboratory QC
METALS (Cont'd)
SOILS
1x8 oz. GLASS WEDEMOUTH
TOTAL mm JAR
SAMPLE
n
ฆ?
SPIKE/DUPLICATE ~
1 x 8 oz. GLASS WEDEMOUTH
JAR
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Standard Operating Procedures Procedure No. 2
Colorado Department of Revision No.: 0
Public Health and Environment Date: 01/2000
Page 10 of 15
EXHIBIT 2.1 (continued)
EPA Sample Container
Requirements Including Laboratory QC for CLP Analysis
Suggested Sampling Bottles Including Laboratory QC
CYANIDE
WATER
SAMPLE
ฆ?
SPIKE/DUPLICATE
SOIL
1 X1- Liter
Polyethylene Bottle
1 X1- Liter
Polyethylene Bottle
SAMPLE
n
1 x 8 oz. GLASS
WIDEMOUTH JAR
SPIKE/DUPLICATE
1 x 8 oz. GLASS
WIDEMOUTH JAR
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Standard Operating Procedures Procedure No. 2
Colorado Department of Revision No.: 0
Public Health and Environment Date: 01/2000
Page 11 of 15
EXHIBIT 2.1 (continued)
EPA Sample Container
Requirements Including Laboratory QC for CLP Analysis
VOLATILE ORGANIC
SEMIVOLATILE ORGANIC
AND/OR INORGANIC
In Field
In Field
A
Empty 40 ml VOA Vials
ASTM Type
Organic-Free Water
A,
\ J
Full
ASTM Type
Organic-Free Water
Empty
VOLATILE ORGANICS
Trip Blank
I u
Full 40 ml. VOA Vials (no head space)
ASTM Type Organic Free Water
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 2
Revision No.: 0
Date: 01/2000
Page 12 of 15
EXHIBIT 2-2
Preservation Requirements for RAS Analyses
Parameter
Water Samples
Volatiles
Semivolatiles
Pesticides/PCBs
Dissolved Metals
Concentration
Low/Medium
Low/Medium
Low/Medium
Low/Medium
Preservation
Chill to 4ฐC. Samples must be filled to zero headspace
and checked for air bubbles. If acidification causes
bubbling, do not acidify.
Chill to 4ฐC.
Chill to 4 ฐC.
Filter sample through 0.45 micron filter immediately after
sample collection or with in-line filtration when possible.
Acidify to pH <.2 with HN03 after filtration.
Total Metals Low/Medium Includes suspended sediments and particulates. Acidify to
pH <2 with HN03.
Cyanides Low/Medium Preserve all samples with approximately 2 ml. of 10
(Normal) NaOH per liter of sample to pH >12. Chill to
4ฐC.
Treatment for chlorine or other known oxidizing agents
may be necessary. Test a drop of the sample with
potassium iodide-starch test paper (K-I starch test paper).
A blue color indicates the need for treatment. Add
ascorbic acid, a few crystals at a time, until a drop of
sample produces no color on the indicator paper. Then
add an additional 0.6 g. of ascorbic acid for each liter of
sample volume.
Soil Samples
Organics Low/Medium Chill to 4 ฐC.
Metals Low/Medium None.
Cyanide Low/Medium Chill to 4ฐC.
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
EXHIBIT 2-2 (continued)
Analytical and Contractual Holding Times for RAS Analyses
Matrix: Water Soil
Analytical Contractual Analytical Contractual
Analysis Holding Times Holding Times Holding Times Holding Times
YOA
14 days
10 days
14 days
10 days
BNA
7 days
5 days
14 days
10 days
Pest./PCB
7 days
5 days
14 days
10 days
Mercury
28 days
26 days
28 days
26 days
Cyanide
?14 days
12 days
14 days
12 days
Metals
"6 months
35 days
6 months
35 days
Procedure No. 2
Revision No.: 0
Date: 01/2000
Page 13 of 15
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Technical Standard Operating Procedures
URS Operating Services, Inc.
START, Region VIII
Contract No. 68-W5-0031
EXHIBIT 2-3
Recommended Sample Containers, Preservation Maximum and Holding Times*
Species Type
Measurement/ Analysis
Preservative
Holding
Time
Water Sample Volume
and Container Type
Solid Sample Volume
and Container Type
Physical
Properties
Color
Cool, 4ฐC
48 hours
(1) 4 oz polyethylene
N/A
Hardness
HNO, to pH<2 or H,S04 to pH < 2
6 months
(1) 4 oz polyethylene
N/A
PH
None Required
ASAP .
(1) 4 oz polyethylene
(1) 4 oz polyethylene
Residue, Filterable
Cool, 4ฐC
7 days
(1) 16 oz polyethylene
N/A
Residue, Non-Filterable
Cool, 4ฐC
7 days
(1) 16 oz polyethylene
N/A
Residue, Total
Cool, 4ฐC
7 days
(1) 16 oz polyethylene
N/A
Residue, Volatile
Cool, 4ฐC
7 days
(1) 16 oz polyethylene
N/A
Metals
Dissolved
Filter on site, HNO-, to pH<2
6 months 1
(1) liter polyethylene
(I) 8 oz polyethylene
Total
HNO, to pH<2
6 months
(1) liter polyethylene
(1) 8 oz polyethylene
Chromium+6
Cool, 4ฐC
24 hours
(1) 16 oz polyethylene
(1) 4 oz polyethylene
Mercury, Dissolved
Filter, HNO, to pH<2
28 days
(1) liter polyethylene
(1) 8 oz polyethylene
Mercury, Total
HNO, to pH<2
28 days
(1) liter polyethylene
(1) 8 oz polyethylene
Inorganics,
Non-Metals
Alkalinity
Cool, 4ฐC
14 days
(1) 4 oz polyethylene
N/A
BOD
Cool, 4ฐC
48 hours
(1) 16 oz polyethylene
N/A
Bromide
None Required
28 days
(1) 16 oz polyethylene
(1) 8 oz polyethylene
Chloride
None Required
28 days
(1) 4 oz polyethylene
(1) 8 oz polyethylene
COD
Cool, 4ฐC H7S04 to pH<2
28 days
(.1) 4 oz polyethylene
(1) 4 oz polyethylene
Cyanide
Cool, 4ฐC, NaOH to pH>12, 0.6 g ascorbic
acid3
14 days 2
(1) liter polyethylene
(1) 8 oz polyethylene
Fluoride
None Required
28 days
(1) 4 oz polyethylene
(1) 4 oz polyethylene
Nitrogen
Ammonia
Cool, 4ฐC, H7S04 to pH<2
28 days
(1) 4 oz polyethylene
(1) 4 oz polyethylene
Kjeldahl, Total
Cool, 4ฐC, H,S04 to pH<2
28 days
(1) 4 oz polyethylene
(1) 4 oz polyethylene
Nitrate plus Nitrite
Cool, 4ฐC, H,S04 to pH<2
28 days
(1) 4 oz polyethylene
(1) 4 oz polyethylene
Nitrate4
Cool, 4ฐC
48 hours
(1) 4 oz polyethylene
(1) 4 oz polyethylene
Nitrite
Cool, 4ฐC
48 hours
(1) 4 oz polyethylene
(1) 4 oz polyethylene
Oil and Grease
Cool, 4ฐC H,S04 to pH<2
28 days
(2) 1 liter amber glass
(1)8 oz glass jars
Inorganics,
Non-Metals
(continued)
Organic Carbon
Cool, 4ฐC HC1 or H3S04 to pH<2
28 days
(l)4ozamber glass
(1) 4 oz glass jars
Phenolics
Cool, 4ฐC, H2S04 to pH<2
28 days
(2) 1 liter amber glass
(1) 4 oz glass jar
PhrKntinrnq
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Procedure No. 2
Revision No.: 0
Date: 01/2000
Page 14 of 15
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Technical Standard Operating Procedures
URS Operating Services, Inc.
START, Region VIII
Contract No. 68-W5-0031
EXHIBIT 2-3
Recommended Sample Containers, Preservation Maximum and Holding Times*
(continued)
Procedure No. 2
Revision No.: 0
Date: 01/2000
Paee 15 of 15
Species Type /
Measurement/ Analysis
Preservative
Holding
ฆ line
Water Sample Volume
and Container Type
Solid Sample Volume
.Mid Container Type
Ortho-phosphate
Dissolved
Filter on site, Cool, 4ฐC
Cool, 4ฐC
48 hours
28 days
(1) 4 oz polyethylene
(1) 4 oz polyethylene
(1) 8 oz glass jar
(1) 8 oz glass jar
Hydrolyzable
Cool, 4ฐC, H,SO to pH<2
28 days " ^
(1) 4 oz polyethylene
(1) 8 oz glass jar
Total
Cool, 4ฐC, H7S04 to pH<2
28 days
(1) 4 oz polyethylene
(1) 8 oz glass jar
Total Dissolved
H,S04 to pH<2, Filter on site, Cool, 4ฐC
24 hours
(1) 4 oz polyethylene
(1) 8 oz glass jar
Silica
Cool, 4ฐC
28 days
(1) 4 oz polyethylene
(1) 4 oz polyethylene
Sulfate
Cool, 4ฐC
28 days
(1) 4 oz polyethylene
(1) 4 oz polyethylene
Sulfide
Cool, 4ฐC, add 2 ml Zinc Acetate plus
NaOH to pH>9
7 days
(1) 4 oz polyethylene
N/A
Sulfite
1 ml EDTA
ASAP
(1) 4 oz polyethylene
N/A
Organ ics
Dioxin/Furan
Cool, 4ฐC
7 to 14 days
(2) 1 liter amber glass
(1) 8 oz glass jars
Herbicides
Cool, 4ฐC
7 to 14 days
(2) 1 liter amber glass
(1) 8 oz glass jars
Pesticides/PCBs
Cool, 4ฐC
7 to 14 days
(2) 1 liter amber glass
(1) 8 oz glass jars
SVOC
Cool, 4ฐC
7 to 14 days
(2) 1 liter amber glass
(1) 8 oz glass jars
VOC
Cool, 4ฐC
7 to 14 days
(2) 40 ml amber glass
(1) 4 oz glass jars
1 Samples should be filtered on site immediately after collection, then a preservative for dissolved metals should be added.
2 Maximum holding time is 24 hours when sulfide is present. Optionally all samples may be tested with lead acetate paper before the pH adjustment in order to
determine if sulfide is present. If sulfide is present it can be removed by the addition of cadmium nitrate powder until a negative spot test is obtained. The sample
is filtered and then NaOH is added to pH 12.
3 Should only be used in the presence of residual chloride.
4 For samples from non-chlorinated drinking water supplies concentrated H2S04 should be added to lower sample pH to less than 2. The sample should be analyzed
within 14 days after sampling.
* Adapted from EPA-600-4-82-055 "Technical Additions to Methods for Chemical Analysis of Water and Wastes."
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 3
Revision No.: 0
Date: 01/2000
Page 1 of 15
STANDARD OPERATING PROCEDURE - 3
CHAIN OF CUSTODY
1.0 PURPOSE
The purpose of this procedure is to describe the proper chain of custody and tracking methods to be followed
for environmental projects. This procedure outlines the documentation necessary to trace sample possession
and shipment and provides standardized forms to be used in the field for both the U.S. Environmental
Protection Agency (EPA) Contract Laboratory Program (CLP) and for non-CLP laboratories.
This procedure provides guidance for routine field operations. Site-specific deviations from the methods
presented herein must be approved by the Project Leader, the Colorado Department of Public Health and
Environment (CDPHE) Quality Assurance Officer, and the Analytical Services Coordinator.
2.0 DEFINITIONS AND ABBREVIATIONS
2.1 Definitions
Not applicable.
2.2 Abbreviations
3.0 RESPONSIBILITIES
Field personnel (samplers) are responsible for performing the tasks in accordance with this procedure. These
personnel are responsible for the care and custody of the collected samples until the samples are transferred
or dispatched properly. All activities and data collected shall be recorded in the field log book.
ASC
BNA
CLP
CLASS
EPA
I AT A
NEIC
PCBs
RAS
RSCC
SCM
TRs
ULSA
VOCs
Analytical Services Coordinator
Base/neutral/acid
Contract Laboratory Program
Contract Laboratory Analytical Services Support
U.S. Environmental Protection Agency
International Air Transport Association
National Enforcement Investigations Center
Polychlorinated biphenyls
Routine Analytical Services
EPA Regional Sample Control Coordinator
UOS Sample Control Manager
Multi-Sample Traffic Reports/Chain-of-Custody forms
Unique Laboratory Sample Analysis
Volatile organic compounds
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 3
Revision No.: 0
Date: 01/2000
Page 2 of 15
The Project Leader or an approved designee is responsible for checking all work performance and verifying
that the work satisfies the applicable tasks required in this procedure. This will be accomplished by
reviewing all documents (Exhibits) and data produced.
4.0 PROCEDURE
4.1 Introduction
Samples are collected as described in the Project Plans.
Written documentation of sample custody from the time of sample collection through the generation
of data by analysis of that sample is recognized as a vital aspect of an environmental study. Sample
custody consists of three parts: sample collection, laboratory analysis, and final evidence files. The
chain of custody of the physical sample and its corresponding documentation will be maintained
throughout the handling of the sample. All samples will be identified, labeled, logged onto a Chain-
of-Custody form, and recorded in a sample tracking log as a part of the procedure to ensure the
integrity of the resulting data. The record of the physical sample (location and time of sampling)
will be joined with the analytical results through accurate accounting of the sample custody. As
described below, sample custody applies to both field and laboratory operations.
A sample or evidence file is under custody if it is in:
The possession of the sampler/analyst;
The view, after being in the possession of, the sampler/analyst;
The possession of the sampler/analyst and then placed in a secured location; or
A designated secure area.
Waterproof ink will be used unless prohibited by weather conditions. For example, a log book
notation will explain that a pencil was used to fill out the sample tag because the ballpoint pen
would not function in freezing weather.
4.1a Samples and Sample Numbers
The CLP Organic and Inorganic Multi-Sample Traffic Reports/Chain-of-Custody Forms (TRs)
document samples shipped to CLP laboratories. They also enable Contract Laboratory Analytical
Services Support (CLASS) and the Region to track samples and ensure that the samples are shipped
to the appropriate contract laboratory. You must use TRs each time you ship Routine Analytical
Services (RAS) samples to a CLP laboratory under one Case Number and RAS analytical program.
Please note that the TR includes a chain-of-custody record which is located at the bottom of the
form. The form is used as physical evidence of sample custody. According to EPA enforcement
requirements, official custody of samples must be maintained from the time of sample collection
until the time the samples are introduced as evidence in the event of litigation. You are responsible
for the care and custody of the sample until sample shipment.
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 3
Revision No.: 0
Date: 01/2000
Page 3 of 15
CLP sample types are defined by the RAS analytical program. There are currently two
organic/inorganic programs: Low/medium concentration inorganic, low/medium concentration
organic. Low/medium inorganic samples may be analyzed for total metals, dissolved metals,
cyanide or all three. Low/medium organics may be analyzed for volatile organic compounds
(VOCs), base/neutral/acid (BNAs), pesticide/PCBs, or any combination of these.
A CLP sample is one matrix - water or soil - never both. The CLP sample is further defined as
consisting of all the sample aliquots from one station location, for each matrix and RAS analytical
program. For example, let's say you were sampling at Pond A. You plan to collect one water
sample and one soil/sediment sample, each to be analyzed for VOCs, BNAs, pesticide/PCBs, Total
Metals and Cyanide. All the bottles for the organic water analyses at this station - VOC vials, BNA
jars, and Pesticide/PCB jars - make up one organic CLP sample, not three, All of the bottles for
the organic soil analysis makes up the second organic CLP sample. The bottle for inorganic soil
analysis make up the second inorganic CLP sample from Pond A. Even though you have collected
a water sample and a soil sample for five different analyses from Pond A, you've collected four
CLP samples - an organic water sample, an organic soil sample, an inorganic water sample, and an
inorganic soil sample.
The CLP generates unique numbers that must be assigned to each organic and inorganic sample.
The unique sample numbers are printed at the CLASS center on adhesive labels and distributed to
the EPA Regional Sample Control Coordinator (RSCC) as requested. It is your responsibility to
assign this critical sample number correctly and to transcribe it accurately onto the TR.
Organic sample numbers are in the format XX123, and have ten labels per strip: four for
extractables, two for VOCs, and four blank (extra). When bottles have been labeled, DESTROY
THE UNUSED LABELS to prevent duplication of Sample Numbers.
Inorganic sample numbers are in the format MXX123 and have seven labels per strip: two for total
metals, two for cyanide and three blank (extra). Remember that the unique sample number must
only be used once. DESTROY THE UNUSED LABELS.
REMEMBER:
a. TRs must be used for each Case Number with every shipment of samples to each CLP
b. Organic samples and inorganic samples are assigned separate, unique sample numbers.
Each sample consists of all the sample aliquots from a sample station location for analysis
in one of the two analytical programs.
c. A CLP RAS sample will be analyzed as either a water or a soil sample.
d. Prevent accidental duplication of sample numbers by destroying unused labels.
laboratory.
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 3
Revision No.: 0
Date: 01/2000
Page 4 of 15
4.2 Transfer of Custody and Sample Tracking Procedures
Samples will be accompanied by a properly completed Chain-of-Custody form. The Chain-of-
Custody form for the CLP laboratories is shown in Exhibit 3-3. The Chain-of-Custody form for
Unique Laboratory Sample Analysis (ULSA) and non-CLP laboratories is shown in Exhibit 3-1.
The sample numbers, locations, and requested analyses will be listed. When transferring the
possession of samples, the individuals relinquishing and receiving will sign, date, and note the time
on the record. This record documents transfer of custody of samples from the sampler to another
person, to the laboratory, and to or from a secure storage area.
Samples will be properly packaged for shipment and dispatched to the appropriate laboratory for
analysis. Shipping containers will be secured with strapping tape. Custody Seals will be placed
on the shipping container for shipment to the laboratory. Exhibit 3-5 presents the EPA Custody
Seal to be used. The preferred procedure is the attachment of a Custody Seal to the front right and
back left of the cooler. The Custody Seals are covered with clear plastic tape. The cooler is
strapped shut with strapping tape in at least two locations.
If the samples are sent by common carrier, appropriate federal regulations will be followed (i.e.,
IATA). Commercial carriers are not required to sign off on the Chain-of-Custody forms as long
as the Chain-of-Custody forms are sealed inside the sample cooler and the Custody Seals remain
intact.
Exhibit 3-6 describes sample information that must be called in to the Analytical Services
Coordinator (ASC) and/or RSCC.
If a sample or sample label is lost during shipment or if a label was never prepared, the following
procedure applies (EPA/330/9-78-001-R, "NEIC Policies and Procedures"):
"A written statement is prepared detailing how the sample was collected, air
dispatched, or hand transferred to the laboratory. The statement should include all
pertinent information, such as entries in field log books regarding the sample,
whether the sample was in the sample collector's physical possession or in a locked
compartment until hand-transported to the laboratory, etc."
5.0 REVIEW
The sampler is responsible for the care and custody of the samples until they are transferred or properly
dispatched. As few people as possible will handle the samples. The sampler is also responsible for reviewing
(or for having a second sampler review) the custody forms for completeness and accuracy before
relinquishing custody.
The Project Leader or an approved designee must review all field activities to determine whether proper chain
of custody procedures were followed during the field work and to decide if additional samples are required.
I:\QAPP\SOP\SOP 03.wpd
-------
Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 3
Revision No.: 0
Date: 01/2000
Page 5 of 15
The sampler should notify the Project Leader of a breach or irregularity in chain-of-custody procedures. The
Project Leader will notify the EPA Remedial Project Manager.
6.0 REFERENCES
U.S. Environmental Protection Agency (EPA). 1978. "Policies and Procedures." EPA/330/9-78-00/-R.
NEIC.
U.S. Environmental Protection Agency (EPA). 1986. "RCRA Groundwater Monitoring Technical
Enforcement Guidance Document." (OSWER Directive 9950.1). September 1986.
U.S. Environmental Protection Agency (EPA). 1987. "A Compendium of Superfund Field Operations
Methods." EPA/540/P-87/001 (OSWER Directive 9355.01-14). December 1987.
7.0 EXHIBITS
Exhibit 3-1 ULSA and Non-CLP Chain-of-Custody Form
Exhibit 3-2 ULSA and Non-CLP Chain-of-Custody Form Instructions
Exhibit 3-3 CLP RAS Traffic Reports and Chain-of-Custody Record
Exhibit 3-4 CLP RAS Traffic Reports and Chain-of-Custody Record Instructions
Exhibit 3-5 EPA Custody Seal
Exhibit 3-6 Calling in Shipping Information
I:\QAPP\SOP\SOP 03.wpd
-------
Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 3
Revision No.: 0
Date: 01/2000
Page 6 of 15
EXHIBIT 3-1
IJLSA and Non-CLP Chain-of-Custody Form
I:\QAPP\SOP\SOP 03.wpd
-------
Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 3
Revision No.: 0
Date: 01/2000
Page 7 of 15
EXHIBIT 3-2
UOS ULSA and Non-CLP Chain-of-Custody Form Instructions
In some sampling situations, analyses for compounds or concentrations beyond the scope of the CLP RAS
program are required. In these cases, laboratories outside the CLP program must be acquired. This may be
accomplished by using the ULSA or by contracting laboratories privately. All sample packing and Custody
Seal protocols remain the same as for CLP labs.
1. ULSA and non-CLP Labs
For samples that are to be analyzed by ULSA, the following documentation must be used. In some
situations, CDPHE will obtain the labs directly. In these cases, only a Chain-of-Custody form and
Computer generated sample label are required. Complete this documentation as described below.
a.
ULSA and non-CLP Chain-of-Custody Form
Use this form with all ULSA and non-CLP sample shipments. Do not mix organic and
inorganic samples. Chain-of-Custody forms may be obtained from the ASC.
Ship To:
Laboratory name.
Project Name/No.: project name and project number.
Project Leader: Project Leader's name.
Samplers:
Sampler(s) sign here.
Station No.:
Appropriate number (consult project plan).
Date and Time:
Both must be included.
Comp/Grab:
Mark if the sample is a composite (a sample composed of more
than one discrete sample) or a grab (a discrete sample).
Station Location: Use the station location abbreviation that was used in the project
plan to designate sampling locations on the maps and tables.
Number of
Containers:
Write in the number of containers. If necessary, use more
more than one row for each sample. For example, one VOC
sample includes two containers (40 ml vials).
I:\QAPP\SOP\SOP 03.wpd
-------
Procedure No. 3
Revision No.: 0
Date: 01/2000
Page 8 of 15
EXHIBIT 3-2 (continued)
ULSA and non-CLP Chain-of-Custody Form Instructions
Standard Operating Procedures
Colorado Department of
Public Health and Environment
Lines:
Write the analyses requested in the boxes next to "Number of
Containers," and check the boxes below for the analyses requested
on each individual sample.
Remarks:
Signature Boxes:
Remarks:
(bottom right)
Distribution of
Copies:
Write the sample label number on the line corresponding to the
sample. For ULSA samples, write the wire tag number here.
The person who turns the samples over to the shipper signs and
dates in the first "relinquished by" box. This person's signature
must be included in the "Samplers" box. Write in the shipper
identification in the first "Received by" box.
Write the airbill number or other shipping identification.
White - Accompanies sample shipment.
Yellow - ASC, CDPHE
Pink - Retained in the Field Office, or sent to the CDPHE ASC.
I:\QAPP\SOP\SOP 03.wpd
-------
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SEE REVERSE FOR ADDITIONAL STANDARD INSTRUCTIONS
SEE REVERSE FOR PURPOSE CODE DEFINITIONS :
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-------
Standard Operating Procedures Procedure No. 3
Colorado Department of Revision No.: 0
Public Health and Environment Date: 01/2000
Page 11 of 15
EXHIBIT 3-4
CLP RAS Traffic Reports and Chain-of-Custody Record Instructions
Use this form with all RAS or RAS plus ULSA sample CLP shipments. Enclose one form in each cooler
being shipped. Do not mix organic and inorganic samples. Organic and inorganic Traffic Report forms and
Chain-of-Custody Record forms may be obtained from the UOS ASC.
Top Right: A Case Number is assigned to the sampling project when an CLASS coordinator initiates
the lab selection process. The Region VIIIRSCC will notify the CDPHE ASC of the Case
Number by phone. If the lab will be conducting RAS or RAS+ULSA, the ULSA number
must also be recorded on the form.
Box 1: Use a project number. Do not give the actual project name.
Regional information is to be given only by the direction of the ASC.
If sampling is non-Superfund, enter the program name; e.g., RCRA.
Enter the site name, the city, state, and Superfund site spill ID code in the designated spaces.
This information does not go through to the lab's copy.
Box 2: Enter Region VIII, the sampling agency (CDPHE), sampler name (printed), and sampler
signature.
Box 3: Circle the appropriate Superfund codes.
Funding Leads
SF - Superfund
PRP - Potentially Responsible Party
ST - State
FED - Federal
Types of Activities
Pre-Remedial
PA - Preliminary Assessment
SSI - Screening Site Inspection
LSI - Listing Site Inspection
I:\QAPP\SOP\SOP 03.wpd
-------
Procedure No. 3
Revision No.: 0
Date: 01/2000
Page 12 of 15
EXHIBIT 3-4 (continued)
CLP RAS Traffic Reports and Chain-of-Custody Record Instructions
Standard Operating Procedures
Colorado Department of
Public Health and Environment
Remedial
RIFS - Remedial Investigation Feasibility Study
RD - Remedial Design
RA - Remedial Action
O&M - Operations and Maintenance
NPLD - National Priorities List Delete
Removal
CLEM - Classic Emergency
REMA - Removal Assessment
REM - Removal
OIL - Oil Response
UST - Underground Storage Tank Response
Box 4: Enter the date shipped, the carrier code (e.g., F = Federal Express), and the airbill number.
Box 5: Enter the name, address, and contact person of the CLP lab contracted to perform the
analyses. This information is supplied to the sampler by the ASC after the lab contract has
been awarded by CLASS.
COLUMNS
Left edge Carefully transcribe the CLP Sample Number from the printed sample labels column:
provided. A stack of labels will be provided to the samplers by the ASC. Each sample analysis
requires a separate line. All bottle tag numbers for one analysis may be put on one line.
Col. A: Enter the appropriate sample description code from Box 7. Note: Item #6 "Oil," Item #7 "Waste,"
and Item #8 "Other" are for RAS plus ULSA projects only.
.Col. B: Organic - If sample is estimated to be low or medium concentration, enter "L." If sample is high
concentration (comprised of more than 15 percent of a compound), it must be sent to a ULSA lab.
Notify the CDPHE ASC if you need a ULSA lab for high concentration samples.
Inorganic - Enter the estimated concentration. Low level is less than 10 ppm of a single
compound; medium level is between 10 ppm and 15 percent; and high level is above. 15
percent.
REMINDER: Ship medium and high concentration organic and inorganic samples in metal
paint cans.
I:\QAPP\SOP\SOP 03.wpd
-------
Standard Operating Procedures Procedure No. 3
Colorado Department of Revision No.: 0
Public Health and Environment Date: 01/2000
Page 13 of 15
EXHDBIT.3-4 (continued)
CLP RAS Traffic Reports and Chain-of-Custody Record Instructions
Mark if the sample is a composite (a sample composed of more than one discrete sample)
or a grab (a discrete) sample.
Indicate the appropriate preservative code from Box 6.
Check the appropriate RAS analyses requested for each sample.
List EPA Tag numbers corresponding to CLP sample numbers.
Use the station location abbreviation that was used in the Field Sampling Plan to designate
sampling locations on the maps and tables.
Enter the date and military time of sample collection.
Enter the initials of the sampler.
If the sample taken will also be analyzed for organics/inorganics, list the corresponding
sample number from the Organic/Inorganic Traffic Report and Chain-of-Custody Record.
Designation of field QC (e.g., rinsates, duplicates) is optional.
BOTTOM OF PAGE
Indicate if this shipment is a portion or the entire sampling for the case number.
Indicate the total number of forms used for the shipment.
Designate lab QC (by CLP sample number).
Provide signatures of all other samplers involved with this sampling event.
Chain-of-Custody Seal number is not applicable in Region VIII.
The person who turns the samples over to the shipper signs and dates in the first "relinquished by" box. This
.person's signature must be included in a "Samplers" box.
BACKPAGE
Instructions summarizing CLP sample volumes, packaging and reporting requirements are printed on the
back of the Organic/Inorganic Traffic Reports and Chain-of-Custody Record.
Distribution Green - Region Copy (RSCC).
of copies: Pink - CLASS copy (Fed Ex overnight).
White - Lab copy.
Yellow - Lab copy for return to CLASS.
Photocopies - ASC, CDPHE and Field Office
Col. C:
Col. D:
Col. E:
Col. F:
Col. G:
Col. H:
Col. I:
Col. J:
Col. K:
I:\QAPP\SOP\SOP 03.wpd
-------
Standard Operating Procedures Procedure No. 3
Colorado Department of Revision No.: 0
Public Health and Environment Date: 01/2000
Page 14 of 15
EXHIBIT 3-5
EPA Custody Seal
UNITED 8TATES
i ^ V ENVIRONMENTAL PROTECTION AGENCY
i r : OFFICIAL SAMPLE SEAL
n5*
SAMPUKO.
DATE
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I:\QAPP\SOP\SOP 03.wpd
-------
Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 3
Revision No.: 0
Date: 01/2000
Page 15 of 15
EXHIBIT 3-6
Calling in Shipping Information
Contact (via FAX or telephone) and submit the following information to the ASC on a daily basis:
Case (and/or ULSA) Number;
Date shipped;
Number of samples by concentration (high, medium, low) and sample matrix;
Carrier and airbill number;
EPA Sample Numbers;
Sample destination(s); and
Next planned shipment.
The ASC will notify the RSCC of all shipments. Field personnel must notify the ASC of Saturday sample
deliveries in time to contact the RSCC before 12:00 noon on Friday.
Report any delays or changes of scope (i.e., changes in number of samples to be collected, matrix changes,
etc.) to the ASC. The ASC will then notify the RSCC.
I:\QAPP\SOP\SOP 03.wpd
-------
-------
Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 4
Revision No.: 0
Date: 01/2000
Page 1 of 16
STANDARD OPERATING PROCEDURE - 4
SAMPLE IDENTIFICATION, LABELING AND PACKAGING
1.0 PURPOSE
The purpose of this procedure is to describe the standard method for sample identification to be used on
environmental investigations. This procedure outlines the required information and provides standardized
forms and labels.
This procedure provides guidance for routine field operations on environmental projects. Site-specific
deviations from the methods presented herein must be approved by the Project Leader and CDPHE Quality
Assurance Officer.
2.0 DEFINITIONS AND ABBREVIATIONS
2.1 Definitions
Field Data Records: Field-generated documents including field log books, Exhibits and forms as
supplied in the CDPHE Standard Operating Procedures.
2.2 Abbreviations
CLP Contract Laboratory Program
EPA U.S. Environmental Protection Agency
ERT Environmental Response Team
ESD EPA Environmental Services Division
FDR Field Data Record
FSP Field Sampling Plan
PPs Project Plans
QC Quality Control
RAS Routine Analytical Service
RSCC Regional Sample Control Coordinator
SAP Sampling and Analysis Plan
ULSA Unique Laboratory Sample Analysis
VOC Volatile Organic Compound
3.0 RESPONSIBILITIES
Field personnel (samplers) are responsible for performing the tasks outlined in this procedure when
conducting work related to environmental projects.
I:\QAPP\SOP\SOP 04.wpd\
-------
Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 4
Revision No.: 0
Date: 01/2000
Page 2 of 16
The Project Leader or an approved designee is responsible for checking all work performed and ensuring that
the work is conducted in a satisfactory manner. This will be accomplished by reviewing all documents
(Exhibits) and data produced.
4.0 SAMPLE IDENTIFICATION PROCEDURES
4.1 Introduction
The coding system described herein will be used to identify each sample taken during the sampling
program. This coding system will provide a method for tracking each sample. If the project involves
Contract Laboratory Program (CLP) laboratories, U. S. Environmental Protection Agency (EPA) and
CDPHE sample numbers will be cross-referenced. Proper sample identification will allow
information about a particular sample to be retrieved and will enable the analytical results to be
assigned to a specific location. It is imperative that each sample be labeled clearly and concisely and
that a consistent and standard identification system be used as described below.
4.2 Method of Sample Identification
The method for identification of a sample depends on the matrix of the sample, and the type of
measurement or analysis performed. On-site measurements will be recorded in field log books. The
measurements may also be recorded on the Field Data Records (FDRs). Examples of on-site
measurements include, but are not limited to: pH, temperature, conductivity, groundwater level, and
air sampling.
Sampling during most environmental investigations will include off-site laboratory analysis of
samples. The laboratory will be either under contract to the EPA CLP or subcontracted directly by
Within the CLP is the Routine Analytical Services (RAS). Within Region VIII is the Unique
Laboratory Sample Analysis (ULSA) program. CLP-RAS samples receive only EPA-issued labels
and tags. They do not require CDPHE labels. Samples going to ULSA or non-CLP laboratories
receive a CDPHE label (see Exhibit 4-1).
Each sample is identified by a unique code which may include, but is not limited to, the following:
site code, sample type, sample point, and sequence number.
4.2.1 Site Code
The site code may be omitted for smaller sites.
4.2.2 Sample Type
A two-letter designation will be used to identify the specific type of sample or the area in
which it was collected. To better delineate physical areas within smaller sites, a two-letter
designation may be created which represents unique sampling areas as approved by the
CDPHE.
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Standard Operating Procedures
Colorado Department of
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Procedure No. 4
Revision No.: 0
Date: 01/2000
Page 3 of 16
Project Leader. Typical designations for sample types which may be collected during the
site investigations are:
SW - Surface water grab sample (streams, rivers, lakes, runoff);
SF - Surface water flow (continuous measurement);
MW - Monitor well sample;
GW - Groundwater sampled from various types of wells;
SS - Source sample;
SB - Soil boring sample;
SG - Soil gas;
WQ - Continuous water quality measurement;
SO - Surface samples (beds, surface soil, shallow depth borings);
SE - Sediment samples collected from stream beds, etc.;
LG - Lagoon samples;
TS - Tank samples including aboveground and below ground enclosures;
DM - Drum samples;
AM - Meteorological station;
AG - Gaseous air samples;
AP - Particulate air samples;
AO - Organic air samples;
MS - Trace metal samples;
RS - Rock samples; and
BI - Biological samples.
4.2.3 Sample Point
A number may be used to identify a sample point location. This location can be a soil
sample point, borehole, well, drum, tank, surface water sample point, lagoon point, air
monitor station, or any other point where a source material, water, soil, core, or air sample
will be taken.
The sample type and sample point together represent the unique sample station from which
the sample will be taken (e.g., MW-01).
The sample point number may be omitted for smaller sites.
4.2.4 Sequence Number
The final sample identification code will be a sequence identifier. This number will be used
to identify separate samples collected at the same sample point. Samplers shall monitor the
sequential use of numbers.
The CDPHE sample type, sample point identifier and sequence number codes will be
established by the Project Leader for each sample to be collected prior to field activities, and
will be identified in the Field Sampling Plan (FSP).
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 4
Revision No.: 0
Date: 01/2000
Page 4 of 16
EPA sample numbers will be provided by the Regional Sample Control Coordinator (RSCC)
immediately prior to sampling.
5.0 Sample Labeling Procedure
5.1 Sample Label
In order to prevent misidentification of samples, all samples will be temporarily identified with the
sample ID and analyses to be preformed on the respective bottle. This will be conducted with the
use of an indelible pen, crayon or paint marker. Sample labels can be affixed to the sample jar prior
to sampling, but if the label gets wet, the writing on the label may run or the label may fall off. If
the sample container is to have labels affixed prior to sampling, each label must be plastic-coated
(blank or preprinted) (see Exhibit 4-1). Each label must meet the following criteria:
Waterproof;
Will not disintegrate;
Will retain:indelible ink markings when wet; and
Must be self-adhesive.
Complete all sample labels in legibly printed text with an indelible ink pen. For CLP-RAS samples,
the EPA RSCC will provide sample labels. For non-CLP laboratories and for ULSA samples, record
the following information on the CDPHE Sample Label:
Date - A six-digit number indicating the month, day and year of collection;
Time - Time (24 hour clock) sample was collected;
Project - Project name (for ULSA samples, do not indicate site location);
Job No. - CDPHE project number;
Location - Brief sample location description. This can also be the sample ID. For ULSA
samples, do not indicate site location;
Depth - Depth at which sample was collected (if applicable);
Sample Number I.D. - EPA ULSA sample number as provided by the EPA RSCC and
CDPHE sample number as defined in Section 4.2 of this procedure;
Preservative - Indicate presence or absence and composition of preservative if present;
Remarks - Pertinent remarks to help identify sample and analysis to be performed; and
Signature - Signature of sampler who actually collected the sample.
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 4
Revision No.: 0
Date: 01/2000
Page 5 of 16
5.2 EPA Sample Tag (To Be Used for CLP-RAS, ULSA, EPA Environmental Services
Division (ESD) or the Environmental Response Team (ERT))
Record the following information on the EPA Sample Tag (Exhibit 4-2):
Project Code - Record the RSCC-supplied project code;
Station No. - Record the CDPHE-assigned station number;
Month/Day/Year - A six-digit number indicating month, day and year of collection;
Time - Time (24 hour clock) sample was collected;
Comp. or Grab - Check applicable box for composite or grab sample;
Station Location - Brief sample location description or sample ID;
Sampler signature - Signature of sampler(s);
Preservative - Check the appropriate box and, if preserved, write in the preservative used
below the "Yes" box. If sample is preserved to 4ฐC, check "Yes" box and write 4ฐC;
Analyses - Check the appropriate box;
Remarks - Provide the CLP-RAS sample number (for CLP-RAS samples) on the preprinted
label; and
Lab Sample No. - For laboratory use only.
As each sample is collected, make a record of this in the field log book as specified in CDPHE SOP
4.6, Use and Maintenance of Field Log Books, and place the sample in a labeled container. Bring
chests to the decontamination area where, if necessary, the samples can be separated for shipping to
the analytical laboratories specified in the Project Plans. Fill out the Chain-of-Custody form for all
samples as described in CDPHE SOP 4.3, Chain of Custody.
5.3 Custody Seal
Custody Seals are required on shipping containers.
Fill out Custody Seals (Exhibit 4-3) and sign and date each. Affix the Custody Seals such that any
opening of the shipping container or sample will be indicated by a broken seal.
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 4
Revision No.: 0
Date: 01/2000
Page 6 of 16
6.0 Sample Packing'and Shipping
Pack all samples for shipment following the guidelines outlined below.
6.1 Steps in Packing a Cooler
Clean the inside and outside of the cooler.
Line one layer of bubble wrap, bottom side down, in bottom of cooler and line with
shredded paper to absorb shock and water.
Line cooler with one large garbage bag.
Wrap all glass sample jars one time with bubble wrap. Take note to leave the
sample tag out, while making sure that there is bubble wrap coverage on the top and
bottom of the sample container.
Affix bubble wrap in place and put sample in plastic bag of appropriate size as to
prevent the bubble wrap from coming unwrapped. Take note to lay the sample tag
flat on the outside so it can be read and eliminate air pockets in the ziplock bag.
Volatile organic compound (VOC) vials are placed in the YOC vial sponge. This
is then wrapped loosely in bubble wrap and bagged like other samples.
Plastic sample bottles are not wrapped in bubble wrap. They are placed in a plastic
ziplock baggie with careful attention paid to eliminate air pockets. Make sure that
the sample tag is placed face out so it can be read during the final Quality Control
(QC) check.
Check all tags and labels to the corresponding chain of custody. This will complete
the final QC check.
Care must be taken to maximize the number of sample jars placed in the cooler
while not overpacking it. Sample jars should fit snugly with little or no movement
if shaken lightly prior to filling open spaces with available materials. Do not place
sample jars on their sides or on top of one another. Above all, glass should never
be touching or capable of touching glass.
Use available materials to fill any potentially open space in the cooler. Tape jars
together, if appropriate, to reduce movement of sample jars during shipment.
6.2 Prepare Samples
6.3 Pack Coolers
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Standard Operating Procedures Procedure No. 4
Colorado Department of Revision No.: 0
Public Health and Environment Date: 01/2000
Page 7 of 16
Ice coolers with:
a. Two to three large ziplock bags with few or no air pockets, or
several small bags. These bags then are double bagged to prevent
any potential for leaking.
b. Put ice inside a trash bag below a layer of shredded paper. This
will help keep the sample at 4ฐC. Put paper on top of the ice so it
closes very tightly. There should be no inside shifting if the cooler
is packed correctly.
Affix a piece of tape on the top of the cooler with the cooler sequence number, total
numbers of coolers for that respective shipment, and the laboratory destination.
Wrap each cooler a minimum of three times around at each end with strapping or
shipping tape. Tape up the drain hole.
6.4 Special Stickers Required On Coolers For Shipment.
Up (1 f) labels on the ends under handles
8027 label (other regulated substances - environmental samples)
Hazardous substance code (9 also indicates chilling)
Typed label stating where shipment is to and who shipment is from
Two custody seals placed on cooler.
6.5 Completing Shipment
Use special hazardous waste (Dangerous Goods) Federal Express air bills. Follow
directions in Section 6.6 for completing Dangerous Goods Airbill.
Ice and packing material is considered part of "solids."
Insure each cooler for $5,000.
6.6 Instructions for Completing a Federal Express Dangerous Goods Airbill
These instructions should be used for non-radioactive environmental samples only. Do not
use these instructions to ship chemicals (hexane, methanol, nitric acid, etc.) or radioactive
samples. If additional questions arise call Federal Express Special Services at 1-800-238-
5355. This number is preprinted at the top of each Dangerous Goods Airbill.
Complete the top portion of the Dangerous Goods Airbill as follows:
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Standard Operating Procedures Procedure No. 4
Colorado Department of Revision No.: 0
Public Health and Environment Date: 01/2000
Page 8 of 16
Instructions
This number should be preprinted. If it is not, then fill it in (CDPHE
Federal Express government no..
Laboratory name and address. If the sample custodian's name is
unknown, then simply print "Sample Custodian."
Check box number 1 - Bill Sender. A project number is required in
the box labeled "your internal billing reference information."
Check government overnight only! In the instructions box, check the
box that is labeled "Dangerous goods as per attached Shipper's
declaration."
In the case of Saturday delivery,...
To be filled in by Federal Express personnel when they weigh the
coolers.
Complete the bottom portion of the Dangerous Goods Airbill as follows:
Transport Details
Cross out the boxes that DO NOT apply (i.e., most environmental samples can be shipped on
passenger aircraft, so cross out the "cargo aircraft only" box).
Shipment Type
Again cross out the boxes that do not apply. Cross out the "Radioactive" box. Remember that these
instructions are for non-radioactive environmental samples ONLY!
Shipper's Certification for Restricted Articles/Dangerous Goods
Check the box marked "IATA/ICAO."
Proper Shipping Name
Write in "Other Regulated Substances." Directly below this, write "(Environmental Samples)."
Class or Division
Fed Ex Box No.
1
2
3
4
4
4
Write "9."
UN or ID Number
Write "8027."
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Standard Operating Procedures Procedure No. 4
Colorado Department of Revision No.: 0
Public Health and Environment Date: 01/2000
Paae 9 of 16
Quantity and Type of Packaging
Write in how many and what kind of coolers are being shipped, as well as the volume and weight
of the enclosed media; for example, "1 plastic cooler, 4 liters liquid, 12 kg soil." Weight may be
filled in at the Federal Express office after being weighed by the Federal Express personnel.
Packing Instructions
Write "906."
Authorization
Leave this blank.
The Project Leader or an approved designee shall check Exhibit 4-1, Sample Label; Exhibit 4-2, EPA
Sample Tag, if applicable; and Exhibit 4-3, Custody Seal for completeness and accuracy. Any
discrepancies will be noted and the Exhibits will be returned to the originator for correction.
7.0 REFERENCES
U.S. Environmental Protection Agency (EPA). 1986. "RCRA Groundwater Monitoring Technical
Enforcement Guidance Document." (OSWER Directive 9950.1). September 1986.
U.S. Environmental Protection Agency (EPA). 1987. "A Compendium of Superfund Field Operations
Methods." EPA/540/P-87/001. (OSWER Directive 9355.01-14). December 1987.
CDPHE. 2000. "Standard Operating Procedure 4.3, Chain of Custody." Technical Standard Operating
Procedures.
CDPHE. 2000. "Standard Operating Procedure 4.6, Use and Maintenance of Field Log Books." Technical
Standard Operating Procedures.
8.0 EXHIBITS
Exhibit 4-1 Sample Label
Exhibit 4-2 EPA Sample Tag
Exhibit 4-3 EPA Custody Seal
Exhibit 4-4 Sample Packaging Summary
Exhibit 4-5 Required Cooler Labels
Exhibit 4-6 Required Cooler Label Placement
Exhibit 4-7 Federal Express Dangerous Goods Airbill
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Standard Operating Procedures Procedure No. 4
Colorado Department of Revision No.: 0
Public Health and Environment Date: 01/2000
Page 10 of 16
EXHIBIT 4-1
Sample Label
CDPHE
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Date Time Project
Job No.
Location
Depth
Sample Number I.D.
Preservative
Remarks
Signature
000001
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 4
Revision No.: 0
Date: 01/2000
Page 11 of 16
EXHIBIT 4-2
EPA Sample Tag
ฃ
I
Preservative:
ฆ. Yes ~ No ~
ANALYSES
BOO Anions
Solids (TSS) fros)
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Standard Operating Procedures Procedure No. 4
Colorado Department of Revision No.: 0
Public Health and Environment Date: 01/2000
Page 12 of 16
EXHIBIT 4-3
EPA Custody Seal
- UNfTED STATES
* \ ENVIRONMENTAL PROTECTION AQSNCY
i . M I \ OFFICIAL SAMPLE SEAL
MMniNO.
OATC
ฆ
M
3
MOMATUU
a
o
PMKT KAMC-AMS TTT1I' *r Ttr*,trtmm
*
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
EXHIBIT 4-4
Sample Packaging Summary
Procedure No. 4
Revision No.: 0
Date: 01/2000
Page 13 of 16
SAMPLE
IATA - .
Approved
Snipping
Container.
Enclose all sample containers in clear plastic bags.
Pack all medium and high level water and soil samples in metal paint cans.
Label paint cans with sample number of sample contained inside.
Surround contents of can with non-combustible absorbent packing
material.
Using freezer packages or ice sealed in plastic bags, cool organic low or
. medium samples and inorganic samples to be analyzed for cyanide to 4ฐC.
*Ice is not required in shipping low level soil samples, but may be utilized at
the discretion of the sampler.
Do not cool dioxin, inorganic low level water, inorganic medium/high level
water or soil, or organic high level water or soil samples.
. ปPack sealed paint cans or plastic-enclosed sample bottles in shipment
. container.
Use a metal ice chest for shipment (do not use cardboard or styrofoam
containers to ship samples).
'Surround contents with non-combustible absorbent packing material (Do
ฆ not use earth or ice packing materials).
*Tape paperwork in plastic bags under cooler lid.
Close cooler and seal with custody seals.
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 4
Revision No.: 0
Date: 01/2000
Page 14 of 16
EXHIBIT 4-5
Required Cooler Labels
ORIENTATION
HAZARD CLASS
4 - OPPOSITE SIDES
FRONT
TOP
Colorado Department of
Public Health and Environment
4300 Cherry Creek Drive South
Denver, CO 80246
FRONT
UN ID NO.
PROPER SHIPPING NAME
NAME
FRONT
"CONTAINS WET ICE"
(IF APPLICABLE)
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Standard Operating Procedures Procedure No. 4
Colorado Department of Revision No.: 0
Public Health and Environment Date: 01/2000
Page 15 of 16
EXHIBIT 4-6
Required Cooler Label Placement
(1) Airbill
(2) Recipient Address
(3) Shipper or Consignee Address
(4) Orientation Arrows
(5) UN ID No. and Proper Shipping Name
(6) Label or ORM Marking
I:\QAPP\SOP\SOP 04.wpd\
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 4
Revision No.: 0
Date: 01/2000
Page 16 of 16
EXHIBIT 4-7
Federal Express Dangerous Goods Airbill
343376^144
osf ruts Mumii fott SAMSffovs eooos smrwrs om.r wirm* ro*CD#rwfปr*i vsa. masju *m hawm.
usf thmwuudqmm. m* wwil Ktt SMifM&irs n> nenmnKSMio au. nqh i/.i iocatwh.
QUESTIONS? CALL 800-233-5355 TOLL FRฃฃ
3. 3 3
343376cil 44
TRACKING HUM8SR
J Sender's Federal Express Account Numoer
*~
I
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13HZ - XXX*-x
From (Your Name) Please Prim
Your Pww Numoef (Very tmoonart) J To {flecปeM's Name* Ptease Pwn
Saim. (3o5 ) 6'U-3coo^OortV L)oฃ.
Comoany '' Oeoartment/Ftoor No.
^ฃ01"* OJr $ฃAt-THi
Street Address
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ADOfTIONAL HANOUNG INFORMATION
TRANSPORT
OETAIS
THIS SHIPMENT IS WITHWTHg w
UMiTATlONS PRESCRIBED FOR r
PASSENGER
AIRCRAFT
(OELETH-NONAPPUCAflUJ
AIRPORT OF 0EPAATURE
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AIRPORT OF OSSTWATION
6^>. A*p~ix&~
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TYPE ^
nonradioactive
(DQฃTE-NONAPPUCASLฃ)
IF ACCEPTABLE FOR PASSENGER AIRCRAFT, THIS SHIPMENT CONTAINS RAOIOACTIVE MATERIAL INTENOEO FOR USE IN. OR INCIDENT
TO, RESEARCH. MEDICAL DIAGNOSIS OR TREATMENT.
I HEREBY DECLARE THAT THE CONTENTS OF THIS CONSIGNMENT ARE FULLY AND ACCURATELY 0ESCRIBED ABOVE BY PROPER SHIPPING
NAME AND ARE CLASSIFIED. PACKED. MARKED, AND LABELED, AND ARE IN ALL RESPECTS IN PROPER CONDITION FOR TRANSPORT BY AIR
ACCORDING TO THE APPLICABLE INTERNATIONAL AND NATIONAL GOVERNMENT REGULATIONS.
NAME ANO TITLE OF SHIPPER
Sam SAMPUt-. -
P&jo<5ur MahmUL^
PLAgE ANO DATE
O^ffA. Co
12-1 i^/ff
EMERGENCY TELEPHONE NUMBER ,
, /?o">Y ^z-xys^-v
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SIGNATURE OF SHIPPER
SEE WARNING
ON 8ACK
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 5
Revision No.: 0
Date: 01/2000
Page 1 of 4
STANDARD OPERATING PROCEDURE - 5
SAMPLE LOCATION DOCUMENTATION
1.0 PURPOSE
The purpose of this procedure is to describe the methods for permanently marking sample points and
documenting site conditions. Site-specific deviations from the methods presented herein must be approved
by the Project Leader and the CDPHE Quality Assurance Officer.
2.0 DEFINITIONS AND ABBREVIATIONS
2.1 Definitions
Not applicable.
2.2 Abbreviations
Not applicable.
3.0 RESPONSIBILITIES
Field personnel are responsible for performing the applicable tasks in accordance with this procedure on
environmental projects.
The Project Leader or an approved designee is responsible for checking all work performed and ensuring that
the work required by this procedure is performed in a satisfactory manner. This is accomplished by
reviewing all documents and data produced.
4.0 PROCEDURE
4.1 Introduction
It is important to adequately document sample locations in environmental investigations because
additional sampling events become necessary. An identifiable record of the previous sampling
locations prevents replicate sample locations and increases the efficiency of the investigation.
4.2 Sample Point Marking
All sample points should be located by the criteria presented in the Project Plan for the site. When
a sample point is located, it will be permanently marked so it can be located by any investigator
working on the project. The following practical methods can be used to permanently locate sample
points:
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 5
Revision No.: 0
Date: 01/2000
Page 2 of 4
A wooden stake driven securely into the ground (when possible) and identified with a unique
site identification code;
A metal spike or concrete nail driven into asphalt or concrete and the site identification code
recorded on an attached tag; and/or
The location and identification code spray-painted on the ground or ground cover surface.
The location of each sample point should be recorded on a site map and referenced, if
possible, to a permanent landmark. By using a compass, a bearing from the landmark can
be determined and the distance between the landmark and sample point can be measured by
pacing or with a tape. Sample points will not be surveyed until they have been sampled, as
field operating conditions can dictate the movement of any sample point and a slight change
would invalidate a surveyed sample point's location. Massive metal objects may cause
interference when a compass is used.
4.3 Photographic Documentation
Identification and documentation of the sample point by photography can also be a useful tool. A
photograph of the sample point can be particularly useful when the sample point has been
intentionally located near a particular feature, structure, or suspected contamination.
Initially, the camera and lenses that will be used for site pictures shall be recorded in the field log
book. Identify the particular picture number and roll number (if more than one roll of film is used)
in the field log book to identify which sampling site is recorded in the photograph. Other information
which will be recorded in the log book and later transferred to the back of the appropriate photograph
includes:
Name of photographer and any individuals in photograph;
An accurate description of what the photograph shows, including the name of the facility or
site;
The specific project name and project code;
Location, weather conditions, date, and time the photograph was taken; and
Orientation of the photographic view and distance to subject.
Unexposed film will be recorded in the log book as such. The location of film development and the
date of processing will be recorded in the log book. The negatives will be supplied uncut, and two
sets of prints will be supplied, one for permanent document control and one for investigative use.
Each photograph is then identified and labeled on the back with the appropriate information with the
use of a photo label Exhibit 5-1. The negatives and one set of prints will be stored in the project
files.
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 5
Revision No.: 0
Date: 01/2000
Page 3 of 4
4.4 Review
Personnel performing sample location documentation are to record the applicable information on all
documents (e.g., field log books, photographs, etc.) as outlined in this procedure.
The Project Leader or an approved designee shall check field log books, daily logs, and photographs
for complete and accurate documentation. Any discrepancies will be noted and the documents will
be returned to the originator for correction. The reviewer will acknowledge that these review
comments have been incorporated by signing and dating the applicable reviewed documents.
5.0 REFERENCES
U.S. Environmental Protection Agency (EPA). 1986. "Engineering Support Branch. Standard Operating
Procedures and Quality Assurance Manual." U.S. EPA Region IV. Environmental Services Division.
Athens, Georgia. April 1986.
U.S. Environmental Protection Agency (EPA). 1987. "A Compendium of Superfund Field Operations
Methods." EPA/540/P-87/001 (OSWERDirective 9355.0-14). December 1987.
6.0 EXHIBITS
Exhibit 5-1 Photograph Label
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Standard Operating Procedures Procedure No. 5
Colorado Department of Revision No.: 0
Public Health and Environment Date: 01/2000
Page 4 of 4
EXHIBIT 5-1
Photograph Label
PHOTO NO.:
PROJECT NAME:.
PROJECT NO.:
PHOTOGRAPHER:.
LOCATION:
DATE/TIME/DIRECTION:
ID OF PERSONS IN PHOTO:_
COMMENTS/DESCRIPTION:
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 6
Revision No.: 0
Date: 01/2000
Page 1 of 4
STANDARD OPERATING PROCEDURE - 6
USE AND MAINTENANCE OF FIELD LOG BOOKS
1.0 PURPOSE
The purpose of this procedure is to describe the methods for use and maintenance of field log books. This
procedure outlines methods, lists examples for proper data entry into a field log book, and provides the
standardized Colorado Department of Public Health and Environment (CDPHE) format.
This procedure provides guidance for routine field operations on environmental projects. Site-specific
deviations from the methods presented herein must be approved by the Project Leader and CDPHE Quality
Assurance Officer.
2.0 DEFINITIONS AND ABBREVIATIONS
2.1 Definitions
Not applicable.
2.2 Abbreviations
QC Quality Control
DIMP Data Information Management Plan
SOP Standard Operating Procedures
CDPHE Colorado Department of Public Health and Environment
3.0 RESPONSIBILITIES
Field personnel are responsible for performing the applicable tasks in accordance with this procedure when
conducting work related to environmental projects. Daily logs will be kept during field activities by a Field
.Team Member to provide daily records of significant events, observations and measurements taken in the
The Project Leader or an approved designee is responsible for checking all work performance and verifying
that the applicable tasks required by this procedure have been performed. This will be accomplished by
reviewing all documents (Exhibits) and data produced during work performance.
field.
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 6
Revision No.: 0
Date: 01/2000
Page 2 of 4
4.0 PROCEDURE
4.1 Introduction
Field log books provide a means for recording observations and activities at a site. Field log books
are intended to provide sufficient data and observation notes to enable participants to reconstruct
events which occurred while performing field activities and to refresh the memory of field personnel
while writing reports or giving testimony during legal proceedings. As such, all entries will be as
factual, detailed and as descriptive as possible so that a particular situation can be reconstructed
without reliance on the collector's memory. Field log books are not intended to be used as the sole
source of project or sampling information. Sufficient log books will be assigned to a project to
ensure that each field team has a logbook with it at all times. If a logbook is not available, field
forms should be used until a field log book becomes available.
4.2 Field Log Book Identification
Field log books shall be bound books with consecutively numbered pages. Log books will be
permanently assigned to field personnel for the duration of a project, but are to be stored in site
project files when not in use. If site activities stop for an extended period of time (i.e., two weeks
or more), field log books will be stored in the project files in the CDPHE office. Each log book will
be identified by a Site Name either prior to or after the completion of sampling.
The cover of each log book will contain the following information:
Person or organization to whom the book is assigned;
Book number;
Project number (if different than site number); and
Site name.
4.3 Log Book Entry Procedure
Every field team will have a logbook and each field activity will be recorded in the logbook by a
designated field team member to provide daily records of significant events, observations, and -
measurements during field operations. Beginning on the first blank page and extending through as
many pages as necessary, the following list provides examples of useful and pertinent information
which may be recorded (optional).
Serial numbers and model numbers for equipment which will be used for the project
duration;
Formulas, constants, and example calculations;
Useful phone numbers; and
County, state, and site address.
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Standard Operating Procedures
Colorado Department of
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Procedure No. 6
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Page 3 of 4
Entries into the log book may contain a variety of information. At a minimum, log book entries must
include the following information at the beginning of each day:
Date, initials and signature at top of each page;
Start time;
Weather;
Decontamination methods to be used;
All field personnel present and directly involved;
Level of personal protective equipment being used on the site;
Signature of the person making the entry;
Equipment used and procedures followed; and
Any field calculations.
In addition, information recorded in the field log book during the day will include (but is not limited
to) the following:
Sample description including sample numbers, time, depth, volume, containers, preservative,
and media sampled;
Information on field QC samples (i.e., duplicates);
Observations about site and samples (odors, appearance, etc.);
Information about any activities, extraneous to sampling activities, that may affect the
integrity of the samples;
Any public involvement, visitors, or press interest;
Equipment used on site including time and date of calibration;
Background levels of each instrument and possible background interferences;
Instrument readings for the borehole, cuttings, or samples in the breathing zone and from the -
specified depth of the borehole, etc.;
Field parameters (pH, specific conductivity, etc.);
Unusual observances, irregularities or problems noted on site or with instrumentation used;
Maps or photographs acquired or taken at the sampling site, including photograph number
and description (CDPHE Standard Operating Procedure (SOP) 4.5, Sample Location
Documentation); and
Forms numbers and any information contained therein used during sampling should be
referenced.
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Standard Operating Procedures
Colorado Department of
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Procedure No. 6
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Date: 01/2000
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All log book entries will be made in indelible black or blue ink. No erasures are permitted. If an
incorrect entry is made, the data will be crossed out with a single strike mark and initialed and dated
by the originator. Entries will be organized into easily understandable tables if possible.
All log book pages will be initialed and dated at the top of the page. Times will be recorded next to
No pages or spaces will be left blank. If the last entry for a day is not at the end of the page, a
diagonal line will be drawn through the remaining space and the line will be initialed and dated.
Logbooks can become contaminated when used in the field. Every effort should be made by the field
team to avoid contaminating the logbook. Logbooks can be kept in ziplock plastic bags or temporary
plastic covers can be used.
4.4 Review
The Project Leader or an approved designee will check field log books, daily logs, and Exhibits for
completeness and accuracy on an appropriate site specific schedule determined by the project leader.
Any discrepancies in these documents will be noted and returned to the originator for correction.
The reviewer will acknowledge that these review comments have been incorporated by signing and
dating the applicable reviewed documents.
5.0 REFERENCES
U.S. Environmental Protection Agency (EPA). 1987. "A Compendium of Superfund Field Operations
Methods." EPA/540/P-87/001 (OSWER Directive 9355.0-14). December 1987.
U.S. Environmental Protection Agency (EPA). 1986. "RCRA Groundwater Monitoring Technical
Enforcement Guidance Document." September 1986.
CDPHE. 2000. "Standard Operating Procedure 5, Sample Location Documentation." Standard Operating
Procedures.
each entry.
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Standard Operating Procedures Procedure No. 7
Colorado Department of Revision: 0
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Page 1 of 17
STANDARD OPERATING PROCEDURES - 7
HAZARD CATEGORIZATION (HAZCAT)
1.0 PURPOSE
The purpose of this procedure is to identify the hazardous characteristics of an unknown chemical, mixture
or waste. The Hazardous Categorization (HAZcat) kit to be used in this identification process contains
supplies and instructions for the ten preliminary chemical categorization tests commonly performed on site.
Preliminary categorization tests are to be performed for either liquid or solid matrix in the order they are
listed below. For more specific chemical identification, please refer to the manuals provided in the HAZcat
Kit.
1. Observation
2. Water Solubility
3. Oxidizer
4. Chlorinated Hydrocarbon/Beilstein Test
5. pH
6. Sulfide
7. Cyanide
8. Flammability
9. Polychlorinated Biphenyls (PCB) Screening
10. Peroxide
By thus classifying the hazardous material, any or all of the following tasks may be performed:
Assignment of hazardous waste characteristics according to Resource Conservation and Recovery
Act (RCRA) (40 CFR, Section 261.20) definitions of ignitability, corrosivity, and reactivity.
Assignment of Department of Transportation (DOT) hazard class (49 CFR, Sections 171, 172) to
permit placarding and manifesting of the material for transportation.
Rapid assessment of the materials present at a site, and the evaluation of their potential hazards to
the populace and environment. Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA) funds are not accessible for a removal action (40 CFR, Section 300.65) if
the materials present are non -hazardous.
Selection of immediate mitigative measures, such as the segregation of containers of incompatible
materials, or the neutralization or containment of a leaking substance with the appropriate material
(i.e., soda ash for an acid spill).
Bulking material into consolidated waste streams for subsequent disposal or treatment, thus reducing
disposal/transportation costs.
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Reducing analytical costs by allowing the selection of a limited number of composite samples from
each waste stream, instead of submitting many discrete samples to the laboratory.
This procedure provides guidance for routine field operations on environmental projects. Site-specific
deviations from the methods described herein must be approved by the Project Leader (PL), CDPHE Quality
Assurance Officer (QAO), and Analytical Services Coordinator.
2.0 DEFINITIONS AND ABBREVIATIONS
2.1 DEFINITIONS
Waste Stream: A set of materials that have like properties under RCRA definitions and are disposed
of together.
Water-Reactive: A material reacts in a way that changes volume or temperature in water. Six
reactions include reacts violently; hesitates, fumes, and reacts; boils; becomes hot; effervesces; or
becomes cold.
Immiscible: Does not dissolve, rather separates into phases.
Effervescence: Small alka-seltzer size bubbles.
Turbidity: A solution is not transparent, cloudy or opaque.
Oxidizer: Initiates or promotes combustion in other materials. Oxidizers increase the flammability
of materials and can cause fire when in contact with combustibles. Chlorine is a common oxidizing
gas.
Head-space: The area inside a test tube above the unknown substance.
Support Medium: Cotton swabs or wire loop.
Flammable: A liquid with a flash point from 30ฐ F to 200ฐ F. For HAZcat, a liquid that flashes or
continues to burn after the match has been removed.
Ignitable: A liquid having a flash point below 140ฐ F (flammable liquid). This is the temperature
that could occur from radiant heat inside a truck in the direct sun light.
2.2 ABBREVIATIONS
AgN03 Silver nitrate
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
DOT Department of Transportation
H2S Hydrogen sulfide gas
HAZcat Hazardous Categorization
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Standard Operating Procedures Procedure No. 7
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Page 3 of 17
HC1
Hydrochloric acid
HCN
Hydrogen cyanide gas
HF
Hydrofluoric acid
KI
Potassium iodide
NaOH
Sodium hydroxide
N02
Nitric acid
PCB
Polychlorinated biphenyl
PID
Photo ionization detector
PL
Project Leader
PPE
Personal protective equipment
ppm
Parts per million
RCRA
Resource Conservation and Recovery Act
S02
Sulfur dioxide
START
Superfund Technical Assistance Response Team
SOP
Standard Operating Procedure
CDPHE QAO
CDPHE Quality Assurance Officer
3.0 RESPONSIBILITIES
Sampling personnel are responsible for performing and documenting the applicable tasks outlined in this
procedure on a provided data sheet. The PL or an approved designee is responsible for checking all work
performance and approving that the work satisfies the applicable tasks required by this procedure. This will
be accomplished by reviewing all documents (Exhibits) and data produced during work performance.
4.0 PROCEDURES
The HAZcat procedure must be performed as outlined by this technical standard operating
procedure (SOP) and/or the manual contained in the HAZcat Kit.
4.1 SAMPLE OBSERVATION
Note color, viscosity, turbidity, number and description of phases.
4.2 WATER SOLUBILITY TEST
Add a small quantity of the material to be tested (dime size or 3 drops) to test tube containing 3 mL
of distilled water.
Note whether a temperature change occurs, effervescence or fumes/gases/vapors are produced
indicating that the sample is water reactive.
Note whether the sample completely dissolves in the water, giving NO turbidity AND forming a one-
phase solution indicating the sample is water soluble.
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Note whether sample is insoluble or immiscible. Indicate sample's specific gravity; if it sinks,
specific gravity is greater than one, if it floats specific gravity is less than one.
Exhibit 7-1, Water Solubility Test Chart, contains detailed descriptions and explanations for water
solubility categorizations.
4.3 OXIDIZER TEST
Conduct on ALL water soluble samples.
Add one-half of a pea-sized amount of sample to a watch glass;
Add sample liquid to watch dish to form a pool the size of a dime.
Acidify a Potassium Iodide (KI)/Oxidizer test strip with a few drops of 3M hydrochloric acid (HC1).
Touch the test strip to the sample on the watch glass/dish. If the test strip turnsblue or black, the
sample is an oxidizer.
Specific observations are contained in Exhibit 7-2, Oxidizer/Acid Test Chart.
4.4 CHLORINATED HYDROCARBONS/BEILSTEIN COPPER WIRE TEST
Conduct on all samples which are insoluble or have a specific gravity greater than one.
WARNING: Do NOT put hot copper wire into liquid, especially if the liquid is flammable - quick
vaporization of chlorinated solvents may produce anaesthetic gases!
Heat copper wire in flame of propane torch until a yellow flame with NO green coloration appears.
Allow wire to air cool (about 15 seconds).
Dip cooled wire into sample and leave for at least 10 seconds.
Put wet wire into torch flame.
Green flame indicates chlorinated solvents.
Yellow flame with a green edge indicates an amine. (Must be water-soluble or oily with a
high pH test.)
A green flame may indicate nitrates if the sample is a water-soluble solid with neutral pH
and was partially sublimed or auto-ignited during Char Test.
-OR-
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4.5 pH TEST
Use the sample in the test tube from the previous water solubility test.
For a solid sample matrix, probe or strip should be dipped into a solution of sample or into an
aqueous extract if partially soluble.
Dip the test strip into the sample solution contained in test tube or watch glass; compare the color
with reference colors on the pack. Note color and pH; indicate whether it is base or acid.
pH is GREATER than 7 indicates basic.
pH is LESS than 7 indicates acidic.
pH EQUAL to or LESS than 2 indicates CORROSIVE acid.
pH EQUAL to or GREATER than 12.5 indicates CORROSIVE base.
4.6 SULFIDE TEST
Perform this test if sample pH is 7 or GREATER. Sulfides are not stable in acid solutions.
Detection limit of approximately 50 parts per million (ppm) can be obtained.
Add the sample to a watch glass to form a dime-sized pool.
Acidify test strip with about 2 to 3 drops of 3 Molar (3M) (concentrated) Hydrochloric acid (HC1).
Touch moistened lead acetate paper to acidified sample.
If the test strip darkens (brown or black), sulfides are present.
4.7 CYANIDE TEST
Perform this test if sample pH is GREATER than 7. Cyanides are not stable in acid solutions.
Detection limit of approximately 5 0 ppm can be obtained. Put 5 mL (about one-half inch) of distilled
water in test tube. Dissolve 5 mL of sample in test tube.
Test pH, if not already 11 or GREATER add 2 or 3 drops of 50% sodium hydroxide (NaOH) to
adjust the pH to 11.
Add 3 drops of rhodanine solution to test tube and swirl.
Add 1 drop of 0.02M Silver Nitrate (AgN03) to test tube.
If there is NO color change, cyanide is present.
If there IS color change or precipitate, cyanide is NOT present.
RESPIRATOR MUST BE WORN DURING CYANIDE TEST!
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Small amounts of cyanide gas can smell of chlorine.
Large amounts of cyanide gas can smell of almonds.
For an alternate cyanide test method, refer to Exhibit 7-3, HAZcat Chemical Identification System.
4.8 FLAMMABILITY TEST
Use the photo ionization detector (PID) to take a head-space reading from the sample jar. A small
amount of sample is applied to a cotton swab (support medium) and exposed to a flame (the
BIC/lighter test).
If the sample ignites readily and vigorously on exposure to flame source, and gives a PID reading
(10.2eV probe/9.8 span) of GREATER than 200 units, the flash point is approximately 100ฐ F or
LESS and the sample is FLAMMABLE.
If the sample ignites and sustains flame on exposure to flame, and gives a PID reading (10.2eV/9.8
span) of LESS than 200 units, flash point is approximately 200ฐ F or LESS, and the sample is
COMBUSTIBLE.
If the sample does NOT ignite OR burn after sustained exposure to a flame source, the sample is
NON-FLAMMABLE.
4.9 PCB SCREENING TEST
Commercial test kits are available in the HAZcat Kit.
4.10 PEROXIDE TEST
Wet a Peroxide Test Strip with one drop of distilled water.
Directly touch the wetted peroxide test strip to the sample.
Note color change.
BLUE: Peroxide or weak chromic acid.
GREEN: Very strong peroxide, or strip was not wetted, organic peroxides will turn strip -
BROWN: Strong chromic acid or very strong peroxide.
YELLOW: Nitric acid.
ORANGE: Hypochlorite.
PURPLE: Silver nitrate.
If Peroxide test strips are unavailable, refer to Exhibit 7-3, HAZcat Chemical Identification System,
for an alternate method.
green.
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Standard Operating Procedures
Colorado Department of
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5.0 THE HAZCAT KIT
The HAZcat kit contains the following items:
5.1 REAGENTS AND TEST STRIPS
Procedure No. 7
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ph Test - pH paper
deionized water
Oxidizer Test - Potassium Iodide test Strips
3M Hydrochloric Acid
Sulfide Test - Lead Acetate/Starch test Strips
Cyanide Test- 50% sodium hydroxide solution
Rhodanine solution (20 mg of para-aminobenzalrhodanine in 100 mL of acetone)
0.02M silver nitrate solution.
Chlorinated Hydrocarbon Test- Copper wire
Propane torch
Peroxide Test - peroxide test strips
Flammability - PID (photo ionization detector)
Propane torch
Support media, such as cotton swabs
PCB Screening- commercial PCB testing kit.
5.2 EQUIPMENT
Test tubes
Test tube rack
Test tube holder
Disposable pipets
Wash bottle of deionized water (250 mL at least)
Copper wire
Propane torch
Strike or matches for ignition
Garbage bags
Hand wipes
Cotton swabs
Duct tape
Photo Ionization Detector
Detector tubes and pump
Container inventory sheets
HAZcat data/result sheets
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5.3 REAGENTS AND TEST STRIPS
Rhodanine solution (in acetone) (30 mL)
3M hydrochloric Acid (30 mL)
50% sodium hydroxide solution (30 mL)
0.02M Silver Nitrate solution (30 mL)
Potassium iodide test strips (2 packs)
Lead acetate/starch test strips (2 packs)
pH test strips (2 packs or pH meter)
Deionized water (250 mL)
6.0 PERSONAL PROTECTIVE EQUIPMENT FOR HAZCAT
6.1 SPECIFIC EQUIPMENT
Personal protective equipment (PPE) that may be required in the identification of hazardous
characteristics of an unknown chemical mixture or waste includes:
6.2 GENERAL
If the HAZcat procedure is performed carefully, with attention to detail, little or no contamination
of the gloves or other protective clothing should occur.
A respirator should be worn when performing HAZcat tests, specifically when
conducting cyanide, pesticide, or sulfuric acid tests.
The Sijal suit offers the most complete protection against acids, bases, and organics.
Saranex is an alternative, offering good protection against acids, bases, some organics and
PCB's. However, Saranex offers poor protection against halogenated and aromatic
hydrocarbons and has stitched seams which may constitute a penetration pathway.
Canister respirators are listed in preference to cartridge respirators since the canister is belt-
mounted outside the breathing zone and is away from the area of maximum contaminant
during sample handling.
If the samples are known to be principally halogenated and aromatic hydrocarbons, then
viton gloves would provide better protection than neoprene. In general, neoprene gloves
Saranex suit or Sijal suit
Canister respirator with GMC-H organic vapor/acid gas cartridges
Neoprene boots
Latex inner & neoprene outer gloves
Eye protection; goggles or safety glasses
Hard hat with face shield (optional)
Acid splash apron (optional)
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offer the best compromise when many classes of chemicals are to be handled, although their
susceptibility to attack by halogenated hydrocarbons should be noted.
7.0 DATA MANAGEMENT
Field data such as, container markings, size, and HAZcat test results are recorded directly on the data sheets
provided in Exhibit 7-4, Hazardous Categorization Data Sheet.
8.0 COMPATIBILITY STUDIES
For a removal action, it is usually desirable to consolidate compatible wastes from different containers in
order to generate waste streams for disposal or treatment. Thus, it would be desirable to consolidate all
cyanide wastes for one stream. For example, all non-oxidizing acids (liquids) would be put into another
container. The qualitative nature of HAZcatting does not completely categorize a given sample since there
may be incompatibilities between samples of the same hazard class. Therefore, a bench-top compatibility
study MUST first be conducted using small quantities of each sample from a given class, so that any
incompatibilities are detected before the materials are mixed bulk.
Composite samples for each hazard class are prepared by taking small quantities (5 to 10 mL) of each sample
of that class, and mixing them in an 8 oz. sample jar. The aliquot drawn from each sample should be
proportional to the bulk amount of that material present on site. Therefore, the following composite might
be prepared from ten containers, each of which was determined to contain liquid cyanide wastes.
Sample #
Container Size
% FULL
Aliquot Taken
(gallon)
(mL)
1
55
. 100
5
2
55
50
2.5
3
10
100
1
4
100
100
10
5
25
100
2.5
The composite sample generated approximately reflects the composition of the waste stream obtained when
the bulk containers are mixed.
On addition of each constituent to the composite sample, the following observations must be made:
Is an effervescence observed?
Is any gas/vapor evolved?
Is any heat generated?
Is any solid precipitated?
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A positive observation of effervescence, gas/vapor, or heat generation indicates INCOMPATIBILITY
between the samples; they are probably NOT suitable for bulking into one consolidated waste stream.
Perhaps only one sample gives such reactions. In this case, that sample would be disposed of as a separate
waste stream (an example is cyanide (reactive)).
During the compositing process, the sample jar should AT ALL TIMES BE POINTED AWAY from the
person compositing, since adverse reactions can occur, and the solution can erupt out of the jar. Care is
essential in this process, as in the HAZcatting procedure itself. During such tests the test tube mouth is
always pointed away from the person conducting the tests.
In the open-air environment HAZcatting processes are not dangerous, provided that the specified PPE is used
and appropriate safety practices are observed. Remember that the potential for injury always exists.
9.0 ADDITIONAL TESTS
9.1 DETECTOR TUBES
Personal hand pumps along with detector tubes can provide confirmation for ambiguous tests and
questionable results. The rhodanine/silver nitrate test for cyanide often proves false negatives.
Validation of results can be done by acidifying a small portion (0.5 mL or less) of the sample to a
pH of LESS than 5 with a few drops of 3M HC1. Hydrogen cyanide gas (HCN) is liberated and
detected with the hydrogen cyanide gas detector tube and pump. ONLY a small quantity of sample
can be acidified because HCN is extremely toxic.
Similarly, acidification of a small aliquot of a sulfide-containing sample generates hydrogen sulfide
gas (H2S) which can be detected with a hydrogen sulfide detector tube and pump. It is important that
very small quantities (0.5 mL) be acidified for health and safety reasons.
When a site is better categorized and the contaminants present or suspected are known, specific
detector tubes can be used to screen for certain hazardous classes. Examples are:
Flammable liquids: Could be screened for acetone, alcohol, methyl ethyl ketone (MEK) or
ethyl acetate.
Acid Oxidizers: Sulfur dioxide (S02) or nitric acid (N02).
Acid Liquids: Hydrofluoric acid (HF) or hydrochloric acid (HC1).
9.2 OTHER TEST STRIPS
Test strips are commercially available to test for metals (nickel, zinc, and chromium) as well as
anions (sulfate, chromate, and nitrate) in aqueous solutions. However, these are limited in use due
to interferences which may occur when many species are present in the same solution.
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9.3 PCB TEST KITS
A variety of PCB kits are available commercially. The CHLOR-N-OIL kit permits the concentration
of PCBs in transformer oils to be qualitatively measured. The McGraw Edison kit uses a chloride
ion electrode to determine the sodium chloride generated and is therefore a bit more quantitative.
Both are easy to use in the field.
9.4 PESTICIDE SCREENING TESTS
A qualitative field test is available for organophosphorus pesticides. Chlorinated pesticides give a
positive wire test. ALWAYS wear respirator when performing pesticide tests.
9.5 PHYSICAL APPEARANCE
An unknown material must NEVER be identified solely by supposition based on color or physical
appearance. These characteristics provide valuable corroborating evidence, but can be misleading.
Similarly, one should never ASSUME that the label on a container is correct.
10.0 AMBIGUOUS RESULTS AND OTHER PROBLEMS
A water soluble sample CANNOT be a chlorinated hydrocarbon. If such a sample gives a positive copper
wire test, it is a solution containing chloride ions. Hydrochloric acid for example, gives a positive copper
wire test but is clearly NOT a chlorinated hydrocarbon.
As commented previously, the cyanide test (in some cases the sulfide and oxidizer test) may give ambiguous
results with certain dirty or opaque solutions. In such cases, the test may be repeated with diluted samples
(using deionized water for dilution) or in the case of sulfide and cyanide tests, confirmation may be obtained
by acidification and use of detector tubes.
Highly colored pure solutions (such as potassium permanganate, which is deep red-purple in color) may also
cause difficulty because their color masks that of the pH paper or the oxidizer test strip. Here again the
sample can be diluted with deionized water without significantly affecting the pH. Potassium permanganate
would be categorized as an oxidizer, and can be acidic or basic depending upon the application in which it
was formulated.
.Since the pH of a solution is a measure of the hydrogen ion concentration in aqueous solution, organic liquids
cannot be tested with pH paper. An aqueous extract must be prepared by mixing the sample with an equal
volume of deionized water. The extract is then tested with pH paper. This is an optional test, because of the
glassware needed to perform the test.
Some samples may have more than one phase; both an aqueous phase and an organic phase for example.. In
this situation, both phases should be HAZcatted separately. Validity of HAZcat tests is dependent upon the
skill of the sampler. Without a representative sample, the person HAZcatting cannot properly characterize
the material in the container.
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11.0 SELECTIVE APPLICATION OF HAZCAT TESTS
In general, most of the preliminary HAZcatting tests do NOT need to be conducted on a given sample.
If a liquid is insoluble in water and forms a layer floating on the water surface (it has a specific gravity of
less than 1), then it is an organic material and does NOT need to be tested for cyanide and sulfide. In
addition, since its specific gravity is LESS than 1 it cannot be chlorinated hydrocarbon; all of which have
a specific gravity GREATER than 1. Since it could be an organic acid, the pH must be measured by
preparing an aqueous extract with deionized water, as the pH of an acid cannot be determined without adding
a small quantity of water.
If an insoluble liquid sample has a specific gravity GREATER than 1, it is most likely a chlorinated
hydrocarbon. In this case, proceed directly to the copper wire test or PCB test kit, if applicable.
If the pH of a sample is LESS than 7, the sample cannot contain sulfide or cyanide (neither is stable in an
acid solution). Hence neither the sulfide test nor the cyanide test needs to be performed.
If a sample gives a positive oxidizer test, it cannot be sulfide or cyanide (the sulfide would have been
oxidized to sulfate and the cyanide to cyanate.
12.0 REFERENCES
Turkington, R. 1995. HAZcat Abridged Manual for Field Use. San Francisco.
Turkington, R. 1995. HAZcat Chemical identification User's Manual. San Francisco: 1994.
Ecology and Environment. 1988. "Field Chemistry for First Responders."
13.0 EXHIBITS
Exhibit 7-1 Water Solubility Test Chart
Exhibit 7-2 Oxidizer/Acid Test Chart
Exhibit 7-3 HAZcat Chemical Identification System
Exhibit 7-4 Hazardous Categorization Data Sheet
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Standard Operating Procedures
Colorado Department of
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Exhibit 7-1
Water Solubility Test Chart
ForUquids:
1. Add 1/2 inch of water (use Water Solubffily Test) to a test tube.
Z Marie thetop of the waterwith a water-proof marfangpen.
3. Add MZ inch of the unknown (quid. ;
4. Nota if the water is stiD at the fine.
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Sulfuric Add
Procedure No. 7
Revision: 0
Date: 01/2000
Page 13 of 17
I:\QAPP\SOP\SOP 07.wpd
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Standard Operating Procedures Procedure No. 7
Colorado Department of Revision: 0
Public Health and Environment Date: 01/2000
Page 14 of 17
Exhibit 7-2
Oxidizer/Acid Test Chart
Viti A Wl WIMI I
SMdyechot
kiAddTest
Nl-^ Hydraaw,
Amines, Ammeni*
G-e
CoppefSaK J Mangsoew
Chrcmiuni
Propyl TWcoyl
jil- ฆJ.lri ซ.'.<ฆ
uBonoe cnonoe
I:\QAPP\SOP\SOP 07.wpd
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 7
Revision: 0
Date: 01/2000
Page IS of 17
Exhibit 7-3
HAZcat Chemical Identification System
Copper Cyanide Test (Uncolored Copper Salts)
1. Break the glass tips off a Hydrogen Cyanide Sensidyne Tube #12L and insert the indicator tube into the Sensidyne
pump with the arrow pointing toward the pump.
2. Add Vi a pea sized amount of the unknown solid to a test tube.
3. Heat the unknown over a torch flame until it begins to change color.
4. Set the Sensidyne pump for 10. Line up the arrows and pull the handle on the pump all the way out until it
catches.
5. Put the end of the indicator tube into the head space of the test tube.
6. Observations: Yellow to red indicator tube color change: Copper cyanide.
This test is qualitative. Quantitative results (scale readings) require a specific number of strokes.
CYANIDE TEST
This test is definitive for inorganic cyanide salts. Cyanide solids and solutions are associated with the mining industry,
metal plating, electronic circuit board manufacturing, jewelry casting and the reclamation of precious metals. It is used
as a rat fumigant by some health jurisdictions. Cyanide salts are basic and non-volatile. Generally these salts are an
ingestion hazard until they become acidic (pH<7) at which time a significant amount of cyanide gas is given off. At
low levels, about one in ten people can smell the cyanide gas as a chlorine-type odor. Larger amounts of cyanide gas
are detected as an almond odor.
Cyanide Test 1 (ferrous ammonium citrate) is an unstable solution and must be rejuvenated with Cyanide Test 2
(ferrous ammonium sulfate) before the test is performed. The rejuvenated reagent solution should be a forest green
color.
This test requires two test tubes.
1. a. Dissolve Vz a pea-sized amount of the unknown solid in a test tube containing lA inch of water;
b. Add V2 inch of the unknown liquid to a test tube.
2. In a separate test tube, add a pinch of Cyanide Test 2 solution to % inch of Cyanide Test 1 solution.
3. Add the Cyanide Test 1 and 2 solution to the test tube containing the unknown solution.
4. Stopper the test tube containing the unknown and the Cyanide Test solution with a rubber stopper and shake the
test tube gently.
5. Remove the stopper and add several drops of Acid Test (3N hydrochloric acid) to the solution.
6. If the mixture remains yellow, add several more drops of the Acid Test to be sure that there will be no color
change.
7. Observations:
Dark Prussian blue color change after the addition of the acid: Cyanide. (If cyanide is present, the solution will
become a deeper blue as more acid is added.) Any blue color indicates the presence of cyanide.
EVAPORATION TEST
Warning: Quickly evaporating liquids are dangerous because of their potential as fire and inhalation hazards.
This is a screening test and an observation. The results are dependent on the temperature and humidity; liquids will
evaporate more rapidly on dry, warm days. If an unknown liquid has no odor and evaporates rapidly, it is particularly
dangerous because exposure can occur without warning. If there is significant evaporation, it will be obvious.
- or -
I:\QAPP\SOP\SOP 07.wpd
Copyright 1993. HazTech Systems, Inc. 155 Yosemite Ave., Unit 16, San Francisco, CA 94124(415)822-5775
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Standard Operating Procedures Procedure No. 7
Colorado Department of Revision: 0
Public Health and Environment Date: 01/2000
Page 16 of 17
Exhibit 7-3 (continued)
HAZcat Chemical Identification System
Metallic oxidizing chromates and permanganates give positive interferences during this test. These materials are
brightly colored inorganic salts. Benzoyl peroxide is a white crystalline or granular material which can be negative on
both the Oxidizer Test and the Peroxide Test. (Benzoyl peroxide can also be the active ingredient in pastes which are
not white.)
Crystals on Container Test
This test must be used to test crystals at the top of a bottle or container for explosive peroxides. Crystals may not always
be visible. Do this procedure carefully. Sensidyne/Haztech does not suggest opening containers of unknown materials.
1. Without removing the cap, use a wash bottle to wash or soak the inside rim of the container cap. Do not move
or shake the bottle. Flush water under the cap area to dampen the crystals. (Flushing works better if a
methanol/water solution is used to lower the surface tension.)
2. Touch the Peroxide Test strip to the underside of the wet cap or wet crystals.
3. Observations:
Any color toward blue: Dangerous peroxides are present. Do not open these containers!
Peroxide Test
1. Wet Peroxide Test strip with one drop of Water Solubility Test (distilled water).
2 Touch the wet Peroxide Test strip to the unknown.
3. Observations:
a. Blue: Peroxide or weak chromic acid.
b. Green: Very strong peroxide. If the Peroxide Test strip was not wetted, organic peroxides will turn the
paper green.
c. Brown: Strong chromic acid or very strong peroxide.
d. Yellow: Nitric acid.
e. Orange: Hypochlorite.
f. Purple: Silver nitrate.
Alternate Test
1. Make a Peroxide Test solution by adding XA inch of Arsenic Test 3 (potassium iodide) to lA inch of Asbestos Test
A4 (glacial acetic acid).
2. a. Add a pea-sized amount of the unknown solid to the Peroxide Test solution.
- or -
b. Add V* inch of the unknown liquid to the Peroxide Test solution.
3. Observations:
Clear to yellow or brown color change: Peroxides.
PHENOL GAS TEST
This is a definitive test for phenol and other volatile phenolic compounds. Phenol is usually shipped in large containers .
or in tank trucks as a 90% phenol solution.
.1. Break the glass tips off a Phenol Sensidyne Tube #60 and insert the indicator tube into the Sensidyne pump with
the arrow pointing toward the pump.
2. a. Add Vi a pea-sized amount of the unknown solid to a test tube;
- or -
b. Add '/4 inch of the unknown liquid to a test tube.
3. Set the Sensidyne pump for 10. Line up the arrows and pull the handle on the pump all the way out until it
catches.
I:\QAPP\SOP\SOP 07.wpd
Copyright 1993. HazTech Systems, Inc. 155 Yosemite Ave., Unit 16, San Francisco, CA 94124(415)822-5775
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
SDWA Safe Drinking Water Act
TCLP Toxicity Characteristic Leaching Procedure
TDU Treatment/Disposal Unit
TSCA Toxic Substances Control Act
SOP Standard Operating Procedure
3.0 IDENTIFICATION AND CHARACTERIZATION OF INVESTIGATION DERIVED
WASTES
To properly deal with IDW, the Project Leader (PL) must identify whether IDW contains Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA) hazardous substances, and if so,
whether these CERCLA hazardous substances are RCRA hazardous wastes. The PL will estimate the type,
quantity and characteristics of any IDW that will be generated during the activity. Additionally, the PL will
determine if CDPHE will manage and dispose of the IDW or if a subcontractor will be in charge of the
disposal of the IDW (i.e., a hazardous waste broker or a driller disposing of soil cuttings and well
development waters after a well has been installed). If a subcontractor is chosen to dispose of IDW, the
contractual agreement should clearly indicate all tasks of the work assignment.
3.1 Types of IDW
Typical types of IDW include, but are not limited to, the following:
Soil cuttings, drill mud and well development waters from soil borings and the installation
of monitoring wells;
Purge water removed from wells before groundwater samples are collected;
Water, solvents, or other fluids used to decontaminate field equipment and personal
protective equipment (PPE); and
PPE and disposable equipment.
3.2 CERCLA Hazardous Substances and RCRA Hazardous Wastes
The PL must make a professional judgement based on all available information when making a
decision whether the IDW contains a CERCLA hazardous substance, and if it does, whether that
substance is a RCRA hazardous waste. The PL may consider the IDW hazardous even if there is a
limited amount of information available. This is particularly important because the presence of
RCRA hazardous IDW invokes special technical considerations and management decisions based
on RCRA regulations (i.e., land disposal restrictions (LDR) and discharge to publicly owned
treatment works (POTWs)).
CERCLA hazardous substances include, in addition to all RCRA hazardous wastes, elements,
compounds, solutions, or mixtures designated as hazardous or toxic under CERCLA or under the
authority of other laws such as Toxic Substances Control Act (TSCA), the Clean Water Act (CWA),
Procedure No. 8
Revision No.: 0
Date: 01/2000
Page 2 of9
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Standard Operating Procedures Procedure No. 8
Colorado Department of Revision No.: 0
Public Health and Environment Date: 01/2000
Page 1 of9
- STANDARD OPERATING PROCEDURE - 8
INVESTIGATION DERIVED WASTE MANAGEMENT
1.0 PURPOSE
This procedure outlines the management of Investigation Derived Wastes (IDW) generated during
environmental field operations. The National Contingency Plan (NCP) requires that management of IDW
generated during environmental investigations complies with all applicable or relevant and appropriate
requirements (ARARs) to the extent practicable. In addition, other legal and practical considerations may
affect the management of IDW.
2.0 DEFINITIONS AND ABBREVIATIONS
2.1 Definitions
Container: A portable device in which a material is stored, transported, treated, disposed of or
otherwise handled.
Unit: A continuous area of land on or in which hazardous waste (i.e., containers) is placed.
AOC: A single Resource Conservation and Recovery Act (RCRA) land-based unit that can include
a non-discrete land area on or in which there is generally dispersed contamination.
2.2 Abbreviations
AOC
Area of Contamination
ARARs
Applicable or Relevant and Appropriate Requirements
CAA
Clean Air Act
CERCLA
Comprehensive Environmental Response, Compensation, and Liability Act
CFR
Code of Federal Regulations
CWA
Clean Water Act
ERB-OSC
Emergency Response Branch On-Scene Coordinator (EPA employee)
FR
Federal Register
IDW
Investigation Derived Wastes
LDR
Land Disposal Restrictions
NCP
National Contingency Plan
NPDES
National Pollution Discharge Elimination System
PL
Project Leader
POTW
Publicly Owned Treatment Works
PPE
Personal Protective Equipment
RCRA
Resource Conservation and Recovery Act
SAP
Site Assessment Manager (EPA employee)
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Standard Operating Procedures Procedure No. 7
Colorado Department of Revision: 0
Public Health and Environment Date: 01/2000
Page 17 of 17
Exhibit 7-4
Hazardous Categorization Data Sheet
Project Name: Date:
Project Number: Sample ID No.:
Notes:
OBSERVATIONS:
TEST:
Container Type: Vat
Drum Container
pH: (Circle Range)
Material: Steel
Glass Poly Fiber
pH > 7 Base
Top: Open
Bung
pH > 12.5 Corrosive Base
Size:
gallons
pH < 7 Acid
Amount: Empty
Half Full ( %)
pH < 2 Corrosive Acid
Sample Matrix: Solid
Sludge Liquid Gas
Sulfide Test: (Perform if pH > 7)
Viscosity: Water
Like
Coats Thick
Surface Syrup
Test Strip: Darkens Not Darken
(sulfides) (no sulfides)
Color:
Cyanide Test: (Perform if pH > 7)
# of Phases:
Odor:
Liauid Solid
Test Strip: Color change No color
or Precipitate Change
(no cvanide") fcvanids)
Flammability.Test/BIC Test
WATER SOLUBILITY TEST: (Add sample to H20)
PID Reading:
Temperature change: Yes
No
Circle one .
Effervescence or gases: Yes No
Flammable: Sample ignites rapidly and
gives PID > 200
Dissolves Won't dissolve
(soluble) (insoluble)
2 or more phases
(immiscible)
Combustible: Sample ignites and sustains
flame, PID < 200
Specific gravity: sinks (S.G> 1) floats (S.G. < 1)
Non-flammable: Sample does not ignite or
burn
Oxidizer Test: (Perform on H20 solubles only)
Notes:
Color change No color change
(oxidizer) (not oxidizer)
Chlorinated Hydrocarbons: .
(Perform only on insolubles or S.G. > 1)
Peroxide Test: (circle one) ,
Flame color: green yellow clear
(chlorinated (amines) (none)
solvent)
Blue: Peroxide or weak chromic acid
Green: Very strong peroxide
Brown: Strong chromic acid/peroxide
Yellow: Nitric acid
Orange: Hypochlorite
Purple: Silver nitrate
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 8
Revision No.: 0
Date: 01/2000
Page 3 of9
the Clean Air Act (CAA), and the Safe Drinking Water Act (SDWA). A list of these hazardous
substances can be located in 40 CFR Part 302.4, Table 302.4. If the IDW contain CERCLA
hazardous substances, the determination must be made if these hazardous substances constitute the
criteria of a RCRA hazardous waste.
IDW is a RCRA hazardous waste if the IDW contains a listed hazardous waste as defined in Section
3.2.2, RCRA Listed Hazardous Wastes, or if the IDW exhibits any of the hazardous waste
characteristics as described in Section 3.2.1, RCRA Characteristic Wastes. Additionally, the
contaminants present in the IDW must not be excluded from regulations as a hazardous waste (40
CFR 261.4).
3.2.1 RCRA Characteristic Wastes
IDW is a RCRA characteristic hazardous waste if it exhibits the characteristics of
ignitability, corrosivity, reactivity (40 CFR Part 261, Subpart C), or toxicity (toxicity
characteristic leaching procedure (TCLP) (55 FR 11796-11877, March 29, 1990)).
IDW exhibits ignitability if:
It is a liquid, other than an aqueous solution containing less than 24% alcohol by
volume, and has a flash point lower than 60ฐC (140ฐF);
It is not a liquid and is capable, under standard temperature and pressure, of causing
fire and, when ignited, creating a hazard;
It is an ignitable compressed gas as defined in 49 CFR 173.300; or
It is an oxidizer as defined in 49 CFR 173.151.
IDW exhibits corrosivity if:
It is aqueous and has a pH less than or equal to 2 or greater than or equal to 12.5;
or
It is a liquid and corrodes steel at a rate greater than 6.35 mm (0.3 5 inches) per year
at a test temperature of 55 ฐC (133 ฐF).
IDW exhibits reactivity if:
It is normally unstable and readily undergoes violent change without detonating;
It reacts violently with water;
It forms potentially explosive mixtures with water;
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 8
Revision No.: 0
Date: 01/2000
Page 4 of9
When mixed with water, it generates toxic gases, vapors or fumes that pose danger
to human health or the environment;
It is a cyanide- or sulfide-bearing waste capable (at the pH range of 2 to 12.5) of
generating toxic gases that can present a danger to human health or the environment;
It is capable of detonation or explosive decomposition; or
It is a forbidden explosive as defined in 49 CFR 173.51.
IDW exhibits TCLP-toxicity when its leachate contains certain contaminants at levels
exceeding their regulatory thresholds. The TCLP-toxicity test is designed to determine the
mobility of both organic and inorganic contaminants present in liquid, solid and multiphasic
wastes.
3.2.2 RCRA Listed Hazardous Wastes
Any type of IDW that contains a listed hazardous waste should be considered a RCRA
hazardous waste. A list of RCRA hazardous wastes according to their sources of origin and
toxicity is found in 40 CFR Part 261, Subpart D.
Wastes from nonspecific sources (F-wastes);
Wastes from specific sources (K-wastes);
Discarded commercial chemical products, manufacturing intermediates, off-
specification (off-spec) chemicals(if they met specification, they would be listed),
and container and spill residues that are "acutely hazardous" (P-wastes); and
Discarded commercial chemical products, manufacturing chemical intermediates,
or off-spec commercial chemical products that are "toxic" (U-wastes).
3.3 Waste Characterization
Whenever possible, the nature of the wastes should be assessed by applying the best professional
judgement, and using readily available information about the site (observation of contamination,
waste manifests, storage records, PAs, Sis, or any other sampling data). The EPA has directed that
IDW may not be a "listed" waste under RCRA unless available information about the site suggests
otherwise (53 FR 51444, December 21,1988). RCRA procedures for determining whether a waste
exhibits RCRA hazardous characteristics do not require testing if the decision can be made by
"applying knowledge of the hazard characteristics in light of the material process used" (40 CFR
262.11(c)).
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Standard Operating Procedures Procedure No. 8
Colorado Department of Revision No.: 0
Public Health and Environment Date: 01/2000
Page 5 of9
The fact that extensive resources need not be used in characterizing IDW does not mean that IDW
can be assumed to be non-hazardous unless clearly proven otherwise. The PL must make the best
informed decision with limited information on whether the wastes are hazardous or not.
When readily available information can not be used, one or more samples will be collected and
submitted to a laboratory for characterization. Specific analyses for the characterization of the IDW
will be determined by a hazardous waste broker, a subcontractor, or the PL, ASM, and EPA-OSC.
Upon receipt of the characterization sample(s), the PL will define disposal options as per the analyses
of the waste characterization samples.
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Standard Operating Procedures Procedure No..8
Coloradi Department of Revision No.: 0
Public Health and Environment Date: 01/2000
Page 6 of9
4.0 IDW Management Options
TABLE 1
IDW Management Options
Type of IDW
Generation Process
Management Options
Non-hazardous
CERCLA or RCRA Hazardous ,
Soil
Well/test pit installation
Borehole drilling
Soil sampling
'
Return to boring, pit or source after
generation.
Spread around or consolidate in boring, pit
or source in the AOC.
Store in a container within the AOC.
Send to on-site TDU.
Send to off-site TDU.
Sludges/Sediments
Sludge pit/sediment sampling
Return to boring, pit or source after
generation.
Spread around or consolidate in boring, pit
or source in the AOC.
Store in a container within the AOC.
Send to on-site TDU.
Send to off-site TDU.
Store for future treatment and/or disposal.
Aqueous sampling
(groundwater, surface water,
drilling fluids, other
wastewater)
Well installation/development
Well purging during sampling
Groundwater discharge pump test
Surface water sampling
Discharge to surface water.
Pour on ground near sampling point.
Send to POTW.
Store in a container within the AOC.
Send to on-site TDU.
Send to off-site TDU.
Send to POTW(,).
Store for future treatment and/or disposal.
Decontamination Fluids
Decontamination of PPE and equipment
Evaporate (small amounts of low organic
fluids).
Pour on ground near AOC.
Send to POTW.
Store in a container within the AOC.
Send to on-site TDU.
Send to off-site TDU.
Send to POTWป>.
Store for future treatment and/or disposal.
Disposable PPE
Sampling procedures or other on-site activities
Place in dumpster at site or at CDPHE.
Store in a container within the AOC.
Send to on-site TDU.
Send to off-site TDU.
AOC = Area of Contamination
TDU = Treatment/Disposal Unit
POTW'" = Publicly Owned Treatment Works (see Section 5.3)
PPE = Personal Protective Equipment
75.50906.00
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 8
Revision No.: 0
Date: 01/2000
Page 7 of 9
4.1 OFF-SITE DISPOSAL OF IDW
IDW should be disposed off-site in the following situations
They are RCRA hazardous water;
They are RCRA hazardous soil that may pose a substantial risk if left at the site;
They are RCRA hazardous PPE and disposable equipment; and/or
If leaving them on-site would create increased risks at the site.
IDW designated for off-site disposal must be properly containerized, tested, and stored before
transport and disposal.
5.0 GUIDELINES FOR MANAGEMENT OPTIONS
When managing IDW, the PL is required to choose an option that is protective of human health and the
environment and complies with (or waives) ARARS.
5.1 Protectiveness
In determining if a particular management/disposal option is protective, the PL should consider the
following:
The contaminants, their concentrations, and the total volume of the IDW;
Media potentially affected (i.e., soil or groundwater) under management options;
Location of the nearest populations and the likelihood and/or degree of site access;
Compliance with ARARs to the extent practicable on site;
Potential exposure to workers if IDW is managed on site; and
Potential for environmental impacts.
5.2 Compliance With ARARs
This SOP is not designed to guide the PL through the entire disposal process of IDW. Please refer
to all applicable ARARs when designing the disposal plan for the IDW.
75.50906.00
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 8
Revision No.: 0
Date: 01/2000
Page 8 of9
5.3 Compliance "With POTWs
Discharge of any and all (i.e. purge water, decontamination water etc.) derived water to a POTW
must comply with both substantive and administrative CWA requirements. These requirements
include, but are not limited to water quality criteria, pre-treatment standards, state water quality
standards, and National Pollution Discharge Elimination System (NPDES) permit conditions.
6.0 Disposal of IDW
Disposal of IDW will be conducted under direction of the CDPHE PL. When applicable, CERCLA or RCRA
hazardous waste disposal options will be conducted in the following order.
6.1 Subcontractor Disposal
When IDW is generated by the activities of a subcontractor (i.e., driller), it should be noted prior to
contractual arrangements that the subcontractor will contain, stage, characterize and dispose of all
IDW generated fort he activity. This needs to be identified in the RFP before the contract goes out
to bid.
6.2 Hazardous Waste Broker Disposal
When a subcontractor is not responsible for the generation of the IDW, a hazardous waste broker
may be used. Hazardous waste brokers generally collect characterization samples, submit for
analyses and delegate the appropriate form of disposal for the IDW as per the characterization
results. Details for this process should be clarified prior to the generation of the IDW, as time limits
apply for the storage of IDW when it is found to be a RCRA or CERCLA hazardous waste. A
general guideline is to allow a maximum of 90 days from the date of IDW collection to the date for
disposal or transport off-site. Hazardous waste brokers potentially supply drums and containers for
waste storage and sample collection, however, a secured location on-site needs to be procured, as
the transportation of RCRA or CERCLA hazardous wastes is regulated by the state and federal
Departments of Transportation.
6.3 CDPHE Disposal
When appropriate, CDPHE will be in charge of all sample collection for characterization, laboratory
procurement for analyses, analytical interpretation, and disposal options as per ARARs.
7.0 REFERENCES
U.S. Environmental Protection Agency (EPA). June 1989. "Determining When LDRs are Applicable to
CERCLA Response Actions. OSWER Directive 9347.3-05FS
U.S. Environmental Protection Agency (EPA). December 1989. "Determining When LDRs Are Relevant
and Appropriate to CERCLA Response Actions. OSWER Directive 9347.3-08FS.
75.50906.00
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 8
Revision No.: 0
Date: 01/2000
Page 9 of9
U.S. Environmental Protection Agency (EPA) 1991. "Management of Investigation Derived Wastes During
Site Inspections." EPA/540/G-91/009, U.S. Environmental Protection Agency. Washington, D.C. May
1991.
U.S. Environmental Protection Agency (EPA). 1992. "Guide to Management of Investigation Derived
Wastes." OSWER Directive 9345.3-03FS, April 1992. U.S. Environmental Protection Agency, Office of
Solid Waste and Emergency Response.
75.50906.00
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 9
Revision No.: 0
Date: 01/2000
Page 1 of 10
STANDARD OPERATING PROCEDURE - 9
MONITOR WELL INSTALLATION
1.0 PURPOSE
The purpose of this procedure is to describe the methods for groundwater monitor well installation. It
describes designs, procedures, and materials that will be used to construct a monitor well that will produce
accurate groundwater level measurements and representative groundwater samples.
This procedure provides guidance for routine field operations on environmental projects. Site-specific
deviations from the methods presented herein must be approved by the Colorado Department of Public Health
and Environment (CDPHE) Project Leader and the Quality Assurance Officer.
2.0 DEFINITIONS AND ABBREVIATIONS
2.1 Definitions
Annulus/Annuler Space: The space between the borehole wall and well casing, or the space between
a casing pipe and liner pipe.
Bridging. The development of gaps or obstructions in either grout or filter pack materials
during emplacement or development.
Conductor Casing: Outer casing used to stabilize or seal off a formation to prevent
formation collapse or vertical cross-contamination within the well.
Filter Pack. Sand, gravel, or glass beads that are uniform, clean, and well rounded that are
placed in the annulus of the well between the borehole wall and the well intake to prevent
formation material from entering through the well intake, and to stabilize the formation.
Grout. A fluid mixture of neat cement and water possibly with various additives or
bentonite of a consistency that can be forced through a pipe and emplaced in the annular
space between the borehole and casing to form a seal.
Pressure Grouting/Sealing-. A process by which a grout is confined within the borehole or
casing by the use of plugs or packers and by which sufficient pressure is applied to force the
grout slurry into and within the annuler space or zone to be grouted.
Schedule Pipe: The standardization of casing diameters and wall thicknesses where casing
wall thickness increases as the schedule number increases.
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 9
Revision No.: 0
Date: 01/2000
Page 2 of 10
Screen/Well Intake: A screening device used to keep materials other than formation fluids
from entering the well.
Slot Size: The width of the slots machined into a slotted well casing (screen) that allows
formation fluids into the well.
2.2 Abbreviations
ANSI American National Standards Institute
EPA U.S. Environmental Protection Agency
ID Inside diameter
PVC Polyvinyl chloride
SOP Standard Operating Procedures
3.0 RESPONSIBILITIES
Field personnel are responsible for performing the applicable tasks in accordance with this procedure when
conducting work related to environmental projects.
The Project Leader or an approved designee is responsible for checking all work performance and verifying
that the work satisfies the standards required by this procedure. This will be accomplished by reviewing all
documents (Exhibits) and inspecting the actual work. All activities and data collected shall be recorded in
the field log book.
4.0 PROCEDURE
4.1 Introduction
Specific Project Plans may have well specifications that differ from the design specifications
presented in this procedure. In addition, licensing and/or certification of the driller may be required.
Well construction procedures will fulfill all regulatory agency requirements.
The diameter of the exploratory boring is generally a minimum of six inches greater than the outside
diameter of the well casing. This is to ensure adequate filter pack settling so that the potential for
bridging during well construction is minimized.
Contamination of the water bearing zone by drilling equipment or cross-contamination of wells
during the drilling process must be avoided. Vertical seepage of surface water into the monitoring
well must also be minimized.
In order to maintain quality control and obtain accurate formation information, a field geologist will
be on the site during well installation to log subsurface conditions and construction details for each
well.
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Standard Operating Procedures
Colorado Department of
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Procedure No. 9
Revision No.: 0
Date: 01/2000
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4.2 Precautions
Use the following precautions during well installation operations:
All activities will be conducted in conformance with the Site Health and Safety Plan;
Every attempt should be made to minimize the transfer of potentially contaminated material
to downhole equipment and monitoring well materials, or to any equipment and supplies
stored on the site; and
Every attempt should be made to contain contaminated soil and water and prevent
further contamination of the environment.
4.2.1 Cutting Containment
Potentially contaminated formation materials brought to the surface during
drilling activities will be placed on heavy plastic (12 mm minimum
thickness) or plywood, or directly into drums to prevent contamination of
the surface area surrounding the borehole. Plastic should be thick enough
to prevent puncturing by formation materials, ground surface or removal
activities. Materials placed on plastic or plywood for an extended period
of time should be covered to provide protection from the elements until they
can be disposed of properly.
4.3 Decontamination
All equipment that might potentially spread contamination or that is used directly in the monitoring
well installation (i.e., well casing, screen, tremie pipe, centralizers, augers, etc.) must be thoroughly
decontaminated prior to use or installation in the well. Decontamination equipment such as steam
cleaners and high pressure, hot water cleaners effectively remove potential contaminants left on
casings and screens during the manufacturing process. When using polyvinyl chloride (PVC) screen
or casing, acid rinse solutions should not be employed for decontamination. All other,
decontamination procedures will conform with specific protocols outlined in the Field Sampling Plan
and CDPHE SOP 4.11, Equipment Decontamination.
Decontaminated materials that are not used immediately after decontamination should be stored
under protective cover (e.g., aluminum foil or plastic sheeting) until used.
4.4 Well Installation and Materials
Materials used in the construction of monitor wells will be chemically nonreactive to the
contaminants suspected to be in the groundwater. The most commonly used well construction
materials are PVC and stainless steel. PVC is the most economical and the easiest material to use.
PVC will not decompose when it comes into contact with groundwater containing low concentrations
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Standard Operating Procedures
Colorado Department of
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Procedure No. 9
Revision No.: 0
Date: 01/2000
Page 4 of 10
of organic materials. However, over time, high organic contaminant concentrations will react with
PVC and cause casing decomposition. Stainless steel provides greater structural strength and its use
may prove advantageous for large diameter wells.
Well casing and screen are available in threaded and unthreaded sections, typically in lengths of 5,
10, and 20 feet. Threaded pipe joints will be wrapped with Teflonฎ tape to facilitate joining and to
improve the seal of stainless steel products. Sections of casing and screens will be assembled on the
site to allow inspection immediately before installation. PVC connections must be flush threaded
or connected by another mechanical method as PVC joint sealant will introduce organic contaminants
into the well.
Monitoring well construction commonly requires the use of American National Standards Institute
(ANSI) Schedule 40 or Schedule 80 pipe to complete monitoring wells. Schedule 40 pipe is a
standard size pipe with a wall thickness of 0.154 inches and an approximate inside diameter (ID) of
2.067 inches. Schedule 80 pipe has a wall thickness of 0.218 inches and an approximate ID of 1.939
inches. Schedule 40 pipe is suitable for most shallow monitoring well applications (total depth less
than 100 feet). Schedule 80 pipe is more suitable for wells with depths in excess of 100 feet or in
wells to be completed in formations with known swelling properties that could lead to casing
collapse.
4.4.1 Well Screen
The purpose of the well screen is to allow sediment-free groundwater to enter the well. The
slot size of the well screen is based on filter pack material selection. Both the screen and
filter pack material are related to the grain size analysis of the aquifer. Methods for
determining appropriate screen slot and filter pack sizes are available in the U.S.
Environmental Protection Agency (EPA) Handbook (U.S. Environmental Protection Agency
(EPA) 1991) and in "Groundwater and Wells" (Driscoll 1986). Selection of screen slot and
filter pack sizes will be determined by industry-wide accepted methods.
For monitoring well construction, two major types of screens are used: continuous slot wire
wrap screen, and slotted pipe. Wire wrap provides the greatest open area resulting in higher -
yields. However, it is significantly more expensive than slotted pipe. Continuous slot wire
wrap screen would be most effective when used to sample low yield formations.
Slotted pipe is composed of the same Schedule 40 or Schedule 80 casing pipe, but it has
been machined to create uniform openings. Slotted pipe has a smaller effective open area
than continuous slot wire wrap screen, but it is usually adequate for wells installed in
relatively shallow, permeable formation aquifers. The effective open area should be at least
2.70 square inches per lineal foot for 10-slot, 2-inch slotted pipe, and 4.50 square inches per
lineal foot for 20-slot, 2-inch slotted pipe.
Screen length will vary depending on site conditions, but for monitoring well installation,
lengths vary from 10 to 20 feet.
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 9
Revision No.: 0
Date: 01/2000
Page 5 of 10
4.4.2 Well Filter Pack
The purpose of the well filter pack is to provide lateral support for the well screen, increase
yield by improving the hydraulic conductivity in the immediate vicinity of the well, and
retain the formation to prevent natural materials from entering the well. Filter packing
allows for the use of larger screen slot openings, which in turn increases well recharge rates.
The materials used to construct the filter pack will be chemically inert (e.g., clean quartz
sand, silica, or glass beads), well rounded, and dimensionally stable.
Clean and properly packaged silicon sand is the most commonly used pack material and
should consist of 90-95% quartz grains. The filter pack should uniformly envelope the well
screen with a thickness of no less than three inches or more than eight inches.
Pack size should be such that it retains 90% of the surrounding formation while the screen
slot size must retain 90% of the filter pack.
4.4.3 Well Seal
The materials used to seal the annulus between the borehole wall and casing must prevent
contaminant migration from ground surface or intermediate zones and must prevent cross-
contamination between strata. The materials will be chemically nonreactive to the
contaminants found on the site so they do not affect the quality of the groundwater samples.
The permeability of the sealants should be one to two orders of magnitude less than the
surrounding formation.
The seal material will be bentonite pellets and/or a slurry of bentonite and clean sand. The
actual mixture of the materials to be used in any boring will be determined in the field and
will be based on drilling and sampling data. Typically, a seal of bentonite pellets with a
thickness of at least two feet is installed above the filter pack to more effectively seal the
screened section of the well and to prevent the intrusion of overlying cement or cement
bentonite grout material into the filter pack.
4.4.4 Annulus Backfill
The annular space above the filter pack and seal is grouted with a bentonite,
bentonite/cement mixture or cement grout with shrinkage reducer. Grouting is used to
minimize the vertical migration of water to the groundwater intake zone and to increase the
integrity and stability of the well casing.
The cement grout will consist of no more than six gallons of potable water per 94-pound bag
of cement. If sand aggregate is used, the mixture will be two parts of aggregate by weight
to one part cement with no more than six gallons of potable water per 94-pound bag of
cement. For bentonite/cement mixture grouts, three-to-five pounds of bentonite should be
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Standard Operating Procedures
Colorado Department of
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Procedure No. 9
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mixed with 6.5 gallons of water per 94-pound bag of cement. Cement grout should be
mixed thoroughly and be free of lumps. After grouting, the well should not be disturbed or
be developed for a minimum of 24 hours.
4.5 Well Installation
Monitor well construction will be similar to the diagram in Exhibit 9-1, Monitoring Well Installation
Log. Some exploratory borings may require partial backfilling prior to installation of the screen and
riser. The field geologist will determine the well depth and the screen setting for each well, as well
as the need for partial backfilling prior to well installation. Exhibit 9-1, Monitoring Well Installation
Log, will be used to record well construction data.
Backfill materials will consist of bentonite pellets and/or bentonite slurry and clean sand. Due to the
high pH and ion exchange capacity of bentonite and the related potential for change in groundwater
chemistry, special care must be taken to ensure that the backfill and well screen are not in close
proximity. Therefore, construct the well in such a manner that a minimum of one to two feet of filter
pack is placed between the backfill and well screen. The actual mix of the materials to be used in
any boring will be determined in the field based on drilling and sampling data. The depths of
placement of all annulus well materials will be determined by the field geologist, based on the
observed subsurface conditions at each well boring location. The drill crew will constantly monitor
backfill depths to the satisfaction of the field geologist by means of a weighted steel or plastic
measuring tape.
Shallow depth (less than 50 feet deep) exploratory borings and monitor wells are generally drilled
and installed with hollow stem auger methods. The well installation is accomplished by placing the
riser pipe and screen through the inside of the hollow stem augers. The borehole annulus will then
be backfilled through the hollow stem augers with clean filter pack material. The filter pack will be
added and the hollow stem auger sections will be sequentially removed from the borehole until the
filter pack is a minimum of two feet above the well screen. This process will be performed without
the addition of water.
After the depth to filter pack has been confirmed, bentonite pellet seal will be installed directly above
the filter pack at a minimum two feet thick. Distilled water will be added and the bentonite pellets
will be allowed to hydrate according to the manufacturer's instructions.
The installation procedure for monitor wells greater than 50 feet deep will consist of placing the riser
pipe and screen into the completed borehole and backfilling the annulus with clean filter pack
material. The borehole annulus will be backfilled to a minimum of two feet above the well screen.
The bentonite pellet seal will be installed directly above the filter pack at a minimum two feet thick.
Distilled water will be added and the bentonite pellets will be allowed to hydrate according to the
manufacturer's instructions.
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Standard Operating Procedures
Colorado Department of
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Procedure No. 9
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An accurate record of the quantity of distilled water that was added to the well during construction
must be noted on Exhibit 9-1, Monitoring Well Installation Log. The remainder of the boring
annulus will be backfilled with a cement/bentonite grout to within three feet of the ground surface.
When necessary, a permanent measuring point reference mark will be placed on the well casings of
completed wells. This mark will provide a consistent point from which to collect water level
readings. Typically this mark will be made when well elevations and locations are surveyed.
In cases when wells are drilled through a zone of known contamination into deeper water bearing
zones, the potential for contamination or downward contaminant transport via drilling activities
exists. In these cases, deep wells will be constructed in a manner that seals the upper contaminated
aquifer from the lower aquifer of unknown contaminant levels. Methods typically employed for this
procedure include the use of pressure grouting and conductor casing to seal zones of known
contamination. Once a seal is established, a borehole of smaller diameter may be drilled through the
conductor casing into the lower zone of unknown contaminant levels and general well installation
procedures may be followed in the lower aquifer.
The exact method for isolating a zone of known contamination may vary depending on site-specific
conditions. The field geologist and driller will decide the most appropriate method for aquifer
isolation and deep well completion based on site-specific field conditions.
4.5.1 Surface Seal Installation
A concrete surface seal will be placed around the annulus of the well to a minimum depth
of one foot or to the top of the bentonite/cement grout seal, whichever is deeper. Protective
steel casings (minimum four-inch diameter, four feet in length) equipped with locking caps
will be installed around the wells. Alternatively, stainless steel risers equipped with locking
caps may be substituted. Where protective casings are employed, two 1/4-inch diameter
holes will be drilled at the base of the protective casing at the ground surface to allow water
drainage from inside the casing. Three well guards or post protectors may be placed in a
radial pattern around each well if the Project Leader determines such protection is necessary
to prevent damage to the protective casing. The well guards will be located four feet from
the well, driven two-to-three feet below ground surface, and will rise three feet above the
ground surface. A concrete pad will be placed around the well on the ground surface. The
pad will be formed in such a manner as to direct surface moisture away from the base of the
protective steel casing.
Alternatively, if the well is located in an area where frequent vehicular traffic occurs, a
commercially supplied traffic rated box will be used as a protective well head or the well
may be installed flush with the ground surface. Appropriate locking mechanisms and locks
will be used to secure the well and prevent surface runoff from entering the traffic box flush
mount or well.
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Standard Operating Procedures
Colorado Department of
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Procedure No. 9
Revision No.: 0
Date: 01/2000
Page 8 of 10
4.6 Review
The Project Leader or an approved designee will check Exhibit 9-1, Monitoring Well Installation
Log, for completeness and accuracy. Any discrepancies will be noted and the log will be returned
to the originator for correction. The reviewer will acknowledge that these review comments have
been incorporated by signing and dating the "reviewed by" and "date" blanks on Exhibit 9-1,
Monitoring Well Installation Log.
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 9
Revision No.: 0
Date: 01/2000
Page 9 of 10
5.0 REFERENCES
CDPHE, 2000. Standard Operating Procedure 11, "Equipment Decontamination." Standard Operating
Procedures.
Driscoll, F. G. 1986. "Groundwater and Wells." Johnson Division, St. Paul, Minnesota.
U.S. Environmental Protection Agency (EPA). 1986. "RCRA Groundwater Monitoring Technical
Enforcement Guidance Document (T.E.G.D.)." OSWER-9950.1.
U.S. Environmental Protection Agency (EPA). 1991. "Handbook of Suggested Practices for the Design and
Installation of Groundwater Monitoring Wells." U.S. Environmental Protection Agency, Washington, D.C.
6.0 EXHIBITS
Exhibit 9-1 Monitoring Well Installation Log
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Standard Operating Procedures
Colorado Department of Procedure No. 9
Public Health and Environment Revision No.: 0
Date: 01/2000
Page 10 of 10
EXHIBIT 9-1
Monitoring Well Installation Log
WELL NUMBER:
DATE DRILLED: JLOCATION-
INSPECTED BY:
PROJECT;
COMMENTS;
JOB NO;
INSTALLED BY:
MONITORING WELL CONSTRUCTION DIAGRAM
Ground surface
elevation 1000.00 ft
Surface seal or apron
type: granular concrete mix
Protective casing
type: anodized steel
length: approximately 1 foot
ID: 4 inch
Backfill
type: bentonite grout
Well casing (riser pipe)
type: PVC
ED: 2 inch
Seal
type: bentonite pellets
Filter pack
type: washed quartz sand pack
si2e: #4 sand
Screen
type: slotted
slotsize:0.010 inch
ID: 2 inch
Bottom of well -
plug, screen, cup, or blank
specify: plug
Well casing (riser) elevation:
Top of seal elevation:
depth:
Top of filter pack elevation:
depth:
Top of screen elevation:
depth:
Bottom of screen elevation:
/ depth:
Bottom of well elevation:
depth:
Bottom of boring elevation:
total depth:
990.00 a
10.0 ft
988.00 ft
12.0 ft
986.00 ft
14.0 ft
976.00 ft
24.0 ft
976.00 ft
24.0 ft
975.50 ft
24.5 ft
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DATE COMPLETED: t/t/01
CASING (RISER) ID: 2 inch
SCREEN LENGTH: 10.0 ft.
SCREEN SLOT SIZE: 0.010 inch
ALL ELEVATIONS IN FEET ABOVE MEAN SEA LEVEL
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 10
Revision No.: 0
Date: 01/2000
Page 1 of7
STANDARD OPERATING PROCEDURE - 10
MONITOR WELL DEVELOPMENT
1.0 PURPOSE
The purpose of this procedure is to describe the methods used for developing groundwater monitor wells on
environmental site investigations. This procedure outlines the methods and advantages and disadvantages
of each method. Site-specific deviations from the methods presented herein must be approved by the
Colorado Department of Public Health and Environment (CDPHE) Project Leader and Quality Assurance
Officer.
2.0 DEFINITIONS AND ABBREVIATIONS
2.1 Definitions
Hydraulic Conductivity (K)\ A standardized measure of the flow of a liquid through a porous
medium. Hydraulic conductivity is generally expressed in terms of a unit hydraulic gradient so that
different rocks (media) can be compared against one another.
Hydraulic Gradient: A pressure gradient. Applied to an aquifer, it is the rate of change in pressure
head per unit distance of flow at a given point and in a given direction [Ft/Ft].
Permeability. Capacity of a rock or soil to transmit fluid, such as water, under an hydraulic gradient.
Turbidity: Cloudiness in water due to suspended and colloidal organic and inorganic material.
2.2 Abbreviations
ARARs Applicable or Relevant and Appropriate Requirements
PID Photo Ionization Detector
3.0 RESPONSIBILITIES
The personnel developing monitor wells are responsible for performing the applicable tasks outlined in this
procedure when conducting work related to environmental projects.
The Project Leader or an approved designee is responsible for checking all work performance and verifying
that the work satisfies the applicable tasks required by this procedure. This will be accomplished by
reviewing all documents (Exhibits) and data produced during work performance. All activities and data
collected shall be recorded in the field log book.
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4.0 PROCEDURES
Standard Operating Procedures
Colorado Department of
Public Health and Environment
4.1 Introduction
Monitor well development is the process of flushing the formation interface, and cleaning the filter
pack and the well screen slots to permit unimpeded flow of groundwater into the monitor well.
Water produced from a properly developed monitoring well is representative of formation water and
does not contain contaminants introduced during drilling and well construction or formation
materials loosened during well installation.
Development is necessary to repair damage done to the formation by drilling so that the natural
hydraulic properties are restored; to remove clays, silts, and fine sands (fines) from the filter pack
and well screen; and to remove any remnant drilling fluids or drilling-introduced contaminants.
Development of groundwater monitor wells is best accomplished by surging the well. This process
agitates the fine grain sediments and moves them into the well so that they may be removed. The
use of non-formation water for development is not advised but may be necessary under certain
conditions. Extreme care should be taken at all times to avoid damaging the borehole, filter pack
and/or well screen. Each well will be considered developed when the groundwater turbidity has
diminished to an acceptable level of clarity.
Table 1 presents the four major methods of monitor well development employed by CDPHE. The
major consideration for determination of a monitor well development method should be the lithologic
characteristics of the interval in which the well is screened. Logistic considerations should be
secondary. Methods can also be used in conjunction with any other method.
TABLE 1
Well Development Methods
Method
Best Application
Avoid "
' Mechanical Surging
(Surge Block)
Wells screened in lithologies of
medium to high porosities and
hydraulic conductivities
Wells screened in lithologies of
low permeability; i.e., clay
sand silts
Air Lift and Surge
(Compressed Air)
Wells screened in lithologies of
high hydraulic conductivity
Wells screened in permeable
lithologies with clay interbeds
Bailer
(Stainless Steel)
Wells screened in low
permeable formations
Deep or large purge volume
wells
Pumping
(Variety of High Volume
Pumps)
Deep or large volume wells
Wells screened in a
combination of high and low
permeability lithologies
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Standard Operating Procedures
Colorado Department of
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Procedure No, 10
Revision No.: 0
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During monitor well development, organic vapors will be monitored to evaluate the potential for fire,
explosion, and toxic effects on field personnel. The maximum sustainable flow (well yield) will be
determined, if required, and recorded on Exhibit 10-1, Well Development Data Summary, for each
monitor well. The well yield is the maximum sustainable rate, measured in gallons/minute, that the
well can be pumped at before the water level in the well falls below the screened interval. The water
level can be measured with the electric tape and the pumping rate can be adjusted until the
equilibrium is reached. Groundwater recovery data will be recorded on Exhibit 10-2, Aquifer Test
Data.
Temperature, Ph, conductivity and other field parameters can be measured during development, but
these have no real bearing on development. The purpose of development is to remove fines from
the well and produce clear water. Time spent properly developing a well is usually repaid during
sampling when groundwater chemistry stability is required.
4.2 Decontamination
All equipment used for monitor well development will be thoroughly decontaminated to minimize
possible cross-contamination of the well. Decontaminate equipment prior to use according to the
methods outlined in CDPHE SOP 4.11, Equipment Decontamination.
4.3 Mechanical Surging
A surge block is a round plunger, slightly smaller in diameter than the inside diameter of the well
screen. Development by mechanical surging produces good results in formations having medium
to high porosities and hydraulic conductivities. Development by this method is as follows:
Lower the surge block into the well to a point below the static water level;
Raise and lower the tool alternately with increasing stroke lengths. As water begins to move
easily both into and out of the screen, the surge block is lowered and the procedure resumed;
and
Periodically, use a bailer or pump to remove accumulated fines from the well. Development
should begin at the static water level and move progressively downward to prevent the surge
block from becoming sand locked.
Note: Surging of low-permeability formations can result in a collapsed screen, especially in wells
that use plastic screens. Clayey and silty formations in which screen slot sizes are smaller the 0.015
inch are particularly prone to screen collapse.
4.4 Air Lift and Surge
The air lift method involves using compressed air to alternately surge and pump the monitor well.
This development method produces best results in formations with high hydraulic conductivities and
is implemented as follows:
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Colorado Department of
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Procedure No. 10
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Lower an air line a few feet below the static water level to introduce air into the well. The
introduced air will blow water and suspended sediments upward and out of the well, and
allow formation water to flow into the well. Initial air pressure should be low to minimize
the possibility of screen collapse;
Lower the air line progressively into the well, waiting until the water reaching the surface
has clarified enough to indicate that the screened interval is developed before lowering the
air line;
Surging cycles may begin once the flow is established. Apply short pulses of high pressure
air into the well to accomplish surging. This has the effect of raising and lowering a column
of water within the screen, thus agitating any fine materials within the filter pack; and
Continue alternating surging and pumping cycles until the desired development is indicated
by clean purge water.
Note: Under some conditions, the aquifer or screen may become air locked when a large burst of
air is injected into the screened area. Certain formations are more prone to air locking, especially
formations which consist of stratified coarse material separated by thin impermeable clay layers. In
formations susceptible to air locking, air lifting should be avoided.
Due to the explosive nature of the water exiting the well casing during air lifting operations, care
must be taken to contain the discharged water. It is imperative that secondary contamination of
surrounding soil, equipment, and personnel does not occur.
4.5 Bailer
A bailer which is heavy enough to sink through the groundwater can be raised and lowered through
the water column to produce an agitating action similar to that of a surge block. The bailer has the
advantage of being able to remove turbid water and fines each time it is brought to the surface. The
bailer method is ideal for formations with low permeabilities as it generally will not produce
pressures great enough to cause well screen collapse. Bailing is generally not suitable for deep wells
or wells which produce large volumes of water.
4.6 Pumping
Pumping is the simplest method of removing fines from the water-bearing formation, filter pack, and
well screen. Pumping is performed at a rate higher than the recharge rate. While this method is
relatively simple, development action tends to take place in the most permeable zone or close to the
top of the well screen. Once the permeable zone has been developed, water tends to move
preferentially through these zones. This results in the rest of the well being poorly developed and
contributing only small volumes of water to the total yield. Pumping from low permeability
formations may compact the finer sediments around the borehole and restrict flow into the well
screen.
4.7 Water Containment
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Standard Operating Procedures
Colorado Department of
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Procedure No. 10
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All contaminated waters generated during well development must be contained and stored so as not
to pose a health and safety threat. Development water must be stored in approved containers or, in
the case of development water containing non-volatile constituents, lined impoundments maybe used
until water sample results are obtained and proper disposal methods are determined. The presence
or absence of volatile constituents will be determined in the field using photo ionization detection
(PID) monitoring instruments. Generally, development water must be properly disposed of within
90 days of its generation. Proper storage and disposal methods for development water will be
determined based on federal, state, and local regulations (i.e., ARARs) and known or suspected
contaminants.
4.8 Review
The Project Leader or designee shall check Exhibit 10-1, Well Development Data Summary and
Exhibit 10-2, Aquifer Test Data for completeness and accuracy. Any discrepancies will be noted and
the Exhibits will be returned to the originator for correction. The reviewer will acknowledge that
review comments have been incorporated by signing and dating the "reviewed by" and "date" blanks
on each Exhibit.
5.0 REFERENCES
CDPHE, 2000. "Standard Operating Procedure 11, Equipment Decontamination." Technical Standard
Operating Procedures.
Driscoll, G. 1986. "Groundwater and Wells." Johnson Division, St. Paul, Minnesota.
Fetter, C. W. 1988. "Applied Hydrogeology." Merril Publishing Company. Columbus, Ohio. Second
Edition. 592p.
U.S. Environmental Protection Agency (EPA). 1987. "Groundwater Handbook." United States
Environmental Protection Agency, Washington, DC.
U.S. Environmental Protection Agency (EPA). 1988. "Guidance for Conducting Remedial Investigations
and Feasibility Studies under CERCLA." United States Environmental Protection Agency, Washington, DC.
6.0 EXHIBITS
Exhibit 10-1 Well Development Data Summary
Exhibit 10-2 Aquifer Test Data
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Standard Operating Procedures Procedure No. 10
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Public Health and Environment Date: 01/2000
~~ Page 6 of 7
EXHIBIT 10-1
Well Development Data Summary
CDPHE
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South '
Denver, CO 80246
WELL DEVELOPMENT
DATA SUMMARY/
Records Management Data.
Project Number
Project Name
Wei! Number
Well Location
Time / Date:
Drilling Method:
Development Company:
Date Development Started:
Screen Intervals
ft To
Elevation:
Weather:
Date Development Completed:
Well Diameter.
ft.
ft. To
ft To
ft
ft To
Depth of Well (L")t
Height of Water Column (L" L1):
Depth to Top of Sediment (L!)
Welt Volume: '
Total Volume Pumped:
Number of Well Volumes Pumped (total votume pumped/well volume):
Commeots:
Jt Depth to Water Before Development (L1):
Jt
JH. Sediment Thickness (L* L'):
sal.
Presented By
Date
Checked By
Date
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Page 7 of 7
EXHIBIT 10-2
Aquifer Test Data
CDPHE
Colorado Dept. of Public Health and Environment
AQUIFER TEST DATA
PROJECT NUMBER:
PROJECT NAME:
PAGE of
Well Number:
Well Location:
Static Water Level: ft.
Time
Total
Elapsed
Time
t (min)
Time Since
Pumping
Stopped
t' (min)
Water
Level
(ft)
Drawdown
S
(ft)
Corrected
Drawdown
Sc'(R)
(ft)
Recovery
S'
(ft)
Corrected
Recovery
S'.
(ft)
Discharge
Q
gpm
.
ฆ
Recorded By:
Date:
Checked By:
Date:
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 11
Revision No.: 0
Date: 01/2000
Page 1 of2
STANDARD OPERATING PROCEDURE - 11
EQUIPMENT DECONTAMINATION
1.0 PURPOSE
This procedure describes the techniques used to decontaminate sampling and field measurement equipment.
Proper decontamination ensures that cross-contamination does not occur.
This procedure provides guidance for routine field operations on environmental projects. Site-specific
deviations from the methods presented herein must be approved by the Project Leader and the CDPHE
Quality Assurance Officer.
2.0 DEFINITIONS AND ABBREVIATIONS
2.1 Definitions
Potable water. Water suitable for drinking.
10 percent nitric acid: A solution composed of 1 part concentrated nitric acid and 9 parts distilled
water (e.g., a 100 ml aliquot of 10 percent nitric acid contains 10 ml concentrated nitric acid and 90
ml distilled water).
2.2 Abbreviations
ml Milliliter
PPs Project plans
SOP Standard Operating Procedures
3.0 RESPONSIBILITIES
Field personnel are responsible for performing the applicable tasks outlined in this procedure when
conducting work related to environmental projects.
The Project Leader or an approved designee is responsible for checking all work performance and verifying
that the work satisfies the applicable tasks required by this procedure. This will be accomplished by
reviewing all documents (Exhibits) and data produced during work performance.
75.50906.00
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Colorado Department of
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Procedure No. 11
Revision No.: 0
Date: 01/2000
Page 2 of2
4.0 PROCEDURES
4.1 Methods
Field personnel shall routinely document all equipment decontamination. Decontamination
procedures shall be documented in the field log books. All documentation of decontamination
procedures shall include the following information:
Serial number and model number of each piece of equipment (where applicable); and
Method of decontamination if it deviates from the method described herein.
Specific formatting information for documentation of decontamination procedures in field log books
is contained in CDPHE SOP 4.6, "Use and Maintenance of Field Log Books."
Each piece of sampling equipment shall be decontaminated as follows:
Brush with bristle or steel wire brush to remove gross particulates (as appropriate);
Scrub thoroughly with a laboratory-grade detergent/potable water solution;
Rinse thoroughly with potable water;
Rinse with reagent-grade methanol or nitric acid (as applicable);
Rinse thoroughly with reagent-grade water; and
Allow equipment to gravity drain.
Oversized and drilling equipment will be decontaminated using a high pressure water sprayer.
Equipment rinsate samples will be collected according to the specifications in the Project Plans (PPs).
Field measurement equipment such as pH and conductivity meters will be decontaminated by double
rinsing with distilled water only and blotting dry. In instances where samples have water insoluble
contaminants, additional rinses may be necessary.
4.2 Review
The Project Leader or designee shall check field log books for completeness and accuracy. Any
discrepancies in these documents will be noted and returned to the originator for correction. The
reviewer will acknowledge that corrections have been incorporated by signing and dating in the
appropriate manner.
5.0 REFERENCES
U.S. Environmental Protection Agency (EPA). 1984. "Standard Operating Safety Guides." Office of
Emergency and Remedial Response.
CDPHE. 2000. Standard Operating Procedure 6, "Use and Maintenance of Field Log Books." Technical
Standard Operating Procedures.
75.50906.00
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 12
Revision No.: 0
Date: 01/2000
Page 1 of9
STANDARD OPERATING PROCEDURE - 12
GROUNDWATER SAMPLING
1.0 PURPOSE
The purpose of this procedure is to describe the equipment and protocols for sampling groundwater monitor
wells. This procedure outlines methods for well purging, sample collection, and filtration, when using
bailers, submergible pumps and bladder pumps.
This procedure provides guidance for routine field operations on environmental projects. Site-specific
deviations from the methods presented herein must be approved by the CDPHE Project Leader and Quality
Assurance Officer.
2.0 DEFINITIONS AND ABBREVIATIONS
2.1 Definitions
Blank: An artificial sample designed to monitor the introduction of contaminants into a process. For
aqueous samples, reagent water is used as a blank matrix.
Field Blanks: Blanks used to assess potential contamination resulting from exposure to ambient field
Trip Blanks'. Blanks obtained from the laboratory or prepared by the field sampling team with
reagent grade water at a designated clean location prior to sampling activities. Trip blanks are not
opened in the field and act as a check for sample contamination originating from sample transport
and site conditions.
Rinsate Blanks: Blanks prepared in the field from reagent-grade water that is poured over or passed
through the sample collection device after the device has been decontaminated, then collected in a
sample container and returned to the laboratory for analysis. Rinsate blanks check the effectiveness
of decontamination procedures. Rinsate blanks can also serve as field blanks if they are prepared
at the site.
Specific Capacity. The discharge of a well expressed as rate of yield per unit drawdown.
2.2 Abbreviations
FID Flame ionization detector
PID Photo ionization detector
POC Purgeable organic carbon
POX Purgeable organic halogens
conditions.
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Standard Operating Procedures
Colorado Department of
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Procedure No. 12
Revision No.: 0
Date: 01/2000
Page 2 of 9
SOP Standard Operating Procedures
TOC Total organic carbon
TOX Total organic halogens
VOC Volatile organic compound
3.0 RESPONSIBILITIES
Sampling personnel are responsible for performing the applicable tasks and procedures outlined herein when
conducting work related to environmental projects.
The Project Leader or an approved designee is responsible for checking all work performance and verifying
that the work satisfies the applicable tasks required by this procedure. This will be accomplished by
reviewing all documents and data produced during work performance.
4.0 PROCEDURES
Read and follow the specific Manufacturer's Operating Instructions before using any equipment.
Prior to initiating sampling of a groundwater well, check that all equipment to be used is in good
operating condition.
If possible and where applicable, begin sampling event at those wells that are the least contaminated
and proceed to those wells that are the most contaminated.
Clean all equipment entering the well by methods in CDPHE SOP 4.11, Equipment
Decontamination.
Remove well casing cap, noting in the log book the following: personnel, well number, date, time
and weather conditions, as well as any evidence of damage or disturbance to the well. This
information may also be recorded on the groundwater sampling data form, Exhibit 12-1, Monitoring
Well Sampling Data.
If required by site specific conditions, monitor headspace of well with a photo ionization detector
(PID), a flame ionization detector (FID), or other appropriate monitoring instrument and record in
the logbook.
Check water level as per CDPHE SOP 4.13, Water Level Measurement.
Purge well.
Sample well as per Section 4.2, Sampling Procedures.
Filter and preserve samples as per Section 4.4, Sample Filtration and Preservation,
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Page 3 of 9
4.1 Well Purging
In order to obtain a representative sample of groundwater from a monitoring well, the water that has
stagnated and/or thermally stratified within the well casing and filter pack must be purged. This
procedure allows representative formation water to enter the well. The preferred method of ensuring
representative formation water is being sampled is to monitor groundwater parameters during
purging.
Measure pH, temperature and specific conductance at regular volumetric intervals (i.e., one-half
casing volume) during well purging using the methods outlined in CDPHE SOP 4.14, Water Sample
Field Measurements.
The purge volume of static water can be calculated by using the following formula:
V = Hr2(0.163*)
Where: V = Static volume of well in gallons
H = Linear feet of static water in well
r = Inside radius of well casing in inches
0.163* = A constant conversion factor for a 2" diameter well. For a 4" diameter well, use
0.653.
Where possible, the well should be sampled within two hours of purging. Record the results on
Exhibit 12-1, Monitoring Well Sampling Data. When parameters vary less than ฑ10% (pH will vary
less than 0.2 pH units) over three consecutive measurements the well may be considered to be
adequately purged (stabilized). In wells with poor recovery, purge to near dryness and allowthe well
to recover prior to sampling. In wells with slow recharge rates, it may be necessary to wait several
hours or until the next day to collect the sample.
When well water parameters do not stabilize the well can be sampled after six purge volumes have
been removed.
Prior to initiating well purging, record the following groundwater parameters on Exhibit 12-1,
Monitoring Well Sampling Data:
Static water level;
Depth of well bottom;
Height of water column;
Volume of water in borehole;
Time;
Temperature;
Conductivity;
pH;
Visual appearance; and
Monitoring equipment (HNu/OVA) readings.
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Colorado Department of
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Procedure No, 12
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Date: 01/2000
Page 4 of9
4.2 Sampling Procedures
After purging the required volume of water from the well, sample within two hours. Do not exceed
two hours between purging and sampling, except in cases when a slow recharge rate requires more
time between well purging and sample collection. To ensure the groundwater sample is
representative of formation water, it is important to minimize the possibility of cross-contamination
by performing the following steps:
Use only Teflonฎ, stainless steel or disposable sampling devices which have been
decontaminated prior to use.
Use dedicated sampling equipment. If dedicated sampling equipment is not available,
thoroughly decontaminate the equipment prior to any sampling and between sampling events
according to the methods outlined in CDPHE SOP 4.11, Equipment Decontamination.
Collect rinsate blanks as outlined in the Project Plans to verify that cross-contamination has
not occurred.
Specify the order in which the samples are to be collected. Collect samples in the order of
volatilization sensitivity. Volatile organics should be collected when flow rate is less than
100 ml/minute. Fill sampling vial(s) completely making sure that there is no head space.
The collection order for most common groundwater parameters is as follows:
Volatile organic compound (VOC);
Purgeable organic carbon (POC);
Purgeable organic halogens (POX);
Total organic halogens (TOX);
Total organic carbon (TOC);
Extractable organics;
Total metals;
Dissolved metals;
Phenols;
Cyanide;
Sulfate and chloride;
Turbidity;
Nitrate and ammonia; and
Radionuclides.
Transfer the groundwater sample to a sample container in such a manner that will minimize agitation
and aeration. Samples should also be immediately placed in a cool place out of direct sunlight, such
as a cooler. The cooler should be kept at an appropriate temperature for preservation requirements
for the applicable analyses.
Immediately after the sample is collected, record applicable information in the field log book. This
information may also be recorded on Exhibit 12-1, Monitoring Well Sampling Data..
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Colorado Department of
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Procedure No. 12
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4.2.1 Sample Containers
The proper sample containers to be used for specific analysis and sample preservation are
outlined in CDPHE SOP 4.2, Sample Containers, Preservation, and Maximum Holding
Times.
4.3 Sampling Methods
4.3.1 Bailer Method
Collect groundwater samples with a bailer by lowering the bailer into the well using a
disposable nylon line. Avoid contacting the ground or any other surface with the line and
bailer. A plastic sheet can be used as an apron. Lower the bailer into the well in a controlled
manner to avoid slapping the ground water surface with the bailer as this may cause
outgassing of the water from the bailer's impact.
After the desired depth is reached, raise the bailer to the surface and empty it through the
bottom by a clamp valve. If the bailer is not equipped with a clamp valve, pour the sample
from the bailer into the appropriate container. Empty the bailer at a slow, controlled rate to
minimize sample aeration. After all sample containers have been filled, measure sample pH,
temperature, and conductivity. Record applicable information on Exhibit 12-1, Monitoring
Well Sampling Data.
The advantages to bailers are that they are portable, easily cleaned, and do not require an
outside power source. The disadvantage to bailer sampling is that this method is slow when
large volumes of water are required or when the well is deep.
4.3.2 Bailer Decontamination
Decontaminate bailers prior to use in each well as per CDPHE SOP 4.11, Equipment
Decontamination. In all cases, the bailer cord should be replaced prior to each sampling.
Disposable bailers may be used in place of Teflonฎ or stainless steel bailers. Disposable
bailers do not require decontamination.
4.3.3 Bladder Pump Method
The bladder pump consists of a stainless steel housing that encloses a flexible membrane or
bladder made of Teflonฎ. A screen is attached below the bladder to filter any material that
may clog the bladder check valves. The pump may be operated by using an air compressor,
compressed air, or compressed nitrogen.
The pump is lowered into the well to the desired depth. The air supply line is attached to the
controller and the discharge line is placed into a suitable receptacle. When collecting
samples for analysis of volatile constituents, do not exceed a pumping rate of 100
milliliters/minute. Higher pumping rates may increase the loss of volatile constituents and
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Colorado Department of
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Procedure No. 12
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may cause fluctuation in pH and pH-sensitive analytes. For non-sensitive analysis, higher
pumping rates may be used. Do not allow the sampling flow rate to exceed the flow rate
used while purging. Place the samples in sample containers as outlined in CDPHE SOP 4.2,
Sample Containers, Preservation, and Maximum Holding Times. Record applicable
sampling information on Exhibit 12-1, Monitoring Well Sampling Data.
The advantages to bladder pumps include ease of operation, ability to pump larger volumes
of water. The disadvantages are that a power source is needed, some loss of volatile
constituents is possible, and the decontamination process is difficult.
4.3.4 Bladder Pump Decontamination
Decontaminate the bladder pump prior to use in each well. Disassemble and inspect the
pump prior to cleaning. Decontamination is completed by the methods outlined in the
owner's manual for the specific type of bladder pump, and CDPHE SOP 4.11, Equipment
Decontamination.
4.3.5 Submerged Electrical Pump
The electrical pump is constructed of stainless steel. Consult the specific Manufacturer's
Operating Instructions before operation. The pump is lowered into the well to the desired
depth. The purge volume calculations should be determined prior to placing the pump in the
well. Purge rates should not cause drastic drawdown which results in water cascading into
the well. When collecting samples for analysis of volatile constituents, do not exceed a
pumping rate of 100 milliliters/minute. Higher pumping rates may increase the loss of
volatile constituents and may cause fluctuation in pH and pH-sensitive analytes. For non-
sensitive analysis, higher pumping rates may be used. Do not allow the sampling flow rate
to exceed the flow rate used while purging. Place the samples in sample containers as
outlined in CDPHE SOP 4.2, Sample Containers, Preservation, and Maximum Holding
Times. Record applicable sampling information on Exhibit 12-1, Monitoring Well Sampling
Data.
4.4 Sample Filtering
Some samples require field filtering within four hours of collection from the well. Filter samples by
using a disposable in-line filter housing, or equivalent setup, equipped with a 0.45 micron glass fibre
filter. Change filters for each sample. Collect the sample water directly into the sample container.
After the samples have been filtered and placed in appropriate containers, preserve samples as stated
in CDPHE SOP 4.2, Sample Containers, Preservation, and Maximum Holding Times.
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Procedure No. 12
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4.5 Chain-of-Custody
All samples shall be accompanied by an appropriate Chain-of-Custody form at the time of transfer.
The procedures for filling out a Chain-of-Custody form, transporting samples, and transferring
custody of samples are outlined in CDPHE SOP 4.3, Chain of Custody.
4.6 Sample Labeling
Label all samples according to the methods outlined in CDPHE SOP 4.4, Sample Identification,
Labeling, and Packaging.
4.7 Potable Water Sampling
During certain phases of field investigations, it may be necessary to collect samples from existing
domestic or municipal water supply systems.
When samples are collected from domestic wells, the wells should be purged before the sample is
collected. Residential wells often have holding tanks which must be evacuated. Evacuation of the
holding tank volume helps assure that representative samples are being collected from the aquifer.
Information about well construction (casing diameter, depth to water, total depth, screened interval,
and holding tank volume) should be obtained, if possible, in order to determine the appropriate
volume of water to purge before sampling. If specific well information is not available, a 15-minute
evacuation period is the minimum acceptable time. In all cases, temperature pH, conductivity and
flow rate should be measured during purging. The well is considered purged when field parameters
stabilize.
The name, mailing address, and the resident's home and work telephone numbers are always entered
into the sampling log book. This information will assist in informing the owner/operator of the water
supply of the results of the sampling program.
Potable water samples must be representative of water quality within a given segment of the
distribution network. Taps selected for sampling should be supplied with water from a service pipe
connected directly to a water main in the segment of interest and should not be separated from the
segment of interest by holding or storage tanks.
All taps should be opened for sufficient time to allow for clearing of the service line. Water samples
can then be collected directly from this line into the appropriate sample containers.
4.8 Review
The reviewer shall check Exhibit 12-1, Monitoring Well Sampling Data, for completeness and
accuracy. Any discrepancies will be noted and the Exhibits will be returned to the originator for
correction. The reviewer will acknowledge that the review comments have been incorporated by
signing and dating the "checked by" and "date" blanks on Exhibit 12-1, Monitoring Well Sampling
Data.
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Procedure No. 12
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Date: 01/2000
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5.0 REFERENCES
Scalf, R. D. 1980. "Manual of Groundwater Sampling Procedures." National Water Well Association and
the U.S. Environmental Protection Agency (EPA) Robert S. Kerr Environmental Research Laboratory.
U.S. Environmental Protection Agency (EPA). 1991. "A Compendium of ERT Groundwater Sampling
Procedures." OSWER Directive 9360.4-06, January 1991. U.S. Environmental Protection Agency.
CDPHE, 2000. "Operating Procedure 2, Sample Containers, Preservation, and Maximum Holding Times."
Standard Operating Procedures.
CDPHE, 2000. "Standard Operating Procedure 3, Chain-of-Custody." Standard Operating Procedures.
CDPHE, 2000. "Standard Operating Procedure 4, Sample Identification, Labeling, and Packaging."
Standard Operating Procedures.
CDPHE, 2000. "Standard Operating Procedure 11, Equipment Decontamination." Standard Operating
Procedures.
CDPHE, 2000. "Standard Operating Procedure 13, Water Level Measurement." Standard Operating
Procedures.
CDPHE, 2000. "Standard Operating Procedure 14, Water Sample Field Measurements." Standard Operating
Procedures.
6.0 EXHIBITS
Exhibit 12-1 Monitoring Well Sampling Data
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Standard Operating Procedures
Colorado Department of
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Procedure No. 12
Revision No.: 0
Date: 01/2000
Page 9 of9
EXHIBIT 12-1
Monitoring Well Sampling Data
CDPHE
Monitoring Well
Sampling Data
Proiect Number
Project Name:
Page of
Well/Borehole
Number:
Well/Borehole Location:
Static Water Level! (ft)
1
Sample No:.
Elevation:
Sampling Method:_
Weather:
Bar. Press.
Amb. Temp. _
WATER ELEVATION DATA
1.) Depth Water Surface:
(From Casing Top as Marked)
Method of Measurement:
2.) Static Water Level Elevation:
(Casing Top Elevation minus 1)
3.) Depth to Well Bottom:
(From Casing Top as Marked)
Product obs:
Depth to Product^
Yes No
4.) Height of Water Column (h):_
(3 minus 1)
Method of Measurement:
Volume of Water in Well:(x) (h) =
(for 2" x= 0.163 gal/ft for 4" x = 0.653 gal/ft)
. (gals)
Amount of Water Removed From Well:
Was Well Pumped Dry? Yes No
Method of Water Removal':
Total Volume/Time:
Time
Temp ฐC Conductivity
EH
Turbidity
Removed Flow Rate
Observations
Recorded By:
Date:
Checked By:
Date:
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Procedure No. 12A
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- STANDARD OPERATING PROCEDURE - 12A
GROUNDWATER SAMPLING FOR LOW FLOW PURGE AND SAMPLING
1.0 PURPOSE
The purpose of this procedure is to describe the equipment and operations for sampling groundwater monitor
wells using a pump to obtain samples with a minimum of turbidity. This procedure is designed to be used
in conjunction with the analyses for the most common types of groundwater contaminants (volatile and
semivolatile organic compounds, pesticides, PCBs, metals and inorganic compounds).
This procedure provides guidance for routine field operations on environmental projects. Site-specific
deviations from the methods presented herein must be approved by the CDPHE Project Leader and Quality
Assurance Officer.
2.0 DEFINITIONS AND ABBREVIATIONS
2.1 Definitions
Blank-. An artificial sample designed to monitor the introduction of contaminants into a process. For
aqueous samples, reagent water is used as a blank matrix.
Field Blanks-. Blanks used to assess potential contamination resulting from exposure to ambient field
Trip Blanks: Blanks obtained from the laboratory or prepared by the field sampling team with
reagent grade water at a designated clean location prior to sampling activities. Trip blanks are not
opened in the field and act as a check for sample contamination originating from sample transport
and site conditions.
Rinsate Blanks: Blanks prepared in the field from reagent-grade water that is poured over or passed
through the sample collection device after the device has been decontaminated, then collected in a
sample container and returned to the laboratory for analysis. Rinsate blanks check the effectiveness
of decontamination procedures. Rinsate blanks can also serve as field blanks if they are prepared
at the site.
Specific Capacity. The discharge of a well expressed as rate of yield per unit drawdown.
2.2 Abbreviations
FID Flame Ionization Detector
HNu/OVA HNu/Organic Vapor Analyzer
ID Inside diameter
conditions.
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Standard Operating Procedures
Colorado Department of
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NTU Nephelometric turbidity units
PCBs Polycfilorinated biphenols
PID Photo Ionization Detector
POC Purgeable organic carbon
POX Purgeable organic halogens
PVC Polyvinyl chloride
TOC Total organic carbon
TOX Total organic halogens
VOC Volatile organic compound
3.0 RESPONSIBILITIES
Sampling personnel are responsible for performing the applicable tasks and procedures outlined herein when
conducting work related to environmental projects.
The Project Leader or an approved designee is responsible for checking all work performance and assuring
that the work satisfies the: applicable tasks required by this procedure. This will be accomplished by
reviewing all documents and data produced during work performance.
4.0 PROCEDURES
Read and follow the specific Manufacturer's Operating Instructions before using any equipment.
Make sure prior to initiating sampling of a groundwater well, that all equipment to be used is in good
operating condition.
If possible and where applicable, start at those wells that are the least contaminated and proceed to
those wells that are the most contaminated.
Decontaminate all equipment entering the well by methods in Section 4.3, Decontamination
Methods.
Remove well casing cap, noting in log book or groundwater sampling data form the following:
personnel, well number, type of sampling equipment used, date, time and weather conditions.
If required by site specific condition, monitor headspace of well with PID, FID or other appropriate
monitoring instrument and record readings in logbook or groundwater sampling data form, Exhibit
12A-1, Monitoring Well Sampling Data.
Check water level as outlined in UOS TSOP 4.13 "Water Level Measurement." Care should be
taken to minimize disturbance of any particulate attached to the sides or the bottom of the well.
Measure total depth of well prior to purging or estimate casing volume of well from previous well
depth measurements.
Purge well as per Section 4.1, "Well Purging."
Procedure No. 12A
Revision No.: 0
Date: 01/2000
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Procedure No. 12A
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Sample well as per Section 4.2, "Sampling Procedures."
Filter and preserve samples as per Section 4.4, "Sample Filtering."
Decontaminate equipment as per Section 4.3, "Decontamination Methods."
4.1 Well Purging
In order to obtain a representative sample of groundwater from a monitoring well, an adjustable rate,
positive displacement pump (centrifugal or bladder pump constructed of steel or Teflonฎ) should
be used. This low flow procedure allows for a minimization of disturbance of sediments which have
accumulated on the sides or in the bottom of the well while allowing a sample to be collected from
the representative water formation with a minimum of purging. The preferred method of ensuring
representative formation water is being collected is to monitor groundwater parameters every three
to five minutes or whatever is appropriate during purging when the pump is placed within the
screened interval. Please note that average purge rates are generally from 0.2 to 1.0 liters per minute
Measure the water level again with the pump in the well before starting the pump. Start the pump
in the well at 0.2 to 0.5 1/min or as appropriate. Ideally, the pump rate should cause little or no water
level drawdown in the well. The water level should be monitored every three to five minutes or as
appropriate during pumping. Care should be taken not to cause the pump suction to be broken, or
entrainment of air into the sample. Record the following for every three to five minute interval or
as appropriate in the log book or Exhibit 12A-1, Monitoring Well Sampling Data: pumping rate
adjustments, drawdown, depth to water, indicator parameter values, clock time and total volume
pumped. Pumping rates, if needed, should be reduced to the minimum capabilities of the pump (e.g.,
0.1 to 0.21/min) to avoid pumping the well dry and/or to ensure stabilization of indicator parameters.
Measure pH, temperature, specific conductance and turbidity every three to five minutes, every one-
half casing volume, or every one to three liters. All indicator parameter measurements will be
conducted as per the methods outlined in UOS TSOP 4.14, Water Sample Field Measurements. All
measurements should be taken using a flow-through cell or from a clean container (e.g.,
decontaminated glass beaker).
Record the results in the field log book. Results may also be recorded on Exhibit 12A-1, Monitoring
Well Sampling Data. When these parameters vary less than ฑ10% (pH will vary less than 0.2 pH
units) over three consecutive measurements, water in the well has adequately stabilized and the
sample should be collected. In wells with slow recharge rates, commence sampling as soon as the
well has recharged to a sufficient level to collect the appropriate volume of samples with the pump.
If indicator parameters have stabilized, but the turbidity is not in the range of the goal of five
nephelometric turbidity units (NTU), the pump rate should be decreased, and measurements of the
parameters should continue every three to five minutes or as appropriate. If indicator parameters do
(1/min).
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not stabilize within a reasonable time (e.g., three to five casing volumes), sample well and note
deviation to sampling procedures.
Prior to initiating well purging, record the following groundwater parameters in the field log book.
The parameters may also be recorded on Exhibit 12A-1, Monitoring Well Sampling Data:
Static water level;
Check water level as outlined in CDPHE SOP 4.13 "Water Level Measurement." Care
should be taken to minimize disturbance of any particulates attached to the sides or the
bottom of the well. Measure total depth of well prior to purging or estimate casing volume
of well from previous well depth measurements.
Time;
Temperature;
Conductivity;
4.1.1 Equipment
An adjustable rate, positive displacement pump (centrifugal or bladder pump constructed of
steel or Teflonฎ) should be used for this method of well purging and sampling on
groundwater wells which have a well casing of 2.0-inch inside diameter (ID) or more.
Tubing to be used for low flow type sampling is limited to Teflonฎ or Teflonฎ lined
polyethylene tubing for organic analyses. For inorganic analyses, Teflonฎ or Teflonฎ-lined
polyethylene, polyvinyl chloride (PVC), Tygon or polyethylene tubing can be used.
In order to minimize cross-contamination, purge and sample each monitor well with
dedicated pumps and tubing. If this is not practical, take extreme care to properly
decontaminate all purging and sampling equipment prior to use following the applicable
methods as stated in Section 4.3, Decontamination Methods.
Record groundwater parameters as outlined above in the log book. Parameters may also be
recorded on Exhibit 12A-1, Monitoring Well Sampling Data.
4.2 Sampling Procedures
After indicator parameters have stabilized in the well, collect the sample immediately. In wells with
slow recharge rates, commence sampling as soon as the well has recharged to a sufficient level to
collect the appropriate volume of samples with the pump.
Transfer the groundwater sample to a sample container by allowing the pump discharge to flow
gently down the inside of the container with minimal turbulence. Samples should also be placed in
a cool place out of direct sunlight, such as an iced cooler.
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Visual appearance; and
Monitoring equipment HNU/Organic Vapor Analyzer (HNu/OVA) readings.
pH;
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Colorado Department of
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Procedure No. 12A
Revision No.: 0
Date: 01/2000
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Collect samples in the order of volatilization sensitivity. Volatile organics should be
collected when the flow rate is less than 100 milliliters per minute (ml/min.). The collection
order for most common groundwater parameters is as follows:
Immediately after the sample is collected, record applicable information in the field log book as
outlined in CDPHE SOP 4.6, Use and Maintenance of Field Log Books. Information may also be
recorded on Exhibit 12A-1, Monitoring Well Sampling Data,
After collection of the samples, the pump's tubing may either be dedicated to the well for resampling
by hanging the tubing inside the well, decontaminated for use at another site, or properly discarded.
4.2.1 Sample Containers
The proper sample containers to be used for specific analysis and sample preservation are
outlined in CDPHE SOP 4.2, Sample Containers, Preservation, and Maximum Holding
Times.
4.2.2 Blanks
A minimum of two types of blanks will be collected to verify the quality of the collected
samples. These blank types are as follows:
Trip Blank: Obtain two volatile organic sample bottles from the laboratory or
prepared by the field sampling team with reagent grade distilled water; transport to
the site; handle in the same manner as the collected samples; and return to the
laboratories for volatile organics analysis. The trip blanks should be kept in the
cooler with the VOC samples at all times.
Rinsate Blank: To ensure that any non-dedicated sampling equipment has been
effectively decontaminated, fill sampling device with reagent grade water or pump
Volatile organic compound (VOC);
Purgeable organic carbon (POC);
Purgeable organic halogens (POX);
Total organic halogens (TOX);
Total organic carbon (TOC);
Extractable organics;
Total metals;
Dissolved metals;
Phenols;
Cyanide;
Sulfate and chloride;
Turbidity;
Nitrate and ammonia; and
Radionuclides.
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Standard Operating Procedures
Colorado Department of
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Procedure No. 12A
Revision No.: 0
Date: 01/2000
Page 6 of9
reagent grade water through the device, transfer to sample bottle(s), and return to
the laboratory for analysis. If contamination is found in the rinsate blanks, identify
the source of the contamination and take corrective action, such as resampling
and/or reviewing decontamination procedures.
Field Blanks: To assess the possible influence of site-related contaminants
entrained in ambient air on sample quality, on-site personnel may collect field
blanks during site activities. Field blanks are collected by pouring reagent grade
water directly into the appropriate sample container. The sample is then analyzed
for site-related contaminants to determine the influence of on-site ambient air on
sample results. A rinsate blank can also serve as a field blank if it is prepared at the
site.
To determine the frequency of blank collection, refer to the Quality Assurance
Project Plan.
4.3 Decontamination Methods
Sampling equipment will be decontaminated prior to use and following sampling of each well.
Pumps will not be removed between purging and sampling operations. The pump and tubing
(including support cable and electrical wires which are in contact with the sample) will be
decontaminated by one of the procedures listed below.
4.3.1 Procedure 1
Steam clean the outside of the submersible pump.
Pump hot water from the steam cleaner through the inside of the pump. This can
be accomplished by placing the pump inside a three or four inch diameter PVC pipe
with end cap. Hot water from the steam cleaner jet will be directed inside the PVC
pipe and the pump exterior will be cleaned. The hot water from the steam cleaner
will then be pumped from the PVC pipe through the pump and collected into
another container. Note: additives or solutions should not be added to the steam
cleaner.
Pump five gallons of non-phosphate detergent solution through the inside of the
pump.
Pump tap water through the inside of the pump to remove all of the detergent
solution.
Pump distilled or deionized water through the pump.
4.3.2 Procedure 2
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Standard Operating Procedures
Colorado Department of
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Procedure No. 12A
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Date: 01/2000
Page 7 of9
The decontaminating solutions can either be pumped from buckets through the
pump or the pump can be disassembled and flushed with the decontaminating
solutions. It is recommended that detergent and isopropyl alcohol used in the
decontamination process be used sparingly and water flushing steps be extended to
ensure that any sediment trapped in the pump is flushed out. The outside of the
pump and the electrical wires must be rinsed with the decontaminating solutions as
well. The procedure is as follows:
Flush the equipment/pump with potable water.
Flush with non-phosphate detergent solution (i.e., five gallons).
Flush with tap water to remove all of the detergent solution.
Flush with distilled or deionized water.
4.4 Sample Filtering
Some samples require field filtering within four hours of collection from the well. Filter samples by
using a disposable in-line filter housing equipped with a 0.45 micron glass fibre filter. Change filters
at each sampling location. Collect the sample water directly into the sample container. It is not
necessary to change the filter when collecting duplicate or replicate samples unless the sampling
media has a high turbidity and has impaired the flow through the filter.
After the samples have been filtered and placed in appropriate containers, preserve samples as
outlined in CDPHE SOP 4.2, Sample Containers, Preservation, and Maximum Holding Times.
4.5 Chain of Custody
All samples shall be accompanied by an appropriate Chain-of-Custody form at the time of transfer.
The procedures for filling out a Chain-of-Custody form, transporting samples, and transferring
custody of samples is outlined in CDPHE SOP 4.3, Chain of Custody.
4.6 Sample Labeling
Label all samples according to the methods outlined in CDPHE SOP 4.4, Sample Identification,
Labeling, and Packaging.
4.7 Review
I:\QAPP\SOP\SOP 12A.wpd
Flush with isopropyl alcohol.
Flush with distilled or deionized water.
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 12A
Revision No.: 0
Date: 01/2000
Page 8 of9
The reviewer shall check Exhibits 12A-1, Monitoring Well Sampling Data, for completeness and
accuracy. Any discrepancies will be noted and the Exhibits will be returned to the originator for
correction. The reviewer will acknowledge that the review comments have been incorporated by
signing and dating the "checked by" and "date" blanks on Exhibit 12A-1, Monitoring Well Sampling
Data.
5.0 REFERENCES
Scalf, R.D. 1980. "Manual of Groundwater Sampling Procedures." National Water Well Association and
the U.S. Environmental Protection Agency (EPA) Robert S. Kerr Environmental Research Laboratory.
U.S. Environmental Protection Agency (EPA). 1991. "A Compendium of ERT Groundwater Sampling
Procedures." OSWER Directive 9360.4-06, January 1991. U.S. Environmental Protection Agency.
U.S. Environmental Protection Agency (EPA). 1994. "Groundwater Flow Sampling Procedure for Low
Flow Purge and Sampling.'^U.S. EPA SOP #GW 0001; Region I, August 10,1994. U.S. Environmental
Protection Agency. s-
CDPHE, 2000. "Quality Assurance Project Plan."
CDPHE, 2000. "Standard Operating Procedure 2, Sample Containers, Preservation, and Maximum Holding
Times." Standard Operating Procedures.
CDPHE, 2000. "Standard Operating Procedure 3, Chain of Custody." Standard Operating Procedures.
CDPHE, 2000. "Standard Operating Procedure 4, Sample Identification, Labeling, and Packaging."
Standard Operating Procedures.
CDPHE, 2000. "Standard Operating Procedure 6, Use and Maintenance of Field Log Books." Standard
Operating Procedures.
CDPHE, 2000. "Standard Operating Procedure 7, Bladder Pump." Standard Operating Procedures.
CDPHE, 2000. "Standard Operating Procedure 13, Water Level Measurement." Standard Operating
Procedures.
CDPHE, 2000. "Standard Operating Procedure 14, Water Sample Field Measurements." Standard Operating
Procedures.
6.0 EXHIBITS
Exhibit 12A-1 Monitoring Well Sampling Data
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Standard Operating Procedures Procedure No PA
Colorado Department of . Revision No.: 0
Public Health and Environment Date: 01/2000
Page9of9
EXHIBIT 12A-1
Monitoring Well Sampling Data
CDPHE
Monitoring Well
Sampling Data
Project Number
Project Name:
Page of
Well/Borehole
Number:
Well/Borehole Location:
i
Static Water Level: (ft) |
!
Sample No:
Elevation: i
Sampling Method:
Weather:
Bar. Press.
Amb. Temp.
WATER ELEVATION DATA
1.1 Depth Water Surface:
Method of Measurement:
(From Casing Top as Marked)
2.1 Static Water Level Elevation:
(Casing Top Elevation minus 1)
Product obs: Yes No
Depth to Product:
3.1 Depth to Well Bottom:
(From Casing Top as Marked)
4.1 Heieht of Water Column (hi:
(3 minus 1)
Method of Measurement:
Volume of Water in Welkfxl (hi = (sals)
(for 2" x= 0.163 gal/ft for 4" x = 0.653 gal/ft)
Amount of Water Removed From Well:
Was Well Pumped Dry? Yes No
Method of Water Removal
Total Volume/Time:
Time TemD ฐC Conductivity dH Turbiditv Removed Flow Rate Observations
Recorded By: Date: Checked By: Date:
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 13
Revision No. 0
Date: 01/2000
Page 1 of 6
TECHNICAL STANDARD OPERATING PROCEDURE - 13
WATER LEVEL MEASUREMENT
1.0 PURPOSE
The purpose of this procedure is to describe the methods used for obtaining accurate water level
measurements from groundwater monitor wells. This procedure outlines the equipment available for water
level measurement and its operation. Site-specific deviations from the methods presented in this procedure
must be approved by the CDPHE Project Leader and Quality Assurance Officer.
2.0 DEFINITIONS AND ABBREVIATIONS
2.1 Definitions
Not applicable.
2.2 Abbreviations
DNAPL Dense Non-Aqueous Phase Liquid
LNAPL Light Non-Aqueous Phase Liquid
3.0 RESPONSIBILITIES
Personnel obtaining water level measurements are responsible for performing the applicable tasks outlined
in this procedure when conducting work related to environmental projects.
The Project Leader or an approved designee is responsible for checking all work performance and verifying
that the work satisfies the applicable tasks required by this procedure. This will be accomplished by
reviewing all documents and data produced during work performance.
.4.0 PROCEDURE
4.1 Introduction
Accurate groundwater level measurements are a fundamental requirement of any groundwater
characterization study. Groundwater level measurements are used to construct water table maps, to
determine gradient, to provide basic data during aquifer testing, to determine permeability and
hydrologic conductivity, and to determine purge volume for well development and sampling. Static
water levels should be measured before the wells are disturbed by any other sampling or monitoring
activities. Water levels, for a group of wells, should be taken within as short a time span as possible
to ensure compatible readings. If there is a rush of air in or out of the well when ce well cap is
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Standard Operating Procedures
Colorado Department of
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Procedure No. 13
Revision No. 0
Date: 01/2000
Page 2 of 6
removed, take water level readings every two minutes until the water level stabilizes with three
consecutive readings within 0.1 foot.
A measuring point is marked on each well casing stickup, either by an impressed mark or paint mark.
All measurements should be taken from this measuring point. If a measuring point is not marked,
then the water levels should be taken from the north side of the casing stickup. The measuring point
used to obtain the water level reading (mark or north side of casing) should be noted in the field log
book.
The depth to water and the depth to the bottom of the well, to the nearest 0.1 foot, should be recorded
on both the appropriate field form and in the field log book, along with any observation such as field
monitoring reading, sediment on bottom, damage to well stickup, etc. Exhibit 13-2, the Water Level
Form, is used when the groundwater well is not sampled. Exhibit 13-1, Monitor Well Sample Data,
is used when water levels are measured during groundwater sampling activities.
All groundwater level measurements will be taken with an optical/electronic interface probe or
electrical water level indicator. Read and follow the specific Manufacturer's Operating Instructions
before using any equipment.
4.2 Interface Probe
The following describes an ORS brand interface probe. Read and follow the specific Manufacturer's
Operating Instructions before using any type of interface probe.
The interface probe consists of a dual sensing probe utilizing an optical liquid sensor and electrical
conductivity probe to distinguish between water and immiscible non-conducting liquids. A coated
steel measuring tape graduated in fractions of feet or meters transmits the sensor's signals to a reel
assembly, where an audible alarm sounds a continuous tone when the sensor is immersed in
immiscible non-conducting liquids and an intermittent tone when immersed in water. The interface
probe is accurate to within 0.1 of a foot.
When using the interface probe to measure water levels in wells or sumps containing a floating
(LNAPL) or sinking (DNAPL) layer of product, it is necessary to compensate for the effects of
differing densities of the product and water. This is accomplished by using the following calculation:
(Immiscible Layer Thickness) (Product Density) + (Water Elevation) = Corrected Water Elevation
Note: An averaged product density for petroleum hydrocarbons (LNAPL) is 0.8.
After the interface probe has been decontaminated as described in Section 4.4, Inspection and
Decontamination, it is lowered into the well or sump until an audible alarm is heard. The depth is
read from the tape by comparing it with the measuring point. The probe is then lowered until a
second alarm is heard (if applicable) indicating the interface level within the well. The probe can
then be lowered until it touches the bottom of the well, to determine the height of the water column,
and to detect any possible DNAPL. When the product/water interface is reached, the probe should
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Standard Operating Procedures
Colorado Department of
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Procedure No. 13
Revision No. 0
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be "jiggled" slightly to ensure that any adhering fluids are removed from the probe to provide the
most accurate measurement of the interface. Record these depths in the field log book. Depths may
also be recorded in Exhibit 13-2, Water Level Form, or Exhibit 13-1, Monitoring Well Sampling
Data.
4.3 Electrical Water Level Indicator
An electrical water level indicator consists of a metallic probe on the end of a steel or plastic tape
graduated in fractions of feet or meters. The tape contains wires that transmit the probe's signals to
a reel containing an audible alarm or light. The electrical probe is not capable of indicating the
presence of an immiscible non-conducting liquid.
The probe is used by lowering it into the well or sump until the alarm activates. The alarm should
be tested prior to use. The depth on the tape is then compared with the measuring point and the depth
is recorded on Exhibit 13-2, Water Level Form, or Exhibit 13-1, Monitoring Well Sampling Data,
and the field logbook. The probe can then be lowered until it touches the bottom of the well to
determine the height of the water column.
4.4 Inspection and Decontamination
It is important to check the condition of electrical lines for nicks or breaks before each use. Breaks
must be repaired before attempting to use the equipment. Periodically, the scale on the instrument
tape should be compared to a tape of known accuracy as stretching of the instrument tape may occur
after prolonged use. Personnel using the equipment will perform periodic tape calibration.
All probes and tapes must be decontaminated after each use. The tape will be decontaminated at the
beginning of each day and after each use. This is best accomplished as described below:
Wipe tape with laboratory-grade detergent solution saturated cloth;
Wipe with distilled water saturated cloth;
Wipe with methanol saturated cloth; and
Wipe with distilled water saturated cloth.
Special considerations for the water level indicators are the connections between the tape and probe,
which are often "jiggled" up and down at the water surface and LNAPL/water and DNAPL/water
interfaces, as well as in sediment on the well bottom. Particles and fluids can lodge in the
connections, so special efforts must be made to invasively clean these areas.
Measure water levels in monitoring wells in order of increasing contaminant level, where levels of
contamination can be determined. Wells containing immiscible liquids should be measured last.
4.5 Review
The Project Leader or an approved designee shall check Exhibit 13-2, Water Level Form, or Exhibit
13-1, Monitoring Well Sampling Data and/or logbooks, for completeness and accuracy. Any
I:\QAPP\SOP\SOP 13.wpd
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Standard Operating Procedures
Colorado Department of
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Procedure No. 13
Revision No. 0
Date: 01/2000
Page 4 of 6
discrepancies will be noted and the Exhibits will be returned to the originator for correction. The
reviewer will acknowledge that review comments have been incorporated by signing and dating the
"reviewer" and "date" blanks on each Exhibit.
5.0 REFERENCES
U.S. Environmental Protection Agency (EPA). 1989. Superfund Ground Accuracy of Depth to Water
Measurements.
U.S. Environmental Protection Agency (EPA). 1991. "A Compendium of ERT Groundwater Sampling
Procedures." OSWER Directive 9360.4-06, January 1991. U.S. Environmental Protection Agency.
CDPHE , 2000. "Standard Operating Procedure 11, Equipment Decontamination." Standard Operating
Procedures.
6.0 EXHIBITS
Exhibit 13-1 Monitoring Well Sampling Data
Exhib it 13 -2 W ater Level F orm
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 13
Revision No. 0
Date: 01/2000
Page 5 of 6
EXHIBIT 13-1
Monitoring Well Sampling Data
CDPHE
Monitoring Well
Sampling Data
Proiect Number
Project Name:
Page of
Well/Borehole
Number.'
Well/Borehole Location:
Static Water Level; (ft) i
Sample No:_
Elevation:
Sampling Method:_
Weather:
Bar. Press.
Amb. Temp.
WATER ELEVATION DATA
1.1 Depth Water Surface:
Method of Measurement:
(From Casing Top as Marked)
2.1 Static Water Level Elevation:
(Casing Top Elevation minus 1)
Product obs: Yes No
Depth to Product:
3.1 Deoth to Well Bottom:
(From Casing Top as Marked)
4.1 Height of Water Column (hi:
(3 minus 1)
Method of Measurement:
Volume of Water in Well:(x1 (hi = (gals)
(for 2" x= 0.163 gal/ft for 4" x = 0.653 gal/ft)
Amount of Water Removed From Well:
Was Well Pumped Dry? Yes No
Method of Water Removal-
Total Volume/Time:
Time
Temp ฐC
Conductivity
EH
Turbidity Removed Flow Rate
Observations
Recorded By:
Date:
Checked By:
Dace:
I:\QAPP\SOP\SOP 13,wpd
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 13
Revision No. 0
Date: 01/2000
Page 6 of 6
EXHIBIT 13-2
Water Level Form
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I:\QAPP\SOP\SOP 13.wpd
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 14
Revision No.: 0
Date: 01/2000
Page 1 of 5
STANDARD OPERATING PROCEDURE - 14
WATER SAMPLE FIELD MEASUREMENTS
1.0 PURPOSE
This procedure outlines the types of measurements and data requirements associated with the collection of
either groundwater or surface water samples. Accurate measurement of water parameters is required when
collecting water samples so that baseline conditions can be established, thus allowing later evaluations of how
these parameters may have affected the sample results.
Site-specific deviations from the methods presented in this procedure must be approved by the Proj ect Leader
and the CDPHE Quality Assurance Officer.
2.0 DEFINITIONS AND ABBREVIATIONS
2.1 Definitions
Not applicable.
2.2 Abbreviations
Not applicable.
3.0 RESPONSIBILITIES
Sampling personnel are responsible for performing the applicable tasks and procedures outlined herein when
conducting work related to environmental projects.
The Project Leader or an approved designee is responsible for checking all work performance and verifying
that the work satisfies the applicable tasks required by this procedure. This will be accomplished by
reviewing all documents (Exhibits) and data produced during work performance.
4.0 PROCEDURE
Read and follow the specific Manufacturer's Operating Instructions before using any equipment.
Calibrate all equipment as specified below. Additionally, calibrate all equipment prior to and at the
commencement of sampling activities to ensure proper equipment operation. Record these measurements
in the field log book or in an instrument log book.
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Standard Operating Procedures Procedure No. 14
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Page 2 of 5
4.1 Temperature
Decontaminate the thermometer according to CDPHE Standard Operating Procedure (SOP)
4.11, Equipment Decontamination. Calibrate electronic thermometers (if applicable)
according to their manufacturer's specifications.
Collect the sample in a clean flask or beaker and insert the temperature probe into the water
as per the manufacturer's specifications.
Read the temperature from the meter and record it in the field log book and on either Exhibit
14-1, Monitoring Well Sampling Data, or Exhibit 14-2, Surface Water Sampling Data.
Discard the sample and rinse the probe with distilled water.
4.2 pH
The pH probe must be thoroughly decontaminated prior to use according to CDPHE SOP
4.11, Equipment Decontamination. Calibrate the pH meter according to the manufacturer's
specifications.
Collect the sample in a clean flask or beaker and insert the pH probe into the water according
to the manufacturer's specifications.
Read the pH measurement from the meter approximately one minute from the time the
sample was collected and record it in the field log book and on either Exhibit 14-1,
Monitoring Well Sampling Data, or Exhibit 14-2, Surface Water Sampling Data.
Discard the sample and decontaminate the probe.
4.3 Conductivity
The conductivity probe must be thoroughly decontaminated prior to use according to
CDPHE SOP 4.11, Equipment Decontamination. Calibrate the conductivity meter according
to the manufacturer's specifications.
Collect the water sample in a clean flask or beaker and insert the conductivity probe into the
water according to the manufacturer's specifications.
Wait for the reading to stabilize and record the conductivity reading from the meter in the
field log book or on either Exhibit 14-1, Monitoring Well Sampling Data or Exhibit 14-2,
Surface Water Sampling Data. Check the conductivity meter settings to be sure the desired
scale is being used.
Discard the sample and decontaminate the electrode.
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Standard Operating Procedures
Colorado Department of
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Procedure No. 14
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Date: 01/2000
Page 3 of 5
4.4 Dissolved Oxygen Measurement
Decontaminate the dissolved oxygen meter according to the manufacturer's specifications.
Because the probe membrane is very fragile and susceptible to dryness, keep it moist at all
times.
Calibrate the dissolved oxygen meter according to the manufacturer's specifications. At a
minimum, calibrate twice daily to correct for instrument drift.
Collect the water sample as close to the source as possible and place it in a clean flask or
beaker.
Insert the dissolved oxygen probe into the sample so that the membrane is fully submerged.
Very gently stir the probe through the sample. Do not agitate the probe as air bubbles cause
erroneous measurements.
" When the reading stabilizes, record it in the field log book and on either Exhibit 14-1,
Monitoring Well Sampling Data, or Exhibit 14-2, Surface Water Sampling Data.
Discard sample and decontaminate the probe.
4.5 Review
The Project Leader or an approved designee shall check the field log book as well as Exhibit 14-1,
Monitoring Well Sampling Data, or Exhibit 14-2, Surface Water Sampling Data, for completeness
and accuracy. Any discrepancies will be noted and the data will be returned to the originator for
correction. The reviewer will acknowledge that review comments have been incorporated by signing
and dating the "checked by" and "date" blanks on Exhibit 14-1, Monitoring Well Sampling Data, or
Exhibit 14-2, Surface Water Sampling Data.
5.0 REFERENCES
U.S. Geological Survey (USGS). 1984. National Handbook of Recommended Methods for Water-Data -
Acquisition.
CDPHE, 2000. "Standard Operating Procedure 4.11, Equipment Decontamination." Standard Operating
Procedures.
6.0 EXHIBITS
Exhibit 14-1 Monitoring Well Sampling Data
Exhibit 14-2 Surface Water Sampling Data
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Standard Operating Procedures
Colorado Department of
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Procedure Ho. 14
Revision No.: 0
Date: 01/2000
Page 4 of 5
EXHIBIT 14-1
Monitoring Well Sampling Data
CDPHE
Monitoring Well
Sampling Data
Project Number _
Project Name:
Page of_
Well/Borehole
Number:
Well/Borehole Location:
Static Water Level!
Jft)
Sample No:_
Elevation:
Sampling Method:_
Weather:
Bar. Press.
Amb. Temp.
WATER ELEVATION DATA
1.1 Depth Water Surface:
Method of Measurement:
(From Casing Top as Marked)
2.1 Static Water Level Elevation:
(Casing Top Elevation minus 1)
Product obs: Yes No
Depth to Product:
3.1 Dentil to Well Bottom:
(From Casing Top as Marked)
4.1 Heieht of Water Column (hi:
(3 minus 1)
Method of Measurement:
Volume of Water in Well:(x1 (hi = (gals)
(for 2" x 0.163 gal/ft for 4" x = 0.653 gal/ft)
Amount of Water Removed From Well:
Was Well Pumped Diy? Yes No
Method of Water Removal:
Total Volume/Time:
Time
Temp ฐC
Conductivity
SH
Turbidity
Removed
Flow Rate
Observations
Recorded By:
Date:
Checked By:
Date:
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Standard Operating Procedures Procedure No. 14
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Public Health and Environment Date: 01/2000
Page 5 of 5
EXHIBIT 14-2
Surface Water Sampling Data
CDPHE
Surface Water
Sampling Data
Project Number _
Project Name:
Page of_
Sample No:_
Elevation:
Sampling Method:_
Weather:
Bar. Press.
Amb. Temp.
WATER SAMPLE DATA
Water Temp:
oC
Method of Measurement:
Specific Conductance:
Method of Measurement:
pH:
Method of Measurement:
Containers Used (VOA Vial, 1 liter jar etc...):
Physical Appearance:
Contamination Observed:
Remarks:
Recorded By:
Date:
Checked By:
Date:
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 15
Revision No.: 0
Date: 01/2000
Page 1 of 10
STANDARD OPERATING PROCEDURE - 15
FLOW MEASUREMENT
1.0 PURPOSE
This procedure provides general guidance for the planning, method selection, and implementation of surface
flow measurements for environmental field investigations that require information on flows for streams,
rivers, or surface impoundments.
2.0 DEFINITIONS AND ABBREVIATIONS
2.1 Definitions
Flow (or Volumetric Flow Rate)-. The volume of water that passes through a cross-sectional plane
of a channel in some unit of time.
Flow Measurement: The act or process of quantifying a flow rate.
2.2 Abbreviations
CFS Cubic feet per second
gpm Gallons per minute
SOP Standard Operating Procedures
USGS U.S. Geological Survey
3.0 RESPONSIBILITIES
Field personnel are responsible for performing the applicable tasks and procedures outlined herein when
conducting work related to environmental projects.
The Project Leader or an approved designee is responsible for checking all work performance and verifying
that the work satisfies the applicable tasks required by this procedure.. This will be accomplished by
reviewing all documents (Exhibits) and procedures.
4.0 PROCEDURES
4.1 General Considerations
The planning and implementation of flow measurements requires consideration of the data collection
requirements. The accuracy and precision required of the flow measurement will determine the
methodology employed in the field. Local site conditions, i.e., site access, stream bed geometry and
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Standard Operating Procedures
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Procedure No. 15
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apparent flow rate, will determine how field procedures must be modified to obtain accurate and
precise data.
The two major variables that are determined during flow measurements are:
The geometry of the cross-sectional plane through which the fluid passes; and
The velocity at which the fluid is moving through a particular cross section.
These variables are discussed in Section 4.2, General Methods and Applications.
The two major factors that cause variance in flow measurements are:
The variations in technical procedures introduced by the operator; and
The variations in fluid flow introduced by turbulence.
The variations in technical procedures introduced by the operator can be minimized by carefully
following the procedures outlined in this Standard Operating Procedure (SOP).
The variance in flow measurement caused by fluid turbulence can be reduced by applying the
following procedures. The more turbulent the flow the less accurate and reproducible the flow
results.
Do not stand upstream or beside the flow measuring device and stand far enough
downstream of the device so that no turbulence affects the device.
Avoid areas just downstream of a waterfalls, rapids, weir, sluice, dam, or any other structure
that creates flow turbulence.
Avoid areas of the stream that have rocky bottoms, stepping stones, wetlands vegetation in
the stream bed or braided channels caused by sandbars.
The more turbulent the flow the less accurate and reproducible the flow results. The ideal location
has easy access, with uniform stream banks that are not obstructed by vegetation or debris and a
uniform stream bed that is that is also free of vegetation and debris.
Health and safety considerations are also important factors to be considered in planning and
execution of flow measurements. Some of these considerations are:
Accessibility of the site, i.e., bank steepness or obstacles;
Depth of the fluid to be measured;
Apparent flow rate of the fluid to be measured;
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Condition of the steam bed, i.e., slipperiness, obstructions, debris, vegetation, etc.; and
Proximity of downstream structures such as dams, weirs, sluices, rapids and waterfalls.
4.2 General Methods and Applications
Selection and implementation of flow measurement practices require that consideration be given to
the following issues which are common to all surface flow measurements at or near environmental
sites:
Preventing the spread of contamination;
Minimizing the risk to health and safety;
Maintaining a high level of accuracy in measuring flows;
Causing the least possible disruption to on-site activities; and
Reducing, where possible, any additional long- and short-term impacts.
Flow measurements are made in open channels that consist of a bed, two banks or sides, and a free
or open water surface.
Most flow measurements are based on determining two key variables cited in Subsection 4.1: cross-
sectional area and velocity across that area. For open channels, especially smaller ones, the cross
section is often best measured directly using a tape. Care must be taken to find a location where the
dimensions are constant during the time period in which flow measurements will be taken. Width
and depth are expressed in terms of meters or feet, and the cross-sectional area is expressed as square
meters or square feet.
Velocity is determined using one of the methods that follows, either directly or by calculation. Units
are commonly given in meters per second or feet per second for most flow velocities. When cross-
sectional area and flow velocity are multiplied, their product is the volumetric flow rate expressed
as cubic meters per second or cubic feet per second (CFS) for large flows, and as liters per second
or gallons per minute for small flows.
4.3 Direct Measurement
At times, the flow in a small stream can be caught in a collector of known volume, such as a 5-gallon
can or 5 5-gallon drum. By clocking the amount of time needed to fill the vessel, one may obtain a
direct measurement of volumetric flow rate without resorting to cross-sectional area and velocity
measurements. A minimum of 10 seconds to fill the container is recommended. Several fill-ups
should be timed, and the results should be averaged to improve the quality of this measurement.
Other means of flow measurement will be used more often than this direct estimate, which is valid
only for flows between 0.06 liter per second (one gallon per minute (gpm)) and about 6.3 liters per'
second (100 gpm).
4.4 Current Meter
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Procedure No. 15
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A current meter can be a mechanical device with a rotating element that, when submerged in a
flowing stream, rotates at a speed proportional to the velocity of the flow at that point below the
surface. The rotating element may be either a vertical shaft or a horizontal shaft. Meter
manufacturers usually provide the user with calibration tables to translate rotation into linear speed
in meters per second or feet per second.
Current meters can also be electromagnetic sensors where the passage of fluids between two
electrodes in a bulb-shaped probe causes a disturbance of the electromagnetic field surrounding the
electrodes. This disturbance generates a small voltage that Can be made proportional to fluid velocity
by internal electronic circuitry. A direct readout of velocity in meters per second or feet per second
is provided for the user (Marsh-McBirney undated).
4.4.1 Applicability
Vertical axis meters are more commonly used because they are simpler, more rugged, and
easier to maintain than horizontal shaft meters. They also have a lower threshold velocity
of 0.03 meters/sec (0.1 feet/sec). The electromagnetic current meters can be used in making
measurements in situations where mechanical meters cannot function, such as weedy
streams where mechanical rotating elements would foul. However, the electromagnetic
meters must always be carefully aligned to be normal to the stream cross section, since the
meter measures only one velocity vector (the one parallel to the probe's longitudinal axis).
Current meters will operate at depths ranging from 0.1 meter (0.3 foot) to any depth where
the meter can be held rigidly in place using cables or extension poles. For most
environmental investigations, depths rarely exceed two or three meters (6.5 to 10 feet).
Since current meters provide readings at a single point, the mean velocity must be based on
multiple readings along a vertical line, or on a single reading that can be converted to an
estimated mean velocity using standard coefficients.
In many areas, the flow of waterways is monitored by local agencies. An effort should be
made to incorporate flow readings from established gauge stations. At many locations,
readings will be accurate and easy to obtain.
Methods for estimating mean velocity include the following:
Six-tenths Depth Method - Uses the observed velocity at a point 0.6 of the total
depth below the surface as the mean velocity for the vertical. Flow is calculated for
each subsection defined by the verticals and is the product of the depth times the
mean velocity for that subsection. Total discharge flow is the sum of all individual
subsection flows, while the average stream velocity is that sum (total discharge)
divided by the total cross-sectional area. The number of readings to be taken to
increase accuracy will depend on the width of the stream, from 2 or 3 readings for
streams less than 5 feet across to 15 to 25 readings for streams wider than 50 feet
across. Ideally, the stream should be partitioned into sections small enough so that
less than 10 percent of the total stream flow passes through each section. In this
manner, individual measurements that may be in error will have less impact on the
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overall average velocity determination. However, practical consideration, such as
a rapidly changing stage or limited time available to conduct measurements, often
may preclude the use of the ideal number of partial sections. Users must recognize
the potential impact on the overall accuracy of velocity measurements from an
inadequate number of verticals within a given cross section. This method works
best at depths between 0.09 and 0.16 meters (0.3 to 2.5 feet) and is the method of
choice when measurements must be made quickly.
Two-point Method - Measures velocities at 0.2 and 0.8 of the total depth below the
surface. The average of the two readings is considered to be the average for the
vertical. Several different verticals are averaged across the cross section. This
method is more accurate than the six-tenths depth method, but it cannot be used at
depths less than 0.76 meters (2.5 feet) because the observation points would be too
near the surface and the streambed.
Three-point Method - Measures velocities at 0.2, 0.6, and 0.8 of the total depth
below the surface. Readings at 0.2 and 0.8 are averaged; then that result is averaged
with the reading at 0.6. This method provides a better mean value when velocities
in the vertical are abnormally distributed, but it should not be used at depths less
than 0.76 meters (2.5 feet).
Vertical-velocity Method - Primarily for deep channels, this method measures
velocities at 0.1 depth increments between 0.1 and 0.9 of the total depth for several
verticals. Because of the multiplicity of readings, this method is rarely used.
4.4.2 Current Meter Methods
A step-by-step summary of a typical flow or discharge measurement is as follows:
Assemble current meter and test for proper operation in accordance with the
manufacturer's instructions. Collect data form or notebook, pencil, stopwatch, 50-
foot tape, etc.
Partition stream into sections (with tag line or bridge railing), visually observing the
velocity and general flow of the stream. An adequate number of stations should be
established to prevent more than 10 percent of the total discharge from passing
through any individual partial section. Note that the partial section in question isnot
the same as the interval between two successive stations. Mark stations
appropriately. A check of measurements may indicate the need for readjustment of
the partitioned sections to upgrade the quality of the readings.
Record stream stage as indicated by one of the staff gauges, and record this value
on the water level recorder chart at the point of pen contact.
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Record the following items and other data as appropriate in the field log book and
on Exhibit 15-1, Surface Water Flow Measurement:
- Project;
- Site;
- Date;
- Time at start of measurements;
- Stream stage at start of measurements;
- Approximate wind direction and speed;
- General stream condition (e.g., turbid, clear, low level, floating debris,
water temperature, type of streambed material, etc.);
- Other factors having a bearing on discharge measurements;
- Location of initial point;
- Total width of stream to be measured;
- Type of current meter and conversion factor, if applicable; and
- Name of investigator taking the readings.
Determine the depth and mean velocity at the first station or "initial point," if
appropriate, and record this information.
Measure depth at the second station from initial point and record. Determine
whether the velocity should be measured at the 0.6 depth from the surface (six-
tenths depth method), at the 0.2 and 0.8 depths (two-point method), or by either of
the other methods available. Calculate respective depths from the surface, measure
the velocity at each point, and record these values.
Follow the same method at each successive station and proceed as quickly as
possible.
Determine the depth and mean velocity at the last station, or endpoint, and record
in the field log book and on Exhibit 15-1, Surface Water Flow Measurement.
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Record in the field log book and on Exhibit 15-1, Surface Water Flow
Measurement, the ending time of this series of measurements and the stage, since
the stage may have been changing during the measurements.
Enter the ending stage value on the recorder chart at the point of pen contact. This
information will illustrate the interval of time and stage variations during the cross-
sectional measurements, also enter the date in the field log book and on Exhibit 15-
1, Surface Water Flow Measurement, and indicate that a calibration has taken place
over this interval.
Remove the tag line (if used); rinse the current meter in clean water, if necessary;
allow the current meter to dry; then pack it in its carrying case.
Other issues of concern regarding stream discharge calibrations include:
Where practical, make the measurements with the investigator standing behind
(downstream) and well to the side of the meter;
Avoid disturbing or standing along the streambed beneath the cross-sectional
measuring points. This location is part of the control area and should remain
constant, if possible, from calibration to calibration of the stream. This step is
especially important if soft, mucky sediment is encountered somewhere along the
cross section;
Where possible, attempt to use the same cross section (location) throughout the
study period and during all of the stream calibrations. However, the number and
position of stations within the cross section may be changed, if necessary, to
accommodate changing flow conditions;
Hold the wading rod vertically if it becomes necessary to switch meters during a
calibration, and ascertain how VNOrm is determined with each of the various types
of meters;
Repeat the stream calibration at regular intervals throughout the study period to
account for seasonal changes in stream bank vegetation and streambed alterations
that may affect measurements.
Once the mean velocity for each stream subsection is determined, that value is multiplied
by the area of the subsection; the product is the volumetric flow through the subsection per
unit of time. The total discharge rate is the sum of all volumetric flows for each subsection
across the entire cross section of the stream. Refer to U.S. Geological Survey (USGS) Water
Supply Paper 2175 for additional information (U.S. Geological Survey (USGS) 1982).
Customary units are CFS for large flows and liters per second (gallons per minute) for small
flows.
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4.5 Current Meters and Stage Gauges
Where repeated measurements of a volumetric flow rate at a certain cross-sectional area are required,
install a permanent stage gauge along the stream's back or side wall to facilitate measurement of the
depth. The gauge will be a rigid rod or board, precisely graduated and firmly mounted with the
streambed serving as a possible reference point. Where stream characteristics are such that
significant bed erosion from scouring may be expected, it is best not to set the streambed as a zero
point. This could lead to confusion from generation of negative numbers for gauge height readings.
An arbitrary datum plume should be selected that is below the elevation of zero flow expected for
the stream site. Gauges may be mounted vertically (perpendicular to the stream surface) or may
incline along the slope of the stream bank. Vertical gauges are simpler to construct and calibrate,
while inclined gauges provide more accurate readings and are less likely to be damaged by material
floating by. The gauge provides one of the measurements needed to estimate area. Width is fixed
for channels with vertical sides and are readily determined for other configurations. Velocity is
determined using a current meter as described above.
Discharge rating curves are used to define the relationship between stage and stream discharge, and
to allow conversion of stage hydrographs to discharge hydrographs. The discharge calibration points
are hand or machine plotted onto a log-log paper graph of stage versus stream discharge. Stream
stage is plotted on the vertical Y axis, and stream discharge is plotted on the horizontal X axis.
Ideally, adequate calibrations are conducted over the full range of stage variations to allow a smooth
curve to be hand drawn through these points on the graph.
The slope and rate of change of slope may vary significantly over the length of this curve. At certain
gauging stations, the slope of this curve may break sharply, or the distribution of points may require
the construction of two partial curves rather than one continuous curve. These latter two situations
apply to more complex stage discharge relationships. It is the task of the investigator to derive a
mathematical relationship that describes this curve as closely as possible (i.e., an equation). The
development of an equation allows calculation of discharge flow by simply plugging in the stream
elevation. This equation allows computerization of the process of converting stage records into
discharge and eventually allows conversion to volume by noting the time interval on the recorder
chart at which this rate of flow applies.
More complicated rating relationships may be required at a particular gauging station. Discharge
may be not only a function of stage but also a function of slope, rate of change of stage, or other
variables specific to each site. Additionally, stage-discharge relationships are rarely permanent, and
discharge calibrations are carried out at periodic intervals to define the effects of various factors
including the following:
Scouring and deposition of sediment;
Alteration of streambed roughness as a result of the creation and dissemination of dunes,
anti-dunes, ripples, and standing-wave features in sandy bottoms; the deposition of leaves
and other debris during different seasons; and the seasonal variation in the growth of
macrophytes;
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Ice effects that may cause additional resistance to flow (if monitoring is carried out during
the colder months, a complete ice-over and additional freeze will tend to constrict the stream
channel with time and may increase the stage, when in fact the flow may not be increasing
at all); and
Human-related activities, such as upstream construction, recreation, etc.
4.5.1 Applicability
This method applies to sites where many flow measurements will be made over a long
period of time. Care must be taken to maintain a known zero reference point elevation. The
point does not have to be the stream's bottom. Where bed erosion over the course of flow
measurements may become a problem, provisions must be made to recalibrate the gauge at
regular intervals (e.g., weekly). The gauge is lowered or raised as necessary to conform with
changing bed conditions. Calculation of flow rate is the same as in the preceding subsection
for current meters alone.
4.6 Review
The Project Leader or an approved designee shall check Exhibit 15-1, Surface Water Flow
Measurement, for completeness and accuracy. Any discrepancies in the data will be noted and the
Exhibits will be returned to the originator for correction. The reviewer will acknowledge that review
comments have been incorporated by signing and dating the "Checked By" and "Date" blanks on
Exhibit 15-1, Surface Water Flow Measurement.
5.0 REFERENCES
Marsh-McBirney, Inc. "Instruction Manual, Model 201 Portable Water Current Meter." Gaithersburg,
Maryland: Marsh-McBirney, Inc. Undated.
U.S. Department of Interior. "Measurement and Computations of Streamflow: Volumes 1 and 2."
Geological Survey Water Supply Paper 2175. Washington, DC: USDA. 1982.
U.S. Environmental Protection Agency (EPA). 1987. "A Compendium of Superfund Field Operations
Methods." EPA/540/P-87/001. (OSWERDirective 9355.0-14.) December 1987.
U.S. Geological Survey (USGS). 1982. Water Supply Paper 2175.
6.0 EXHIBITS
Exhibit 15-1 Surface Water Flow Measurement
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EXHIBIT 15-1
Surface Water Flow Measurement
CDPHE
Colorado Dept of Public
Health and Environment
Surface Water Flow Measurement
Records Management Data
Date Project Nome:
Site:
Fiuw Meaju.-emeif M*^'d
Flow Meter
Gauging/Sample Location:
Channel Description:
Stream Width:
Measurement Filtering Method: Fixed Point Averaging (FPA)
FDA Interval: seconds
Loebook Paees:
. Distance from - -
Initial-Point .::;
;Meter.Heigbtv-
\ Width:;of
* , -j Meflsurement:5;?v:>
Depth-o Cฆ Water,
(ft1)
: Velocity
{ft/sec);c
Discharge^::;
'V:;(CFS)^.
- - .
Recorded By:
Date: Checked By:
Date:
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Standard Operating Procedures
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Procedure No. 16
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~ STANDARD OPERATING PROCEDURE - 16
SURFACE AND SHALLOW DEPTH SOIL SAMPLING
1.0 PURPOSE
The purpose of this procedure is to describe the equipment and operations used for sampling surface and
shallow depth soils. This procedure outlines the methods for soil sampling with routine field operations on
environmental projects. Site-specific deviations from the methods presented herein must be approved by the
Project Leader and the CDPHE Quality Assurance Officer.
2.0 DEFINITIONS AND ABBREVIATIONS
2.1 Definitions.
Soil: All unconsolidated materials above bedrock.
Surface Soils: Soils located zero to six inches below ground surface.
Shallow Depth Soils: Soils located above the bedrock surface and from six inches to six feet below
ground surface.
2.2 Abbreviations
POC Purgeable organic compound
POX Purgeable organic halogens
PRP Potentially Responsible Party
SVOC Semivolatile organic compounds
TOC Total organic carbon
TOX Total organic halogens
SOP Standard Operating Procedure
CDPHE Colorado Department of Public Health and Environment
VOC Volatile organic compound
3.0 RESPONSIBILITIES
Sampling personnel are responsible for performing the applicable tasks and procedures outlined herein when
conducting work related to environmental projects.
The Project Leader or an approved designee is responsible for ensuring that performance standards specified
by this SOP are achieved. This will be accomplished by reviewing all documents, exhibits and field
procedures.
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4.0 PROCEDURES
4.1 Introduction
The objective of surface and shallow depth soil sampling is to ascertain the type, degree, and extent
of soil contamination at a site. The data can be used to evaluate potential threats to human health
or the environment, to evaluate potential exposure pathways, or to calculate environmental risks.
4.2 Sampling Equipment
Surface and shallow soil sampling equipment includes:
Stainless steel mixing bowl;
Stainless steel trowels or spoons;
Stainless steel hand auger;
Stainless steel core sampler which uses stainless steel or Lexanฎ liners (optional);
Stainless steel shovel; and
Appropriate sample containers.
4.3 Decontamination
Before initial use, and after each subsequent use, all sampling equipment must be decontaminated
using the procedures outlined in CDPHE Standard Operating Procedure (SOP) 4.11, Equipment
Decontamination.
4.4 Sampling Location/Site Selection
Follow the sample design criteria outlined in the Project Plan for each sampling event. Relocate
the sample sites when conditions dictate - such as natural or artificial obstructions at the proposed
sample location (e.g., boulders, asphalt, etc.). Document the actual sample locations on a
topographic map or site sketch and photograph all sample locations.
4.5 Sampling Approaches
It is important to select an appropriate sampling approach for accurate characterization of site
conditions. Prior to undertaking any soil sampling program, it is necessary to establish appropriate
measurement and system Data Quality Objectives. Refer to the U.S. Environmental Protection
Agency (EPA) Soil Sampling Quality Assurance User's Guide (listed in Section 5.0, References)
for guidance in establishing Data Quality Objectives, statistical sampling methodologies and
protocols for each of the sampling approaches. Each approach is defined below.
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4.5.1 Judgmental or Biased Sampling
Judgmental or Biased sampling is used primarily for documenting an observed release to
either the groundwater, surface water, air or soil exposure pathways. This form of sampling
is based on the subjective selection of sampling locations where contamination is most likely
to occur. Locations are based on relative historical site information and on-site investigation
(site walk-over) where contamination is most likely to occur.
There is no randomization associated with this sampling approach because samples are
primarily collected at areas of suspected highest contaminant concentrations. Any statistical
calculations based on the results of this sampling technique will be biased.
4.5.2 Random Sampling
Random sampling, used for the characterization of a heterogeneous non-stratified waste,
involves arbitrary collection of samples within a defined area. This method is most effective
and accurate if the chemical heterogeneity of the waste remains constant from batch to batch.
The easiest method for Random Sampling is to divide the area for sampling into an
imaginary grid, assign a series of numbers to the units of the grid, and select the numbers
or units to be sampled through the use of a random-numbers table which can be found in the
text of any basic statistics book. Note that haphazardly selecting sample numbers or units
is not a suitable substitute for a randomly selected sample. Refer to Exhibit 16-1, Figure 1
for the random sampling approach.
4.5.3 Stratified Random Sampling
Stratified random sampling, used for the characterization of a heterogeneous stratified
waste, involves arbitrary collection of samples within a defined area and strata. This method
is most effective and accurate if the chemical heterogeneity of the waste remains constant
from batch to batch. The easiest method for stratified random sampling is to divide the area
for sampling into an imaginary grid, assign a series of numbers to the units of the grid, and
select the numbers or units to be sampled through the use of a random-numbers table which
can be found in the text of any basic statistics book. A random sample is then collected from
each strata at the selected numbers or units on the grid. Note that haphazardly selecting
sample numbers or units is not a suitable substitute for a randomly selected sample. Refer
to Exhibit 16-1, Figure 1 for the random sampling approach. Exhibit 16-1, Figure 2
illustrates a stratified random sampling approach.
4.5.4 Systematic Grid Sampling
Systematic grid sampling involves dividing the area of concern into smaller sampling areas
using a square or triangular grid. Samples are then collected from the intersection of the grid
lines or "Nodes." The origin and direction for placement of the grid should be selected by
using an initial random point. The distance between nodes is dependent upon the size of the
site or area of concern and the number of samples to be collected. Generally, a larger
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distance Is used for a large area of concern. Refer to Exhibit 16-1, Figure 3 for the
systematic grid sampling approach.
4.5.5 Systematic Random Sampling
Systematic random sampling involves dividing the area of concern into smaller sampling
areas. Samples are collected within each individual grid cell using random selection
procedures. Exhibit 16-1, Figure 4 illustrates a systematic random sampling approach.
4.5.6 Search Sampling
Search sampling utilizes a systematic grid or systematic random sampling approach to define
areas where contaminants exceed clean-up criteria. The distance between the grid lines and
number of samples to be collected are dependent upon the acceptable level of error (i.e., the
chance of missing a hot spot). This sampling approach requires that assumptions be made
regarding the size, shape, and depth of hot spots. Exhibit 16-1, Figure 5 illustrates a search
sampling approach.
4.5.7 Transect Sampling
Transect sampling involves establishing one or more transect lines, parallel or non-parallel,
across the area of concern. If the lines are parallel, this sampling approach is similar to
systematic grid sampling, The advantage of transect sampling over systematic grid sampling
is the relative ease of establishing and relocation transect lines versus an entire grid.
Samples are collected at regular intervals along the transect line at the surface and/or at a
specified depth(s). The distance between the sample locations is determined by the length
of the line and the number of samples to be collected. Refer to Exhibit 16-1, Figure 6 for
the transect sampling approach.
4.6 General
All boreholes and pits will be filled in with the material removed during sampling unless otherwise
specified in the Project Plan. Where a vegetative turf has been established, fill in with native soil
or potting soil and replace the turf if practical in all holes or trenches when sampling is completed.
4.6.1 Homogenizing Samples
Homogenizing is the mixing of a sample to provide a uniform distribution of the
contaminants. Proper homogenization ensures that the containerized samples are
representative of the total soil sample collected. All samples to be composited or split
should be homogenized after all aliquots have been combined. DO NOT HOMOGENIZE
(MIX OR STIR) SAMPLES FOR VOLATILE COMPOUND ANALYSIS.
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4.6.2 Compositing Samples
Compositing is the process of physically combining and homogenizing several individual
soil aliquot of the same volume or weight. Compositing samples provides an average
concentration of contaminants over a certain number of sampling points.
4.6.3 Splitting Samples
Splitting samples (after preparation) is performed when multiple portions of the same
samples are required to be analyzed separately. Fill the sample containers for the same
analyses one after another in a consistent manner (i.e., fill EPA volatile organic compound
(VOC) container, fill Potentially Responsible Party's (PRP) YOC container, fill EPA
semivolatile organic compounds (SVOC) container, fill PRP SVOC container).
4.7 Surface Soil Sampling
Perform the following steps for surface soil sampling:
Prior to sampling, remove leaves, grass, and surface debris using decontaminated stainless
steel trowel;
Label the lid of the sample container with an indelible pen or affix the sample label to the
side of the jar and tape as to make it impervious to water prior to filling the container with
soil.
Collect surface soil samples with a decontaminated stainless steel trowel, spoon or hand
auger and transfer to a decontaminated stainless steel bowl for homogenizing. If VOC
analyses are to be conducted, fill the appropriate VOC sample containers and then proceed
to transfer the appropriate aliquot of soil to the decontaminated stainless steel bowl for
homogenizing;
Collect samples in the order of volatilization sensitivity. The most common collection order
is as follows:
Volatile organic compounds (VOC);
Purgeable organic carbon (POC);
Purgeable organic halogens (POX);
Total organic halogens (TOX);
Total organic carbon (TOC);
Extractable organics;
Total metals;
Dissolved metals;
Phenols;
Cyanide;
Sulfate and chloride;
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Turbidity;
Nitrate and ammonia; and
Radionuclides.
Immediately transfer the sample into a container appropriate to the analysis being performed
( CDPHE SOP 4.2, Sample Preservation, Containers and Maximum Holding Times);
Place the samples in a cooler with ice which must be maintained at approximately 4ฐC (if
appropriate for analyses) for transport to an analytical laboratory;
Immediately after the sample is collected, record applicable information in the field log book
as outlined in CDPHE SOP 4.6, Use and Maintenance of Field Log Books. This
information may also be entered on Exhibit 16-2, Surface/Shallow Soil Sampling Log.
Excess soil^sample media shall be placed in the soil boring or pit and filled to grade with
native soil or potting soil.
Decontaminate all sampling equipment ( CDPHE SOP 4.11, Equipment Decontamination);
and
Complete the Chain-of-Custody Record and associated documentation (CDPHE SOP 4.3,
Chain of Custody).
4.8 Surface Soil Sampling (Composite Samples Only)
Perform the following steps for surface soil (composite) sampling:
Prior to sampling, remove leaves, grass, and surface debris using decontaminated stainless
steel trowel;
Collect surface soil aliquots with a decontaminated stainless steel spoon, trowel or hand
auger and add to a stainless steel bowl and homogenize. Prior to homogenizing, remove an
aliquot for VOC analysis (if appropriate) and then homogenize;
Samples will be identified and label as per CDPHE SOP 4.4, Sample Identification,
Labeling, and Packaging;
Samples will be preserved and held as per CDPHE SOP 4.2, Sample Containers,
Preservation and Maximum Holding Times;
Complete the Chain-of-Custody Record and associated documentation (CDPHE SOP 4.3,
Chain of Custody).
Procedure No. 16
Revision No.: 0
Date: 01/2000
Page 6 of 12
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Record applicable information in the field log book as outlined in CDPHE SOP 4.6, Use and
Maintenance of Field Log Books. This information may also be entered on Exhibit 16-2,
Surface/Shallow Soil Sampling Log.
Decontaminate all sampling equipment (CDPHE SOP 4.11, Equipment Decontamination).
4.9 Shallow Depth Soil Sampling
Perform the following steps to collect shallow depth soil samples:
Use a decontaminated stainless steel shovel to remove the top layer of soil.
Remove leaves, grass, and surface debris that may have contacted the shovel using a
decontaminated stainless steel trowel;
-1*
Excavate soil to the pre-determined sampling depth by using a decontaminated hand auger.
Periodically, remove the cuttings from the auger;
When the proper sample depth is reached, remove the hand auger and all cuttings from the
hole;
Lower the decontaminated core sampler or hand auger to the bottom of the hole. When
using a core sampler, it must contain a decontaminated liner appropriate for the constituents
to be analyzed;
Mark the sample interval (i.e., one foot above ground level) on the hammer stem or auger;
Operate the slide hammer on the core sampler to drive the sampler head into the soil, or
advance the auger until it is flush with the interval mark at ground level;
Record weight of hammer, length of slide, blow counts and geologic soil data for all samples
collected with a core sampler in the field log book as outlined in CDPHE SOP 4.6, Use and
Maintenance of Field Log Books. This information may also be entered on Exhibit 16-2,
Surface/Shallow Soil Sampling Log;
When the core sampler liner or auger has been advanced the total depth of the required
sample, remove it from the bottom of the hole;
Immediately remove the liner from the core sampler and transfer the sample into a container
or stainless steel bowl for compositing and homogenizing as specified in the project-specific
Field Sampling Plan appropriate to the analysis being performed using a stainless steel spoon
or trowel. Prior to compositing and homogenizing, fill the appropriate aliquot for VOC
analysis (if conducted) and then composite and homogenize;
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Standard Operating Procedures
Colorado Department of
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Procedure No. 16
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Date: 01/2000
Page 8 of 12
Samples "will be identified and label as per CDPHE SOP 4.4, Sample Identification,
Labeling, and Packaging;
Samples will be preserved and held as per CDPHE SOP 4.2, Sample Containers,
Preservation and Maximum Holding Times;
Complete the Chain-of-Custody Record and associated documentation (CDPHE SOP 4.3,
Chain of Custody).
Record applicable information in the field log book as outlined in CDPHE SOP 4.6, Use and
Maintenance of Field Log Books. This information can also be entered on Exhibit 16-2,
Surface/Shallow Soil Sampling Log.
Decontaminate all sampling equipment (CDPHE SOP 4.11, Equipment Decontamination).
4.10 Abandonment Procedures
Abandon boreholes and fill to grade by filling in with the material removed for sampling or clean
fill (i.e., potting soil).
4.11 Review
The Project Leader or an approved designee shall check all Exhibits and field log books used to
record information during sampling for completeness and accuracy. Any discrepancies will be
noted and the documents will be returned to the originator for correction. The reviewer will
acknowledge that these review comments have been incorporated by signing and dating the
"checked by" and "date" blanks on the Exhibits and at the applicable places in the log book.
5.0 REFERENCES
U.S. Environmental Protection Agency (EPA). 1989. "Soil Sampling Quality Assurance User's Guide."
EPA/600/8-89/046, U.S. Environmental Protection Agency, Washington, DC.
CDPHE. 2000. "Standard Operating Procedure 1, Use and Maintenance of Field Log Books." Standard
Operating Procedures.
CDPHE. 2000. "Standard Operating Procedure 2, Sample Preservation, Containers, and Maximum Holding
Times." Standard Operating Procedures.
CDPHE. 2000. "Standard Operating Procedure 3, Chain of Custody." Standard Operating Procedures.
CDPHE. 2000. "Standard Operating Procedure 4, Sample Identification, Labeling, and Packaging."
Standard Operating Procedures.
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 16
Revision No.: 0
Date: 01/2000
Page 9 of 12
CDPHE. 2000. " Standard Operating Procedure 5, Sample Location Documentation." Standard Operating
Procedures.
CDPHE. 2000. "Standard Operating Procedure 6, Use and Maintenance of Field Log Books." Standard
Operating Procedures.
CDPHE. 2000. "Standard Operating Procedure 11, Equipment Decontamination." Standard Operating
Procedures.
6.0 EXHIBITS
Exhibit 16-1 Figures for Different Forms of Grid Sampling
Exhibit 16-2 Surface/Shallow Soil Sampling Log
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Standard Operating Procedures Procedure No. 16
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Public Health and Environment Date: 01/2000
Page 10 of 12
EXHIBIT 16-1
Figures For Different Forms of Grid Sampling
Figure!: Random Sampling"
100
0
75
a
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25
B J
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I
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100 1 25 150
175 200 225
FEET
Figure 2:
Stratified Random Sampling
Figure 2:. Systematic Grid Sampling'
" Aftปf U.S. EPA, Mruvy. 19S3
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Standard Operating Procedures Pr ,r .. ...
/- i j r\ - Procedure No. 6
Colorado Department of D . . .
n. ut- u uiT j r- Revision No.: 0
Health Environment Date; 0I/M00
Page 11 of 12
EXHIBIT 4.16-1 (Continued)
Figures For Different Forms of Grid Sampling
Figure 4: Systematic Random Sampling
CO -
ci
Q
irJ
Mi
75
/4a
a
B
B
a
B
\
so
B
s
B
3
s
a
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B
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a
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7
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2S SO 75 100 123 150 175 200 225
FEET
Figure 5: Search Sampling
100
25
2S SO 75 100 125 150 173 200 225
FEET
Figure 6: Transect Sampling
100
75
V*
Ui
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Standard Operating Procedures Procedure No. 16
Colorado Department of . Revision No.: 0
Public Health and Environment Date: 01/2000
Page 12 ofl2
EXHIBIT 16-2
Surface/Shallow Soil Sampling Log
Pwaact Hfimr
f^gjuQ Ktmt
1
4 i ฆ ซ
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 17
Revision No.: 0
Date: 01/2000
Page 1 of 6
STANDARD OPERATING PROCEDURE - 17
SEDIMENT SAMPLING
1.0 PURPOSE
This procedure establishes the guidelines for sediment sampling using a variety of sampling devices.
Methods for preventing sample and equipment cross-contamination are included. Proper sediment sampling
ensures that any evaluations of sediment contamination are based on actual contaminant levels and are not
based on improper sampling techniques.
This procedure provides guidance for routine field operations on environmental projects. Site-specific
deviations from the methods presented herein must be approved by the CDPHE Project Leader Quality
Assurance Officer.
2.0 DEFINITIONS AND ABBREVIATIONS
2.1 Definitions
Not applicable.
2.2 Abbreviations
VOC Volatile Organic Compounds
3.0 RESPONSIBILITIES
Field personnel collecting sediment samples are responsible for performing the applicable tasks outlined in
this procedure when conducting work related to environmental projects.
The Project Leader or an approved designee is responsible for checking all work performance and verifying
that the work satisfies the applicable tasks required by this procedure. This will be accomplished by
reviewing all documents (Exhibits) and data produced during work performance.
4.0 PROCEDURES
4.1 Non-Subaqueous Sediment Sampling
Non-subaqueous sediment sampling will consist of the following:
Field personnel will record all data in the field log books as described in UOS Technical
Standard Operating Procedure (TSOP) 4.5, Sample Location Documentation;
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Standard Operating Procedures
Colorado Department of
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Procedure No. 17
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Insert a decontaminated Teflonฎ or stainless steel spoon, scoop or trowel into sediment surface
and remove sample; or rotate auger into the sediment and remove sample;
Collect samples for volatile organic compounds (VOC) analysis from the sampling device or
from unmixed sediment placed into a stainless steel bowl;
Place the sample in a decontaminated stainless steel bowl. Stir sample thoroughly (non-VOC
samples only) with a decontaminated stainless steel spoon or spatula to provide a homogeneous
mixture prior to filling sampling containers;
Fill the appropriate sample containers as specified in CDPHE SOP 4.2, Sample Containers,
Preservation, and Maximum Holding Times;
Identify or label samples according to CDPHE SOP 4.4, Sample Identification, Labeling, and
Packaging;
Samples will be preserved and held as per CDPHE SOP 4.2, Sample Containers, Preservation
and Maximum Holding Times;
Decontaminate the sampling equipment as described in CDPHE SOP 4.11, Equipment
Decontamination.
4.2 Subaqueous Sediment Sampling
Subaqueous sediment sampling will consist of the following:
Specific sediment sampling devices are described in Exhibit 17-1, Sampling Equipment and
Techniques;
Decontaminate all sampling equipment according to CDPHE SOP 11, Equipment
Decontamination;
If sampling from a boat, attempt to collect the sample with the boat engine off or attempt to -
ensure that all exhaust fumes are directed away from the sample collection area until the sample
has been collected;
Lower the sampler at a controlled descent of approximately one foot per second (ft/sec.), until
the sampler reaches the bottom as indicated by a slackening of the cable. Slowly retrieve the
sampler and raise it at a controlled speed. When the sampler is at the water surface, attach a
tag line(s) to steady and pull the sampler back into the boat. If large samplers are used, a
motorized winch will be required for retrieval;
Open and tie back any vent flaps on the sampler and carefully siphon off any overlying water
over the side of the boat;
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Standard Operating Procedures Procedure No. 17
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Visually inspect the sample for acceptability (e.g., determine if an undisturbed surface layer is
evident, the overlying water is not excessively turbid, and adequate penetration is achieved);
if the sample is not acceptable, discard it and collect another sample from an adjacent location;
Carefully extrude the sediment from the sampler by slowly lifting on the winch cable and
sliding the sample out the bottom of the sampler. If using core liners, remove the front face of
the core liner to expose the side of the core;
Visually inspect the side of the sample to identify any obvious stratification (e.g., different
sediment types, sizes or colors), and if no patterns are evident, collect a sample from the surface
and mid-core depth. During some investigations, it may be necessary to collect separate
samples from the surface and mid-core depths. This may best be accomplished by gently
scraping the side of the core with a decontaminated stainless steel scraper or knife. Scrape
from the bottom to the top of the core only. If the sediment is unconsolidated, do not scrape;
Remove a sample from the upper two centimeters (cm) of the sample using a decontaminated
Teflonฎ or stainless steel scoop and place it in the sample container. From an undisturbed area
of the sample surface, scoop a two-cm sample only if grain size analysis is required. After
grain size analysis samples are collected, scrape off the upper sediment layer and discard
overboard. Collect samples from the mid-section of the sediment. Sediment must be removed
with caution to avoid contaminating the sample (i.e., from exposure to engine exhaust, rust, or
grease);
Nonrepresentative materials such as twigs or debris should not be included in the sample.
Sediments contacting the side of the sampler or core liner should not be included for analysis.
Aliquot size (i.e., mass), container type, storage conditions, and holding times will follow
guidelines in the project plans and CDPHE SOP 4.2, Sample Containers, Preservation, and
Maximum Holding Times; and
Identify or label samples as outlined in CDPHE SOP 4.4, Sample Identification, Labeling, and
Packaging.
4.3 Stream Sediment Sampling
Stream sediment sampling will include the following:
The sample should be collected in an area of sediment accumulation, such as the inside of
stream meanders, quiet shallow areas, and low velocity zones. Avoid areas of net erosion, such
as high velocity, turbulent flow zones;
If possible, remain on the stream bank. If the sample cannot be obtained from the bank, enter
the stream from a point downstream of the sediment sampling location. Entering a river may
be hazardous, hence, consult the Site Health and Safety Plan for specific safety procedures.
Collect the sediment sample by reaching into the stream with a decontaminated stainless steel
spoon or Teflonฎ scoop and scooping a sample in an upstream direction. Attempt to minimize
the loss of fine material;
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Colorado Department of
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Procedure No. 17
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Date: 01/2000
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Place sample in a stainless steel beaker or bowl and gently mix with a stainless steel spoon (non
VOC samples only). Transfer the sediment samples to the appropriate sample containers using
the stainless steel spoon. Do not mix samples for volatile organic analysis. If duplicate or split
samples are to be obtained, transfer the sediment directly from the stainless steel bowl into the
sample containers in the same manner as standard samples;
Identify or label sample containers in accordance with CDPHE TSOP 4.4, Sample
Identification, Labeling, and Packaging, and store as specified in CDPHE TSOP 44.2, Sample
Containers, Preservation and Maximum Holding times;
Decontaminate sampling equipment as outlined in CDPHE SOP 4.11, Equipment
Decontamination; and
Record all data in field log books.
4.4 Review
The Project Leader or an approved designee shall check all documents (Exhibits) generated during
sampling operations for completeness and accuracy. Any discrepancies will be noted and the
documents will be returned to the originator for correction. The reviewer will acknowledge that these
review comments have been incorporated by signing and dating the applicable reviewed documents.
5.0 REFERENCES
CDPHE, 2000. "Standard Operating Procedure 1, General Field Operation." Standard Operating Procedures.
CDPHE, 2000. "Standard Operating Procedure 2, Sample Containers, Preservation, and Maximum Holding
Times." Standard Operating Procedures.
CDPHE, 2000. "Standard Operating Procedure 4, Sample Identification, Labeling, and Packaging."
Standard Operating Procedures.
CDPHE, 2000. "Standard Operating Procedure 11, Equipment Decontamination." Standard Operating
Procedures.
CDPHE, 2000. "Standard Operating Procedure 18, Surface Water Sampling." Standard Operating
Procedures.
6.0 EXHIBITS
Exhibit 17-1 Sampling Equipment and Techniques
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Procedure No. 17
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EXHIBIT 17-1
Sampling Equipment and Techniques
Sediment samples may be obtained using on-shore or off-shore techniques. Sediment sampling equipment
and techniques must be designed to minimize the risk of dilution or loss of material as the sample is moved
through the water column. For situations where boats are required for sampling, extra precautionary
measures must be employed. At a minimum, life preservers must be provided and two individuals will
undertake the sampling and an additional person will remain in visual contact on-shore to observe the
operations.
Sediment sampling is described below.
Dip Sampler
A dip sampler consists of a pole with ajar or scoop attached. The pole may be made of bamboo, wood,
Teflonฎ, or aluminum and be either telescoping or of fixed length. The scoop or jar at the end of the pole
is attached by a clamp.
The dip sampler is operated by submerging the jar or scoop and pulling it through the sediments to be
sampled. The samples retrieved are then transferred into the appropriate sample container after decanting
the liquid. Further decanting can occur while the sample is present in the sample jar. Avoid contact with
sampler's gloves. Transferring the sample may require the use of a stainless steel or Teflonฎ spoon/spatula.
Hand Operated Core Samplers
Hand operated sediment core samplers are used to obtain sediment samples in shallow water (less than three
feet). These samplers operate in a manner similar to soil core samplers. However because of the saturated
conditions of most sediments, provisions must be made to retain the sample within the core. Core samplers
are generally constructed of a rigid metal outer tube into which a two-inch plastic core sleeve fits with
minimum clearance. The cutting edge of the core sampler has a recessed lip on which the plastic sleeve rests
and which accommodates a core retainer. This retainer is oriented such that when the sampler is pressed into
the sediment, the core is free to move past the retainer. Due to construction of the retainer, the core will not
-fall through the retainer upon removal of the sampler from the sediment.
When the sampler is removed from the sediment, the plastic sleeve is removed. The sediment is removed
from the sleeve and placed in the appropriate sample container. Chlorinated organics will not be collected
using core samplers because core sleeves and retainers are generally made of plastic. The hand operated core
sampler will not be useful for obtaining samples of gravelly, stony or consolidated sediments.
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Procedure No. 17
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Gravity Core Samplers
Gravity core samplers are used to obtain sediment samples in water bodies or lagoons with depths of greater
than three to five feet. These types of samplers can be used for collecting one- to two-foot cores of surface
sediments at depths of up to 100 feet beneath the water surface.
As with all core type samplers, gravity core samplers are not suitable for obtaining samples of coarse,
gravelly, stony, or consolidated deposits. They are, however, useful for fine grained inorganic sediment
sampling.
The gravity core sampler operates in a manner similar to the hand operated core in that a two-inch plastic
sleeve fits within a metal core housing fitted with a cutting edge. Plastic nests are used to retain the core
within the plastic sleeve. An opening exists above the core sleeve to allow free flow of water into and
through the core as it moves vertically downward to the sediment. The sampler has a messenger-activated
valve assembly which seals the opening above the plastic sleeve following sediment penetration. This valve
is activated by the messenger creating a partial vacuum to assist in sample retention during retrieval.
Samples are obtained by allowing the sampler, which is attached to approximately 100 feet of aircraft cable,
to drop to the benthic deposits. The weight of the sampler drives the core into the sediment to varying depths
depending on the characteristics of the sediments. The messenger is then dropped on the taut aircraft cable
to seal the opening above the plastic sleeve. The sampler is then carefully retrieved.
Upon retrieval of the sampler, the plastic core sleeve is removed and the sample placed in the appropriate
sample container. Care should be exercised in labeling in order to properly identify sample orientation.
Dredges are generally used to sample sediments which cannot easily be obtained using coring devices or
when large quantities of materials are required. Various dredge designs are available for sampling in deep
or turbulent waters and for obtaining samples from gravelly, stony or dense deposits.
Dredges generally consist of a clam shell arrangement of two buckets. The buckets may either close upon
impact or be activated by use of a messenger. Dredges are commonly quite heavy and therefore require use
.of a winch and crane assembly for sample retrieval.
Upon retrieval of the dredge, the sample can either be sieved or transferred directly to a sample container for
labeling and storage. Dredge types which could be used for sampling include Ponar, Petersen and Ekman
dredges.
Hand Auger
Sediment samples may be collected using a hand auger. When using a hand auger, provisions must be made
to ensure that sediment samples remain in the auger. Hand augers are best utilized when sampling non-
subaqueous sediments.
Dredges
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Colorado Department of
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Procedure No. 18
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Date: 01/2000
Page 1 of 17
STANDARD OPERATING PROCEDURE - 18
SURFACE WATER SAMPLING
1.0 PURPOSE
The purpose of this procedure is to describe the methods for surface water sampling. It describes the
procedures and equipment to be used to obtain representative surface water samples that are capable of
producing accurate quantification of water quality.
This procedure provides guidance for routine field operations on environmental projects. Site-specific
deviations from the methods presented herein must be approved by the CDPHE Project Leader and Quality
Assurance Officer.
2.0 DEFINITIONS AND ABBREVIATIONS
2.1 Definitions
Aliquot-. Fractional amount.
Composite Samples: Samples composed of more than one aliquot collected at various sampling sites
and/or at different times.
Epilimnetic zone: The uppermost layer of water in a lake, characterized by an essentially uniform
temperature that is generally warmer than elsewhere in the lake and by a relatively uniform mixing
caused by wind and wave action. Specifically, the light (less dense), oxygen-rich layer of water in a
thermally stratified lake.
Grab Samples: Samples that are collected at one particular point and time.
Hypolimnetic zone: The lowermost layer of water in a lake, characterized by an essentially uniform'
temperature (except during turnover) that is generally colder than elsewhere in the lake and often
characterized by relatively stagnant or oxygen-deficient water.
Rinsate: Waste water generated as a result of rinsing sampling equipment during decontamination
procedures.
Surface water samples: Samples of water collected from streams, ponds, rivers, lakes, or other
impoundments open to the atmosphere.
2.2 Abbreviations
PA Preliminary Assessment
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Procedure No. 18
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Date: 01/2000
Page 2 of 17
SI
SOP
Site Inspection
Standard Operating Procedures
3.0 RESPONSIBILITIES
Field personnel are responsible for performing the applicable tasks in accordance with this procedure
when conducting work related to environmental projects.
The Project Leader or an approved designee is responsible for checking all work performance and
verifying that the work satisfies the applicable tasks required by this procedure. This will be
accomplished by reviewing all documents (Exhibits) and data produced during work performance.
4.0 PROCEDURE
4.1 Introduction
The objective of surface water sampling is to evaluate the surface water quality entering and/or leaving
a site. It is also used to obtain data on waste loads, water quality and characteristics that will permit
prediction or modeling of the water system (to describe probable water quality), and effects on uses
under a variety of conditions.
4.2 Sampling Equipment
There is a variety of equipment available for surface water sampling. Because each site may contain
varied surface water conditions, collection of a representative sample may be difficult. In general, a
sampling device will include the following characteristics:
Be constructed of disposable or non-reactive material (Teflonฎ or stainless steel); and
Have a minimum capacity of 500 ml to minimize sample disturbance.
All surface water sampling equipment will be designed to maintain sample integrity and to provide
the desired level of quality in achieving desired analytical results.
Sampling equipment includes all sampling devices and containers that are used to collect or contain
a sample prior to final sample analysis.
4.3 Decontamination
Prior to and after each sampling event, all sampling equipment must be thoroughly decontaminated
following the methods outlined in CDPHE Standard Operating Procedure (SOP) 4.11, Equipment
Decontamination. The primary purpose of equipment decontamination is to prevent the potential of
cross-contamination within the samples collected.
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Procedure No. 18
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4.4 Sampling Location/Site Selection
Prior to sampling, consideration must be given to the specific sampling locations in order to provide
a representative sample. This and other considerations are detailed in the Project Plans.
The general determining factors in the selection of a sampling device for sampling liquids in lakes,
ponds, lagoons, and surface impoundments are listed below:
Accessibility:
- Boat: If the water is navigable, any sampling location is accessible by boat.
- Bridges: Provide ready access, are readily identifiable, and permit water sampling
at any point across the width of the water body.
- Wading: Personnel safety must be paramount. Wading is not recommended in areas
where bottom deposits are easily disturbed, thereby increasing the possibility of
increased sediment in the samples.
Rivers, streams, and creeks:
Sampling stations will be located wherever a marked physical change occurs in the
stream channel. For example, between a rapids/deep water transition, as well as at
both ends of the reach (only applicable for PA/SI, not ERB).
Sampling stations will be located short distances above and below dams and weirs,
to determine the artificial increase in dissolved oxygen (only applicable for PA/SI,
not ERB).
A minimum of three sampling locations will be established between any two points
of major change in a stream (only applicable for PA/SI, not ERB).
Sampling stations will be located upstream and downstream of any waste discharge
site. Since the inflow frequently hugs the stream bank with very little lateral mixing,
care must be taken to establish the sampling station after complete mixing with the
main stream.
A tributary sampling station will be established near the mouth and upstream of any
effects from the main stream. The station on the main stream will be just upstream
from the confluence.
Sample as close as is practical to areas or points of important water uses.
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Procedure No. 18
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- At stations where wastes and tributary waters are well-mixed, one sampling point
near mid-channel is usually adequate. At stations where mixing is inadequate, the
station will be sampled at quarter points across the width of the station.
Lakes, ponds, and impoundments:
- A single station at the deepest point may be sufficient for naturally-formed ponds
(near the center) and for impoundments (near the dam or spillway).
- A sampling grid is the most representative for lakes and large impoundments.
- In lakes with irregular shapes and with several bays and coves that are protected from
the wind, sampling stations should be established in these areas.
- A control station above a waste source is usually necessary to compare background
water quality. It should be carefully selected and it may be necessary to have two or
three control stations to establish the rate at which unstable material is changing. The
time of travel between stations should be sufficient to permit accurate measurement
of the change in the constituents under consideration.
4.5 Sampling Methods
4.5.1 General
The specific sampling method utilized will depend on the accessibility to, the size,
and the depth of the water body, as well as the type of samples being collected.
In most ambient water quality studies, grab samples will be collected. However, the
objectives of the study will dictate the sampling method.
For rivers, streams and creeks, the type of samples collected will be dependent upon
the size and the amount of turbulence in the water body. Approximate the depth and
location of samples in order to assure consistency. Flow rates will be measured using
an appropriate method as described in UOS SOP 4.15, Flow Measurement.
With small streams less than 20 feet wide, a single grab sample collected
at mid-depth in the center of the channel is usually adequate to represent the
entire cross-section. In small streams and creeks less than 10 feet wide, a
single grab sample can be collected by immersing the bottle directly under
the surface of the water as close to the center of the channel as possible.
This method reduces the potential for cross contamination as it does not
require the decontamination of equipment. Clean non-reactive surgical or
nitrile gloves are worn while the sample jar is immersed and filled in the
sample media.
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Procedure No. 18
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For slightly larger streams, a vertical composite sample in the center of the
channel may be required. The composite sample consists of samples taken
just below the surface, at mid-depth and just above the bottom.
For rivers, several vertical composite samples are collected across the water
body. The vertical composite samples will be collected at points in the
cross-section approximately proportional to flow. The number of vertical
composites required and the number of depths sampled for each are usually
determined in the field. This determination is based on a reasonable
balance between two considerations:
- The larger the number of subsamples, the more nearly the composite
sample will represent the water body; but
- Taking many subsamples is time-consuming and increases the
chance of cross-contamination.
For lakes, ponds and impoundments, the greater tendency to stratify and the
relative lack of adequate mixing usually requires that more subsamples be
collected. The flow rate of impoundments will be measured as described
in CDPHE SOP 4.15, Flow Measurement.
- In ponds and small impoundments, a single vertical composite
sample at the deepest point is usually adequate.
- In lakes and larger impoundments, several vertical composites
should be combined into a single sample. In some cases, it may be
useful to form several composites of the epilimnetic and
hypolimnetic zones. Normally, however, a composite consists of
several verticals with subsamples collected at various depths.
4.5.2 Weighted Bottle Sampler
Collecting a representative sample from a larger body of water requires the gathering
of samples from various depths and locations. For this type of sampling a weighted
bottle sampler is used. The sampler consists of a Teflonฎ bottle, a weighted sinker,
a bottle stopper and a wire cord used to raise, lower and open the samples. This type
of sampler can be fabricated or purchased. The following procedures will be
followed when sampling with a weighted bottle sampler (Exhibit 18-1, Weighted
Bottle Sampler):
Decontaminate all equipment in accordance with the procedures described
in CDPHE SOP 4.11, Equipment Decontamination;
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Procedure No. 18
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Assemble the weighted bottle sampler in accordance with the sampler
instruction manual;
Gently lower the sampler to the desired depth so as not to remove the
stopper prematurely. Do not let sampler disturb bottom sediments;
Pull out the stopper with a sharp jerk of the sampler line;
Allow the bottle to fill completely, as evidenced by the cessation of air
bubbles;
Raise the sampler, seal, wipe clean, label or identify and prepare the bottle
for transport in accordance with project guidelines;
Record the applicable information in the field log book. The information
may also be recorded on Exhibit 18-6, Surface Water Sampling Data; and
Mark sample location and approximate depth, if possible, and note on maps
and in field log book in accordance with CDPHE SOP 4.6, Use and
Maintenance of Field Log Books.
One additional grab sample from each location will be collected and described in
terms of pH, conductivity, temperature, turbidity, odors and other significant
characteristics. This sample will not be used for laboratory analysis.
4.5.3 Pond Sampler
The pond or dip sampler (Exhibit 18-2, Pond Sampler) consists of a scoop or
container attached to the end of a telescoping or solid pole. The sampler will be of
non-reactive material such as wood, plastic, or metal. The sample will be collected
in a jar or beaker made of stainless steel or Teflonฎ. Preferably, a disposable beaker
that can be replaced prior to each sampling will be used at each station. Liquid
wastes from water courses, ponds, pits, lagoons or open vessels will be "ladled" into
a sample container.
Perform the following procedures when sampling with a pond sampler:
Decontaminate all sampling equipment in accordance with the procedures
described in CDPHE SOP 4.11, Equipment Decontamination;
Assemble pond sampler in accordance with manufacturer's instructions;
Extend pole to length that will allow safe access to desired sample location;
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Colorado Department of
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Procedure No. 18
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Submerge pond sampler to desired sample depth. Submerge the sampler
very slowly to minimize surface disturbance;
Allow the sampler to fill very slowly;
Retrieve the sampling device with minimal surface water disturbance;
Remove the cap from the sample bottle and slightly tilt the mouth of the
bottle below the sampler edge;
Empty the sampler slowly, allowing the sample stream to flow gently down
the side of the bottle with minimal entry turbulence. Fill sample bottle to
appropriate head space, if any,
ป Seal sample bottle, wipe clean, label or identify and prepare for transport
in accordance with project guidelines;
Collect additional grab samples to acquire field measurements such as
temperature, pH, conductivity, turbidity and other significant
characteristics;
Record applicable data in the field log book. The data may also be recorded
on Exhibit 18-6, Surface Water Sampling Data;
Mark sample location and approximate depth, if possible, and note location
on maps and in field log book in accordance with CDPHE SOP 4.6, Use
and Maintenance of Field Log Books; and
Decontaminate equipment in accordance with procedures described in
CDPHE SOP 4.11, Equipment Decontamination.
4.5.4 Manual Hand Pumps
Manual pumps are available in various sizes and configurations. Manual hand pumps
are commonly operated by peristaltic, bellows or diaphragm, and siphon action.
Manual hand pumps that operate by a bellows or diaphragm, and siphon action
should not be used to collect samples that will be analyzed for volatile organics (4.18-
3, Manual Hand Pump). These types of pumps should be constructed out of inert
materials; i.e., Teflonฎ or stainless steel.
Perform the following procedures when collecting surface water samples with a
manual hand pump:
Assemble and operate the pump in accordance with the manufacturer's
instructions;
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Colorado Department of
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Procedure No. 18
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The inlet hose and any surface of the pump used for sampling will be
constructed of materials that are operable and non-reactive;
To avoid agitation, insert the sampling tube into the liquid sample prior to
pump activation;
Insert a liquid trap (preferably the sample container) into the sample inlet
hose to collect the sample and to prevent pump contamination;
Sample bottles will be sealed, wiped clean, labeled or identified and
prepared for transport in accordance with appropriate SOPs;
Record applicable data in the field log book. Data may also be recorded on
.18-6, Surface Water Sampling Data;
Decontaminate equipment in accordance with procedures described in
CDPHE SOP 4.11, Equipment Decontamination; and
Mark sample locations and approximate depth, where possible, and note
location on map and in field log book in accordance with CDPHE SOP 4.6,
Use and Maintenance of Field Log Books.
4.5.5 Peristaltic Pump
Gathering surface water samples with the assistance of a peristaltic pump is another
commonly used sampling technique. In this method the sample is drawn through
heavy-walled tubing and pumped directly into the sample container. This system
allows the operator to extend into the liquid body to sample from depth, or sweep the
width of narrow streams. Medical-grade silicon tubing is often used in the peristaltic
pump and the system is suitable for sampling almost any parameter, including most
organics (Exhibit 18-4, Peristaltic Pump).
Peristaltic pumps are available with a range of power sources. For field use the
battery operated units have proven most convenient and very reliable.
Perform the following procedures when sampling with a peristaltic pump:
Prepare the peristaltic pump in accordance with manufacturer's instructions.
When using a battery-operated pump, be sure battery is fully charged prior
to entering the field.
In most situations, it is necessary to change the Teflonฎ suction line and the
silicon pump tubing between sample locations to avoid cross-
contamination. This action requires maintaining a sufficiently large stock
of tubing material to avoid having to decontaminate the tubing in the field.
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Procedure No. 18
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Gently lower the pump intake tube to the desired sample depth. Avoid
unnecessary agitation (aeration) of the liquid to be sampled and bottom
sediments.
ฆ Prior to activating the pump, note in which direction the pump will be
rotating. (Most peristaltic pumps are capable of rotating in two directions.)
Accidental reverse rotation of the pump will cause aeration of the liquid to
be sampled.
Run the pump until no air bubbles are noted in the discharge.
Discharge water shall be released down stream from sampling area during
sampling event.
To prevent excess agitation and/or aeration of the sampler, fill the sample
containers by tilting the container and flow the sample water down the side
of sampling container.
Record applicable data in the field log book (i.e. color, turbidity, pH, degree
of turbulence, and weather conditions). Data may also be recorded on
Exhibit 18-6, Surface Water Sampling Data.
In most cases, no specific decontamination procedures are required due to
the use of disposable tubing. However, site-specific sample procedures
may require additional decontamination. Check with the Project Leader
prior to commencing field operations.
Mark sample location and approximate depth, if possible, and note location
on map and in field log book in accordance with CDPHE SOP 4.6, Use and
Maintenance of Field Log Books.
When medical grade silicon tubing is not available for analytical requirements, the
system can be altered as illustrated in Exhibit 18-5, Peristaltic Pump - Modified. In
this configuration, the sample volume accumulates in the vacuum flask and does not
enter the pump. This system will provide excellent sample integrity for most
analyses; however, the potential for losing volatile fractions to the reduced pressure
of the vacuum flask renders this method unacceptable for sampling of volatiles.
It may sometimes be necessary to sample large bodies of water where a near-surface
sample will not sufficiently characterize the body as a whole. In this instance, the
above-mentioned pump is appropriate. It is capable of lifting water from slightly
deeper than six meters. It should be noted that this lift ability decreases somewhat
with higher density fluids and with increased wear on the silicone pump tubing.
Similarly, increases in altitude will decrease the pump's ability to lift from depth.
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Procedure No. 18
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When sampling a liquid stream that exhibits a considerable flow rate, it may be
necessary to weight the bottom of the suction line.
4.5.6 Optional Sampling Methods
The above-mentioned methods of surface water sampling will be used most often on
CDPHE environmental projects; however, choice of sampling equipment depends on
site specific conditions. Additional types of samplers available are:
Kemmerer sampler;
Wheaton sampler;
Bacon Bomb sampler;
Open tube sampler;
D.O. Punker sampler; and
Bailer.
Prior to any field work, the Project Leader will review the available sampling
equipment and choose the sampler that will best suit the project requirements.
4.6 Sample Collection Records
All surface water samples gathered in the field will be labeled, shipped and documented in
accordance with the site-specific requirements set forth in the Project Plans and in the
following:
Samples will be transported in accordance with the procedures outlined in the
CDPHE SOP 4.3, Chain-of-Custody;
All samples will be labeled or identified in accordance with procedures outlined in
the CDPHE SOP 4.4, Sample Identification, Labeling, and Packaging;
Quality assurance and quality control procedures outlined in the site-specific Project
Plan;
The Surface Water Sampling Data form contained in Exhibit 18-6 must be filled out
for each surface water sample collected; and
Detailed Field Log Books documenting the sampling event must be kept. All field
notes will be in accordance with procedures outlined in the CDPHE SOP 4.6, Use and
Maintenance of Field Log Books.
4.7 Review
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The Project Leader and an approved designee shall check all Exhibits and field log books used
to record information during sampling for completeness and accuracy. Any discrepancies will
be noted and and the documents will be returned to the originator for correction.
The reviewer will acknowledge that these review comments have been incorporated by signing
and dating the "checked by" and "date" blanks on the Exhibits and at the applicable places in
the log books.
5.0 REFERENCES
CDPHE, 2000. "Standard Operating Procedure 3, Chain-of-Custody." Standard Operating Procedures.
CDPHE, 2000. "Standard Operating Procedure 4, Sample Identification, Labeling, and Packaging."
Standard Operating Procedures.
CDPHE, 2000. "Standard Operating Procedure 6, Use and Maintenance of Field Log Books." Standard
Operating Procedures.
CDPHE, 2000. "Standard Operating Procedure 11, Equipment Decontamination." Standard Operating
Procedures.
CDPHE, 2000. "Standard Operating Procedure 15, Flow Measurement." Standard Operating Procedures.
6.0 EXHIBITS
Exhibit 18-1 Weighted Bottle Sampler
Exhibit 18-2 Pond Sampler
Exhibit 18-3 Manual Hand Pump
Exhibit 18-4 Peristaltic Pump
Exhibit 18-5 Peristaltic Pump - Modified
Exhibit 18-6 Surface Water Sampling Data
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Colorado Department of Procedure No. 18
Public Health and Envrionment Revision No.: 0
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EXHIBIT 18-1
Weighted Bottle Sampler
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EXHIBIT 18-2
Pond Sampler
Bolt hole
Beaker, polypropylene,
250 ml (1 qt)
5
hz
7
Pole, telescoping, heavy duty
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Procedure No. 18
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EXHIBIT 18-3
Manual Hand Pump
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EXHIBIT 18-4
Peristaltic Pump
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EXHIBIT 18-5
Peristaltic Pump - Modified
Glass tubing
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EXHIBIT 18-6
Surface Water Sampling Data
CDPHE
Surface Water
Sampling Data
Project Number.
Project Name:
Page of
Sample No:_
Elevation:
Sampling Method:_
Weather:
Bar. Press.
Amb. Temp.
WATER SAMPLE DATA
Water Temp:
oC
Method of Measurement:
Specific Conductance:
Method of Measurement:
pH:
Method of Measurement:
Containers Used (VOA Vial, 1 liter jar etc...):
Physical Appearance:
Contamination Observed:
Remarks:
Recorded By:
Date:
Checked By:
Date:
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 19
Revision No.: 0
Date: 01/2000
Page 1 of 8
STANDARD OPERATING PROCEDURE - 19
SOIL GAS SAMPLING
1.0 PURPOSE
The purpose of this procedure is to describe the equipment and operations used for sampling surface and
shallow depth soil gas. This procedure outlines the methods for decontamination and soil gas sampling for
routine field operations on environmental projects. The purpose of this document is to present alternative
procedures that may be chosen on a case-by-case basis. Regardless of application, any soil gas sampling
program should include a review of the following items: sampling program development, sample
documentation techniques, analytical instrumentation, sample analysis, and final data interpretation. Site-
specific deviations from the methods presented herein must be approved by the CDPHE Project Leader
Quality Assurance Officer.
2.0 DEFINITIONS AND ABBREVIATIONS
2.1 Definitions
Soil: All unconsolidated materials above bedrock.
Surface Soils: Soils located zero to six inches below ground surface.
Shallow Soils: Soils located six inches to six feet below ground surface.
2.2 Abbreviations
EPA U.S. Environmental Protection Agency
FID Flame ionization detector
GC Gas Chromatography
GC/MS Gas Chromatography/Mass Spectrometry
PID Photo ionization detector
SOP Standard Operating Procedure
VOCs Volatile organic compounds
3.0 RESPONSIBILITIES
Sampling personnel are responsible for performing the applicable tasks and procedures outlined herein when
conducting work related to environmental projects.
The Project Leader or an approved designee is responsible for checking all work performance and verifying
that the work satisfies the applicable tasks required by this procedure. This will be accomplished by
reviewing all documents (Exhibits) and data produced during work performance.
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Procedure No. 19
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Date: 01/2000
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4.0 PROCEDURES
4.1 Introduction
The objective of surface and shallow depth soil gas sampling to assess potential contamination
problems arising from active transport of volatile organic compounds (VOCs) by groundwater or
localized vadose zone diffusion due to point sources, such as leaking underground storage tanks.
Soil gas surveys may be used to define:
Source location(s) by systematically sampling toward higher concentrations;
Plume boundaries, utilizing the more sensitive analytical procedures;
Relative concentration gradients through grid sampling; or
Simply defining the presence/absence of vadose zone contamination without rigorous
quantification.
Soil gas sampling is most often utilized as a screening technique to identify trends of contamination,
and is not to be used as a definitive quantitative procedure.
4.2 Sampling Equipment
Shallow soil sampling equipment includes:
Borehole equipment - slam bars, soil corers, Geoprobe, hollow stem augers;
Sampling pumps to evacuate chambers or pull gas sample;
Tedlarฎ bags or applicable sample storage media
Analytical equipment to read volatile organic vapors (photo ionization detector (PID), flame
ionization detector (FID), Syntex Gas Chromatography (GC), Gas Chromatography/Mass
Spectrometry (GC/MS)).
4.3 Decontamination
Before initial use, and after each subsequent use, all sampling equipment must be decontaminated
using procedures outlined inCDPHE Standard Operating Procedure (SOP) 4.11, Equipment
Decontamination.
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Procedure No. 19
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4.4 Sampling Location/Site Selection
Follow the sample design criteria outlined in the Sampling and Analysis Plan for each sampling
event. Relocate the sample sites as conditions dictate - such as natural or artificial obstructions at
the proposed sample location (e.g., boulders, asphalt, etc.). Document the actual sample locations,
photographically or on a sketched site map.
4.5 Sampling Approaches
It is important to select an appropriate sampling approach for accurate characterization of site
conditions. Each approach is defined below.
4.5.1 Borehole Method
Soil gas may be obtained directly from augured or driven holes. This technique requires
construction of a hole, and collection of gas into a container at the bottom of the hole, or
through a tube to a container at the top of the hole. Sample containers may be gas-tight
syringes, Tedlarฎ bags, glass sample bulbs or other gas-holding containers.
The fastest and cheapest borehole construction method should be attempted first (slam bar,
soil core, or Geoprobe). Specialized soil gas probe tips and shafts are available on the
Geoprobe for this technique (Exhibit 19-2, Probe Tip and Probe Shaft; and Exhibit 19-3,
Insertion and Extraction Tools). The use of a hollow stem auger can be more expensive, but
it can assist in volatilizing contaminants, and has shown a twofold increase in sensitivity
over static methods.
Samples may be collected from the bottom of an augured or driven hole by using a small,
gas-tight syringe with the cylinder and plunger attached to separate extension rods. An
alternative method is to lower a small diameter Teflonฎ tube, connected at the surface to a
sample container (e.g., gas-tight syringe or Tedlarฎ bag) and pump to the bottom of the
borehole. A sample can then be extracted using the sampling pump. Care should be taken
to maintain positive pressure in the sample container and to quickly seal the container to
avoid contact with the atmosphere. If hollow stem augers are used, the augers should be'
raised slightly from the bottom of the borehole to create a void space. The soil gas sample
should then be collected while the augers are in place in the borehole to minimize loss of
VOCs while extracting the augers.
The advantages of using the borehole method are that it provides inexpensive subsurface
sampling, uses minimum apparatus, and provides quick collection. The disadvantages are
that the technique is not controlled, it is not effective for surface soils, there may be potential
variability of results, and representativeness is difficult to achieve and impossible to
document.
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Standard Operating Procedures
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Procedure No. 19
Revision No.: 0
Date: 01/2000
Page 4 of 8
4.5.2 Soil Headspace
A viable alternative to collecting a gas sample is to collect a soil sample that contains
contaminants adsorbed onto soil particles, dissolved within soil water, and existing in
associated pore spaces. Physical soil properties may dictate this as the only practical
method.
Soil samples with low concentration VOCs should be collected so as to be as undisturbed
as possible and then sealed from atmospheric contact. Various tube-type samplers have been
employed, including split spoons and shelby tubes with inner sleeves. The sleeves are sealed
with caps and later placed directly into sample containers (2-4 oz septa jars, or 40 ml vials).
A gas-tight syringe is inserted into the septa liner and the headspace gas collected and
analyzed. A field laboratory equipped with the Syntex GC, Photovac GC, or the GC/MS can
read the VOC content in the headspace by heating and agitation (sonication) of the sample.
The advantages of this method include higher sensitivity, and samples are collected quickly.
The disadvantages are that soil type may prevent collection, and sample preparation may be
required.
For rapid field screening purposes the following procedure can be used. Soil samples can
be placed in glass containers, covered with aluminum foil, heated (preferably in a warm
water bath) and agitated. The aluminum foil can then be pierced with a PID or FID and a
VOC concentration determined.
4.6 General
All boreholes will be filled in with the material removed during sampling unless otherwise specified
in the project-specific Field Sampling Plan. Where a vegetative turf has been established, fill in and
replace the turf if practical in all holes or trenches when sampling is completed.
4.7 Review
The Project Leader or an approved designee shall check all Exhibits and field log books used to
record information during sampling for completeness and accuracy. Any discrepancies will be noted
and the documents will be returned to the originator for correction. The reviewer will acknowledge
that these review comments have been incorporated by signing and dating the "checked by" and
"date" blanks on the Exhibits and at the applicable places in the log book.
5.0 REFERENCES
CDPEE, 2000." Standard Operating Procedure 4.1, Use and Maintenance of Field Log Books." Technical
Standard Operating Procedures.
CDPHE, 1999. "Standard Operating Procedure 4.3, Chain of Custody." Standard Operating Procedures.
75.50906.00
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 19
Revision No.: 0
Date: 01/2000
Page 5 of 8
CDPHE, 2000. "Standard Operating Procedure 4.4, Sample Identification, Labeling, and Packaging."
Standard Operating Procedures.
CDPHE, 2000. "Standard Operating Procedure 4.5, Sample Location Documentation." Standard Operating
Procedures.
CDPHE, 2000. "Standard Operating Procedure 4.6, Use and Maintenance of Field Log Books." Standard
Operating Procedures.
6.0 EXHIBITS
Exhibit 19-1 Soil Sampling
Exhibit 19-2 Probe Tip and Probe Shaft
Exhibit 19-3 Insertion and Extraction Tools
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 19
Revision No.: 0
Date: 01/2000
Page 6 of 8
EXHIBIT 19-1
Soil Sampling
75.50906.00
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Standard Operating Procedures Procedure No. 19
Colorado Department of Revision No.: 0
Public Health and Environment Date: 01/2000
Page 7 of 8
EXHIBIT 19-2
Probe Tip and Probe Shaft
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Standard Operating Procedures
Colorado Department of Procedure No. 19
Public Health and Environment Revision No.: 0
Date: 01/2000
Page 8 of 8
EXHIBIT 19-3
Insertion and Extraction Tools
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Procedure No. 20
Revision No.: 0
Date: 01/2000
Page 1 of 18
STANDARD OPERATING PROCEDURE - 20
DRUM AND CONTAINER OPENING AND SAMPLING
Standard Operating Procedures
Colorado Department of
Public Health and Environment
1.0 PURPOSE
The purpose of this document is to provide recommended procedures for implementing safe and effective
opening and sampling of drums and containers less than 120 gallons. Container contents are sampled and
characterized for disposal, bulking, recycling, grouping, and classification purposes.
This procedure provides guidance for field operations associated with all types of drum and container opening
and sampling. Deviations from the methods presented herein must be approved by the Project Leader and
(CDPHE) Quality Assurance Officer.
2.0 DEFINITIONS AND ABBREVIATIONS
2.1 Definitions
Tanks: Any container with a capacity of 120 gallons or greater. Tanks can be aboveground, free
standing, below ground, or mobile. Tanks can be constructed of plastic, steel or concrete and can
include tank trucks, rail cars and even boats.
Drums: 55-gallon steel or plastic containers. Generally the top can be removed. Steel drums tend
to corrode with use and can sometimes rupture as a result of freezing. Plastic drums tend to be
corrosion resistant but are more susceptible to rupturing as a result of freezing. Drums can also be
smaller than 55-gallons. Overpacks are large drums that damaged/leaking drums are totally enclosed
in.
Containers: Any bottle, can, bag and the like with a capacity of 120 gallons or less.
Bung: The opening on the lid of a holding drum which is designed for liquids to enter and exit the *
drum.
Chime: The metal ring which is bolted tightly to the top of the drum, sealing the lid to the drum.
2.2 Abbreviations
CLP Contract Laboratory Program
COLIWASA Composite Liquid Waste Sampler
FID Flame ionization detector
IATA International Air Transport Association
ID Inside diameter
OSHA Occupational Safety and Health Administration
PID Photo ionization detector
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Procedure No. 20
Revision No.: 0
Date: 01/2000
Page 2 of 18
PPE
PPs
PVC
QA
QC
SCBA
SHSP
TSA
Personal Protective Equipment
Project Plans
Polyvinyl Chloride
Quality Assurance
Quality Control
Self-Contained Breathing Apparatus
Site Health and Safety Plan
Temporary Storage Area
3.0 RESPONSIBILITIES
Field personnel are responsible for performing the applicable tasks in accordance with this procedure when
performing work related to drum and container opening and sampling.
The Project Leader or an approved designee is responsible for checking all work performance and verifying
that the work satisfies the applicable tasks required by the procedure. This will be accomplished by
reviewing all documents (Exhibits) and reviewing procedures during work performance. All activities and
data collected shall be recorded in the field log book.
4.0 PROCEDURE
4.1 Drum Sampling
Prior to sampling, drums must be inventoried, staged, and opened. Inventory entails recording visual
qualities of each drum and any characteristics pertinent to the contents' classification. Staging
involves the organization, and sometimes consolidation of drums that have similar wastes or
characteristics. Opening of closed drums can be performed manually or remotely. Remote drum
opening is recommended for worker safety. The most widely used method of sampling a drum
involves the use of a glass thief. This method is quick, simple, relatively inexpensive, and requires
no decontamination.
4.1.1 Sample Preservation, Containers, Handling, and Storage
These guidelines must be followed when taking samples from a drum:
No preservatives shall be added to the sample;
Read International Air Transport Association (LATA) regulations for shipping your
particular sample and follow the specific requirements;
Place each sample container in two ziplock bags;
Place each bagged container in a one-gallon covered can containing absorbent
packing material. Place lid on can. (Drum samples are considered to be high
concentration.);
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Procedure No. 20
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Mark the sample identification number on the outside of the can;
Place the marked cans in a cooler and fill remaining space with absorbent packing
material;
Fill out a chain-of-custody record for each cooler, place in plastic, and affix to the
inside lid of the cooler;
Secure and custody seal the lid of the cooler; and
Arrange for the appropriate transportation mode consistent with the type of
hazardous waste involved.
4.2 Potential Problems
The practice of tapping drums to determine their contents is neither safe nor effective and should not
be used if the drums are visually overpressurized or if shock-sensitive materials are suspected.
Drums that have been overpressurized to the extent that the head is swollen above the level of the
chime should not be moved. A number of devices have been developed for venting critically swollen
drums. One method that has proven to be effective is a tube and spear device. A light aluminum tube
(three meters long) is positioned at the vapor space of the drum. A rigid, hooking device attached to
the tube goes over the chime and holds the tube securely in place. The spear is inserted into the tube
and positioned against the drum wall. A sharp blow on the end of the spear drives the sharpened tip
through the drum and the gas vents along the grooves. The venting should be done from behind a
wall or barricade. This device can be designed cheaply and easily and constructed where needed.
Once the pressure has been relieved, the bung can be removed and the drum sampled.
4.3 Equipment
The following are standard materials and equipment required for sampling:
Health and Safety Plan;
Personal Protective Equipment (PPE);
Wide-mouthed glass jars with Teflonฎ cap liner (approximately 500-ml volume);
Uniquely numbered sample identification labels with corresponding data sheets;
Chain-of-Custody sheets;
Decontamination plan and materials;
Glass thieving tubes or Composite Liquid Waste Sampler (COLIWASA); and
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Drum opening devices.
4.3.1 Bung Wrench
A common method for opening drums manually is using a universal bung wrench (Exhibit
20-1, Universal Bung Wrench). These wrenches have fittings made to remove nearly all
commonly encountered bungs. They are usually constructed of cast iron, brass, or a bronze-
beryllium nonsparking alloy formulated to reduce the likelihood of sparks. The use of a
nonsparking wrench does not completely eliminate the possibility of sparks being produced.
Manual drum opening with bung wrenches should not be performed unless the drums are
structurally sound (no evidence of bulging or deformation), and their contents are known.
If opening the drum with a bung wrench is deemed safe and cost-effective, then certain
procedures should be implemented to minimize the hazard:
Field personnel should be fully outfitted with protective gear;
Drums should be positioned upright with the bung up, or, for drums with bungs on
the side, laid on their sides with the bung plugs up;
The wrenching motion should be a slow, steady pull across the drum. If the length
of the bung wrench handle provides inadequate leverage for unscrewing the plug, a
"cheater bar" can be attached to the handle to improve leverage.
4.3.2 Drum Deheader
One means by which a drum can be opened manually when a bung is not removable with
a bung wrench is by using a drum deheader (Exhibit 20-2, Drum Deheader). This tool is
constructed of forged steel with an alloy steel blade and is designed to cut the lid of a drum
off or part-way off by means of a scissors-like cutting action. A limitation of this device is
that it can be attached only to closed-head drums. Drums with removable heads must be
opened by other means.
Drums are opened with a drum deheader by first positioning the cutting edge just inside the
top chime and then tightening the adjustment screw so that the deheader is held against the
side of the drum. Moving the handle of the deheader up and down while sliding the
deheader along the chime will enable the entire top to be rapidly cut off if so desired. If the
top chime of a drum has been damaged or badly dented it may not be possible to cut the
entire top off. Because there is always the possibility that a drum may be under pressure,
the initial cut should be made very slowly to allow for the gradual release of any built up
pressure. The safest technique would be to employ a remote method prior to using the
deheader.
Self-propelled drum openers which are either electrically or pneumatically driven are
available, and can be used for quicker and more efficient deheading.
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4.3.3 Hand Pick, Pickaxe, and Hand Spike
These tools are usually constructed of brass or a nonsparking alloy with a sharpened point
that can penetrate the drum lid or head when the tool is swung (Exhibit 20-3, Hand Pick,
Pickaxe, and Hand Spike). The hand picks or pickaxes that are most commonly used are
commercially available, whereas the spikes are generally uniquely fabricated four-foot-long
poles with a pointed end.
When a drum must be opened and neither a bung wrench nor a drum deheader is suitable,
then it can be opened for sampling by using a hand pick, pickaxe, or hand spike. Often the
drum lid or head must be hit with a great deal of force in order to penetrate it. Because of
this, the potential for splash or spraying is greater than with other opening methods;
therefore, this method of drum opening is not recommended, particularly when opening
drums containing liquids. Some spikes have been modified by the addition of a circular
splash plate near the penetrating end. This plate acts as a shield and reduces the amount of
splash in the direction of the person using the spike. Even with this shield, good splash gear
is essential.
Since drums, some of which may be under pressure, cannot be opened slowly with these
tools, spray from drums is common and appropriate safety measures must be taken. The
pick or spike should be decontaminated after each drum is opened to avoid cross-
contamination and adverse chemical reaction from incompatible materials.
4.3.4 Backhoe Spike
The most common means used to open drums remotely for sampling is the use of a metal
spike attached or welded to a backhoe bucket (Exhibit 20-4, Backhoe Spike). In addition
to being very efficient, this method can greatly reduce the likelihood of personnel exposure.
Drums should be "staged" or placed in rows with adequate aisle space to allow ease in
backhoe maneuvering. Once staged, the drums can be quickly opened by punching a hole
in the drum head or lid with a spike.
The spike should be decontaminated after each drum is opened to prevent cross-
contamination. Even though some splash or spray may occur when this method is used, the
operator of the backhoe can be protected by mounting a large shatter-resistant shield in front
of the operator's cage. This combined with the normal personal protection gear should be
sufficient to protect the operator. Additional respiratory protection can be afforded by
providing the operator with supplied air.
4.3.5 Hydraulic Drum Opener
Recently, hydraulic devices have been fabricated to open drums remotely (Exhibit 20-5,
Hydraulic Drum Opener). One such device uses hydraulic pressure to pierce through the
wall of a drum. The device consists of a manually operated pump which pressurizes oil
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through a length of hydraulic line. The pressurized oil advances a piercing device through
the drum to allow an access point for subsequent sampling.
4.3.6 Pneumatic Devices
A pneumatic bung remover consists of a compressed air supply that is controlled by a heavy-
duty, two-staged regulator (Exhibit 20-6, Pneumatic Bung Remover). A high-pressure air
line of desired length delivers compressed air to a pneumatic drill, which is adapted to turn
a bung fitting selected to fit the bung to be removed. An adjustable bracketing system has
been designed to position and align the pneumatic drill over the bung. This bracketing
system must be attached to the drum before the drill can be operated. Once the bung has
been loosened, the bracketing system must be removed before the drum can be sampled.
This remote bung opener does not permit the slow venting of the container, and therefore,
appropriate precautions must be taken. It also requires the container to be upright and
relatively level. Bungs that are rusted shut cannot be removed with this device.
4.4 Decontamination
All sampling equipment and the exterior of the sample jars will be decontaminated as described in
the following section.
These decontamination procedures will be used on all pieces of equipment to maintain sample
integrity and eliminate the cross-contamination of samples.
4.4.1 Decontamination of Sampling Equipment
All sampling equipment, jars, and containers will be decontaminated after each sample has
been obtained. The decontamination procedure will follow the procedures listed in the
Technical Standard Operating Procedure 4.11, Equipment Decontamination.
4.4.3 Decontamination of Field Personnel
All on-site personnel will wear personal protective equipment (PPE) as described in the Site
Health and Safety Plan (SHSP). Personnel decontamination procedures are also described
in the SHSP and will be implemented at each sampling location.
4.5 Methods
4.5.1 Drum Staging
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Prior to sampling, the drums should be staged to allow easy access. Ideally, the staging area
should be located just far enough from the drum opening area to prevent a chain reaction if
one drum should explode or catch fire when opened.
During staging, the drums should be physically separated (if potential contents are known
from drum type or existing labels) into the following categories: Those containing solids,
those containing liquid, and those which are empty. This is done because the strategy for
sampling and handling drums or containers in these categories will be different. Separation
may be achieved by:
Visual inspection of the drum and its labels, codes, etc. Solids and sludges are
typically disposed of in open-top drums. Closed-head drums with a bung opening
generally contain liquid; and
Visual inspection of the contents of the drum during sampling, followed by
restaging, if needed.
Once a drum has been staged and sampled, and any immediate hazard has been eliminated
by overpacking or transferring the drum's contents, the drum is affixed with a numbered tag
and/or transferred to a secondary staging area, if necessary. Color-coded tags, labels, or
bands should be used to mark similar waste types. Considering that such labels can be lost,
it may be appropriate to paint-number each container. A description of each drum, its
condition, any unusual markings, and the location where it was buried or stored are recorded
on a drum data sheet. This data sheet becomes the principal record-keeping tool for tracking
the drum on site.
Where there is good reason to suspect that drums containing radioactive, explosive, and
shock-sensitive materials are present, these materials should be staged in a separate, isolated
area. Placement of explosives and shock-sensitive materials in diked and fenced areas will
minimize the hazard and the adverse effects of any premature detonation of explosives.
Where space allows, the drum opening area should be physically separated from the drum
removal and drum staging operations. Drums are moved from the staging area to the drum
opening area one at a time using forklift trucks equipped with drum grapplers or barrel
grappler. In a large-scale drum handling operation, drums may be conveyed to the drum
opening area using a roller conveyor.
4.5.2 Drum Opening
There are three basic techniques available for opening drums at hazardous waste sites:
Manual opening with nonsparking bung wrenches;
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Drum deheading; and
Remote drum puncturing or bung removal.
The choice of drum opening techniques and accessories depends on the number of drums
to be opened, their waste contents, and physical condition. Remote drum opening equipment
should always be considered in order to protect worker safety. Under OSHA 1910.120,
manual drum opening with bung wrenches or deheaders may be performed ONLY when
drums are structurally sound, drum contents are known, and the contents are NOT shock
sensitive, reactive, explosive, or flammable in nature.
4.6 Drum Sampling
After the drum has been opened, preliminary monitoring of headspace gases should be performed
using an explosimeter and flame ionization detector (FID) or photo ionization detector (PID).
In most cases, it is impossible to observe the contents of sealed or partially sealed vessels. Since
some layering of stratification is likely in any solution left undisturbed over time, a sample must be
taken that represents the entire depth of the vessel.
When sampling a previously sealed vessel, check for the presence of bottom sludges. This is easily
accomplished by measuring the depth to the apparent bottom then comparing this value to the interior
depth.
4.6.1 Glass Thief Sampler
The most widely used implement for sampling a drum or similar vessel is a glass tube (glass
thief, 6- to 16-mm inside diameter (ID) x 48-inch length). This tool is simple, cost effective,
quick, and collects a sample without having to be decontaminated.
The standard operating procedure for using a drum thief is as follows:
Remove cover from sample container;
Insert glass tubing almost to the bottom of the drum or until a solid layer is
encountered. About one foot of tubing should extend above the drum;
Allow the waste in the drum to reach its natural level in the tube;
Cap the top of the sampling tube with a tapered stopper or gloved thumb, ensuring
liquid does not come into contact with the stopper;
Carefully remove the capped tube from the drum and insert the uncapped end of the
tube into the sample container;
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Release the stopper and allow the glass thief to drain completely into the sample
container. Fill the container to about 2/3 capacity;
Remove the tube from the sample container, break it into pieces and place the pieces
in the drum;
Cap the sample container tightly and place the prelabeled sample container into the
carrier;
Replace the bung or place plastic over the drum; and
Transport the sample to the decontamination area for preparation for transport to the
analytical laboratory.
In many instances, a drum containing waste material will have a sludge layer on the bottom.
Slow insertion of the sample tube down into this layer and then gradual withdrawal will
allow the sludge to act as a bottom plug to maintain the fluid in the tube. The plug can be
gently removed and placed into the sample container by using a stainless steel lab spoon.
It should be noted that in some instances, disposal of the tube by breaking it into the drum
may interfere with eventual plans for the removal of the contents. The use of this technique,
or other disposal techniques evaluated, should be cleared with the Project Leader for
compatibility with planned disposal techniques.
4.6.2 COLIWASA
Designs exist for equipment that will collect a sample from the full depth of a drum and
maintain it in the transfer tube until delivery to the sample bottle. These designs include
primarily the COLIWASA and modifications thereof. The COLIWASA is a much cited
sampler designed to permit representative sampling of multiphase wastes from drums and
other containerized wastes. One configuration consists of a 152 cm by 4 cm inside diameter
(ID) section of tubing with a neoprene stopper at one end attached by a rod running the
length of the tube to a locking mechanism at the other end. Manipulation of the locking'
mechanism opens and closes the sampler by raising and lowering the neoprene stopper.
Put the sampler in the open position by placing the stopper rod handle in the T-
position and pushing the rod down until the handle sits against the sampler's locking
block;
Slowly lower the sampler into the liquid waste;
When the sampler stopper hits the bottom of the waste container, push the sampler
tube downward against the stopper to close the sampler. Lock the sampler in the
closed position by turning the T-handle until it is upright and one end rests tightly on
the locking block.
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Carefully discharge the sample into a suitable sample container by slowly pulling the
lower end of the T-handle away from the locking block while the discharge end of
the sampler is positioned in a sample container.
Cap the sample container with a Teflonฎ-lined cap; attach label; seal; and record on
the sample data sheet; and
Unscrew the T-handle of the sampler and disengage the locking block. Clean the
sampler.
4.7 Health and Safety
The opening of closed containers is one of the most hazardous site activities. Maximum effort should
be made to ensure the safety of the sampling team. Please refer to Health and Safety Standard
Operating Procedure 3.9, Container Handling, for guidelines for safely working in and around drums.
Proper protective equipment and general awareness of the possible dangers will minimize the risk
inherent to sampling operations. Employing proper drum opening techniques and equipment will also
safeguard personnel. The use of remote sampling equipment whenever feasible is highly
recommended.
Most drum sampling activities are performed in level B PPE with additional splash protection,
including the following:
Protective coverall (saranex, Tyvek, polyvinyl chloride (PVC), acid suit, etc.);
Hard hat;
Self-Contained Breathing Apparatus (SCBA);
Steel toe, steel shank boot (or booties covering steel toe work boots);
Surgical gloves;
Solvent and acid resistant gloves;
Splash apron; and
Face splash shield.
.5.0 REFERENCES
National Institute for Occupational Safety and Health (NIOSH), U.S. Coast Guard, and U.S. Environmental
Protection Agency (EPA). 1985. Occupational Safety and Health Guidance Manual for Hazardous Waste
Site Activities. U.S. Government Printing Office, Washington, D.C.
U.S. Environmental Protection Agency (EPA). 1985. (OSWERDirective 9380.0-3.) "Guidance Document
for Cleanup of Surface Tank and Drum Sites." U.S. Environmental Protection Agency. Washington, DC.
U.S. Environmental Protection Agency (EPA). 1987. "A Compendium of Superfund Field Operations
Methods." EPA/540/P-87/001, U.S. Environmental Protection Agency. Washington, DC.
CDPHE. 2000. "Site Health and Safety Plan."
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CDPHE. 2000. "Standard Operating Procedure 4.11, Equipment Decontamination." Standard Operating
Procedures.
6.0 EXHIBITS
Exhibit 20-1 Universal Bung Wrench
Exhibit 20-2 Drum Deheader
Exhibit 20-3 Hand Pick, Pickaxe, and Hand Spike
Exhibit 20-4 Backhoe Spike
Exhibit 20-5 Hydraulic Drum Opener
Exhibit 20-6 Pneumatic Bung Remover
Exhibit 20-7 COLIWASA Sampler
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Exhibit 20-1
Universal Bung Wrench
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Exhibit 20-2
Drum Deheader
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Exhibit 20-3
Hand Pick, Pickaxe, and Hand Spike
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Exhibit 20-4
Backhoe Spike
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Exhibit 20-5
Hydraulic Drum Opener
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Exhibit 20-6
Pneumatic Bung Remover
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Exhibit 20-7
COLIWASA Sampler
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STANDARD OPERATING PROCEDURE - 21
TANK SAMPLING
1.0 PURPOSE
The purpose of this Procedure is to describe the equipment and methods used for tank sampling. This
procedure outlines the methods for equipment operation with a variety of tank sampling devices, techniques
for routine tank sampling at environmental sites and equipment decontamination procedures. Site-specific
deviations from the methods presented herein must be approved by the Project Leader and CDPHE Quality
Assurance Officer.
2.0 DEFINITIONS AND ABBREVIATIONS
2.1 Definitions
Tank: Any bulk container with a capacity of more than 120 gallons, such as railroad tank cars, large
above- and below-ground storage containers and tank trailers.
2.2 Abbreviations
COLIWASA Composite Liquid Waste Sampler
ID Inside diameter
3.0 RESPONSIBILITIES
Sampling personnel are responsible for performing the applicable tasks and procedures outlined herein when
conducting work related to environmental projects.
The Project Leader or an approved designee is responsible for checking all work performance and verifying
that the work satisfies the applicable tasks required by this procedure. This will be accomplished by-
reviewing all documents (Exhibits) and data produced.
4.0 PROCEDURES
4.1 Introduction
The objective of tank sampling is to ascertain the type, degree and amount of hazardous materials
contained in a tank and/or the extent of contamination of the tank. The data collected from tank
sampling is used to evaluate potential exposure pathways, to calculate environmental risks and to
provide data which serves as a basis for design and implementation of an efficient, cost-effective site
remediation system.
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4.2 Sampling Equipment
4.2.1 Introduction
Before sampling any tank or other large container, first try to determine as much as possible
about the contents. A measuring tape, an oil/water interface probe or dip sticks can be used
to answer questions such as:
What is the volume of the tank?
What is the volume of the material in the tank?
Does the tank contain both solid and liquid phases; and
Does the tank contain two or more separate liquid layers?
Once some basic physical properties of the tank contents have been determined, an
appropriate sampling method can be selected. Some basic methods and their best application
are:
Homogenous liquid: dip sampler, bailer, pump, spigot
Multi-layered liquids: weighted bottle, COLIWASA, Bacon Bomb
Solid and liquid: dip sampler, sediment sampler
4.2.2 Weighted Bottle Sampler
Collecting a representative liquid sample from a large tank or from a tank where the contents
have separated into layers is facilitated by the use of a weighted bottle sampler, which
enables samples to be collected from various depths. The weighted bottle sampler consists
of a glass or Teflonฎ bottle, a weighted sinker, a bottle stopper, and a wire or cord to raise,
lower, and open the sampler. This type of sampler can be fabricated or purchased dependant
upon time and expected usage demands. The following procedures will be followed when
sampling with a weighted bottle sampler.
Decontaminate all equipment in accordance with SOP 4.11, Equipment
Decontamination;
Assemble the weighted bottle sampler in accordance with the manufacturer's
instructions;
Gently lower the sampler to the desired depth so the stopper is not removed
prematurely (do not let the sampler disturb bottom sediments);
Pull the stopper out with a sharp jerk of the sampler line;
Allow the bottle to fill completely, as evidenced by the cessation of air bubbles in
the tank liquid;
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Raise the sampler, seal, decontaminate, label or identify, and prepare the bottle for
transport in accordance with project guidelines;
Record all pertinent information in the field log book and on appropriate field
Decontaminate equipment in accordance with SOP 4.11, Equipment
Decontamination.
4.2.3 Dip Sampler
A dip sampler consists of a container attached (by an adjustable clamp) to the end of a
telescoping pole. The pole is of a non-reactive material such as wood, plastic, or metal. The
sample is collected in ajar or beaker made of stainless steel, glass or Teflonฎ. Liquid waste
from the tank is "ladled" into the appropriate sample container. The following procedures
are performed while sampling with a dip sampler:
Decontaminate all sampling equipment in accordance with the procedures in SOP
4.11, Equipment Decontamination;
Assemble dip sampler in accordance with manufacturer's instructions;
Extend pole to a length which will allow safe access to tank contents;
Submerge the dip sampler to the desired sample depth slowly to minimize surface
disturbance;
Allow the sampler container to fill very slowly;
Retrieve the dip sampler with minimum disturbance of liquid surface;
Remove the cap from the sample bottle and slightly tilt the mouth of the bottle
below the sampler container edge;
Empty the dip sampler slowly, allowing the sample stream to flow gently down the
inside of the bottle with minimal entry turbulence;
Seal and label or identify the sample bottle; and
Decontaminate the equipment according to SOP 4.11, Equipment Decontamination.
4.2.4 COLIWASA
Designs exist for equipment that will collect a sample from the full depth of a drum or tank
and maintain it in the transfer tube until delivery to the sample bottle. These designs include
primarily the Composite Liquid Waste Sampler (Exhibit 21-1, COLIWASA Sampler) and
forms;
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modifications thereof. The COLIWASA is a much-cited sampler designed to permit
representative sampling of multiphase wastes from drums and other containerized wastes.
One configuration consists of a 152 cm by 4 cm inside diameter (ID) section of tubing with
a neoprene stopper at one end attached by a rod running the length of the tube to a locking
mechanism at the other end. Manipulation of the locking mechanism opens and closes the
sampler by raising and lowering the neoprene stopper. The major drawbacks associated with
using a COLIWASA concern decontamination and cost. The sampler is difficult if not
impossible to decontaminate in the field and it is a high cost method in relation to alternative
procedures (e.g., glass tubes). It still has applications, however, especially in instances
where a true representation of a multiphase waste is absolutely necessary. The following
procedures are performed while sampling with a COLIWASA.
Read the operation manual and familiarize yourself with equipment parts and
Put the sampler in the open position by placing the stopper rod handle in the T-
position and pushing the rod down until the handle sits against the sampler's locking
block.
Slowly lower the sampler into the liquid waste, (lower the sampler at a rate that
permits the levels of the liquid inside and outside the sampler tube to be about the
same height. If the level of the liquid in the sample tube is lower than that outside
the sampler, the sampling rate is too fast and will result in a nonrepresentative
sample.
When the sampler stopper hits the bottom of the waste container, push the sampler
tube downward against the stopper to close the sampler. Lock the sampler in the
closed position by turning the T-handle until it is upright and one end rests tightly
on the locking block.
Slowly withdraw the sample from the waste container with one hand while wiping
the sampler tube with a disposable cloth or rag with the other hand.
Carefully discharge the sample into a suitable sample container by slowly pulling
the lower end of the T-handle away from the locking block while the lower end of
the sampler is positioned in a sample container.
Cap the sample container with a Teflon-lined cap; attach label and seal; and record
on sample data sheet.
Unscrew the T-handle of the sampler and disengage the locking block. Clean the
sampler.
4.2.5 Bacon Bomb Sampler
function.
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The bacon bomb sampler (Exhibit 21-2), is designed to collect material from various levels
within a storage tank. It consists of a cylindrical body, usually made of chrome-plated brass
and bronze with an internal tapered plunger that acts as a valve to admit the sample. A line
is attached to the top of the plunger opens and closes the valve. A line is attached to the
removable top cover which has a locking mechanism to keep the plunger closed after
sampling. The following procedures are performed while sampling with a bacon bomb
sampler.
Attach the sample line and the plunger line to the sampler.
Measure and then mark the sampling line at the desired depth.
Gradually lower the bacon bomb sampler by the sample line until the desired level
is reached.
When the desired level is reached, pull up on the plunger line and allow the sampler
to fill before releasing the plunger line to seal off the sampler.
Retrieve the sampler by the sample line. Be careful not to pull up on the plunger
line and thereby prevent accidental opening of the bottom valve.
Rinse or wipe off the exterior of the sampler body.
Position the sampler over the sample container and release its contents by pulling
up on the plunger line.
Cap the sample container tightly and place the prelabeled sample container in a
carrier.
Replace the bung or place plastic over the tank.
Log all samples in the site log book and label all samples. Samples may also be
logged on field data sheets.
Package samples and complete necessary paperwork.
Transport sample to decontamination zone to prepare it for transport to the
analytical laboratory.
4.3 Decontamination
Before initial use, all sampling equipment that may contribute to cross-contamination must be
thoroughly decontaminated following the methods outlined in SOP 4.11, Equipment
Decontamination.
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Place all rinsate and unsampled material in 55-gallon drums and store temporarily on the site. Follow
all applicable state and federal transportation and disposal regulations. Document decontamination
operations in the field log book.
4.4 Sampling Documentation
Proper documentation of sampling procedures and sample control are accomplished by following
SOP 4.4, Sample Identification, SOP 4.3, Chain of Custody and Sample Tracking, and SOP 4.5,
Sample Location Documentation. Photographic documentation (SOP 4.5) of tank location, tank
condition and tank contents are particularly important in a tank sampling program. The
Aboveground Storage Tank Characterization and Sampling Form (Exhibit 21-3) should be completed
for each tank examined and sampled.
4.5 Sampling Methods
Containers will be opened according to the specifications presented in the Project Plans and Site
Health and Safety Plan. Open the tank cover or access port with non-sparking tools. Care should
be taken not to agitate and homogenize liquids and sludges or to unnecessarily mix stratified layers
of liquid in the tank.
Field personnel will monitor the surrounding air and the head space of the tank for fumes and vapors
according to the Site Health and Safety Plan. Sampling may proceed once the area has been
determined to be safe and/or the appropriate precautions have been taken.
Check for the presence of sludge in the tank by measuring the apparent depth and comparing this
number with the known tank depth. Bottom sludges can be sampled using a sediment sampling
device, such as those outlined in SOP 4.17, Sediment Sampling.
4.6 Review
The Project Leader or an approved designee shall check Exhibit 21-3, Aboveground Storage Tank
Characterization and Sampling Form, for completeness and accuracy. Any discrepancies in the data
will be noted and the form will be returned to the originator for correction. The reviewer will
acknowledge that review comments have been incorporated by signing and dating the "Checked By"
and "Date" blanks on Exhibit 21-3, Aboveground Storage Tank Characterization and Sampling
Form.
5.0 REFERENCES
U.S. Environmental Protection Agency (EPA). 1985. (OSWERDirective 9380.0-3.) "Guidance Document
for Cleanup of Surface Tank and Drum Sites." U.S. Environmental Protection Agency. Washington, DC.
U.S. Environmental Protection Agency (EPA). 1987. "A Compendium of Superfund Field Operations
Methods." EPA/540/P-87/001, U.S. Environmental Protection Agency. Washington, DC.
CDPHE, 2000. "Standard Operating Procedure 1, General Field Operation." Standard Operating Procedures.
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 21
Revision No.: 0
Date: 01/2000
Page 7 of 10
CDPHE, 2000. "Standard Operating Procedure 3, Chain of Custody." Standard Operating Procedures.
CDPHE, 2000. "Standard Operating Procedure 4, Sample Location Documentation." Standard Operating
Procedures.
CDPHE, 2000. "Standard Operating Procedure 5, Sample Location Decontamination." Standard Operating
Procedures.
CDPHE, 2000. "Standard Operating Procedure 6, Use and Maintenance of Field Log Books." Standard
Operating Procedures.
CDPHE, 2000. "Standard Operating Procedure 11, Equipment Decontamination." Standard Operating
Procedures.
CDPHE, 2000. "Standard Operating Procedure 17, Sediment Sampling." Standard Operating Procedures.
CDPHE, 2000. "Standard Operating Procedure 18, Surface Water Sampling." Standard Operating
Procedures.
6.0 EXHIBITS
Exhibit 21-1 COLIWASA Sampler
Exhibit 21-2 Bacon Bomb Sampler
Exhibit 21-3 Aboveground Storage Tank Characterization and Sampling Form
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Standard Operating Procedures Procedure No. 21
Colorado Department of Revision No.: 0
Public Health and Environment Date: 01/2000
Page 8 of 10
EXHIBIT 21-1
COLIWASA Sampler
T handle-
locking block-
Stopper"
6.35 cm (2.5*)
152 cm (60")
SAMPLING POSITION
2.8S cm (1.125")
17.8 cm (7*)
L
10.IS cm (4")
Pipe, PVC, translucent
4.13 cm (1.625") I.D..
4.26 cm (1.375") O.D".
Stopper'rod, PVC,
0.95 cm (.375") O.D.
A---
Stopper, neoprene, #9, tapered
0.95 cm (.375") PVC lock nut '
and washer
CLOSED POSITION
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Standard Operating Procedures
Colorado Department of Procedure No. 21
Public Health and Environment Revision No.: 0
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Page 9 of 10
EXHIBIT 21-2
Bacon Bomb Sampler
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Procedure No. 21
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EXHIBIT 21-3
Aboveground Storage Tank Characterization and Sampling Form
Standard Operating Procedures
Colorado Department of
Public Health and Environment
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
STANDARD OPERATING PROCEDURE - 22
AQUIFER SLUG TESTING
1.0 PURPOSE
The purpose of this procedure is to provide technical guidance and methods for performing slug tests on
piezometers and monitor wells. It outlines methods and provides for documentation of field data.
This procedure provides guidance for routine field operations on environmental projects. Site-specific
deviations from the methods presented herein must be approved by the CDPHE Project Leader and Quality
Assurance Officer.
2.0 DEFINITIONS AND ABBREVIATIONS
2.1 Definitions
Aquifer: A geologic formation capable of yielding significant quantities of water to wells.
Electronic Data Logger: An electronic instrument capable of recording electrical impulses and
converting them to data usable for scientific analysis. This instrument, when connected to a transducer
probe, can record rapid changes in water levels over short time intervals.
Hydraulic Conductivity: A measure of the ability of a porous medium to transmit fluids. It is
dependent on both the fluid and the medium. The hydraulic conductivity is generally defined as a rate
of flow through a unit cross-sectional area under a unit hydraulic gradient. English units for hydraulic
conductivity are commonly expressed either in gal/day/ft2 or ft/day. SI metric units are often
expressed in cm/s.
Hydraulic Gradient: It is defined for any fluid as dh/dl, which is the ratio of the change in total
hydraulic head (dh) per length (dl) of flow. It dimensionally has the units of (ft/ft).
Measuring Point: A survey mark on a well casing from which all measurements are taken.
Piezometer: A well designed for groundwater level measurements. Typically, a piezometer consists
of a small diameter pipe screened over the aquifer interval.
Slug: Sealed pipe or other object which is used to produce an instantaneous head change in a well by
displacement. The head change can be produced by either quickly lowering the slug into the water or,
after submerging the slug and allowing the water level to equilibrate, by quickly raising the slug above
water.
Procedure No. 22
Revision No.: 0
Date: 01/2000
Page 1 of 7
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Standard Operating Procedures
Colorado Department of
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Procedure No. 22
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Date: 01/2000
Page 2 of7
Transducer Probe: The pressure transducer responds to pressure changes caused by groundwater level
fluctuations. Pressure changes are converted to an electrical impulse and sent to an electronic data
logger.
2.2 Abbreviations
3.0 RESPONSIBILITIES
Field personnel are responsible for performing the applicable tasks in accordance with this procedure when
conducting work related to environmental projects.
The Project Leader or an approved designee is responsible for checking all work performance and verifying
that the work satisfies the applicable tasks required by this procedure. This is accomplished by reviewing
all documents (Exhibits) and data produced during work performance.
4.0 PROCEDURES
4.1 Introduction
A slug test is conducted by measuring water level responses over time to an "instantaneous"
withdrawal or addition of a "slug" of water. The addition of water is generally referred to as a falling
head slug test whereas the removal of water is commonly called a rising head slug test. The rising
head slug test is usually performed by lowering a solid slug below the water table and allowing the
water level to equilibrate to static conditions. The slug is quickly withdrawn from the well and the
subsequent rise in water levels is measured. The falling head slug test is performed by adding a slug -
and measuring the fall in water levels subsequent to the initial instantaneous rise.
Both types of tests can usually be performed at a monitoring well site. Although procedures described
below are for a rising head slug test they can be considered applicable to both types of tests.
Do not perform slug tests simultaneously in adjacent monitor wells (i.e., within 50 feet of each other
vertically or horizontally). Typically, use a 5- to 10-foot long slug of appropriate diameter to fit the
well casing to provide the "instantaneous" head change.
cm/s Centimeters per second
dh Total hydraulic head
dl Length of flow
ft/d Feet per day
gal/day/ft2 Gallons per day per square foot
SI International System of Units
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Standard Operating Procedures
Colorado Department of
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Procedure No. 22
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Date: 01/2000
Page 3 of 7
4.2 Decontamination
Prior to lowering the equipment into any well or boring, decontaminate each item using the procedure
outlined in TSOP 4.11, Equipment Decontamination.
4.3 Pre-Test Data Recording
Complete Exhibit 22-1, Slug-Test Data prior to conducting each slug test. Obtain the following
information from existing well logs prior to the slug test and record on Exhibit 22-1:
Casing diameter;
Borehole diameter;
Location of surveyed measuring point;
Total casing depth;
Static water level (prior to introducing slug);
Screen depth and interval;
Location of filter pack;
Lithology of screened interval; and
Volume of slug.
4.4 Field Methods
4.4.1 Setup
Measure the static water level from the surveyed location measuring point on the well
head with an electronic water level indicator. Record water levels to the nearest 0.01
foot. Determine the total monitor well depth with a weighted measuring tape from the
measuring point.
Measure water levels during the slug test with either an electronic data logger or an
electronic water level indicator. Refer to the equipment operations manual for any
instructions needed. Using the manufacturer's operations manual, select the appropriate
transducer probe for the monitor well to be tested.
Set the transducer probe in the monitor well at the appropriate depth as determined by
the sensitivity of the transducer, height of the water column in the well, and length of the
slug. Secure the probe cable so that it will not move during the test. If using an
electronic data logger follow the manufacturer's operating instructions to complete the
test setup and verify that the equipment is working correctly.
After completion of the initial test setup and pre-run check, lower the solid slug into the
monitor well so that the top of the slug is approximately two to three feet below the initial
static water level. If there is insufficient water in the monitor well to allow complete
submergence of the slug, immerse the slug as fully as possible without disturbing the
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Standard Operating Procedures
Colorado Department of
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Procedure No. 22
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Date: 01/2000
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transducer probe. Allow the water level in the monitor well to equilibrate to static water
level conditions.
Prior to slug removal, start the electronic data logger. Then quickly remove the slug from
the monitor well. The transducer probe must remain stationary during the entire test.
Continue the test until the water level returns to within 10 percent of the static water level
or until 24 hours have elapsed.
Set recording intervals on the data logger using either default time intervals or the
intervals presented below as appropriate for test conditions.
Elapsed Time Water Level Measurement Interval
(After removing slug)
Measure the water level in the monitor well periodically with the water level indicator to
verify that the data logger is functioning properly. Record the data on Exhibit 22-1, Slug
Test Data. The required test completion time will depend upon the hydraulic conductivity
of the surrounding formation. Slug tests may vary in duration from several minutes to
more than a day.
If available, print out all logger data in the field using a compatible printer. Otherwise,
periodically download data from the data logger onto the appropriate forms. Staple the
printout of the slug test data to the corresponding Exhibit 22-1, Slug Test Data.
Slug tests performed in monitor wells, that are anticipated to exhibit slow water level
response (as indicated by monitor well development records), may be measured with an
electronic water level indicator.
4.5 Analysis Methods
Analyze slug test data using an analytical method appropriate for the monitor well and local aquifer
conditions. Methods may include: Hvorslev (1951); Cooper and others, (1967); Cooper and Jacob
(1946); Bouwer and Rice (1976); and Bouwer (1989). Refer to the reference list in Section 5.0,
References, for actual analytical methods.
4.4.2 Testing
0-30 sec.
30-120 sec.
2-10 min.
10-100 min.
100-1,000 min
1.0 sec.
3.0 sec.
5.0 sec.
2 min.
10 min.
100 min.
1,000-10,000 min.
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Standard Operating Procedures
Colorado Department of
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Procedure No. 22
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In the field, an estimate of the hydraulic conductivity may be made by using Hvorslev's method
(1951), where the hydraulic conductivity K is estimated by the following equation:
r = radius of the well casing
L = length of the well screen
R = radius of the well screen
T0 = the time it takes for the water level to rise or fall to 37 percent of the
initial change
4.6 Review
Personnel performing slug tests will record the applicable field data in the field log book and on
Exhibit 22-1, Slug Test Data, as determined by the Project Leader. Staple electronic data logger
printouts to the appropriate Exhibit for each monitor well. The personnel performing slug tests must
sign and date Exhibit 22-1, Slug Test Data, in the "measured by" and "date" blanks. These personnel
must also sign and date electronic data logger printouts and all calculations prepared during slug test
analyses.
The Project Leader or designee will check the slug test data, electronic data logger printouts, and
calculations prepared during slug test analyses for completeness and accuracy. Any discrepancies
will be noted and the documents will be returned to the originator for correction. The reviewer will
acknowledge that these review comments have been incorporated by signing and dating Exhibit 22-1,
Slug Test Data, and the applicable reviewed documents.
5.0 REFERENCES
Bower, H. 1989. "The Bower and Rice Slug Test - An Update." Groundwater, 27: 3: 304-309.
Bower, H. and R. C. Rice. 1976. "A Slug Test for Determining Hydraulic Conductivity of Unconfined
Aquifers With Completely or Partially Penetrating Wells." Water Resources Research, 12: 423-428.
CDPHE, 2000. "Standard Operating Procedure 4.11, Equipment Decontamination." Standard Operating
Procedures.
Cooper, H. H., Jr., J. D. Bredehoeft, and I. S. Papadopulos. 1967. "Response of a Finite Diameter Well to
an Instantaneous Change of Water." Water Resources Research. 3:1: 263-269.
Cooper, H. H., Jr., and C. E. Jacob. 1946. "A Generalized Graphical Method for Evaluating Formation
Constants and Summarizing Well Field History." Transcripts of the American Geophysical Union. 27: 4.
r2 In (.L/R)
2LT
O
where: K
hydraulic permeability
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Standard Operating Procedures
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Procedure No. 22
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Hvorslev, M. J. 1951. "Time Log and Soil Permeability in Groundwater Observations." Bulletin 36.
Waterways Experiment Station. U.S. Army Corps of Engineers, Vicksburg, Miss.
6.0 EXHIBITS
Exhibit 22-1 Slug Test Data
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Standard Operating Procedures Procedure No. 22
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EXHIBIT 22-1
Slug Test Data
CDPHE
Colorado Departmer.f of Public Health and Environinenr
4j00 Cherry Creek Drive South
Denver, CO 80246
Slug Test Data
Records Management Data !
Project Number Project Name j Page 1
1 . of .
Location
Actual Time
Elapsed Time (min.)
Depth to Water from
Ton of Casing (ft)
H
Excess Head (ft)
H/Ho
Comments
Presented By
Date
Checked Bv
Date
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Standard Operating Procedures
Colorado Department of
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Procedure No. 23
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Date: 01/2000
Page 1 of 15
STANDARD OPERATING PROCEDURE - 23
AQUIFER PUMP TESTS
1.0 PURPOSE
The purpose of this procedure is to provide technical guidance for performing aquifer tests that utilize both
pumping and observation wells. This procedure outlines methods for conducting step-drawdown/recovery
and constant discharge/recovery tests and providing documentation of this data.
This procedure does not discuss analysis of the data collected during aquifer pumping tests. Numerous
analytical methods are available. Each method includes unique assumptions and limitations; hence, the
particular analytical method must be tailored to site-specific conditions under which the aquifer test was
conducted. Consult Section 5.0 of this procedure for specific sources on aquifer analysis.
This procedure provides guidance for routine field operations on environmental projects. Site-specific
deviations from the methods presented herein must be approved by the CDPHE Project Leader and Quality
Assurance Officer.
2.0 DEFINITIONS AND ABBREVIATIONS
2.1 Definitions
Aquifer: A geologic formation capable of yielding significant quantities of water to wells.
Electronic Data Logger: An electronic instrument capable of recording electrical impulses and
converting them into data usable for scientific analysis. This instrument, when connected to a
transducer probe, can record rapid changes in water levels over short time intervals.
Hydraulic Conductivity. A measure of the ability of a porous medium to transmit fluids. It is
dependent on both the fluid and the medium. The hydraulic conductivity is generally defined as a rate'
of flow through a unit cross-sectional area under a unit hydraulic gradient. English units for
hydraulic conductivity are commonly expressed either in gallons per day per square foot (gal/day/ft2)
or feet per day (ft/day). International System of Units (SI) metric units are often expressed in
centimeters per second (cm/s).
Hydraulic Gradient: It is defined as dh/dl, which is the ratio of the change in total hydraulic head
per length of flow. It dimensionally has the units of (ft/ft).
Piezometer: A well designed for groundwater level measurements. Typically, a piezometer consists
of a small diameter pipe screened over the aquifer interval.
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Standard Operating Procedures Procedure No. 23
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Slug: Sealed pipe or other object which is used to produce an instantaneous head change in a well.
The head change can be produced by either quickly lowering the slug into the water or, after
submerging the slug and allowing the water level to equilibrate, by quickly raising the slug above
water.
Specific Capacity. The discharge from a well expressed as a rate of yield per unit drawdown
(gpm/ft).
Storage Coefficient: The volume of water that an aquifer releases from storage per unit surface area
of aquifer per unit decline in the component of hydraulic head normal to that surface (dimensionless).
Transmissivity: It is expressed as Kb where K is the hydraulic conductivity and b is the saturated
thickness of the aquifer. The transmissivity is defined as a rate of flow through a unit width of aquifer
thickness b under a unit hydraulic gradient. English units for transmissivity are commonly expressed
either in gal/day/ft or ft2/day. SI metric units are often expressed in square meters per second (m2/s).
Transducer Probe: The pressure transducer responds to pressure changes caused by groundwater
level fluctuations. Pressure changes are converted to an electrical impulse and sent to an electronic
data logger.
2.2 Abbreviations
cm/s Centimeters per second
dh Total hydraulic head
dl Length of flow
ft/d Feet per day
ft2/d Feet squared per day
gal/day/ft Gallons per day per foot
gal/day/ft2 Gallons per day per square foot
gpm/ft Gallons per minute per foot of drawdown
m2/s Meters squared per second
SI International System of Units
SOP Standard Operating Procedures
3.0 RESPONSIBILITIES
Field personnel are responsible for performing the applicable tasks in accordance with this procedure when
conducting work related to environmental projects.
The Project Leader or an approved designee is responsible for checking all work performance and verifying
that the work satisfies the applicable tasks required by this procedure. This is accomplished by reviewing
all documents (Exhibits) and data produced during work performance. All activities and data collected shall
be recorded in the field log book.
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Standard Operating Procedures
Colorado Department of
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Procedure No. 23
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4.0 PROCEDURES
4.1 Introduction
The assessment of aquifer characteristics is vital to any investigation of groundwater contamination.
Pump tests are one of the primary methods to quantitatively estimate aquifer characteristics.
Depending upon the duration of the test, pump testing may also simulate actual pumping during
groundwater remediation and provide valuable information for future recovery systems.
Drawdown pump tests may be conducted to determine both the performance characteristics of a well
and the hydraulic parameters of an aquifer. In a well performance test, well yield and drawdown
are measured so that the specific capacity can be calculated. These data, taken under controlled
conditions, give a measure of the productive capacity of the completed well and also provide
information needed for the selection of pump equipment.
Aquifer pump tests also provide data from which the principal aquifer properties, transmissivity and
storage coefficient, can be calculated. These properties are essential in determining not only the
radius of influence for individual or multiple pumping wells but also are necessary in establishing
groundwater flow velocities.
An aquifer test consists of pumping a well at either constant or variable pumping rates and measuring
the drawdown in the pumping well and in any nearby observation wells. There are generally two
types of aquifer tests; one is a constant rate test and the other is a step-drawdown test. In a constant
rate test, pumping is sustained at a constant discharge rate for the duration of the test, whereas in a
step-drawdown test a constant discharge rate is maintained for relatively short periods of time, after
which time the rate is usually increased. Although data from both types of aquifer pumping tests can
be utilized for aquifer analyses, step-drawdown data tend to be more difficult to interpret. Step-
drawdown data from this type of test do not easily lend themselves to conventional analysis and
require a special analytical method. In addition, as pumping rates are increased, fluctuations in step-
drawdowns may occur as the well experiences the effects of well development concurrent with
pumping. If possible, a constant rate pump test should be conducted to determine aquifer properties.
Data requirements for aquifer tests include static water level measurements made prior to
commencement of the test, discharge rate(s) and time of change in discharge rates; drawdown
measurements made during preestablished time intervals, and the time pumping stopped. A recovery
test should also be conducted following a step-drawdown pump test to assure the precision and
validity of all resulting data. Recovery water levels should be measured at preset time intervals after
the pump is stopped.
For well performance tests, well yield and drawdown are measured usually near the end of the test.
Although aquifer testing is more involved than well testing, the following methods for determining
well yields and drawdowns are similar in both types of tests. These methods and procedures apply
primarily to constant discharge, step-drawdown aquifer and recovery tests.
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Standard Operating Procedures
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Procedure No. 23
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4.2 Decontamination
Prior to lowering the equipment into any well, decontaminate each item using the procedure outlined
in Standard Operating Procedure (SOP) 4.11, Equipment Decontamination.
4.3 Pre-Test Data Recording
Complete the applicable portions of Exhibit 23 -1, Aquifer Test Data, prior to conducting the aquifer
test. Use a separate Exhibit page for each well. Also, obtain the following information (from
existing logs) for each well to be used in the test prior to performing the test:
Casing diameter;
Borehole diameter;
Location of surveyed measuring point;
Total casing depth;
Static water level of each monitor well;
Screen depth and interval;
Filter pack depth and interval; and
Lithology of screened interval.
Assemble the equipment necessary to conduct the aquifer pumping test. A list of useful equipment
is presented in Exhibit 23-2, Aquifer Testing Equipment List.
4.4 Pumping Test Design
Aquifer testing and analysis methods are generally based upon the following assumptions:
The aquifer is homogenous and isotropic;
The aquifer is infinite in extent in the horizontal direction from the well and has a constant
thickness;
The well screen interval fully penetrates the aquifer;
Groundwater flow within the aquifer and pumped well is laminar; and
The initial static water level is horizontal.
Typically, these assumptions may be invalidated by the nature of the subsurface geologic conditions
and materials that comprise the aquifer. However, under many hydrogeologic conditions,
conventional pump test analyses are appropriate to use. (Under conditions where the above
assumptions may be invalidated, there is a variety of specific analytical techniques that can
accommodate them.) In these situations, it is recommended that these highly specific methods of
analyses be utilized.
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Standard Operating Procedures
Colorado Department of
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Procedure No. 23
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Prior to the start of the pump test, a pretest should be conducted to determine the general
characteristics and anticipated response of the aquifer. Data to be obtained from this test include the
following:
The maximum sustained discharge rate that will effectively stress the aquifer but will not
dewater the test well;
The maximum anticipated drawdown. For most pumping tests, a major portion of the
drawdown will occur in the first few hours of pumping; and
An estimate of the total volume of water to be produced from the pumping test. Appropriate
disposal methods must be considered before any pumping can occur.
The actual pump test should not be started until water levels in the aquifer have returned to (pre-test)
static levels.
The accuracy of drawdown data taken during a pumping test depends upon the following:
Maintaining a constant yield during the test (only for a constant rate test);
Measuring the drawdown carefully in the pumping well and observation wells;
Recording drawdown readings at appropriate time intervals;
Evaluating how changes in barometric pressures, stream levels, and tidal oscillations affect
drawdown data;
Comparing recovery data with drawdown data taken during the pumping portion of the test;
Ifpossible and conditions allow, continue the pumping test for at least 8 hours for a confined
aquifer and 24 hours for an unconfined aquifer during constant discharge. For step-
drawdown tests, 24 hours is usually sufficient for either type of aquifer.
The accuracy of data taken from a pumping well is usually less reliable than data obtained from an
observation well because of turbulence created by the pump. Therefore, if possible, drawdown
measurements should be obtained from several observation wells within the expected radius of
influence. Also select and monitor drawdown in an observation well that is located at a sufficient
distance to be unaffected by the pumping well. Data from this well may provide an important
understanding of the effects of not only evapotranspiration but other external stresses that may cause
groundwater levels to fluctuate.
Drawdown data from an observation well are necessary to calculate the storage coefficient
accurately, whereas transmissivity values may be calculated from either a pumping or an observation
and
well.
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Standard Operating Procedures
Colorado Department of
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Procedure No. 23
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Generally, in unconfined aquifers, observation wells should be less than 100 feet from the pumped
well. For thick, confined aquifers that are considerably stratified, observation wells should be within
300 to 700 feet from the pumped well.
If drawdown measurements are obtained with an electronic data logger, refer to SOP 4.22, Aquifer
Slug Testing, Section 4.4.1 for verification procedures prior to testing. Measurement intervals are
discussed in Section 4.4.2 of SOP 4.22, Aquifer Slug Testing.
4.5 Background Water Level Measurements
The objective of background measurements is to identify any naturally-occurring temporal and
diurnal changes to the groundwater system. When these observed fluctuations occur, drawdown data
should be adjusted to reflect background fluctuations. Perform the following steps during the pump
test to record background water levels:
Measure water levels in at least one well not expected to be influenced by the pumping well.
Continue monitoring for the duration of the test;
Use an electronic water level indicator to measure water levels in background wells; and
Measure all water levels to within 0.01 foot.
4.6 Drawdown/Recovery Test
Perform the following steps to conduct a drawdown test:
Measure static water levels in the pumping well and all selected monitor wells and
piezometers. Record all measurements in the field log book and on Exhibit 23-1, Aquifer
Test Data. Use a separate Exhibit page for each well;
Prior to installing the pump, measure the static water level in the pumping well. Depending
on site restraints, place the pump above the bottom of the well to avoid pumping fines that
have accumulated on the bottom of the well. This will prolong the operating life of the'
pump. Keep the pump intake at least two feet above the bottom of the well, if possible;
If measurements are to be obtained with an electric logger, install the transducer probe in the
well so that it will not move during the test; carefully secure the transducer cable to the top
of the well casing;
Program the data logger for logarithmic cycle measurements so that water-level
measurements are recorded at the times shown in Exhibit 23-3, Time Intervals for
Drawdown Measurements in a Pumped Well;
Measure and record water levels in all wells with an electronic water level indicator;
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Standard Operating Procedures Procedure No. 23
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Start the electronic data logger;
Start the pump at the discharge rate determined in the pretest;
Measure water levels in all wells after pumping starts. Record times in the field log book
and on Exhibit 23-1, Aquifer Test Data. Exhibit 23-3, Time Intervals for Drawdown
Measurements in a Pumped Well, and Exhibit 23-4, Time Intervals for Drawdown
Measurements in Observation Wells, provide suggested time measurement intervals.
Always record these measurements in a log book or on appropriate field forms in case the
electronic data logger fails;
Calculate drawdown during the test;
Do not change water level measurement devices during a test; and
Plot all data on semilog graph paper in the field, where the X-axis is time (minutes) since
pumping began on ths log scale and the Y-axis is drawdown (feet) m the arithmetic scale.
4.7 Step-Drawdown/Recovery Test
Follow steps described in Section 4.5 on drawdown test procedures. Incorporate the following
changes to the above procedures:
Maintain constant discharge rates for each step. Discharge measurements can be made with
a totalizing flow meter or by timing flow into a five-gallon bucket. These measurements
should be performed at regular intervals of approximately 15 minutes.
On Exhibit 23-1, Aquifer Test Data and in the field log book, note the actual time that the
discharge rate in the pumped well is increased and note the time the pump is shut off. Also
note any other unusual and routine occurrences.
Ideally, the step-drawdown test will employ several different discharge rates with each
subsequent flow rate greater than the previous flow rate.
Consider the water level in the pumping well when selecting the next pumping step. In low
permeability sediments, it is recommended that the flow rate be increased by approximately
1.5 times. This conservative approach tends to preclude dewatering the well. Refer to
Exhibit 23-5, Pumping Test Discharge Rate Criteria, for optimum pumping rates during the
step-drawdown test.
Maintain the current flow rate if no increase in the flow rate can be sustained by the well
beyond the first step. Continue the test as a constant rate test and analyze the data
accordingly. Prior to dewatering, shut off the pump and perform a recovery test.
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Standard Operating Procedures
Colorado Department of
Public health and Environment
Procedure No. 23
Revision No.: 0
Date: 01/2000
Page 8 of 15
The duration of a step depends on the observed water level in the pumping well. The target
duration of each step is at least 60 minutes. If the water level in the test does not change by
more than 0.1 foot after 10 minutes of pumping for a particular step, increase the discharge
to the next step. If the water level in the test well comes within a foot of the top of the pump,
then pumping should be eased to prevent dewatering and possible pump damage. If within
a step, the pumping level reaches equilibrium (maintains a steady level), maintain the flow
rate for at least 30 minutes. Usually such cases indicate a large transmissivity or recharge.
4.7.1 Well Recovery Test
The recovery portion of the drawdown pumping test is the same as it is for a step-drawdown
test. It begins immediately after pumping ceases. Perform the following steps for recovery
testing:
Measure water levels in all wells;
Before the pump is shut off, prepare the electronic data logger for restart of the
logarithmic cycle;
When the pump is shut off, immediately re-start the electronic data logger and begin
water level measurements per the intervals outlined in Exhibit 23-3, Time Intervals
for Drawdown Measurements in a Pumped Well, and Exhibit 23-4, Time Intervals
for Drawdown Measurements in Observation Wells;
Continue monitoring water level recovery until water levels in all wells return to
their static level (within 0.1 foot); and
Terminate recovery measurements if the water level returns to the static level. (Do
not remove the pump from the well until the recovery test is complete).
4.8 Review
Personnel performing aquifer pumping tests will record the applicable field data in the field log book'
and on Exhibit 23 -1, Aquifer Test Data, and will sign and date the "measured by" and "date" blanks.
Electronic data logger printouts will be stapled to the appropriate Exhibit for each monitor well.
These personnel will also sign and date electronic data logger printouts and all calculations prepared
during aquifer pumping test analyses.
The Project Leader or designee will check Exhibit 23-1, Aquifer Test Data, electronic data logger
printouts and calculations prepared during aquifer test analyses for completeness and accuracy. Any
discrepancies will be noted and the documents will be returned to the originator for correction. The
reviewer will acknowledge that these review comments have been incorporated by signing and dating
the applicable reviewed documents.
5.0 REFERENCES
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Standard Operating Procedures
Colorado Department of
Public health and Environment
Procedure No. 23
Revision No.: 0
Date: 01/2000
Page 9 of 15
CDPHE, 2000. Standard Operating Procedure 4.11, Equipment Decontamination. Standard Operating
Procedures
CDPHE, 2000. Standard Operating Procedure 4.22, Aquifer Slug Testing. Standard Operating Procedures
Driscoll, F. G. 1986. "Groundwater and Wells." Johnson Division. St. Paul, Minnesota.
Fetter, C. W. 1988. "Applied Hydrogeology." Merrill Publishing Company. Columbus, Ohio. 592p.
Freeze, R. A. and Cherry, J. A. 1979. "Groundwater." Prentice-Hall, Inc. 604p.
Headquarters, Dept. of Army, Air Force and Navy. 1983. "Dewatering and Groundwater Control." Army
TM 5-818-5/AFM 88-5, Chapter 6/NAVFACP-418. U.S. Government Printing Office. Washington, DC.
Heath, R. C. 1984. "Basic Groundwater Hydrology." U.S. Geological Survey Water Supply Paper 2220.
U.S. Government Printing Office. Washington, DC. 84p.
Todd, D. K. 1980. "Groundwater Hydrology." John Wiley & Sons. 535p.
6.0 EXHIBITS
Exhibit 23-1 Aquifer Test Data
Exhibit 23-2 Aquifer Testing Equipment List
Exhibit 23-3 Time Intervals for Drawdown Measurements in a Pumped Well
Exhibit 23-4 Time Intervals for Drawdown Measurements in Observation Wells
Exhibit 23-5 Pumping Test Discharge Rate Criteria
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Standard Operating Procedures Procedure No. 23
Colorado Department of Revision No.: 0
Public health and Environment Date: 01/2000
Page 10 of 15
EXHIBIT 23-1
Aquifer Test Data
CDPHE
Colorado Dept. of Public Health and Environment
AQUIFER TEST DATA
PROJECT NUMBER:
PROJECT NAME:
PAGE of
Well Number:
Well Location:
Static Water Level: ft.
Time
Total
Elapsed
Time
t (min)
Time Since
Pumping
Stopped
t' (min)
Water
Level
(ft)
Drawdown
S
(ft)
Corrected
Drawdown
SC'(R)
(ft)
Recovery
S'
(ft)
Corrected
Recovery
s*.
(ft)
Discharge
Q
gpm
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Standard Operating Procedures
Colorado Department of
Public health and Environment
Procedure No. 23
Revision No.: 0
Date: 01/2000
Page 11 of 15
EXHIBIT 23-2
Aquifer Testing Equipment List
The following list represents field equipment necessary to successfully conduct a proper pump test:
Field Log Book
Pickup truck with hitch and trailer
Submersible pump and control box
Pump discharge pipe or hose (with quick connect fittings)
Manifold system with flowmeters (with quick connect fittings)
Discharge hose (with quick connect fittings)
5 KW or 10 KW generator with compatible AC plug system
Support boom with swing arm (to support pump in extraction well)
Five-gallon fuel cans and funnel
Electric sounders (plus extra batteries)
Duct tape
Teflonฎ tape
Work gloves
Tools (especially pipe wrenches)
Tape measures (with increments in 0.01 ft)
Rinse bottle and extra deionized water (prevents cross-contaminating wells)
Mirror
Flashlight
Stopwatch
Five-gallon bucket
Rubber gloves
Aquifer test data (Exhibit 23-1)
Four-cycle semilog graph paper
Clipboard
Project site map, well logs, well detail sheets
Checklist
Keys to well locking devices
Pencils, rulers, calculator
Buckets with extra fittings, etc. (spare parts)
Appropriate safety equipment
Technical Standard Operating Procedure 4.23, Aquifer Pump Tests
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Standard Operating Procedures
Colorado Department of
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Procedure No. 23
Revision No.: 0
Date: 01/2000
Page 12 of 15
EXHIBIT 23-2 (continued)
Optional equipment may be required for the following reasons: (1) a long-duration test is required (24 hours
or longer), (2) groundwater sampling is required, or (3) climatic conditions.
Lantern with extra fuel
Foul weather gear
Sampling equipment
Folding chair
Hat
Sunscreen
Drinking water (many sites do not have this available)
One-inch PYC discharge line (as needed)
Toilet facilities
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Optional Equipment
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Standard Operating Procedures Procedure No. 23
Colorado Department of Revision No.: 0
Public health and Environment Date: 01/2000
Page 13 of IS
EXHIBIT 23-3
Time Intervals for Drawdown Measurements in a Pumped Well
Time Since Pumping Started (or Stopped)
Time Intervals Between Measurement
(in minutes) (in minutes)
0-10 0.5-1
10-15 1
15-60 5
60-300 30
300 - 1440 60
1440 - termination of test 480 (8 hr)
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Procedure No. 23
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EXHIBIT 23-4
Time Intervals for Drawdown Measurements in Observation Wells
Standard Operating Procedures
Colorado Department of
Public health and Environment
Time Since Pumping Started (or Stopped)
(in minutes)
0-60
60 -120
120-240
240 - 360
360 - 1,440
1,440 - termination of test
Time Intervals Between Measurements
(in minutes)
2
5
10
30
60
480 (8 hours)
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Standard Operating Procedures Procedure No 23
Colorado Department of Revision No.: 0
Public health and Environment Date: 01/2000
Page 15 of 15
EXHIBIT 23-5
Pumping Test Discharge Rate Criteria
. ,ฆ. .. .ฆ . . *.
^Sand'-.v.
.*ซ.* : ป .*
v.;
ฆ .* ฆ I* . ซ
v
f
0% V Static Laval
25%
50%
75%
100% L. Top of Pump
V
Static Laval
- 10%
c ~
- 20%
c
~
- 30%
o
O _
V.
- 40%
ฉ
15
- 50%
5
o
- 60%
XI
.2
- 70%
75
< "
- 80%
90% -o-Shut pump off
100% (Top of Pump)
Conduct step-test accordingly through 75% of the available water column.
Beyond 75%, monitor drawdown very carefully. Shut pump off atฃ 90% of
water column.
G.S. = Ground surface
Q = Discharge rate '
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Standard Operating Procedures Procedure No. 24
Colorado Department of Revision No.: 0
Public Health and Environment Date: 01/2000
Page 1 of 13
- STANDARD OPERATING PROCEDURE - 24
GEOLOGIC BOREHOLE LOGGING
1.0 PURPOSE
The purpose of this procedure is to describe the methods for geological borehole logging of soil and data
collection.
This procedure provides guidance for routine field operations on environmental projects. Site-specific
deviations from the methods presented herein must be approved by the CDPHE Project Leader and Quality
Assurance Officer.
2.0 DEFINITIONS AND ABBREVIATIONS
2.1 Definitions
Plasticity: The property of permanently changing shape without movement on any visible fractures
2.2 Abbreviations
AGI American Geologic Institute
PID/OVA Photo Ionization Detector/Organic Vapor Analyzer
SPT Standard Penetration Test
USCS Unified Soil Classification System
3.0 RESPONSIBILITIES
Personnel conducting exploratory soil boring and monitoring well borehole logging are responsible for
performing the applicable tasks outlined in this procedure when conducting work related to environmental
projects.
The Project Leader or an approved designee is responsible for checking all work performance and verifying
that the work satisfies the applicable tasks required by this procedure. This will be accomplished by
reviewing all documents (Exhibits) and data produced during work performance.
4.0 PROCEDURE
4.1 Introduction
A major portion of the work produced at an environmental site is geologic in nature and is concerned with
characterizing the physical subsurface and the geologic and hydrologic processes operating at the site. A
properly prepared borehole log serves as an essential tool in making environmental assessments. This
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Standard Operating Procedures
Colorado Department of
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Procedure No. 24
Revision No.: 0
Date: 01/2000
Page 2 of 13
Technical Standard Operating Procedure (TSOP) defines the methodology of collecting pertinent data so that
all borehole logs made at a site can create a consistent, uniform database from which interpretations can be
made. Inferences such as vertical and horizontal extent of strata, facies changes, attitude of bedding or
layering, structural features (faults, folds, fractures, dikes, etc.), location of the water table, lithologic
characterizations, and the extent of subsurface contamination are made from observations recorded on the
borehole log. These observations include bedding, grain size, degree of sorting, shape of grains, color,
hardness, organic vapor levels, and other observable physical characteristics including visible evidence of
contamination.
Logging should document both general and specific lithologic information about the borehole. In
all cases, the lithologic log should be identified by the specific site number; well/boring number;
drilling method; location; date of drilling; individual logger (geologist); drilling contractor;
significant organic vapor reading; visible evidence of contamination; depth to water first
encountered; final depth of water level; well/boring elevation (if data is available); total depth in feet;
graphic log; and lithologic description.
Lithologic descriptions for unconsolidated materials often use the Unified Soil Classification System
(USCS) or standard geologic field description methods, Compton 1962. Descriptions of bedrock
should follow applicable U.S. Geologic Survey standards.
Lithologic descriptions of unconsolidated material should contain the following characteristics when
possible:
Soil or formation name;
Gradation degree of sorting;
Principal constituent;
Specific descriptors for principal constituents (e.g., plasticity, grain size, and shape);
Firmness/hardness;
Minor constituents;
Moisture content;
Color;
Particle morphology; and
Other descriptors (i.e., visual evidence of contamination, specific monitoring equipment
readings including PID/OVA readings).
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Standard Operating Procedures
Colorado Department of
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Procedure No. 24
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Page 3 of 13
4.2 Classification System
Sections 4.24-1 through 4.24-2 will describe in detail the parameters and descriptive terminology
used to classify each sample for the bore log.
4.2.1 Soil or Formation Name
The soil or formation name will include the major constituent(s) and may be preceded by i
single-word modifier indicatingthe subordinate constituent. Percentages of each constituent
will be used to classify the material without actually recording constituent percentage. The
textural terms used to classify a soil are shown in Exhibit 24-1, Triangular Diagram
Showing Percentage of Sand, Silt, and Clay in Each Textural Class.
4.2.2 Gradation (Degree of Sorting)
Size sorting describes the extent to which grain size is uniform. The comparison chart listed
in Exhibit 24-2, "Comparison Chart for Estimating Degree of Sorting," will be used to
describe soils being logged from a borehole.
4.2.3 Principal Constituent
Principal constituents recorded during borehole logging include an identification of the
following unconsolidated material types:
If known, an identification of the potential source of the material should be made (i.e.,
alluvium, colluvium, artificial fill, or residual material).
4.2.4 Principal Constituent Descriptors
Additional descriptors for the principal material constituents may be added to the log in
order to farther delineate or accurately record subtle changes in the lithologic structure.
Modifiers such as grain size, shape, and plasticity of materials (i.e., high, medium, and low
plasticity).
4.2.5 Consistency/Density/Rock Hardness
The characteristics of unconsolidated material are often determined by the Standard
Penetration Test (SPT). The SPT involves driving a split spoon sampler into the material
Clay;
Silt;
Sand;
Cobbles;
Gravel; and
Boulders.
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Standard Operating Procedures Procedure No. 24
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Page 4 of 13
by dropping a 140 pound weight from a height of 30 inches. The resistance of the material
is reported in the number of blows of the weight required to drive the spoon one foot and
translates into the following descriptors:
# of Blows/Foot Cohesive Consistency fClaV)
0-2 Very soft
2-4 Soft
4-8 Medium
8-15 Stiff
15-30 Very stiff
30+ Hard
# of Blows/Foot
Cohesive Consistency (Gravel')
f 0-4
= '" 4-10
10-30
30-50
50+
# of Blows/Foot
Very loose
Loose
Medium dense
Dense
Very Dense
Rock Hardness
<20
20-30
30-50
50-80
80+
4.2.6 Minor Constituents
Weathered
Firm
Medium Hard
Hard
Very Hard
Constituents not previously described in the principal constituent description may be
described as a percentage or by weight. Typically, modifiers for minor constituents conform
to the following standards:
No modifier <5%
Slightly 5-12%
Moderately (i.e. add (y) or (ey) such as silty clay) 12-40% .
Very 40-50%
4.2.7 Moisture Content
Terms ranging from dry to saturated, are used to describe the relative moisture content of
a field soil sample. These terms are described as follows:
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Standard Operating Procedures
Colorado Department of
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Procedure No. 24
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Date: 01/2000
Page 5 ofl3
Dry - The sample is completely without moisture. Dry, silty sands, for example,
will produce suspended particles when dropped by hand.
Damp - Samples containing a very slight amount of water.
Moist - Soils in this range are near the maximum water content for their maximum
compactibility or density. Moist soils will form a ball when compressed in the hand.
Wet - The soil samples are wet enough to produce free water upon shaking but still
contain unoccupied air voids. Fine-grained soils close to the liquid limit would be
termed wet.
Saturated - Soils with zero air voids. Samples placed in sample jars or bags
will probably have standing water after a short period of time.
4.2.8 Cofor
The color of soil and associated materials will be recorded on the borehole log. Color
descriptors should include but are not limited to the following descriptors: black, grey-
black, brown, olive, mottled, streaked, etc. Color charts should be used to provide general
logging guidance but specific use is not necessary for adequately describing lithology.
4.2.9 Particle Morphology
The key elements of particle morphology are roundness and sphericity. Roundness is a
measure of the curvature of grain corners. Sphericity is a measure of how equal the three
axial lengths (x, y, z) of an object are. Determination of both properties is facilitated by the
use of a hand lens. Estimate grain roundness and sphericity by using the American Geologic
Institute (AGI) Data Sheet (Exhibit 24-4).
4.2.10 Other Descriptors
Field screening data collected during the drilling process may help further characterize site
conditions during subsurface investigations. Readings from on-site monitoring equipment
such as PIDs, OVAs and Oxygen/Explosimeters should be recorded at each sample interval.
Other useful information includes the organic content and the presence or absence of waste
material in samples.
4.2.11 Particle Size Distribution
An estimate of particle sorting by grain size is often useful for borehole logging purposes.
Precise estimates of percent composition of the sample is not necessary.
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Procedure No. 24
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USCS Grain Size Categories
Standard Operating Procedures
Colorado Department of
Public Health and Environment
F,\act Size Limits
Approximate Inch Equivalents
Name of Loose Aggregate
>256 mm
>10 in.
Boulder gravel
64-256 mm
2.5-10 in.
Cobble gravel
32 - 64 mm
1.2-2.5 in.
Very coarse pebble gravel
16 - 32 mm
0.6-1.2 in.
Coarse pebble gravel
8-16 mm
0.3 - 0.6 in.
Medium pebble gravel
4-8 mm
0.15-0.3 in.
Fine pebble gravel
2-4 mm
0.08-0.15 in.
Granule (or very fine pebble) gravel
1-2 mm
0.04-0.08 in.
Very coarse sand
1/2 -1 mm
0.02 - 0.04 in.
Coarse sand
1/4-1/2 mm
0.01-0.02 in.
Medium sand
1/8 -1/4 mm
0.005-0.01 in.
Fine sand
1/16 -1/8 mm
0.002-0.005 in.
Very fine sand
1/256 -1/16 mm
0.00015-0.002 in.
Silt
<1/256 mm
<0.00015 in.
Clay (clay-size materials)
From Wentworth Scale, Compton 1962.
The Comparison Chart for Estimating Percentage Composition (Exhibit 24-3) can be used
to estimate the percentage of various grain sizes present in a sample. However, visual
estimates usually provide sufficient information for characterizing site lithology.
4.3 Borehole Logs
Record data collected during exploratory boring soil logging in the field log book and on Exhibit 24-
5, Borehole Log. Use this Exhibit on all applicable field drilling and subsurface sampling operations.
Geologic correlation and aquifer properties prediction are dependent on good exploratory boring
sample descriptions. Rotary drilling with fluids is generally unacceptable since the drilling fluids
may potentially contaminate the aquifer under investigation. High quality borehole data are
generally acquired with a split-spoon or pitcher core barrel. This method of sampling provides
detailed logging. The lithofacies interpreted from cuttings logs may lack the accuracy necessary for
detailed correlation. Where possible, techniques such as geophysical borehole logging will be used
to supplement cuttings descriptions. Note on the log any geologic description determined from
borehole cuttings. The cuttings are often mixed over the entire length of the boring.
In bedrock formations, cuttings may be acquired from a reverse circulation, air rotary or from a dual
wall rotary boring. These cuttings do not provide information on the in situ properties of the
materials, but do provide adequate sample description information.
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Standard Operating Procedures Procedure No. 24
Colorado Department of Revision No.: 0
Public Health and Environment Date: 01/2000
Page 7 of 13
In summary, close sample spacing or continuous sampling in a boring provide the best material for
descriptive geology. Use traditional geologic terminology and supplement with the USCS
descriptive system when appropriate. Provide sufficient data on layering and other sedimentary
structures and undisturbed textures. Sample numbers, depths, and analytes should be included in
each description. The applicable field methods described by Compton (1962) and AGI (1982) are
recommended. These methods are fully referenced in Section 5.0.
4.4 Review
Personnel conducting borehole logging of soil will record field data on Exhibit 24-5, Borehole Log,
and will record a chronological summary in the project log book. The applicable methods outlined
in this procedure shall be used to record the data on this Exhibit. The personnel conducting these
operations will sign and date the "logged by" and "date" blanks on Exhibit 24-5, Borehole Log.
The Project Leader or designee shall check all field generated data and Exhibit 24-5, Borehole Log,
for completeness and accuracy. Any discrepancies will be noted and the Exhibits will be returned
to the originator for correction. The reviewer will acknowledge that corrections have been
incorporated by signing and dating the "reviewed by" and "date" blanks on Exhibit 24-5, Borehole
Log.
5.0 REFERENCES
American Geological Institute. 1982. "AGI Data Sheets." Falls Church, Virginia.
ASTM1984. "ASTM D1586, Description and Identification of Soils, Visual-Manual Procedure" in "Annual
Book of ASTM Standards." V.04.08
Compton,R.R. 1962. "Manual of Field Geology." John Wiley and Sons, Inc., New York, New York, 378p.
Munsell. 1988. "Munsell Soil Color Charts." Macbeth Division, Kollmorgen Instruments Corporation,
Baltimore, Maryland, 1988 edition.
U.S. Environmental Protection Agency (EPA). 1987. "A Compendium of Superfund Field Operations
Methods." EPA/540/P-87/001 (OSWER Directive 9355.0-14). December 1987.
6.0 EXHIBITS
Exhibit 24-1 Triangular Diagram Showing Percentage of Sand, Silt and Clay in Each Textural Class
Exhibit 24-2 Comparison Chart for Estimating Degree of Sorting
Exhibit 24-3 Comparison Chart for Estimating Percentage Composition
Exhibit 24-4 Comparison Chart for Estimating Roundness and Sphericity
Exhibit 24-5 Borehole Log
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Standard Operating Procedures Procedure No. 24
Colorado Department of ฆ Revision No.: 0
Public Health and Environment Date: 01/2000
Page 8 of 13
EXHIBIT 24-1
Triangular Diagram Showing Percentage of Sand, Silt and Clay in Each Textural Class
clay
100% 0
100% 80 60 40 20 0
sand % sand
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Procedure No. 24
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Date: 01/2000
Page 9 of 13
EXHIBIT 24-2
Comparison Chart for Estimating Degree of Sorting
Standard Operating Procedures
Colorado Department of '
Public Health and Environment
Very Poorly
Graded
Poorly
Graded
Moderately
Graded
Well
Graded
Very Well
Graded
m
12
O
Very Wall
Sorted
Wed
Sorted
Moderately
Sorted
Poorly
Sorted
Very Poorly
Sorted
.. 5
Terms for degrees of sorting. The numbers indicate the number of size-
classes included by the bulk {80 percent) of the material. The drawings
represent sandstones as seen wrth a hand lens. Sift and day-size
materials are shown diagrammatically by the fine stipple.
Reference; Compton, R.R. 1952. Manual of Gaology. John Wiley A Sons, Inc. New York, N p. 214
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Standard Operating Procedures Procedure No. 24
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Public Health and Environment Date: 01/2000
Page 10 of 13
EXHIBIT 24-3
Comparison Chart for Estimating Percentage Composition
Reference: Compton, R.R. 19S2. Manual of Geology. John Wiley A Sons, Inc. New York, NY p. 332-333
I:\QAPP\SOP\SOP 24.wpd
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Standard Operating Procedures
Colorado Department of -
Public Health and Environment
EXHIBIT 24-4
Comparison Chart for Estimating Roundness and Sphericity
Procedure No. 24
Revision No.: 0
Date: 01/2000
Page 11 of 13
Reundness '
\
Very Sub Sub Well
Angular Angular Angular Rounded Rounded Rounded
\ 0.5 1.5 , 2.5 3.5 4.5 5.5 .
Discoidal
.0.5
>>
5
o
fk
Sub
ical Discoidal
O
/i
u*
cn
Sub
ismoldal
3.5
t ฆy*^'
ฃ
1
Prismoida!
ฆ $?; i '-^* MMM ffi ?HM
EFj-'vXSttL'flKBlB^^wSSnaP^.^aKBMLJSflK^RiLJ^Hfl
Re/erenceiAmerican Geological Institute. 1S82. "AGI Data Sheet 18.1" in ACI Data Sheets. Pall Church, VA
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Standard Operating Procedures
Colorado Department of . Procedure No. 24
Public Health and Environment Revision No.: 0
Date: 01/2000
Page 12 of 13
EXHIBIT 24-5
Borehole Log
?Hป
\ w .
ปซ0/imfciUUcn
J
D*aS
Diyrt wfVm^Fiat Frrimiimmi
(L
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LTTKOCjWxNO FKTOCC.COr
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 24
Revision No.: 0
Date: 01/2000
Page 13 of 13
EXHIBIT 24-5 (Continued)
.ih ฆ j ฆ i .Vial
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 25
Revision No.: 0
Date: 01/2000
Page 1 of3
STANDARD OPERATING PROCEDURE - 25
RESIDENTIAL DUST SAMPLING
1.0 PURPOSE
The purpose of this procedure is to describe the equipment and operations used for residential dust sampling.
This procedure provides guidance for routine operations during residential dust sampling. Site-specific
deviations from the methods presented herein must be approved by the Project Leader and the Colorado
Department of Public Health and Environment (CDPHE) Quality Assurance Officer.
2.0 DEFINITIONS AND ABBREVIATIONS
2.1 Definitions
Not applicable.
2.2 Abbreviations
EPA U.S. Environmental Protection Agency
NIOSH National Institute of Occupational Safety and Health
OSHA Occupational Safety and Health Administration
SOP Standard Operating Procedure
3.0 RESPONSIBILITIES
Field personnel are responsible for performing the applicable tasks in accordance with this procedure when
conducting work related to environmental projects.
The Project Leader or an approved designee is responsible for checking all work performance and verifying
that the work satisfies the applicable tasks required by this procedure. This will be accomplished by
.reviewing all documents (Exhibits) and data produced by work performance.
4.0 PROCEDURES
4.1 Introduction
Residential dust samples will be collected in conjunction with specific surface/shallow depth soil
samples to determine if there is a direct relationship between airborne contamination and soil
contamination. Residential dust samples will be collected from residences that are within or near the
corresponding soil sampling locations.
I:\QAPP\SOP\SOP 25.wpd:
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 25
Revision No.: 0
Date: 01/2000
Page 2 of3
4.2 Equipment
Residential dust sampling will be conducted using the following equipment:
Portable personal sampling pump (similar to the Dupont Alpha-1ฎ);
Tygonฎ tubing and stainless steel sampling nozzle (with an approximate aperture of 1.5 cm
x 3 mm); and
A 37 mm (diameter) three-piece Aerosol Analysis Monitor Cassette fitted with a thin
cellulose support pad and 0.8 micron mixed cellulose ester filter will commonly be utilized.
Sampling media may vary according to the contaminants present. In addition, sampling will
be conducted in accordance with the U.S. Environmental Protection Agency (EPA), the
Occupational Safety and Health Administration (OSHA), or the National Institute of
Occupational Safety and Health (NIOSH) methods where applicable.
4.3 Calibration
Calibration (in accordance with EPA, OSHA, or NIOSH methods) will be implemented using the
mini-Buck Calibrator or equivalent. All calibrations will be completed according to manufacturer's
specifications, and recorded in the field log book. Calibrations may also be recorded in the
equipment calibration logs.
4.4 Method
Residential dust sampling will be conducted as follows:
Set up pump and sampling apparatus in the area to be sampled. The sampling media should
be placed at least four feet off the ground in an area that accurately represents contamination
concentrations, i.e., away from exhausts and fans;
Start the pump and record the start time in the field log book;
Check the pump periodically to ensure proper functioning for the duration of sampling;
After the appropriate sampling interval has elapsed, stop the pump and record the stop time
in the field log book.
4.5 Decontamination
Decontamination procedure for residential dust sampling equipment will include the following:
Remove the cassette;
Replace the cassette stoppers;
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 25
Revision No.: 0
Date: 01/2000
Page 3 of 3
Label the cassette following guidelines identified in CDPHE Standard Operating Procedure
(SOP) 4.4, Sample Identification, Labeling, and Packaging; and
After each sample is collected, replace the Tygonฎ tubing and sampling nozzle.
4.6 Background Samples
Background samples will be collected as specified in the Sampling and Analysis Plan.
4.7 Review
The Project Leader or an approved designee shall check all documents (Exhibits) generated during
sampling operations for completeness and accuracy. Any discrepancies will be noted and the
documents will be returned to the originator for correction. The reviewer will acknowledge that
these review comments have been incorporated by signing and dating the applicable reviewed
documents.
5.0 REFERENCES
CDPHE, 2000. " Standard Operating Procedure 4, Sample Identification, Labeling, and Packaging."
Standard Operating Procedures.
6.0 EXHIBITS
Not applicable.
I:\QAPP\SOP\SOP 25.wpd:
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 26
Revision No.: 0
Date: 01/2000
Page 1 of 5
STANDARD OPERATING PROCEDURE - 26
CHIP, WIPE AND SWEEP SAMPLING
1.0 PURPOSE
The purpose of this procedure is to describe the equipment and methods required for obtaining a
representative chip, wipe or sweep sample to monitor potential surficial contamination.
These methods of sampling are appropriate for surfaces contaminated with non-volatile species of analytes
(i.e., polychlorinated biphenyls (PCB), polychlorinated dibenzodioxin (PCDD), polychlorinated dibenzofuran
(PCDF), metals, cyanide, etc.). Detection limits are analyte specific. Sample size should be determined
based on the detection limit desired and the amount of a sample requested by the analytical laboratory. A
typical sample area is one square foot; however, based upon sample location, the area may be modified due
to area configuration. Site-specific deviations from the methods presented herein must be approved by the
Project Leader and the CDPHE (CDPHE) Quality Assurance Officer.
Chip sampling is appropriate for porous surfaces and is generally accomplished with either a hammer and
chisel, or an electric hammer. The sampling device should be decontaminated as outlined in CDPHE
Standard Operating Procedure (SOP) 4.11, Equipment Decontamination. To collect the sample, a measured
and marked off area is chipped both horizontally and vertically to an even depth of 1/8 inch. The sample is
then transferred to the appropriate container.
Wipe samples are best collected from smooth surfaces and help to indicate surficial contamination. A sample
location is delineated. Sampling is conducted using a sterile gauze pad soaked with a predesignated solvent.
The gauze pad is then stroked firmly over the sample surface, first vertically, then horizontally, to ensure
complete coverage. The gauze pad is then transferred to the sample container.
Sweep sampling is an effective method for the collection of dust or residue on porous or non-porous surfaces.
To collect such a sample, an appropriate area is delineated. Sampling is conducted by using a dedicated
brush to transfer the sample to a dedicated dust pan for placement of the sample into the appropriate sample
container.
2.0 DEFINITIONS AND ABBREVIATIONS
2.1 Definitions
Not applicable.
I:\QAPP\SOP\SOP 26.wpd:bas
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 26
Revision No.: 0
Date: 01/2000
Page 2 of 5
2.2 Abbreviations
HPLC
NIOSH
PCB
PCDD
PCDF
PPs
High Performance Liquid Chromatography
National Institute of Occupational Safety and Health
Polychlorinated biphenyls
Polychlorinated dibenzodioxin
Polychlorinated dibenzofiiran
Project Plans
3.0 RESPONSIBILITIES
Field personnel are responsible for performing the actual sampling, maintaining sample integrity and
preparing the proper chain-of-custody forms.
The Project Leader or an approved designee is responsible for deciding when chip, wipe, and sweep sampling
is needed, for checking all work performance, and for verifying the resulting data.
4.0 EQUIPMENT
The following equipment is needed for chip, wipe or sweep sampling:
Disposable chemical-protective gloves that are appropriate for the solvent, contaminant, and analysis
involved;
Sterile wrapped gauze pad (3 in. X 3 in.) (wipe sampling);
Appropriate High Performance Liquid Chromatography (HPLC) grade solvent (wipe sampling);
Medium sized decontaminated paint brush and dust pan (sweep sampling);
Medium sized decontaminated chisel and hammer (chip sampling);
5.0 SAMPLING LOCATION/SITE SELECTION
Follow the sample design criteria outlined in the applicable Project Plan for each sampling event. Sampling
sites can be relocated when conditions dictate, such as when natural or artificial obstructions prevent access
to the proposed sample location. Document the actual sample locations, using a camera or sketched site map.
6.0 PROCEDURES
6.1 Preparation
Determine the extent of the sampling effort, the sampling methods to be employed, and the
types and amounts of equipment and supplies needed.
I:\QAPP\SOP\SOP 26.wpd:bas
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 26
Revision No.: 0
Date: 01/2000
Page 3 of 5
Obtain necessary sampling and monitoring equipment.
Decontaminate or preclean equipment, and ensure that it is in proper working order.
Mark all sampling locations, record in log book, and photo document prior to sampling.
6.2 Sampling Steps
6.2.1 Chip Sampling
Chip the sample area horizontally and then vertically to an even depth of
approximately 1/8 inch.
Place the sample in a clean jar appropriate for the intended analysis, as described in
CDPHE SOP 4.2, Sample Containers, Preservation and Maximum Holding Times.
The sample jar should be labeled in accordance with CDPHE SOP 4.4, Sample
Identification, Labeling, and Packaging. The proper chain-of-custody procedures
should be followed, as outlined in CDPHE SOP 4.3, Chain of Custody.
Dispose of the sampling device as outlined in CDPHE SOP 4.8, Investigation
Derived Waste Management, or decontaminate as outlined in CDPHE SOP 4.11,
Equipment Decontamination, if practical.
6.2.2 Wipe Sampling
Moisten the filter with a solvent selected to dissolve the contaminants of concern as
specified in the Project Plan. The filter should be wet but not dripping.
Thoroughly wipe a predetermined area with the moistened filter using firm strokes.
Wipe vertically and then horizontally to ensure complete coverage. A stencil can
help judge the size of the wipe area. If a larger or smaller area is wiped, record the
change in the field logbook. If the surface is not flat, be sure to wipe any crevices
or depressions. If the surface is so rough that the filter would be ripped and torn
during wiping, press the filter firmly on the surface and lift with a slight sideways
motion.
Without allowing the filter to contact any other surface, fold it in half with the
exposed side in, and then fold it in half a second time to form a 90 degree angle in
the center of the filter.
Place the filter (angle first) into a clean jar appropriate for the intended analysis, as
described in CDPHE SOP 4.2, Sample Containers, Preservation and Maximum
Holding Times. Label the sample jar in accordance with CDPHE SOP 4.4, Sample
Identification, Labeling, and Packaging. The proper chain of custody procedures
should be followed, as outlined in CDPHE SOP 4.3, Chain of Custody. The sample
I:\QAPP\SOP\SOP 26.wpd;bas
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 26
Revision No.: 0
Date: 01/2000
Page 4 of 5
jars should be placed in a container appropriate for the intended analysis (e.g.,
cooler or sturdy box) and sent to the laboratory as provided for in the project
Sampling and Analysis Plan.
Follow decontamination procedures as outlined in CDPHE SOP 4.11, Equipment
Decontamination.
6.2.3 Sweep Sampling
Sweep the measured area using a dedicated sweeping or paint style brush. Continue
to sweep the dust with the brush into a dedicated dust pan which has been placed
firmly on the outside of the premeasured sampling area.
Transfer the sample from the dust pan to a clean jar appropriate for the intended
analysis, as described in CDPHE SOP 4.2, Sample Containers, Preservation and
Maximum Holding Times. The sample jar should be labeled in accordance with
CDPHE SOP 4.4, Sample Identification, Labeling, and Packaging. The proper
chain-of-custody procedures should be followed, as outlined in CDPHE SOP 4.3,
Chain of Custody.
Leave contaminated sampling brush and dust pan in sample media or dispose of as
outlined in CDPHE SOP 4.8, Investigation Derived Waste Management.
Follow decontamination procedures as outlined in CDPHE SOP 4.11, Equipment
Decontamination.
7.0 DOCUMENTATION
All chip, wipe or sweep sampling procedures should be fully documented in the field logbook. In addition
to the information listed in CDPHE SOP 4.6, Use and Maintenance of Field Log Books, include the
following:
Time of collection of each chip, wipe or sweep sample;
Predominant wind direction (if sampling outdoors);
Sketch map(s) and/or photographs showing sampling area; and
Description of item(s) being sampled.
8.0 REVIEW
The Project Leader or an approved designee shall check all documents (Exhibits) generated during sampling
operations for completeness and accuracy. Any discrepancies will be noted and the documents will be
returned to the originator for correction. The reviewer will acknowledge that these review comments have
been incorporated by signing and dating the applicable reviewed documents.
I:\QAPP\SOP\SOP 26.wpd:bas
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Standard Operating Procedures
Colorado Department of
Public Health and Environment
Procedure No. 26
Revision No.: 0
Date: 01/2000
Page 5 of 5
9.0 REFERENCES
U.S. Environmental Protection Agency (EPA). 1987. "A Compendium of Superfund Field Operation
Methods." EPA/540/P-87/001, U.S. Environmental Protection Agency. Washington, D.C.
U.S. Environmental Protection Agency (EPA). 1991. "A Compendium of ERT Waste Sampling
Procedures." OSWER Directive 9360.4-07, January 1991. Office of Emergency and Remedial response,
U.S. Environmental Protection Agency.
CDPHE, 2000. "Standard Operating Procedure 2,Sample Containers, Preservation, and Maximum Holding
Times." Standard Operating Procedures.
CDPHE, 2000. "Standard Operating Procedure 3, Chain of Custody." Standard Operating Procedures.
CDPHE, 2000. "Standard Operating Procedure 4, Sample Identification, Labeling, and Packaging."
Standard Operating Procedures.
CDPHE, 2000. "Standard Operating Procedure 6, Use and Maintenance of Field Log Books." Standard
Operating Procedures.
CDPHE, 2000. "Standard Operating Procedure 8, Investigation Derived Waste Management." Standard
Operating Procedures.
CDPHE, 2000. "Standard Operating Procedure 11, Equipment Decontamination." Standard Operating
Procedures.
10.0 EXHIBITS
Not applicable.
I:\QAPP\SOP\SOP 26.wpd:bas
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Attachment 2
August 31, 2012 letter from the EPA to the Pueblo City Council
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 8
1595 Wynkoop Street
DENVER, CO 80202-1129
Phone 800-227-8917
http://www.epa.gov/region08
(AUG 31 2012
Ref: 8EPR-AR
Chris Kaufman, President
Pueblo City Council
200 South Main Street
Pueblo, CO 81003
Dear Mr. Kaufman:
The U.S. Environmental Protection Agency (EPA) appreciates and welcomes the ongoing
discussion about the Eilers neighborhood and the former Colorado Smelter site. We do however
believe it is appropriate to clarify the understanding of the data collected to date and how EPA
assesses these data for purposes of listing a site on the National Priorities List (NPL). This letter
is intended to respond specifically to certain statements made by Merril Coomes at a City
Council meeting (Monday, 6/25/12) and in a letter to the Pueblo Chieftain (Sunday, 8/12/12) that
contain several inaccuracies. The EPA is committed to assuring that factual information is
available to all interested stakeholders and that this information is the basis for decision making.
Mr. Coomes' assertion that arsenic concentrations identified in Eilers area samples are identical
to those characterized during the 2006 "Pueblo-wide" soil study is simply not correct. EPA
technical staff including Charles Partridge, PhD, EPA toxicologist, and Robert Edgar, PhD, EPA
statistician, reviewed the data from the 2006 Colorado State University-Pueblo (CSU-Pueblo) -
"Pueblo-wide" soil study and compared it to the data collected in the Eilers neighborhood in
support of listing the Colorado Smelter site. Based on rigorous analysis using five different
statistical tests, EPA determined that the soil arsenic data collected from the Eilers neighborhood
are indeed statistically significantly higher when compared to the soil arsenic data from the 2006
CSU-Pueblo study.
The following figure shows a comparison of the levels of arsenic in the soil from the 2006 CSU-
Pueblo study versus the levels of arsenic found in the soils of the Eilers neighborhood. On the
vertical axis are the numbers of samples at those concentrations. You can see that the average
concentration of 12.4 milligrams per kilogram (mg/kg) for the CSU-Pueblo samples is much
lower than the EPA/CDPHE study's average concentration of 55.4 mg/kg samples. Additionally
all 66 of the CSU-Pueblo samples contained less than 70 mg/kg arsenic and approximately 92
percent of the CSU-Pueblo samples contained 20 mg/kg or less of arsenic. None of the CSU-
Pueblo samples contained greater than 70 mg/kg of arsenic; whereas there were samples with
arsenic concentrations exceeding 70 mg/kg and as high as 210 mg/kg in the EPA/CDPHE
-------
study's samples. This figure dramatically illustrates the increased levels of arsenic in the soils
surrounding the Colorado Smelter site when compared to those levels of arsenic found in soils
across the City of Pueblo.
10 20 30 40 50 60 70 80 90 100 110 120 130 140 150 160 170 180 190 200 210
Level of Arsenic in Soil (mg/kg)
EPA Neighborhood Soil Data ฆ CSU-Pueblo 2006 Soil Data
Regarding Mr. Coomes' assertions that lead and arsenic in the Eilers neighborhood may be from
other sources, site history and factual information clearly link contaminants from the smelter to
the area of concern. The notion that lead from historic smelting may also be mixed with lead
from old paint in residential yards does not make the concern about inhalation, ingestion and
public health less compelling.
The EPA and Colorado Department of Public Health and Environment sampling results clearly .
indicate a need to more fully investigate smelter related contamination and potential associated
health risks. A key part of the Superfund process that occurs after listing on the NPL is a
comprehensive scientific assessment of the nature and extent of contamination, exposure, and
risk.
The EPA is committed to providing accurate information as we move forward and to answering
questions in a timely manner. Ultimately, decisions about any cleanup activity will be made
based on science and a continuing consultation with the community. We hope Pueblo residents
2
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will take the opportunity to discuss and leam more about these concerns at upcoming public
meetings and other forums. We are open to and would welcome continued City involvement in
this dialogue. These are important issues and we are eager to engage with the community and to
work with all stakeholders to find a long-term solution that benefits the community.
Please feel free to contact me or my staff should you have questions or concerns going forward.
1 can be reached at (303) 312-6827.
Sincerely,
David Ostrander, Acting Director
Assessment & Revitalization Program
Cc:
Amy Nawrocki, District 1 Representative
Pueblo City Council
Eva Montoya, District 2 Representative
Pueblo City Council
Leroy Garcia. District 3 Representative
Pueblo City Council
Sandy Daff, District 4 Representative
Pueblo City Council
Steve Nawrocki, Vice President
Pueblo City Council
Chris Nicoll, Representative at Large
Pueblo City Council
Jim Munch, Pueblo City Manager
Tom Florczak, City Attorney
Dr. Christine Nevin-Woods. Director
Pueblo City-County Health Department
Moussa Diawara, PhD
Colorado State University - Pueblo
Dr. Chris Urbina, MD, MPH, Executive Director and Chief Medical Officer
CDPHE
Dan Scheppers, Remediation Program Manager
CDPHE
3
Printed on Recycled
Paper
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Attachment 3
Excerpt of USGW Open File Report 81-197
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UNITED STATES DEPARTMENT OF THE INTERIOR
GEOLOGICAL SURVEY
CHEMICAL ANALYSES OF SOILS AND OTHER SURFICIAL
MATERIALS OF THE CONTERMINOUS UNITED STATES
By
Josephine G. Boerngen and Hansford T. Shacklette
Open-File Report 81-197
1981
This report is preliminary and has not been
edited or reviewed for conformity with U.S.
Geological Survey standards or nomenclature
-------
Contents
Page
Introduction.... 1
Sample collection, preparation, and analysis.. 2
Location, description, and concentration of elements for samples of
surficial materials 3
References cited 6
Table Page
Table 1. Location, description, and concentration of elements for
samples of surficial materials 8
iii
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Introduction
A sampling program was begun in 1961 that was designed to give esti-
mates of the abundance of elements in soils and other surficial materials
and in associated plants from sites selected along routes of travel, and
in study areas, of U.S. Geological Survey scientists. The sampling plan
was kept simple. The proposed sampling intensity consisted of one sample
of soil and one of plants collected at sites about 50 mi. (81 km) along
routes of travel to areas of other types of field study. Sampling sites
were selected, insofar as possible, that represented soil in its natural
condition. This program resulted in the sampling of 863 sites. The
results of the soil analyses were published for 35 elements by plotting
their concentrations, in two to five frequency classes, on maps (Shacklette,
Hamilton, Boerngen, and Bowles, 1971).
Soon after this publication, interest in environmental geochemistry,
particularly the application to problems of industrial and vehicular pol-
lution, increased greatly. At the same time, advances in analytical tech-
niques made the analysis of additional elements practical. Therefore, the
samples from the first study, with some additional samples, were analyzed
and reported as follows: mercury by Shacklette, Boerngen, and Turner (1971);
lithium and cadmium by Shacklette, Boerngen, Cahill, and Rahill (1973); and
selenium, fluorine, and arsenic by Shacklette, Boerngen, and Keith (197k).
Sampling according to this plan continued, as opportunities arose,
until autumn, 1975, resulting in the sampling of 355 additional sites that
were selected to give a more uniform geographical coverage of the conter-
minous United States. These samples were analyzed and the data were merged
with those of the original samples to produce the results given in this
report.
The elemental composition of only the surficial materials were given
in all reports; the data on analysis of the plant samples are held in files
of the U.S. Geological Survey.
This study was made possible by the cooperation of many persons in the
U.S. Geological Survey. We express our appreciation to those who collected
samples, as follows: Jessie M. Bowles, F. A. Branson, R. A. Cadigan, F. C.
Canney, H. L. Cannon, F. W. Cater, Jr., M. A. Chaffey, Todd Church, J. J.
Connor, Dwight Crowder, R. J. Ebens, R. N. Eicher, J. A. Erdman, R. F.
Gantner, G. B. Gott, W. R. Griffitts, T. P. Hill, E. K. Jenne, M. I. Kaufman,
J. R. Keith, Frank Kleinhampl, A. T. Miesch, R. F. Miller, R. C. Pearson,
E. V. Post, Douglas Richman, James Scott, D. E. Seeland, R. C. Severson,
M. H. Staatz, T. A. Steven, M. H. Strobell, V. E. Swanson, R. R. Tidball,
H. A. Tourtelot, J. D. Vine, and R. W. White.
We thank the following members of the U.S. Department of Agriculture,
Soil Conservation Service for providing soil samples from areas in Minnesota:
Donald D. Barron, Carroll R. Carlson, Donald E. DeMartelaire, Royce R. Lewis,
Charles Sutton, and Paul Nyberg.
1
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We acknowledge the analytical support provided by the following U.S.
Geological Survey chemists: Lowell Artis, Philip Aruscavage, A. J. Barbel,
S. D. Botts, L. A. Bradley, J. W. Bud ins ky, Alice Caemmerer, J, P. Cahill,
1. Y. Campbell, G. W. Chloe, Don Cole, Eป F. Cooley, N. M. Conklin, Vi. 3.
Grande11, Maurice Devalliere, P. L. D. Elmore, E, J. Finlay, Johnnie Gardner,
J. L. Glenn, T. F. Harms, R. C. Haven, R. H. Heidel, M. B. Hinkle, Claude
Huffman, Jr., L. B, Jenkins,, R. J. Knight, B, W. Lanthorn, L. M. Lee, K. W.
Leong, J. B. McHugh, J. D. Mensik, ?. M. Merrit, H. T. Millard, Jr., Wayne
Mountj oy, H. M. Nakagawa, H. G. Neiman, Uteana (Ma, C. S. E. Papp, R. L.
Rahill, V. 1, Shaw, G. D, Shipley, Hezekiah Smith, A, J. Sutton, Jr., J, A.
Thomas, Barbara Tobin, J. E. Troxel, J, H. Turner, and G. H, VanSickle.
We were assisted in computer programming for the data by J. B. Fife
and George fanTrump, Jr.
Sample collection, preparation, and analysis
The sampling sites were selected, if possible, to represent surficial
materials that were altered very little from their natural condition and
that supported native or cultivated plants suitable for sampling. In
practice, this site selection necessitated sampling away from roadcuts and
fills, but in some areas only cultivated fields were available for sampling,
The materials sampled included soil as defined by soil scientists, beach
and dune sands, very stony lithosols, and organic deposits generally con-
sidered to be peat instead of soil. Most samples were collected at a depth
of about 8 in. (20 cm), which reduced or avoided the effects of surface con-
tamination. In zonal soils, this depth commonly is within the range of the
B soil horizon (zone of element accumulation). Some lithosols over near-
surface bedrock did not extend downward to 8 in. (20 cm); they were sampled
at the bottom of soil development in the profile.
Areas of field studies commonly were sampled more intensively than at
intervals of 50 miles (81 km). Samples used from these studies were selected
to represent about the same geographical coverage as did those along roads.
The soil samples were dried in the laboratory, pulverized and sieved,
and the minus-2mm fractions were used for analysis. The methods of analysis
used for some elements were changed during the course of the study as new
techniques and instruments became available. The results published in the
first report (Shacklette, Hamilton, Boemgen, and Bowles, 1971) were obtained
for most elements by use of a semiquantitative six-step emission spectrographs
method (Veiman, 1976) Other methods were used for the following elementsi
atomic absorption, with flame (Huffman and Dinnin, 1976) for mercury, lithium,
magnesium, sodium, rubidium, and zinc; atomic absorption, flame less (Vaughn,
196?) for mercury; X-ray fluorescence spectrometry (Wahlberg, 1976) for
calcium, germanium, iron, potassium, selenium, silver, sulfur, and titanium;
combustion (Huffman and Dinnin, 1976), total carbon; and neutron activation
(Millard, 197$, 1976) for thorium and uranium.
2
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Table 1.--Location/ description/ and, concentration elements 1tor sample; of( surljtcial, ซatjerial|^--cont|inued.
Sample
Lat i-
Long-
Date
Site and Soil Descriptions
No.
State
County
tude
i tude
Colin.
GC066550
CO
MESA
39
1 1
109
3
72
9
US 50-6 REST STOP .5 MI E STATE LINE; GRAY-BROWN SOIL ON SILTSTONE
G C 06 66 SO
CO
MESA
39
1 1
108
17
72
9
J CT 1-70 & RT 65; LIGHT BROWN SILT
GC 26 2150
CO
MINERAL
37
28
106
A7
68
5
US 160 AT SUMMIT WOLF CREEK PASS; SHALLOW SOIL OVER BEDROCK
GC033A50
CO
MOFFAT
AO
32
107
27
65
8
US AO A MI E CRAIG#' BROWN SILTY LOAM
GC033550
CO
MOFFAT
AO
26
108
16
65
8
US AO 12 MI W MAYBELL; BROWN SANDY B HORIZON
GC033650
CO
MOFFAT
AO
16
109
2
65
8
US AO 1 MI E COLO-UTAH LINE.* RED BROWN SAND
GC185 A 50
CO
MOFFAT
AO
1 5
108
AO
65
6
US AO 5 MI E MASSADONA; BROWN CLAYEY SILT 8-IN. DEPTH
GC015550
CO
MONTEZUMA
37
28
108
39
62
5
US 160 9 MI NW CORTEZ; LOESS SOIL ON DAKOTA SANDSTONE
GC073250
CO
MONTEZUMA
37
21
108
30
73
3
US 160 A MI E CORTEZ; SANDY LOAM
GC016250
CO
MONTROSE
38
31
107
S6
62
5
SITE AND SOIL DESCRIPTION NOT RECORDED
GC027850
CO
MONTROSE
38
1 5
108
21
72
8
NUCLA RD OFF RT 90 AT W LIMIT UNCOMPAGRE NAT FOREST; COLLUVIUH ft SILT
GC 02 8050
CO
MONTROSE
38
26
107
35
72
8
US 50 2 MI W CIMARRON; LIGHT BROWN LOAM OVER SHALE
GC0AAA50
CO
MORGAN
AO
1 5
103
A 5
66
10
RT 71 1 MI N BRUSH; BROWN SANDY LOAM
GC085A50
CO
OTERO
37
A 5
103
30
75
6
RT 109 15 MI S LA JUNTA.' SANDY LOAM/ MODERATELY WELL DEVELOPED
GC085850
CO
OTERO
37
AO
10A
0
75
6
US 350 1 MI N DELHI.' ARIDISOL FROM SANDSTONE AND SHALE
GC016350
CO
OURAY
37
57
107
AO
62
5
SITE AND SOIL DESCRIPTION NOT RECORDED
GC027950
CO
OURAY
38
9
107
A9
72
8
RT 62 3 MI W RIDGEWAY.* SILT OVER SHALE
GC033350
CO
PARK
AO
2 A
106
38
65
8
US AO ON RABBIT EARS PASS.' SANDY B HORIZON ON HORNBLENDE SCHIST
GC155050
CO
PARK
39
27
105
A 2
63
7
US 285 AT KENOSHA PASS SUMMIT.' DARK LOAM/ FROM GRUS
GC1814 50
CO
PARK
39
13
106
0
6 A
7
US 285 A MI S FAIRPLAY.' SOIL NOT DESCRIBED
G C 1 5 6 7 50
CO
PROUERS
38
0
102
7
63
10
US 50 1 Ml W HOLLY.' IRRIGATED CALCIMORPHIC SOIL
GC277650
CO
PROUERS
37
A 5
102
35
69
1
US 385 9 MI N COUNTY LINE.' LIGHT YELLOW SAND OVER SANDSTONE BUTTES
GC086050
CO
PUEBLO
38
25
10A
11
75
6
BOONE RD 12 MI N BOONE." WINDBLOWN SAND
GC170150
CO
PUEBLO
37
56
10A
A 7
6 A
5
1-25 20 MI S PUEBLO; ARID LIGHT SOIL
M GC185250
CO
ROUTT
AO
29
107
2
65
6
US AO 2 MI E STEAMBOAT SPRINGS.' BROWN SILTY CLAY 8-IN. DEPTH
^ G C1813 50
CO
SAGUACHE
38
1 A
105
55
6A
7
US 285 .5 MI N VILLA GROVE.' SAN LUIS VALLEY LOAM
GC010351
CO
SAN MIGUEL
38
2
108
AO
6 A
9
18 MI SW NUCLA.' SOIL ON ALLUVIAL FILL
GC027750
CO
SAN MIGUEL
38
8
108
23
72
8
BLM RD AT BURN CANYON 7 MI W NORWOOD.' SOIL DERIVED FROM SANDSTONE
GC 066950
CO
SUMMIT
39
33
106
9
72
9
US 6 .5 MI E OFFICERS GULCH CAMPGROUND; BROWN GRAVELLY SOIL ON .TILL
GC016850
CO
TELLER
38
57
105
17
62
5
US 2A E EDGE FLORISSANT.* BLACK SOIL
GC000250
CO
WASHINGTON
39
A 5
103
1 A
62
5
US 36 1 MI W ANTON.' MEDIUM BROWN SILTY LOAM
GC263250
CO
UELD
AO
53
10A
A 7
68
8
US 85 2 MI S ROCKPORT AND .5 MI E ON GROVER RD/* B HORIZON CALICHE VEIN
GC268750
CO
WELD
AO
59
103
A 2
68
8
RT 71 26 MI N STONEHAM; LOESS AND SAND CAP OVER FISSILE LIMESTONE
GC268850
CO
WELD
AO
38
1 OA
5
68
8
RT 1A 18 MI W JCT RT 52; SANDY SILT TOPSOIL CALCAREOUS SANDY SUBSOIL
GC000350
CO
YUMA
39
A 2
102
23
62
5
US 36 1 MI W IDALIA; BROWN SILTY LOAM
GC006250
CT
NEW HAVEN
A1
16
72
50
62
10
CONN TPK 2 MI E EXIT 52.* YELLOWISH-ORANGE SANDY CLAY
GC006150
CT
NEW LONDON
A1
35
72
A
62
10
CONN TPK 3 MI NE EXIT 81.' YELLOW-BROWN B HORIZON
GC032A 50
DE
NEW CASTLE
39
19
75
37
72
9
RT 13 2 Ml N SMYRNA.' LIGHT BROWN SAND
GC032250
DE
SUSSEX
38
A3
75
9
72
9
RT 2A 2 Ml SU MIDWAY.* SANDY PEBBLY SOIL
GC278150
FL
ALACHUA
29
30
82
18
69
1
US AA1 1 MI S MICANOPY; UPLAND HUMIC SAND
GC025850
FL
BREVARD
28
10
80
37
71
7
1-95 12 MI N JCT WITH LIS 192; ORGANIC SOIL AND SAND
GC026650
FL
BROWARD
26
9
80
29
71
7
JCT US 27 & RT 8A NEAR ANDYTOWN; ORGANIC & SANDY SOIL
GC278550
FL
CHARLOTTE
27
0
82
10
69
1
US At 5 Ml W MURDOCK.' FINE SAND
GC070A50
FL
CITRUS
28
A8
82
2 A
73
2
US 19 3 MI N HOMOSASSA/' YELLOW SANDY SOIL
GCQ25A 50
FL
CLAY
31
50
82
5
71
7
JCT RT 218 & US 301 8 MI N LAWTEY.* MUCK
GC0265 50
FL
COLLIER
25
50
80
59
71
7
US A1 AT PAOLITA STATION; MUCK WITH SAND & SHELLS
GC026750
FL
COLLIER
26
10
80
57
71
7
RT 8A U OF SEMINOLE RESERVATION/' ORGANIC & SANDY SOIL
GC 278750
FL
COLLIER
25
55
81
A 5
69
1
RT 92 ON BEACH RIDGE OF MARCO ISLAND.' CALCAREOUS SAND
GC278850
FL
COLLIER
26
8
81
30
69
1
RT 838 10 MI W JCT RT 29; HUMIC SAND OVER MARL/ NON-CALCAREOUS
GC026A 50
FL
DIXIE
29
38
83
8
71
7
US 19-98 AT CROSS CITY.' ORGANIC & SANDY SOIL
-------
Table 1.--Location* description* and concentration of elements for samples of surficiai materialscontinued
Sample No.
Al X
As ppm
B ppm
Ba ppm
Be ppm
Br ppm
C X
Ca X
Ce ppm
Co ppm
Cr ppm
Cu ppm
GC066550
3.00
8.3
50
300
1.5
<.5
1.4
4.09
<150
N
30.0
10.0
GC0666SO
10.00
5.5
30
1 #000
1.5
<.5
1.3
2.53
<150
5
50.0
20.0
GC2621SO
>10.00
4.9
30
700
1.0
--
1.00
N
7
30.0
30.0
GC033450
?.oo
7.2
30
700
N
--
1.00
150
15
100.0
20.0
GC033550
5.00
4.2
30
500
N
.60
N
N
15.0
10.0
GC033650
5.00
5.3
50
500
N
--
1.80
N
N
15.0
1 5.0
GC185450
3.00
10.0
70
300
N
7.43
--
3
30.0
30.0
GC015550
7.00
20
500
2.0
--
.60
N
7
50.0
30.0
GC073250
3.00
5.4
30
300
N
<.5
1.6
1 .40
N
<3
20.0
10.0
GC016250
7.00
70
500
2.0
--
4.20
7
100.0
50.0
GC027850
3.00
3.5
30
300
N
<.5
.7
.33
N
5
100.0
20.0
GCQ2S050
7.00
10.1
20
700
1.5
.9
2.2
5.42
--
5
70.0
20.0
GC044450
3.00
4.9
20
700
1 .0
--
.50
N
5
30.0
1 5.0
GC085 A 50
5.00
9.6
<20
700
1.0
.9
1 .4
3.62
N
7
30.0
15.0
G C 08 5 850
10.00
8.8
30
1,000
1 .0
1.2
3.3
8.45
N
7
70.0
30.0
GC016350
>10.00
N
700
2.0
.65
N
20
30.0
70.0
G C 02 79 50
10.00
10.8
30
500
N
1.2
5.9
14.49
7
70.0
50.0
GC033350
>10.00
3.3
N
700
N
--
--
1 .20
N
15
50.0
30.0
GC15 5050
3.00
4.0
N
500
N
--
1.50
N
H
50.0
30.0
GC181450
7.00
30
500
N
--
1.10
7
50.0
10.0
GC156750
7.00
8.8
50
700
N
--
3.80
N
10
50.0
20.0
G C 27 76 50
1.00
3.9
<20
100
N
--
.09
N
3
3.0
5.0
^ G C 086050
5.00
2.3
N
1 ,000
N
<5
.3
.28
N
5
15.0
7.0
O GC170150
5.00
8.5
30
500
N
8.40
7
50.0
15.0
GC185250
5.00
8.2
30
700
N
--
--
.58
150
15
70,0
30.0
GC181350
>10.00
20
700
N
--
1.40
N
15
50.0
20.0
GC 0103 51
5.00
7.2
30
300
N
--
8.40
N
N
70.0
20.0
GC027750
5.00
6.7
30
500
N
<.5
1.6
1.68
<150
5
50.0
20.0
GC066950
7.00
4.9
<20
500
1.5
.9
1 .2
1.07
<150
10
50.0
20.0
G C0168 50
>10.00
N
1 ,500
2.0
--
1 .80
N
10
70.0
30.0
GC000250
5.00
5.0
30
700
N
--
.79
1 50
15
30.0
30.0
GC263250
5.00
9.1
20
700
N
--
.55
N
3
20.0
1 5.0
GC268750
1.50
5.0
N
700
N
--
32.00
N
3
10.0
1 5.0
G C 26 88 50
10.00
4.5
20
300
1.5
--
4.90
N
3
30.0
1 5.0
GC 0003 50
3.00
5.4
30
700
N
1 .00
150
7
30.0
20.0
GC 0062 50
7.00
3.7
N
300
N
.70
N
10
30.0
20.0
GC006150
>10.00
4.5
N
500
N
__
--
.98
N
5
50.0
10.0
GC032450
3.00
2.7
20
500
N
2.3
2.1
.17
N
5
50.0
7.0
GC032250
1.50
<1
<20
300
N
.7
1.5
.15
N
N
10.0
3.0
G C 2781 50
2.00
1.5
20
200
1.5
--
.95
N
N
50.0
3.0
GC 02 5 850
.20
.2
<20
30
N
<5
.2
.11
N
H
1.0
N
GC026650
1.00
2.5
N
30
N
4.1
6.9
2.03
N
20.0
7.0
GC278550
.20
2.9
20
30
N
--
.04
N
H
2.0
2.0
GC070450
.30
.5
<20
20
N
<5
.4
N
N
5.0
N
GC025450
5.00
3.9
N
20
N
2.5
29.9
--
N
N
10.0
5.0
GC026550
3.00
3.3
<20
30
N
9.4
14.79
N
N
30.0
2.0
GC026750
.30
.3
<20
50
N
<5
3.0
.25
N
N
2.0
1.0
GC278750
.20
1.3
20
50
N
--
1 .80
N
N
3.0
3.0
GC278850
. 70
1.0
30
50
N
--
.14
N
N
5.0
1.0
GC0264 50
.20
7.0
<20
10
N
<.5
1.0
.95
N
N
2.0
1.0
-------
Table 1 .--Location# description# and concentration of elements for samples of surficfal materia Iscontinued'
Sample No.
f X
Fe X
Ga ppm
Ge ppm
Hg ppm
1 ppm
K X
La ppm
L i ppm
Hg X
Hn ppm
Mo ppm
GC066550
.070
1.50
10
1.48
.02
1.4
1 .27
50
30
.500
100
N
GC066650
2.00
20
1.25
.02
<.5
1.80
<30
15
1.000
200
N
GC262150
.046
3.00
30
.24
2.50
50
20
1.000
Is 5 00
N
GC 03 34 50
.037
2.00
20
--
.02
--
1 .70
70
21
.700
700
N
GC033550
.011
.70
10
--
.01
1.70
N
12
.200
200
N
G C 03 36 50
.025
.70
7
.02
--
1 .80
N
17
.500
300
N
G C1 8 5 4 50
.057
1 .50
30
.05
--
1.70
30
35
1 .500
300
N
G C 01 5550
--
2.00
20
2.10
30
.700
300
N
G C 07 3 2 50
1.00
7
1.27
.02
. 8
.74
N
1 5
.700
100
N
G C 01 62 50
--
2.00
30
--
2.10
30
2.000
300
N
6 C 02 78 50
2.00
10
.92
.03
<.5
1.10
50
15
.200
1 50
N
GC028050
.050
3.00
20
1.18
.05
.7
1 .80
<30
30
1 .000
300
N
GC0444 50
.055
1.50
20
.05
--
2.70
30
22
.300
300
N
GCG85450
.070
2.00
15
1.47
.04
1.0
1 .60
50
32
1.000
200
N
GC085850
--
1.50
20
1.03
.05
1.5
1 .83
N
35
.700
100
5
GC016350
7.00
30
1.90
50
1.000
1,500
N
GC 02 79 50
.070
3.00
20
.94
.02
2.1
1.46
50
24
1.000
300
7
GC033350
.027
3.00
30
.04
--
2.50
50
40
1.000
500
N
GC155050
.045
1.50
1 5
--
1 .30
--
2.00
50
37
.500
300
N
G C1814 50
2.00
20
2.50
70
.500
300
N
GC156750
.051
3.00
30
--
.20
--
2.20
50
29
1 .000
500
N
GC277650
.007
.70
N
--
.08
--
.19
N
9
.050
70
N
GC086050
--
1.50
20
1 .42
.03
.5
2.88
50
1 5
.300
200
N
GC170150
.044
2.00
20
.06
--
1.70
30
22
.700
300
N
GC 1 85250
.041
2.00
20
--
.14
--
2.13
70
28
.700
700
N
GC181350
3.00
20
2.70
70
.500
1#000
N
GC010351
.110
1.50
1 5
--
.06
2.00
N
42
1.000
1 50
N
GC027750
2.00
1 5
1 .69
.03
1 .0
1.16
<30
30
.500
1 50
N
GC066950
--
3.00
15
1 .44
.04
.6
1.76
50
20
.700
500
N
GC016850
--
3.00
30
-- .
--
2.20
50
.700
700
N
GC0002 50
.053
1.50
30
-T
.08
--
2.21
70
25
.700
700
N
GC 26 3 2 50
.021
2.00
20
--
.02
2.90
30
12
.300
300
It
GC268750
.056
.70
5
--
.03
--
.85
N
9
.700
70
N
GC268850
.073
2.00
20
.01
--
2.50
50
28
1.500
300
N
GC000350
.044
1.50
20
.07
--
2.27
70
19
.700
500
N
GC0062 50
.005
1.50
10
.22
1.30
N
31
.500
700
N
GC 0061 50
.028
2.00
20
.39
--
1.80
30
23
.500
200
7
GC0324 50
1 .00
10
1 .22
.05
1.5
1.71
<30
15
.100
100
N
GC0322 50
-
.50
5
.55
.03
<5
1 .21
N
7
.050
70
N
GC 27 8150
.130
.70
<5
.06
--
.24
N
14
.300
1 50
N
GC025850
.03
N
.98
.01
<.5
.12
N
.007
N
N
GC026650
--
.30
N
.39
.04
2.1
1.47
N
5
.150
30
N
GC278550
.024
.07
N
--
.11
--
.02
N
<5
.010
2
N
GC070450
.10
N
.97
.111
<.5
.11
N
<5
.007
10
N
GC025450
.15
N
.60
.14
2.3
N
<5
.010
10
N
GC026550
--
1.00
5
.62
.03
--
.06
N
20
.150
100
N
GC026750
--
.20
N
.??
.03
.7
.14
N
<5
.015
20
N
6C278750
<001
.10
N
--
.10
--
.02
N
<5
.020
20
N
GC278B50
<.001
.15
N
.03
--
.04
30
7
.020
20
N
GC026450
.
.20
N
.74
.02
<.5
.04
N
<5
.015
10
N
-------
Table 1
-Location# description*
and concentration
Sample No.
Na X
Nb ppm
Nd ppm
Ni ppm
P X
GC066550
.50
<10
N
5
CC066650
2.00
<10
N
10
GC262150
3.00
10
100
7
.040
GC0334 50
1.00
20
N
20
.024
GC033550
.70
N
N
5
.01 2
G C 03 3650
.70
N
N
7
.016
GC185450
.70
N
N
1 5
.096
GC015550
1 .00
20
N
20
.008
G CO 732 50
.20
N
7
--
GC01 62 50
2.00
15
N
30
.060
GC027850
.30
<10
N
7
GC028050
1.00
<10
N
10
--
GC044450
.70
15
70
15
.030
GC085450
1 .00
10
N
10
G C 08 58 50
.50
N
20
GC016350
1.50
20
70
20
.090
6 C 027 9 50
1.00
<10
N
20
GC033350
2.00
15
N
20
.016
GC155050
2.00
1 5
N
7
.120
GC181450
1.00
10
N
15
.030
G C15 6 750
1 .50
15
N
30
.04 4
GC277650
.05
N
5
.004
GC086050
2.00
10
N
5
--
GC170150
1.50
10
N
20
.044
GC 1 8 5 2 50
.70
15
70
15
.087
GC181350
1.00
10
N
15
.060
GC010351
1 .00
N
20
.040
GC027750
.50
<10
N
10
GC066950
1.50
<10
N
15
GC016850
3.00
15
70
15
.060
GC000250
.70
1 5
70
1 5
.039
GC263250
1.00
10
N
7
.01 6
G C 268 7 50
.70
N
7
.016
GC268850
1 .00
10
N
10
.024
GC 000 3 50
.70
1 5
N
10
.048
GC006250
1.50
N
N
15
.020
GC006150
1.50
10
N
10
.020
GC032450
.50
<10
N
7
GC032250
.20
<10
<5
--
GC278150
<.05
10
7
.600
GC025850
N
N
N
--
GC 02 66 50
.10
N
5
__
G C 278 5 50
N
N
--
N
.004
GC070450
N
<10
N
--
GC025450
N
N
--
5
GC026550
.05
N
5
--
GC026750
<.05
N
N
--
GC278750
<.05
15
N
.030
GC278850
<.05
N
70
N
.004
G C 02 6 4 50
N
N
N
--
elements
i i > ' i * > ( i
for samples of surficiai materialscontinued
Pb ppm
Rb ppm
S %
Sb ppm
Sc ppm
Se ppm
Si X
1 5
1 5
20
30
1 5
20
30
30
N
100
1 0
20
20
20
1 5
100
1 5
50
30
70
30
N
20
30
30
50
N
1 5
30
30
20
20
10
15
20
N
N
20
10
N
N
100
N
N
10
10
N
N
N
N
50
85
<.08
<.08
1
<1
35
40
50
70
60
80
125
40
85
60
40
<20
<20
<20
<20
<20
<20
<20
<.08
<.08
<.08
<.08
.72
<.08
<.08
<.08
<.08
<08
<.08
<.08
<.08
<.08
<.08
<.08
<.08
<.08
<1
<1
<1
3
<1
<1
2
<1
<1
<1
<1
8
<1
<1
<1
<1
<1
5
5
7
7
5
N
7
7
<5
10
5
7
7
7
10
15
7
10
7
15
10
N
<5
10
15
7
5
7
10
10
15
7
N
7
10
7
10
5
N
7
N
N
N
N
N
5
N
N
N
N
3
0
5
3
1
2
6
-------
Table 1. location* description* and, concentration
. Sample No.
GC0665S0
GC0666 50
G C 262150
GC033450
GC033550
GC033650
G C 1 8 5A 50
GC015550
GC073250
GC 0162 50
GC027850
GC028050
GC044450
GC085450
GC085850
GC016350
GC027950
GC033350
GC15 5050
GC181450
GC156750
GC277650
GC086050
^ GC170150
GC18 52 50
GC181350
GC010351
GC027750
GC066950
GC016850
GC000250
GC263250
GC268750
GC268850
GC 0003 50
GC006250
GC0061 50.
GC032450
GC0322 50
GC 2 781 50
GC025850
GC026650
GC278550
GC0704 50
GC025450
GC026550
GC026750
GC278750
GC 27 8850
GC 0264 50
Sn ppm
Sr ppm
2.28
150
1 .38
1 50
--
700
--
200
100
--
70
150
150
. 91
50
--
300
.44
70
.96
200
150
1 . 79
200
2.65
1*000
--
300
1.27
300
300
200
--
100
300
10
2.18
150
--
5 00
--
150
--
300
200
2.01
100
1.02
1 50
1*000
1 50
--
200
500
--
300
--
100
100
--
150
.40
100
.17
30
70
.23
N
7.88
200
<5
<.10
5
<.10
N
.61
150
<.10
5
30
7
1 .92
N
Ti X
Th ppm
.150
10.13
.200
9.41
.300
.300
.070
--
.100
--
.150
.300
--
.150
.200
.200
7.00
.300
8.55
.150
.200
13.30
.150
15.28
.500
.200
1 3. 60
.300
.100
.100
.300
.070
--
.150
6.41
.150
--
.300
.500
--
.070
.200
11.03
.200
14.17
.300
.300
.150
.050
.150
--
.150
.200
.300
.200
6.98
.150
2.76
.200
.030
--
.020
--
.070
--
.100
--
.100
6.05
.100
3.16
.070
.100
--
.070
ฆ
.010
--
elements for samples oh surf'iiciial materialscontinued*
U ppm
V ppm
Y ppm
ฅb ppm
In X
Zr ppm
3.87
70
20
2.0
32
150
4.32
150
20
2.0
82
ISO
70
20
5.0
85
300
70
30
5.0
40
300
20
10
1.5
100
20
10
1.5
20
100
1 50
30
3.0
180
70
70
30
5.0
35
300
2.35
30
10
1.5
34
200
1 50
20
3.0
140
70
2.55
30
10
2.0
28
300
3.10
150
20
2.0
97
70
50
30
3.0
60
150
3.24
70
20
3.0
66
150
5.98
100
1 5
1.5
50
70
100
30
--
155
150
4.89
200
20
3.0
110
100
70
20
3.0
60
150
50
30
2.0
250
150
70
20
3.0
100
100
150
30
5.0
100
150
15
N
1.0
15
70
2.74
50
20
3.0
38
200
150
30
3.0
50
200
70
30
5.0
79
300
100
50
5.0
125 '
200
70
15
1.5
70
50
2.74
70
20
3.0
37
500
2.88
70
20
3.0
2*080
150
100
30
3.0
65
150
70
70
7.0
70
300
50
30
3.0
30
200
20
N
1.0
20
30
50
20
2.0
35
100
30
30
3.0
60
300
50
20
3.0
45
150
70
30
3.0
35
200
2.1 2
30
20
3.0
29
300
.95
10
10
1.0
17
300
30
50
3.0
20
300
.47
N
N
N
<5
70
1.68
20
N
N
40
N
N
N
N
70
.62
<7
N
1.0
<5
300
2.47
7
10
1.0
8
200
3.32
30
<10
1.0
14
50
.57
N
N
N
<5
50
7
<10
1.0
35
500
7
20
1.5
500
.33
N
N
N
8
20
-------
Attachment 4
Wilcoxon Rank-Sum Test Calculations
-------
Descriptive Statistics of Arsenic data
SAS Output:
Obs Set n mean std
1 BKGRD 68 12.5912 10.8881
2 INVEST 93 40.1183 32.5366
BKGRD (Diawara) vs. INVEST (ARR) sets 1
09:25 Monday, September 22, 2014
median min max q1 q3
10.3 1.8 66.5 6.2 14.25
33.0 10.0 195.0 24.0 41.00
-------
SAS Output:
2
Monday, September 22, 2014
Expected Std Dev
Wilcoxon - Rank - Sum comparison of Arsenic |ata: BKGgD ^Diawara) u^|grI[^EST
Mean
Score
68
93
2810.0
10231.0
5508.0
7533.0
292.153425
292.153425
41 .323529
110.010753
2810.0000
Set
MJfi8XOn ฎcores (Rank Sums) for Variable As
INVEST
The NPAR 1 WAY Procedure
Classified by Variable Set
Sum of
-9.2332
<.0001
<.0001
<.0001
<.0001
Average scores were used for ties.
85.2829
1
<.0001
Wilcoxon Two - Sample Test
Statistic
Normal Approximation
02:25
One-Sided Pr <
-------
NCSS Output: Two-Sample Test Report
Dataset C: \myf i les\h rs\as_co m pa re .xls
Variable As
9/22/2014 9:44:09 AM 1
Descriptive Statistics
Variable Count Mean
Set=BKGRD 68 12.59118
Set=INVEST 93 40.11828
Standard
Deviation
10.8881
32.53655
Standard
Error
1.320376
3.373883
95.0% LCL
of Mean
9.955695
33.41746
95.0% UCL
of Mean
15.22666
46.8191
Note: T* (Set=BKGRD) = 1.9960, T* (Set=INVEST) = 1.9861
Descriptive Statistics for the Median
95.0% LCL 95.0% UCL
Variable Count Median of Median of Median
Set=BKGRD 68 10.3 7.6 11.4
Set=INVEST 93 33 30 36
Mann-Whitney U or Wilcoxon Rank-Sum Test for Difference in Location
Variable
Set=BKGRD
Set=INVEST
Mann
Whitney U
464
5860
W
Sum Ranks
2810
10231
Mean
of W
5508
7533
Number Sets of Ties = 34, Multiplicity Factor = 996
Std Dev
of W
292.1534
292.1534
Alternative
Hypothesis
Diff < 0
Exact Probability*
Prob Reject HO
Level (a = 0.010)
Approx. Without Correction
Prob Reject HO
Z-Value Level (a = 0.010)
-9.2349 0.000000 Yes
Approx. With Correction
Prob Reject HO
Z-Value Level (a = 0.010)
-9.2332 0.000000 Yes
(Diff = BKGRD median - INVEST median, i.e., testing that Diff<0 is same as testing that BKGRD Median < INVEST Median)
*Exact probabilities are given only when there are no ties and the sample sizes in both groups are < 20.
-------
9/22/2014 9:44:09 AM
NCSS Output: Two-Sample Test Report
Dataset C: \myf i les\h rs\as_co m pa re .xls
Variable As
Plots Section
Histogram
Histogram
As when Set=BKGRD
As when Set=INVEST
Normal Probability Plot of As when Set=BKGRD
Normal Probability Plot of As when Set=INVEST
Percent of Values
Percent of Values
-------
9/22/2014 9:44:09 AM 3
NCSS Output: Two-Sample Test Report
Dataset C: \myf i les\h rs\as_co m pa re .xls
Variable As
-------
Attachment 5
Colorado Smelter Outreach Timeline
-------
Colorado Smelter Outreach Timeline
2007 - EPA and CDPHE reviewed Moussa Diawara Pueblo soils study and the CDPHE Pueblo
Discovery effort and saw the need for more soil sampling in populated areas.
June 2010 - CDPHE requested access from 100 property owners/re si dents to sample residential
yards. CDPHE sampled 47 out of 100 yards where access was requested.
June 2011 - CDPHE sent soil sampling results letters to residents.
October 2011 - EPA/CDPHE met with Pueblo City-County Health Department to share
findings, discuss recent EPA Removal Action at Blende Smelter, and that the Colorado Smelter
site was too large and complex for a Removal Action.
March 15 - 16, 2012 - Meetings with locals, including recognized community leaders and
Sandy Daff, District 4 Representative, about how best to do our outreach.
March 28, 2012 - Presentation to Pueblo Board of Health.
April 30, 2012 - Presentation to Pueblo City Council.
May 17, 2012 - Meeting with Pueblo City Attorney. Separate meeting with about 14
Bessemer/Eilers residents including Representative Daff.
June 1, 2012 - Mailings to 1000 residents living within Vi mile of the Colorado Smelter site
including the Site Fact Sheet, "This is Superfund" Community Guide Booklet, and Frequently
Asked Questions and Answers.
June 11-12, 2012 - Larger Community Meetings at NeighborWorks; two city council
representatives present at each meeting.
June 25, 2012 - Meeting before City Council to discuss the Colorado Smelter contamination and
possible addition to the National Priorities List to get resources for clean up.
August 2012 - Meeting with CDOT about their project area that overlaps the Colorado Smelter
site.
September 2012 - Door-to-door survey of residents in Eilers and Bessemer neighborhoods. We
had 175 respondents to the questionnaire regarding the Superfund listing, risks posed by the site,
and best ways to keep residents informed during the site listing and Superfund process.
November 2012 - Results sent to City Council; Follow up calls made and had brief discussions
with two City Council members who stated they would defer to Sandy Daff on this matter. No
other calls returned from other City Council Members.
-------
January 26, 2013 - Attended Council woman Sandy Daffs Neighborhood meeting to give site
update and let residents know about February Outreach meeting. At this meeting it was stated
that previous blood lead studies showed some elevated blood lead levels in children from the
Eilers/Bessemer neighborhood.
February 21, 2013 - Two public availability sessions: EPA/CDPHE/ATSDR presented on
previous sample data collected, risks of arsenic and lead, the Superfund process, sampling and
cleanup methods in a residential cleanup, and property values and institutional controls at
Superfund sites. The two availability sessions were attended by approximately 80 people.
March-April 2013 - Following Pueblo City Council members visit/meeting to EPA
headquarters in Washington DC, EPA Region 8 staff committed to reviewing the 2010 sampling data
with one to two city council members per their request. To date City Council has not been able to
schedule a meeting with EPA.
April 25, 2013 - Two outreach meetings/availability sessions (afternoon session was a public
meeting and evening session was an availability session): EPA/CDPHE/ATSDR discussed
health effects of arsenic and lead, the benefits and challenges of Superfund, the data collection
process, and how EPA determined that this smelter and neighborhood are part of a NPL-caliber
site. Neighborhood participants in the meetings ranged from supportive to non-supportive of
Superfund; however, those supportive of cleanup were more vocal than in previous outreach
sessions. Of particular concern to some community members is how institutional controls or
deed restrictions might impact their properties. These two meetings were attended by
approximately 35 people. Prior to these meetings, the EPA met with the Pueblo Chieftain
Editorial Board.
June 3, 2013 - CDPHE met with State legislators, city council members, PCCHD and the public
to listen to their local environmental and public health concerns. These meetings resulted in a
commitment by the state to follow up with a larger meeting on July 23, 2013.
July 23, 2013 - EPA, CDPHE, ATSDR, and Pueblo City-County Health met with local residents
and elected officials including Pueblo City Council, Pueblo County Commissioners, and State
Representatives to listen and discuss the Colorado Smelter site data, public health concerns, and
using the Superfund program to address the health risks. EPA reiterated that we have worked
through funding, property values, and community impact concerns at many sites. Also, EPA
discussed that their policy is not to move forward until the community supports the project.
July 31, 2013 - EPA, CDPHE, ATSDR, and Pueblo City-County Health presentation for County
Commissioners MacFadyen and Hart.
August 26, 2013 - EPA staff met with Sierra Club and attended Eilers Neighborhood meeting to
answer residents' questions, get input about how best to conduct outreach, and get residents'
participation in outreach. EPA has committed to developing a fact sheet regarding the Pros and
Cons of Superfund (similar to a poster that has already been developed for community meetings)
for the door-to-door work. The Eilers meeting participants were excited about the pending
ATSDR health study and will likely be able to assist in outreach so that as many people
participate in the study as possible.
-------
August 27, 2013 - Outreach to Rocky Mountain Head Start, Bessemer Academy, Central High
School, Patient Advocate for the area schools' nurses. The team shared our English and Spanish
outreach materials with Bessemer Academy and Rocky Mountain Head Start - these contacts
should be able to help maximize participation in the ATSDR health study.
April - July 2014 - Neutral facilitator funded to assist with Community Advisory Group (CAG
development).
September 9, 2014 - First official CAG meeting held.
-------
Attachment 6
Figure 4 of Mr. Coomes' Comment Submittal
-------
Figure 4. Difference Equals Composite Value Minus Average Value For the
Aliquots
~
~
~
~
~~
~ %
* * % ~
~ ~~
1 X
~
~"~
~ ~ ซ~
~ ~
% ~~
U
~
~
~
~
100
200
300
~
400
500
600
700
Average Lead Concentration
p. r-4
------- |