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HomeMy WebLinkAboutUNDERGROUND TANK ENVIRONMENTAL STRATEGIES CORPORATION 101 Metro Drive · Suite 650 · San Jose, California 95110 · 1'~08) 453-6100 · FAX 1408) 453-0496 MACKE-VEE COMPANY AND MR. PISTON BAKERSFIELD,, CALIFORNIA SUMP CLOSURE PLAN PREPARED BY ENVIRONMENTAL STRATEGIES CORPORATION MARCH 18, 1993 Reston VA · Boxborough, MA · Pittsburgh, PA · Chester, UK · London, UK Contents Introduction Background Scope of Work Waste Characterization Transportation and Disposal Health and Safety Report Submittals List of Figures: Figure 1 - Site Location Figure 2 - Sump Location Figure 3 - Directions to Mercy Hospital List of Appendices: Appendix A - Sampling and analysis plan/quality assurance quality control plan Appendix B - EPA Region 9 guidelines for closure of shallow disposal wells (1992) Appendix C - February 4., 1992 letter to KCDEHS Appendix D - Analytical results Appendix E - Site photographs Appendix F - Site safety plan acknowledgement form Page 1 1 4 6 6 6 I0 2 3 9 -i- Introduction This closure plan has been prepared in response to and in accordance with the Environmental Protection Agency (EPA) Administrative Order Docket No. AO-CA92-01 (Order) section 15, dated September 30, 1992, issued to Macke-Vee Company and Mr. Piston (the Respondents). The site is currently owned by Macke-Vee Company and operated by Mr. Piston Machine and Parts. The closure plan describes the tasks necessary to close a sump located at 4110 Wible Road #D in Bakersfield, California, in accordance with requirements established by the EPA and the Kern County Department of Environmental Health Services (KCDEHS). It includes a description of site conditions, the scope of work to be performed, the characterization of the materials to be removed, a description of the transpom~ttion and waste disposal mechanisms, a health and safety plan, and a list of report submittals. In addition, the sampling procedures and quality assurance and quality control elements are provided in Appendix A. This document has been prepared in accordance with the EPA Region 9 Guidelines for Closure of Shallow i3isposal Wells (1992) and guidance provided by the KCDEHS to Mr. John MacKessy in a letter dated March 9, 1992 (Appendix B). Background On August 16, 1990, the KCDEHS inspected the Mr. Piston facility located at 4110 Wible Road #D in Ba. kersfield, California, and discovered that a sump was being used to contain nm-off waste water from the washing and steam cleaning of engine parts (Figure 1). The sump is located approximately 42 feet north of the Mr. Piston building and is about 8 feet wide, 10 feet long and 2.8 feet deep. The sump is surrounded by a 3-foot concrete apron border within an asphalt parking lot and appears to be unlined with an earthen bottom (Figure 2). The sides and the bottom of the sump are earthen. The sump was fed strictly by overland flow and was not directly connected to any drains, piping, or septic systems. The KCDEHS has classified the sump as a Class V shallow injection well. On October 9, 1991, the KCDEHS sent a violation notice to the respondents requiting them to sample and remove the sludge that had accumulated in the sump. The respondents took samples from the sludge and submitted the results to the KCDEHS in a letter dated February 4, 11992. A sample of the sludge was analyzed for California Analytical Method (CAM) 17 heavy metals, volatile organic compounds (VOCs), total peu'oleum hydrocarbons (TPH) as gasoline and diesel, and oil and grease. Sampling results are presented in Appendix C. The only metal -1- UNITED STATES ENVIRONMENTAL PROTECTION AGENCY RI-'GION IX 75 Hawlhom® Street San Francisco, CA 94105-3901 Hail Code= W-6-2 Terry Gray Kern County Dept. of Environmental Health Services 2700 M Street, Suite 300 Bakersfield, CA 93301 Dear Terry: I am enclosing a copy of the revised Macke-Vee Company/Mr. Piston work plan for your comment. I'd like to get back to the Macke-Vee Company and Environmental Strategies Corporation by April 14, so if you have any comments on the work plan, please call me or send them by April 12. Sincerely, Cynthia Brouwers Environmental Engineer Groundwater Pollution Control Section enclosure Printed on Recycled Paper ESC EN'~rIRONMENTAL STRATEGIES CORP. 101 Metro Ddve Suite 650 San Jose, California 95110 408-453-61 O0 Figure 1 Site Location N Asphalt r 3' Concrete Apron ~x 10' Wide ~ I x2.8'DeepSump Mr. Piston Building 4110 Wible Road, #D Asphalt Scale (ft) 20 I ESC ENVIRONMENTAL STRATEGIES CORPORATION 101 Metro Drive Suite 650 San Jose, California 95110 408-453-61 O0 Figure 2 Sump Location Mackce-Vec Company P,'opcrly Bakersfield, California detected at a concentration exceeding its total threshold limit concentration (TI'LC) of 1000 mg/kg was lead which was measured at 6,830 mg/kg in the sludge. The only VOCs detected, in the sample were those typically found in petroleum products. Such constituents included benzene (5 rog/kg), ethyl benzene (6 mg/kg), toluene (15 mg/kg), and xylenes (57 rog/kg). The concentration of TPH as gasoline was 300 mg/kg and the concentration of TPH as diesel was 1500 mg/kg. The level of oil and grease detected was 41~000 mg/kg. In compliance with the request of the KCDEHS in October 1991, the Respondents immediately ceased all activities associated with the steam cleaning of engine parts and are not allowing any fluids in to the sump through the placement of a temporary cover (Appendix E). In September 1992, the EPA assumed responsibility as the lead agency for the site and issued an administrative order to the Respondents. The EPA made a determination that there is a potential for the contaminants to migrate into underground sources of drinking water and that the elevated concentrations of these contaminants in the drinking water could be hazardous to human health. The EPA has ordered the Respondents to cease all operations associated with the sump and submit a workplan for its closure. After the workplan has been approved by the EPA, the Respondents must implement the plan and submit a £mal report within 60 days of the date of approval. Scope of Work This scope of work describes in detail the events that will take place during the closure of the sump. The EPA, the Department of Toxic Substances Control (DTSC), and KCDEHS will be contacted at least seven days in advance of any site operations relating to closure activities. The sump will be closed in accordance with the terms of the order from EPA Region 9 and KCDEHS guidelines. Closure will consist of excavating the sludge that remains in the sump and any contaminated soil and properly di~sposing of them. The concrete apron and any concrete sidewalls will also be removed and properly disposed of. The sludge is estimated to be 1.6 feet deep and. approximately 8 feet by 10 feet in surface area. Before excavating the sludge, all underground utilities will be identified. The 2.5-inch diameter metal pipes forming a grate covering the sump will be removed to gain access. The sludge will be removed with a backhoe and the excavation will proceed until the walls consist of visibly clean soil. It is estimated that approximately 6 to 10 cubic yards of sludge and soil will need to be removed. The concrete apron and sidewalls will then be removed. The concrete will be broken up using a pneumatic drill. If the concrete is not reinforced, it may be possible to remove it using a backhoe. The sludge will be placed in a properly lined bin and labeled with the collection date and site location. The concrete will be placed on and covered with 20-mil polyethylene sheeting. The wastes will be properly characterized and disposed of (see below). Verification samples will be collected below the; middle of the sump at depths of 0.5, 2.0, 4.0, and 6.0 feet. If the soil is visibly contaminated at the 6 foot depth, additional samples will be taken every 5 feet to a depth 5 feet below the last suspected contamination. The samples will be analyzed by a state certified laboratory for CAM-17 met,ds, VOCs in accordance with EPA method 8240 or EPA 8010/8020, and TPH as diesel. Samples will be collected in accordance with the sampling and analysis plan presented in Appendix A. The samples will provide the technical and analytical data necessary to determine whether contaminants have migrated beyond the excavation limits. The excavation pit will be secured and covered while the samples are being analyzed. During inspections of the site, KCDEHS and DTSC personnel noted that Mr. Piston employees were washing equipment at a washrack located at the rear of the building. Reportedly, the washwater flowed over the ground to the sump. To determine whether there is any residual contamination associated with the drainage route, soil samples will be collected along the drainage route at a depth of 3 to 6 inches below the ground surface. Approximately 3 samples will be collected based on a sample spacing of 10 feet between locations. The frrst sample will be collected at the washrack. The samples will be analyted for CAM-17 metals and TPH as diesel. No samples will be analyzed for VOCs due to the likely volatilization of the constituents at the ground surface. Verification sampling results and results from the drainage route will be' provided to EPA who, with the assistance of the DTSC and the KCDEHS, will evaluate the analytical results and determine if further action is necessary. If the results confirm that no further remediation is necessary, (i.e., all verification samples are less that cleanup standards) the sump will be backfilled and compacted with clean material. An asphalt cap will be placed directly above the compacted fill material returning the site to its original grade. If the results indicate that there is residual contamination, then further excavation and verification sampling may occur. The extent of possible further excavation will be based on the verification sampling results. If the sump requires extensive excavation or additional remedi,'d action appears to be required, then the excavated pit will be covered with temporary trench plates and an impermeable liner, the remedial options will be evaluated, and a new work plan will be prepared. Waste Characterization Composite samples will be collected from the 55-gallon drams of sludge and from the concrete apron and analyzed to determine the appropriate method for disposed of the waste material. The materials will be analyzed for the ch,'u'acteristics of ha?ardous waste under the Resource Conservation and Recovery Act (RCRA), as specified in 40 C.F.R. Part 261 Appendix II and the EPA order. The; analytical results will be submitted to the EPA. Transportation and Disposal Following waste characterization, the materials will be disposed of at an appropriate California certified disposal facility. The bin containing the sludge will be properly lined, labeled, and manifested. The wastes will be transported in accordance with all appropriate U.S. DOT regulations. No waste materials will be allowed to leave the site until the load is secured, covered, and proper shipping papers have been completed and provided to the drivers. Health and Safety An exclusion zone will be established in the immediate area of excavation and marked by bamer tape. The zone can be adjusted ,as necessary. A Site Safety Officer (SSO) will be responsible for informing all individuals entering the exclusion zone of the contents of this plan ,and for ensuring that each person signs the Safety Plan Acknowledgment Form (Appendix F). By signing the Safety Plan Acknowledgement Form, individuals are acknowledging that they have been informed of the presence of specific hazards on-site and the policies and procedures required to minimize exposure to potential adverse effects of site hazards. All personnel entering the exclusion zone must have completed training requirements for ha?ardous waste site work in accordance with Occupational Safety and Health Administration (OSHA) requirements at 29 CFR 1910.120. The SSO will conduct a site safety kick-off meeting to address the site conditions. All personnel entering the exclusion zone must have completed appropriate medical monitoring requirements required under 29 CFR 1910.120(f). Previous sampling and analytical data have indicated that the constituents of concern at the site include lead and benzene, chemical hazards associated with these constituents are presented below: 1. Lead (inorganic). · The OSHA time weighted average (TWA) is 0.05 mg/m3 for air exposure in a 8-hour work day for a 40 hour work week · The immediate dangerous to life and health, (IDLH) level is 700 mg/m3 through inhalation · The route of exposure could be through inhalation or ingestion 2. Benzene · The NIOSH TWA (10-hour work day) is 0.1 ppm · The IDLH is 3,000 ppm through inhalation · The route of exposure could be flu'ough inhalation or ingestion Because of the potential hazards at the site due to the presence of organic vapors, the air will be sampled regularly with a photoionization detector (PID) to determine if organic vapor levels rise above background. Level D personal protective equipment (PPE) will initially be used at the site. This will be upgraded to level C PPE if the level of VOCs measured exceeds background by 50 pans per million (ppm) at any time or by 5 ppm for 15 minutes. Upgrade to level C will ,'dso occur if the SSO believes that the work functions present the opportunity for splashes, immersion in, inhalmion of, or contact with hazardous concentrations of chemicals. Level D PPE will consist of: · Chemical-resistant coveralls or standm-d work uniforms, as needed, · Steel-toe s~ffety boots. · Gloves as needed. · Safety glasses as needed. · Hard hat. Level C PPE will consist of the above plus: · Chemical-resistant coveralls (uncoated, e.g., Tyvek) · Disposable, chemical-resistant gloves · Air purifying respirator with organic/high-efficiency particulate air-purifying cartridges A confined space is defined as a space or work area not designated or intended for normal human occupancy, having limited means of access and poor ventilation, or any structure, including buildings or rooms, which have limited means of egress. There are no confined space entries anticipa~:l for this site. Site personnel will be prepared for an emergency. The following is a list of emergency contacts and directions to the hospital from the site. - 7 - Fire: 911 Police: 911 Ambulance: 911 Hospital: Mercy Hospital Address: 2215 Tmxtun Avenue, Bakersfield, CA Telephone: (209) 632-5000 Directions from site to hospital: Go north on Wi,ble Road and continue to go north as Wible Road becomes Oak Street. Turn right on Truxtun Avenue and go 5 blocks down and the hospital will be on the left side of the street (Figure 3). -8- :1 ESC ENVIRONMENTAL STRATEGIES CORP., 101 Metro Drive Suite 650 San Jose, California 95110 408-453-61 O0 Figure 3 Directions to Mercy Hospital Bakersfield, California C:CAl172 Report Submittals On completion of the closure activities, a report will be submitted to the EPA. The report will include: · a plot plan showing the locations of sampling points, buildings, and adjacent streets · copies of all sludge, soil, and quality control sampling results · copies of manifests or other documentation pertaining to proper disposal of all removed sludge and soil · a description of the extent of any contamination that may require further investigation or remediation · if such investigation or remediation appears necessary, recommendations to address the problem from a registered geologist or professional engineer, with sufficient experience in soils and groundwater Ali repons submitted to EPA that relate to the closure activities, will include the certification given in "Requirements for Contractors." Verification Sampling Samples will be collected to verify that remediation is complete. Verification soil samples will be collected within the sump using a stainless steel drive shoe sampler containing brass or stainless steel tubes. The sampler will be advanced using a 2.5-inch stainless steel hand held auger to 0.5, 2.0, 4.0, and 6.0 feet below the sump bottom. If the soil is visibly contaminated at the 6 foot depth, additional samples will be taken every 5 feet to a depth of 5 feet below the last suspected contamination. A hand held auger will be used to attain the required depth and a drive sampler will be driven into the desired location. The samples collected in the tubes will be capped on both ends with plastic caps ,and aluminum foil or Teflon, and the caps will be taped to the tube to minimize moisture loss. Each s~unple tube will be completely filled and undisturbed to minimize volatilization. The verification samples will be analyzed using EPA methods 8240 or 8010/8020 for VOCs CAM-17 for metals, and EPA method 5030/8020 for total extractable petroleum hydrocarbons. A state-certified laboratory will be used and the results provided based on a 24-hour turnaround time. Drainage Pathway Sampling Samples will be collected along a drainageway from the washrack to the sump identified by KCDEHS and DTSC to determine the potential for contamination. Samples will be collected using a decontaminated stainless steel trowel at a depth 3 to 6 inches below ground surface. The samples will be transferred to sample bottles. The s,'unples will be analyted using CAM-17 for metals and EPA method 5030/8020 for total extractable petroleum hydroc~bons. Waste Characterization Sampling The samples of sludge and concrete will be collected in 1-quart jars with teflon lined septa provided by the disposal facility. The jars will be filled using a hand troveel. The sample(s) will be analyzed for RCRA hazardous waste characteristics, Sample Handling/Chain-of-Custody Procedures Each sample container will be labeled and appropriate chain-of-custody and sample identification forms completed. The samples will be placed in a cooler with ice. The samples will be accompanied by a chain-of-custody form. When transferring samples, the individuals relinquishing and receiving the samples will sign, date and note the time on the chain-of-custody form. Samples will be packaged properly for shipment and dispatched to the appropriate California State Certified laboratory for analysis. The laboratory will maintain the samples in a cooler at 4° C. The sample custodian at the laboratory will re~:eive and assume custody of the samples. The sample custodian will verify that all samples are present, they an', in good condition, they are accompanied by a chain-of- custody form, the sample identification is complete and corresponds to the chain-of-custody form, and that the temperature of the shipping container is appropriate. Quality Assurance/Quality Control To assure the quality of the sampling results a trip blank, a replicate sample, and a matrix spike/matrix spike duplicate (MS/MSD) sample will be analyzed. The trip blank is a sample prepared by the laboratory that is transferred with the field samples to ensure no contamination is introduced in transportation or handling. A replicate sample is used to determine consistency in both sampling procedures and analytical methods. In the MS/MSD analysis, predetermined quantities of stock solutions of certain analytes are added to a sample matrix before sample extraction, digestion, and analysis. Samples are split into duphcates, spiked, and analyzed. Percent recoveries are calculated for each of the analytes detected and used to atgsess analytical accuracy. The relative percent difference between the duplicate samples is calculated and used to assess analytical precision. Decontamination Procedures All sampling equipment that comes in contact with potentially contaminated soil will be decontaminated before and after use. In addition, all soil sampling tubes will be cleaned before use. Sampling equipment will be decontaminated by washing with Alconox or tri-sodium phosphate, rinsing with tap water, and rinsing with analyte- free water. All decontamination water will be chummed with the sludge and disposed of in the same manner. While collecting soil samples, the sampler will wear rubber surgical gloves. The gloves will be replaced with new ones for every sample taken to minimize cross contamination. Appendix 3 EPA - REGION 9 GU]DEL~S FOR CLOSURE O'F SHALLOW DISPOSAL WELLS ¢ ,,, .:: . 1992 TABLE OF C',OIVI'ENTS LIST OF FIGURF. S ................................................. 2 LIST OF TABI.F-S .................................................. 2 I. INTRODUCYION ............................................... 3 II. REQUIREMENTS FOR CONTRA~ORS ............................ 5 LABORATORY SE~ .ECrlON ....................................... 6 IV. CLASS IV AND V W~I I. CLOSURE GUIDEI.INF. S ................... 7 SAMPLING METHODS AND PROCEDURES ....................... 19 A. Sampling Equipment ........................................ 19 B. Equipment Decontamination ................................. 20 C. Quality Assurance/Quality Control .............................. 20 1. Trip Blanks ......................................... 20 2. Equipment Blanks .................................... 21 3. Replicate Samples .................................... 21 4. Split Samples ........................................ 21 5. Spiked Sample~ ...................................... 21 6. Field Blanks ................... · ...................... 21 D. Sample Analysis ...................................... ' ....22 E. Sample Collection - L/quid ................................... 23 1. Volatile Organics ..................................... 23 2. Semi-Volatile Organics ................................. 23 3. Metals ............................................. 24 4. Total Petroleum Hydrocarbons (TPH) ..................... 24 5. Total Recoverable Petroleum Hydrocarbons (TRPH) .......... 24 F. Sample Collection - Sediment ................................. 24 G. Sample Collection - Soil ..................................... 25 H. Common Sampling Errors ................................... 28 I. Chain of Custody ........................................... 28 REFERENCF_~ ................................................... 31 1 1 I I ! I I I I I i I I I LIST OF FIGURF_,S Figure A-l: .Soil Sample Locations for a Septic System Receiving Both Industrial and Sanitary Wastes - Plan View .................... 11 Figure A-2: Soil Sample Locations for a Septic System Receiving Both Industrial and Sanitary Wastes - Side View .................... 12 Figure B-l: Soil Sample Locations for a Septic System Receiving Only Industrial Wastes - Plan View .............................. 13 Figure B-2: Soft Sample Locations for a Septic System Receiving Only Industrial Wastes - Side View .............................. 14 Figure C-1: Drywell, Cesspool, or Drainage Well Receiving Both Industrial and Sanitary Wastes. or Only Industrial Wastes - Plan View ................................................. 15 Figure C-2: Drywell, Cesspool, or Drainage Well Receiving Both Industrial and Sanitary Wastes or Only Industrial Wastes - Side View ................................................. 16 Figure D-l: Leachfield/infiltration Gallery Receiving Both Industrial and Sanitary Wastes or Only Industrial Wastes - Plan View ........... 17 Figure D-2: Leachfield/Infiltration Gallery Receiving Both Industrial and Sanitary Wastes or Only Industrial Wastes - Side View ........... 18 Figure E - Chain-of-Custody Form ................................ 30 LIST OF TABI Table I - Sampling Methods ..................................... 26 Table II - TCLP Sampling Methods ................................ 27 I. INTRODUCTION The Safe Drinldng Water Act (SDWA) of 1974, as mended, requires the U. $. Environmental Protection Agency (U.S. EPA) to establish a program which provides for the safety of the nation's dr/nking water. The Underground Injection Control (UIC) program was established under the SDWA to prevent conf_~m[n~l~on of underground sources of drinking water from improper use of disposal wells. UndergroUnd sources of drinking water 'vary in depth and quality from pristine aquifers a few feet beneath the ground surface to aquifers that are thousands of feet deep containing up to 10,000 parts per million of dissolved solids, usually in the form of salts. Over 50% of the U.S. population relies on these aquifers for drinking water, and the percentage is increasing every year. Disposal wells covered by the UIC program include bored, driven or drilled shafts or dug holes whose depth is greater than the largest surface dimension, where the principal function of the shaft or hole is the emplacement of fluids. Under certain conditions, sumps, septic tanks, cesspools and drainfields may also be considered disposal wells. For the purposes of the UIC program, a fluid is any material or substance which flows or moves, whether in a semisolid, liquid, sludge, gas or any other form or state. Contaminants introduced into underground sources of drinking water through the use of disposal wells include bacteria and viruses, minerals and nitrates, heavy metals, organic chemicals and pesticides. Most types of disposal wells are subject to construction, performance and monitoring requirements designed to ensure that no contamination of underground sources of drinking water occurs through their use. Wells that discharge fluids into or above an underground source of drinking water are' generally classified as shallow disposal wells and are not always subject to these requirements. The disposal of hazardous fluids into shallow wells (Class IV wells) is prohibited under the SDWA. However, many shallow wells (CIass V) accept fluids that are not deemed as hazardous, but still have a potential to contaminate underground sources of drinking water. EPA Region 9 is requesting closure of such wells. This guidance is designed to aid in the proper closure of shallow disposal wells. In addition to providing guidelines for the closure of these wells, general information is included concerning sampling equipment, methods and procedures for collecting liquid, sediment and soil samples; required methods of sample analysis; contractor and laboratory requirements; and sample chain of custody requirements. 3 It is important'tO note that this g~_!dance is designed to aid in the c~sure of well& The owner or operator of a,facility is ultimately iresponsible for proper closure of the wells. and is also responsible for complying with other federal regulations such as t~CRA and CEtlCIM, and with state and local regulations. The owner or operator must etma~ that facility practl'ces do not contribute to the contamination of ground water. II. REQIJIREMENTS FOR CONTRACTORS Activities invOlving site assessment and well closure require a professional level of expertise. In addition' to knowledge regarding the correct procedures and methods used in collecting samples, some investigations may require a knowledge of the mechanisms of contaminant transport; federal, state and loc~d regulations and ordinances relating to waste management; and actions needed to remediate a contaminated site. To ensure that the contractor has the qualifications - through a combination of education and experience - to perform sampling and site assessment requirements, EPA Region 9 requires that: 1. The contractor submit an acceptable sampling plan which addresses: types of sampling containers and their preparation sample preservation methods sampling equipment and method of sample retrieval familiarity with specified sampling methods quality assurance/quality control measures certified lab to which samples will be sent chain of custody o The individual signing any report related to a workplan for closure of a well or a sampling plan must be a registered geologist or professional engineer registered w/th the state. This individual shall be responsible for the content, validity and completeness of the report. All reports related to well closure activities shall include the following certification: I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, I certify that the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and im£risonment for knowing violations. 1 .! III. LABORATOIRY SELECTION Either state-certified laboratories or those associated with EPA's Contract Lab Program must be used for sample analyses. If the distance to the nearest laboratory is such that hand-delivery is not possible, samplt~s should be express/overnight delivered. All laboratories involved in the analysis of smr~ples must retain their calibration logs for two years, laboratory data logs for three year.% and sampling labels or information from the labels for three years. All analytical tests must be performed in accordance with methods acceptable under quality assurance i,~idelines. A qu~ty ass~mm:e-,-t~tan must be submitted with the s~ For more information regarding laboratory selection, see the reference section of this do,mment. IV. CLASS IV AND V WELL CLOSURE GUIDELINES When any Class IV or Class V well threatens to violate a primary drinking water regulation or otherwise causes conditions that may adversely affect public health, EPA Region 9, upon learning of such violation or conditions, will require closure of the well. Closure must then be accomplished in such a manner as to ensure that no movement of fluid containing any contaminant will move into underground sources of drinking water (USDWs). As an element of proper well closure, Region 9 may require cleanup of soil and/or groundwater in and around the Class IV or V well. To meet EPA requirements, well closure should, at a minimum, include the dements of the following guidelines: 1. Provide an acceptable alternative to well discharge for disposal of waste fluids. The alternative must comply with all regulations such that no violation or future violation of primary drinking water standards will result. EPA requests the use of management practices that reduce the amount of contaminants released into the environment through product changes, improved ope,?ating practices, reuse of materials, onsite closed-loop recycling, on and off-site reclamation, and water conservation. 2. Identify the locations of all drains, drain lines, drywells, and cesspools or septic systems at the facility. 3. Contact EPA at least seven (7) days in advance of any site operations relating to closure activities. 4. Take representative samples from the liquid and/or sludge phase present in the drain(s) and the well(s) or septic tank(s) in accordance with the procedures described in '$arnpling Methods and Pm,',~dures~ under "Sample Collection~. Have the samples analyzed for volatile org_amcs, metals, total petroleum hyrlrocarbo~ and oil and grease in accordance w~th me methocls descn~>ed unoer "~'/ample Anaiys;s" and, when necessary, prepared in accordance with the methods for the Toxicity Characteristic Leaching Procedure (TCLP) in 40 C.F.R. Part 261 Appendix I1 as amended June 29, 1990. Copies of sampling and analysis results, and results of all quality control samples, must be submitted to EPA. 5. Remove the contents from the drains and drain lines and the well(s) or septic tank(s) and determine appropriate disposal methods based on the results of the sample analyses. The owner/operator is ultimately responsible for proper disposal of all wastes, and should carefully review all arrangements for disposal to ensure compliance with federal, state and local regulatory requirements. 6. Disconnect the drain llne~ from the well, pressure wash the drains and line,~/ill them with-grout'or cement, and permanently seal them All waste associated with- ' cleaning the drains and lines should be disposed of in accordance with fedcral, statc, and local regulations. 7. Observe the following closure requirements for septic tanks and wells: Septic system accepting industrial and sanitary wastewater into a common septic tank and drainfield or leachfielcl. The septic tank should have the contents removed and disposed of appropriately. If a visual impection of the tank indicates cracl~ or leaks, thc tank and any visibly or potentially contaminated soil in the vicinity should be removed and disposed of appropriately. Soil samples should be taken below the bottom of the tank excavation in the manner described in "Sampling Methods and Procedures* under "Sample Collection" and analyzed by a certified analytical laboratory. If the tank does not have any cracks or leaks, soil samples may be taken at either end of the tank at a depth that is at least as deep as the bottom of the tank. The tank may then be used for sanitary waste only, and the drain pipes leading from the restrooms need not be disconnected. Soil samples must also be taken along every twenty feet of drainfield or leachtield and sent to a certified laboratory for analysis. It is recommended that soil .samples be taken at other locations where there is a potential for a high degree of contamination (worst-case locatiom) such as elbows and joints in pipe lines, floor drains and clarifiers. All soil samples should be analyzed according to the methods in "Sampling Methods and Procedures" under "Sample Analysis". In addition, at least two soil samples, taken at the worst-case location around either the tank or drainfield, must be both analyzed for total concentrations arm prepared in accordance with the methods for the Toxicity Characteristic Leaching Procex~e (TCLP) in 40 CF.R. Part 261 ~4ppendir II as a~mdexl June 29, 1990. See Figures A-1 and A-2 for required and recommended soil sample locations. Case B: Septic system accepting only industrial wastewater into a septic tank and drainfield or leachfield. The septic tank and the contents should be removed and disposed of appropriately. Any visibly or potentially contaminated soft in the vicinity of the tank should be removed and disposed of appropriately. Soft samples should be taken below the bottom of the ~nk excavation in the manner described in ~Sampling Methods and Procedures~ under ~Sample Collection~ and analyzed by a certified analytical laboratory. Soft samples must also be taken along every twenty feet of drai~eld or leachfield. It is recommended that soft samples be taken at other suspected worst-case locations such as elbows and joints in pipe lines, floor drains and clarifiers. All soft samples should be analyzed according to the methods in "Sampling Methods and Procedures~. In addition, at least two soil samples, taken at the worst-cxtse location arourut either the tank or drainfield, must be both analyzed for total concentrations and prepared in ac. coMan~ with the meth~ for the 8 ~ble fill mte~ See H~ ~1 ~d ~2 for r~,d ~d r~mmendod.sofl sample l~fio~ ". Drywells, cesspools or drainage wells accepting industrial and sanitary wastewaters, or only industrial wastewaters. The contents of the drywell, cesspool or drai,age well (identified hereafter as "well") should bc removed and disposed of appropria,tel~y._~It is required that thc well casing be removcd if it is practicable. Any visibly~r pot'~n~i~ly~nmminated soft underlying thc contents of the well should be removed.~ofl samples should be taken in the center of thc bottom of thc well in thc manner des'cribed, in-"Sampling Methods and Procedures" under "Sample Collection" and analyzed by a certified analytical laboratory. If taking samples fi.om the bottom of the well is not feasible, samples should be taken on opposite sides of the well, at a distance not to exceed ~ne foot away from the borehole, and starting at a depth that is equivalent to the d¢.pth of the bottom of the well. It is recommended that soil samples be taken at other suspected worst-case locations such as elbows and joints in pipe lines, floor drains m~d clarifiers. All soil samples should be analyzed according to the methods in "Sampling Methods and Procedures". In addition, at ~ two ~oil .rumple. z, taken at the worart-ca~'~ location, .must be both tmalyzed for total co--ns and prepared in accontan~ witii the methixts for the Taxidty Charact~ ~ Proced,_~e (TCLP) in 40 C. ER. Part 261 Aj~pmdir II as amended June 29, 1990. The remaining hole where the well has been removed should then be filled with grout and sealed with asphalt or cement. See Figures C-1 and C-2 for required and recommended soil sample locations. Case D: Leachfield/infiltration gallery ~Lccepting sanitary and industrial wastewaters, or only industrial wastewaters. The practice of disposing sanitary and/or industrial wastewaters directly to a leachfield/filtration gallery without the use of a septic tank is unacceptable. The leachfield should be excavated, and ali visibly or potentially contaminated soils removed and disposed of appropriately. Soil samples :must be taken along every twenty feet of. drainfield or leachfield in the manner described in "Sampling Methods and Procedures under "Sample Collection" and sent to a certified laboratory for analysis. It is recommended that soil samples be taken at other suspected worst-case locations such as elbows and joints in pipe lines, floor drains and clarifiers. All soil samples should be analyzed according to the methods in "Sampling Methods and Procedures". In addition, ramt be both analyzed for total concentrations and prepared in acco~ with the method~ for the ToaSty Charact t. eaO oceaure ffcrP) in 40 CPa Part 261 H as amended June 29, 1990. The area should be regraded using clean fill. See Figures D-1 and D-2 for required and recommended soil sample locations. 8. Contact state and local agencies and incorporate their requirements into the well closure plans. 9. Submit a report, upon completion of well closure activities, that includes the following items: A plot plan showing locations of disposal or drainage well(s), sampling points, buildings and adjacent streets. Indicate the north direction by an arrow. Copies of all fluid, sludge and soil sample analysis results, and results of ail quality control samples. Copies of manifests or other documentation pertaining to proper disposal of all removed liquid, sludge and soil. A description of the extent of site, contamination. Should site remediation appear necessary, recommendations fi-om a registered geologist or professional engineer, with sufficient experience in soils, should be included to address the problem. 10. Include, on all repons submitted to EPA that relate to well closure activities, the certification given in "Requirements for Contr~ctors~. These guidelines do not constitute a remediation plan. It is the responsibility of the owner or operator to ensure that further site eva&ation be conducted if analytical results of the soil samples indicate the presence of contamination. All submittals are to be sent to: Groundwater Pollution Control Section U.S. Environmental Protection Agency 75 Hawthorne Street, W4-2 San Francisco, CA 94105 Contact: (41,5) 744-1832 Case A: Soil Sample Locations for a Septic System Rec .eiving Both Industrial and Sanitary Wastes : XYZ Industries · Required Sampling Location O Recommended ~ampllng Location * Additional samples, shouEI be taken every 5' until 5' belOW'the last auspected contamlnatloft. -L0 .LO · ~'* Xb, Dralnfleld Septic Tank I I sample every 20' Figure A-2: Side View Note: The soil sample locations shown above meet the minimum requirements of the EPA UlC Program. However, the owner and/or operator of the well Is also responsible for meeting the requirements of all other applicable federal, state~ and local laws, and for adequately assessing the extent of any soil or ground water contamination. 1") Case B: Soil Sample Locations for a Septic System Receiving Only Industrial Wastes XYZ Industries Drains Iol sam ,pie eve~ 20' Septic Tank Drainfleld · Required Sampling Location 'O Recommended Sampling Location Figure B,I: Plan View Note: The soil sample locations shown above meet the minimum requirements of the EPA UIC 'Program. However, the'owner and/or operator of the well Is also responsible for meeting the requirements of all other applicable federal, state, and local laws, and for adequately assessing the extent of any soil or ground water contamination. 13 Case B: Soil Sample Locations for a Septic System Receiving Only Industrial Wastes ,~ XYZ Industries · Required Sampling I.c~.atlor~ O Recommonde,d, Sampl!pg Location * Additional sampl.es eh~uld be taken every 5' until 5' below the last suspected contamination. Septic Tank o ..to "'1o ' 1o Dralnfleld sample every 20' Figure B-2: Side View Note: The soil sample locations shown above meet the minimum requirements of the EPA UIC Program. However, the owner and/or operator of the well Is also responslble for meeting the requirements of all other applicable federal, state, and local laws, and for adequately asaesslng the extent of any soil or ground water contamlnatlon. 14 Case C: Drywell, Cesspool, or Drainage Well Receiving Both Industrial and Sanitary Wastes or Only Industrial Wastes XYZ Industries Drains I'"1 Rest Rooms Drywell, Cesspool; or Drainage Well · Required Sampling Location A Alternate Required Sampling Locations o Recommended Sampling Location Figure C-1: Plan View Note: The soil sample locations 8hown above meet the minimum requirements of the EPA UIC'Program. However, the Owner and/or operator of the well Is also responsible for meeting the requirements of all other applicable federal~ state~ and local laws, and for adequately assessing the extent of any soil or ground water contamination. 15 Case C: Drywell, Cesspool, or Drainage Well Receiving Both Industrial and Sanitary Wastes or Only Industrial Wastes XYZ Industries · Required Sampling Location i Altemate Requ, lred Sampling Locations O Recommended S.ampllrtg Location * Additional samples should be taken every 5' until $' below the last suspected contamination. "'1o "'1o Figure C-2: Side View Note: The soil sample locations shown above meet the minimum requirements of the EPA UIC Program. However, the owner and/or operator of the well Is also responsible for meeting the requirements of all other applicable federal, state, and local laws, and for adequately assessing the extent of any soil or ground water contamination. 16 Case D: Leachfield/Infiltration Gallery Receiving Both Industrial and Sanitary Wastes or Only Industrial Wastes Drains XYZ Industries ;0 Ro~t Rooms ................. sample every 20' Leachfleld/ Infiltration Gallery · Required Sampling Location 0 Recommended Sampling Location Figure D-l: Plan' View Note: The soil sample locations shown above meet the minimum requirements of the EPA UlC'Program. However, the Owner and/or operator of the wall ts also responsible for meeting the requirements ofall other applicable federal, state, and local laws, and for adequately assessing the extent of any soil or ground water contamination. 17 Case D: Leachfield/Infiltration Gallery Receiving' Both Industrial and Sanitary Wastes or Only Industrial Wastes XYZ Industries · Required Sampling Location O Recommended. Sampll .rig Location * Additional samples should be taken every 5' until 5' below the last suspected contamination. Leachfleld/Inflltration Gallery '"":F; ............. .... ; ................................... ::::::::::::::::::::::::::::::::::::::: *"/ eT -re ~"1o ~o /~'' "'l sample every 20' Figure D-2: Side View Note: The sob sample locations shown above meet the minimum requirements of the EPA UIC Program. However, the owner and/or operator of the well Is also responsible for meeting the requirements of all other applicable federal, state, and local laws, and for adequately assessing the extent of any soil or ground water contamination. V. SAMPLING METHODS AND PROCEDURES A. Samoline E~uioment Various types of equipment may be used to collect grab samples from shallow well systems. Typical sampling equipment includes pond samplers, weighted bottles, and bailers. The equipment is usually made of stainless steel, glass or Teflon. Other equipment may be used when the situation warrants. The pond sampler is used when the system is easily accessible and when the sampling point is deeper than arm's length. This sampling device consists of a telescoping aluminum rod to which a stainless steel or nalgene beaker is attached using an adjustable stainless steel C-clamp. The size of the beaker is determined by the volume and number of samples to be collected. Weighted bottles or similar devices may be utilized to sample fluid at a depth below an oil/water interface. Such devices must be lowered below the floating product phase before opening. Fluid from below the interface may then be retrieved. The bailer is useful for sampling from small diameter wells, septic tanks, and other areas where openings are too small to permit use of the pond sampler. A bailer is lowered into the fluid with a rope and retrieved with a sample of the fluid. Often sediment samples from the bottom of a sump are collected using a beaker attached to a pond sampler. A stainless steel lab scoop is generally used to transfer the sediment from the beaker to the required container. Trowels and drive samplers are also used to collect samples. In addition to the sampling equipment typically used to obtain samples, nalgene bottles for liquid sample transfer; certified organic-free, metal-free water for quality assurance blank samples; and instruments for measurement of fluid pH and temperature are used. It is important to avoid using equipme, nt or containers that may alter the sample through the introduction of foreign matter. Contaminated sampling equipment can result in leaching or particulate fallout, volatilization or adsorption of the sample. B. Equipment Decontamination All sampling equipment must be deconlzminated before and after each sampling event. All quality control equipment blank saznple~ must.be obtained after'equipment has been thoroughly decontsminated, prior to .collecting fluid, sediment or soil samples. Decontamination procedures should be as follows: 2. 3. 4. 5. 6. 7. Disassemble equipment Wash with non-phosphate detergent (alconox) and tap water Rinse with tap water Rime with isopropyl alcohol (use a squirt bottle) Triple rinse with deionized or distilled water Rinse with acid Rinse with certified organic free,, metal-free water 1 J J J J I .1 1 1 C. Quality Assurance/Quality Control Quality assurance (QA) is the process of assuring that data obtained are technically sound and properly documented. Quality control (QC) procedures are employed to measure the degree to which quality assurance objectives are met. The laboratory is not informed of the existence of field QC samples. This document is intended to prov/de guidelines on some of the minimum requirements necessary to ensure the quality of the data produced during sampling/analysis activities. The regulated facilities are responsible for the quality of the data produced, and are expected to provide data of known, documented, and verifiable quality. Following is a list of some of the qualil~ control samples which can be employed. In general, at least one replicate sample, and one type of blank must be obtained for every ten field samples. If there are less than ten field sampling points, at least one replicate sample and one type of blank must be obtained. 1. Trip Blanks: Trip blanks are used to detect contamination or cross-contamination which may have occurred during sample handling and tr~msportation- These blanks must be prepared prior to the sampling effort and will accompany sample containers used during sampling and in the transport cooler. The trip blanks consist of certified metal-free, organic-free water and will be analyzed by a certified laboratory at the time the other samples are analyzed. 2O 2. Equipment Blarflcs: Quality control (QC) equipment blanl~; are used'to assess the caliber of field decontamination procedures. After the sampling equipment has undergone decontamination procedures, certified metal-free, organic-free water is poured into the sampling equipment and from there into sampling containers. These containers are preserved, documented and analyzed in exactly the same manner as those containers holding samples of waste fluid. ,3. Replicate Samples: Replicate sampling is used to determine consistency in both sampling procedures. and analytical methods. In general, replicate samples must be obtained at one out of every ten sampling points, and at least one replicate sample must be obtained if there are less than ten sampling points. To collect 'these samples, fluid is obtained from a sampling point and split between two identical containers. Both containers undergo the same method of analysis at the laboratory. In addition, split samples, spiked samples and field blanks are used for QA/QC purposes. These can be briefly described as follows: '~ 4. Split Samples: A split sample is divided into two containers for analysis by separate laboratories. The purpose of this type of sample is to independently confn'm laboratory results. 5. Spiked Samples: A spiked sample is produced by adding a known quantity of analyte(s) of interest to the sample. Spiked samples are used to check the accuracy of analytical procedurea. 6. Field Blanks: This sample consists of certified metal..free, organic-free water to which the same quantity of preservative is added as is added to the field samples. These samples provide a check on any contamination of chemical preservatives. i 1 i '1 i I ! ! ! ! ! ! ! D. Samvle Analysis Region 9 requires that all samples asSodated wi~h well closure activities be analyzed for the compOunds listed below us/nE the indicated methods. Analysis for semi- volatile organic compounds i~ only necessary when SUch compounds are suspected of being in the waste stream. Volatile Organics: EPA MethOq 8240 (Volatile Organics); EPA Method 8260 (Volatile Organ/cs by Capillary Column); or a comb/nation of EPA Methods 8010 (Halo§enated Volatile Organics), 8015 (Nonhalogenated Volatile Organics) and 8020 (Aromatic Volatile Organics). Semi-Volatile Organics: EPA Method 8270 (Semi-volatile Org .anics) is recommended when the presence of semi-volatile organics is suspected in the waste stream. Metals: Appropriate EPA Methods for all metals on the Toxicity Characteristics (TC) list (arsenic, barium, cadre/urn, chromium, lead, mercury, selenium, and silver). Total Petroleum Hydrocarbons (TPH): EPA Methods 5030/8015 and 5030/8020 to analyze for gasoline in liquid or soil, EPA Method 3510/8015 for diesel in liquid, and EPA Method 3540/8015 for diesel in soil. Total Recoverable Petroleum HYdrocarbons (TRPH): EPA Methods 9070A/418.1 for liquid and EPA Methods 9071A/418.1 for soil. As of 10/1/92 EPA Methods 9071A/418.1 will be replaced by EPA Methods 3560/8440. For information on these methods, contact: Quality Assurance Management Section U.S. Environmental Protection Agency 75 Hawthorne Street, P-3-2 San Francisco, CA 94105 (415) 744-1492 Note: Some waste streams may contain additional comtituents not covered by these methods. In those cases, additional EPA analytical methods must be employed to determine whether other constituents are present at concentrations which violate the primary drinking water standards or may otherwise adversely affect the health of persons. For literature regarding appropriate methods, see the reference section at the end of thi.q doo~ment. 22 J J J .1 JI ,i .i ,,i ,11 JI ,E. Sample Collection - Liquid 1. Volatile Organics: Samples for Volatile organics are genen~y taken first to minimize the disturbance of the fluid and resulting loss of volatiles. An off/water interface probe should be utilized to define the base of any free floating product encountered while sampling. If no floating liquid phase is present, a sampling device can be lowered into the fluid - as deeply as possible without disturbing the sediment - and extracted with a represenhative grab sample of fluid. The fluid can then be transferred to pre-chilled, pre-labeled 40-rnl volatile organic analysis (VOA) vials with Teflon septa. The sample should be preserved by adding hydrochloric acid (HC1) to a pH of less than 2. Two 40-ml vials should be obtained for each VOA sample. When analyzing using the Toxicity Characteristic Leaching Procedure (TCLP), bear in mind that the volume of sample to be collected is dependent on the solids content of the sample. Sufficient sample volume is needed to allow for each physical phase to be analyzed separately. Sample bottles should be filled as completely as possible so that no head space remains. Do not add HC1 to samples that will be prepared using the TCLP. If a separate floating phase is encountered while.sampling, a sampling device that collects fluid from beneath the floating phase should be used. This device is operated by gently lowering it in the closed position to a depth below the off/water interface, carefully opening and filling it with sampling fluid, and then closing and retrieving the sample. When transferring the sampling fluid from the sampling container to a VOA vial, the fluid must be poured slowly and smoothly to produce a meniscus over the lip of the vial. The screw-top lid with the Teflon septum is then tightened onto the vial, and the vial turned upside down and gently tapped to check for the presence of air bubbles. If air is trapped in the vial, i.e. head space is present, the sample must be retaken. VOA samples should not be taken near any exhau:st systems which may cause contamination of the sample. The samples should be tagged with an identification number, chilled to approximately 4°C in a cooler, and sent to a certified analytical laboratory. 2. Semi-Volatile Organics: Samples for semi-volatile organics should be collected after those for volatile organics. The method of collection is the stone as that described for volatiles. After the fluid is collected, it should be transferred to a pre-labeled, one-liter glass bottle with a Teflon septum. The sample must be tagged and chilled to approximately 4°C for shipping to the analytical laboratory. 3. Metals: Samples for total metals should be t~d~en after those for volatile and semi-volatile organics. After collection, the sample is transferred to a one-liter, polyethylene, ~rtifled metal-free bottle and the unfiltered sample is acidified with 1:1 redistilled HNO'd to a pH of less than 2 at the time of collection. Do not add HNO3 to samples that will be analyzed for mercury or those that will be prepared using the TCLP. 4. Total Petroleum HYdrocarbons _(TPH) Use collection methods described for sampling for volatile organics. If sampling for TPH as gasoline, the fluid should be transferred to two pre-labeled 40-ml vials with Teflon septa (as described for volatile organics). If sampling for TPH as Diesel, the fluid should be transferred using a funnel to a pre-labeled, one-liter glass bottle with a Teflon septum. Preserve the sample by adding hydrochloric acid (HCI) to a pH of less than 2. The sample must be tagged and chilled to 4°C for shipping to the analytical laboratory. 5. Total Recoverable Petroleum Hydrocarbons (TRPH) Use the collection methods described for volatile organics. The fluid should be transferred to a one-liter glass bottle with a Teflon septum. The sample must then be preserved, tagged and chilled as above. F. Sample Collection - Sediment Often sediment samples from the bottom of a sump are collected using a beaker attached to a pond sampler. A stainless steel lab scoop is generally used to transfer the sediment from the beaker to the required container. Sediment samples should be placed in an 8-oz. wide-mouthed glass jar. The jar should be completely filled so that no headspace is present. After being taped and labeled, the sample should be placed immediately in an ice chest and kept cold (4°C) for delivery to the laboratory. Care should be taken throughout to avoid contamination of both the inside and outside of the jar and its contents. 24 1 1 i i '1 '1 '1 i I I G. Sample Collection - Soil The bore hole can be made with a continuous flight or hollow stem.auger, rotary' core drill or other drilling method. It is recommended that core ~mpling equipment ~ avoid the use of drilling fluids since these greatly increase the potential for sample con.ruination. Soil sampling k/ts are commercially available that can be used at relatively shallow depths to both drill the bore hole and collect a soil core. These units contain augers, coring tubes and suf:ficicnt drill rod extensions to sample up to depths of twenty-five feet. The most common procedures for collecting soil samples use a thin-wall steel tube (core barrel), fitted with a brass liner, which is forced into the undisturbed soil at the bottom of the bore hole. This is sometimes referred to as drive sampling. Core barrels are generally from one inch to three inches in diameter and 12 to 24 inches long. When the core barrel is retrieved, friction will usually retain the sample inside the barrel in most unsaturated materials. SarnpIex should be taken at loc~ns where the potoaiaI for a high degree of contamination exists (suspected m:wst~ loca~:ons) such as elbows, joints in pipe lines, clan~ floor drains, tanks and we. lis. Several depth borOtgs should be planned to be sampled for chemical analysis. Sample interval2: will vary, but in general sho,_dd be taken between one and two feet b~neath the ~rcav~n or the bottom of the ~eptic tank, cesspoo~ wei~ pipe line or floor drain xurface, and then every five feet to the water table, or until five feet part the last suspected contmninmion. Upon retrieval from the borehole, the :sample hners should be removed and placed on clean plastic. Using cuttings or corings, the borehole should be logged to the full depth by an on-site geologist according to the Unified Soil Classification System. After logging, the exposed ends of the liner should be covered. Typically, Teflon sheets and plastic end caps are used and secured with silicone-based tape. After each use, sampling equipment must be decontaminated,. Sample labels should be written or attached securely to the end caps and should contain the following information: boring number, sample location, sample number, sample depth, date and time of sampling, name of sampler, and required analytical method. Sealed and labeled samples must be placed in cooled ice chests and shipped to the analytical laboratory. 1 I I 25 I FAX TRANBHISBZON ............................ lltlh ........ L.tthTmm: ...... hh ........ lhJh. ..... Il :m. ..I..IIIIIII. ,. Jill ...... :h.. ......... llh. ... l ~IFIO~TION ....... f.:ll : ..Jf tfl ........... h :: ..tilth ........ !!llh ...lllllh I' . .: ...Il.Sill Il -. .................. hllh. ..h ..... :-::'::'"'::,: ....... :::',::::: '-' ......... ~ .... L,nmz . . ........ ~JJn ~ ...... hh .... : ........ lhh: .... Ill ,l . lb :..:: ......... :: : .... l.llhll .... mt ....... mm .... ...... t.,,,,, ~ t ............ :,, - . ...... .......... md ......... m::[[ : :..~ .......... llhl ...... ~lll ~lll ....... :::::,::,: ...... ::::::::,,:,::: ..... llllh. .... Still: . ..Still Il llllm ....... ,:.,: ........ h.,,,, ........ OF PA~E~ ,..t.h:h. , [..Itl ! Ii ~ .,.ti.I.d. ..... :::.: ........ tt ..... ......... ~ ~ I ~~l .......... Jm. ............ J}.J}l,; .......... J}}i ~A~ ~<~ ~ pH<2 .C~x~ium ~ EPA ~ ~ ~ ~ ~A ~o.~ 0~1 ~A ~.~ (~) ~A ~m~4~ O~u~) ~<2 ~ ~4,&~' ~,) , 2*7 ,,H. Common Sampling Errors The following, are common errors made during sampling that lead to inconsistent analytical results: Failure to calibrate in.qtruments Lack of equipment maintenance Use of inappropriate sample containers Lack of QA samples to assure precision of sampling methods and laboratory analysis. Sample loss or leakage during shipping or handling due to improper packaging Mislabelling Poor field records I. Chain of Custody The purpose of chain of custody procequres is to be able to trace possession of a sample from the time it is collected until the analytical results are obtained by the laboratory. Chain of custody procedures are important when analytical results are introduced as evidence in a legal proceeding. A sample is in "custody" if: It is actually in one's physical pc,ssession It is in one's view It was in one's possession and it was secured so that it could not be tampered with. It is kept in a secured area with access restricted to authorized personnel .only. It is placed in a container that is sealed with an official seal that will be broken when the container is opened. Chain of custody documentation includes, but is not limited to, the entries in the sampler's field notebook, the official seals on the sampling containers and the chain of custody record. The inspector needs to assure that the relationship between the physical sample and the related documentation is clear, complete, and accurate. The sample number, date and time of sampling, location and sample type, preservative used, analysis required, and sampler's initials should appear on all documents. 28 When transferring the samples, the indMdual relinquishing and the individual receiving the sample' must sign and record the date and time on the chain of custody record. Every person who takes custody must fill in the appropriate section of the chain of custody record. For a sample of a chain of custody record see Figure E.' When the samples are sent by' ma/l, the package must be registered with return receipt requested. 2¸9 REFERENCES Carlin, Jayne and Tom, Laura, December 1986. EPA Region 9 Underground Injection Control Direct Implementation Quality Assurance Project Plan. County of Kern, Department of Environmental Health Services, July 1990. Site Characterization and Remediation. Engineering Enterprises, lnc, March 1986. Sampling Document for-USEPA Region IX Direct Implementation Program. Engineering Enterprises, April 1988. Generic Plan for Injectate and Sediment Sampling at Class V Facilities in Region IX. Engineering Enterprises, February. 1989. Standard Operating Procedures for Injectate and Sediment Sampling at Class V Facilities in Region II. Kern County Health Department and Kern County Fire Department. Requirements for Permanent Closure of Underground Hazardous Substance Storage Tanks. Santa Clara Valley Water District, June 1989. Standards for the Construction and Destruction of Wells and other Deep Excavations in Santa Clara County. Stanislaus County Underground Tank Program, September 1989. Stanislaus County Guidelines for Sampling and Site Investigations. State of California, Leaking Underground Fuel Tank Task Force, December 1987. Leaking Underground Fuel Tank Field Manual: Guidelines for Site Assessment, Cleanup and Underground Storage Tank Closure. State of California, Water Resources Control Board, August 1991. California Underground Storage Tank Regulations and Related Health and Safety Code Sections. USEPA Region 9 Quality Assurance', Management Section, October 1989. Preparation of a USEPA Region 9 Sampling and Analysis Plan for Private and State- Lead Superfund Projects (gQA -06-89). USEPA Region 9 Quality Assurance,, Management Section, September 1989. USEPA Region 9 Guidance for Preparing Quality Assurance Project Plans for Superfund 31 Remedial Projects (9QA-03-89). USEPA, Test Methods for Evaluating; Solid Waste, Physical/Chemical Methods (SW-846), available from Government Pr/at/ag Office (202) 783-3238 (Doc. No. 955-001- 0oo00-1). USEPA, Methods for Chemical Analysis of Water and Wastes, Doc. No. EPA 600/4-79-020. USEPA, Methods for Organic Chemical Analysis of Municipal and Industrial Wastewater, Doc. No. EPA 600/4-82-057. USEPA, Methods for the Determination of Organic Compounds in Drinking Water, Doc. No. EPA 600/4-88-039. USEPA, Region 9 Quality Assurance Management Section, January, 1990, Laboratory Documentation Requirements for Data Validation, Doc. No. 9QA-07-90. 32 DUANE R. SMITH AND ASSOCIATES Consulting Geologists 73.01 Frultvale Extension Bakersfield, Ct~lifornta g330g {$05i 1589-7801 February 4~, 1992 Mr. Terry Gray Kern County Resource~ Management Agency Environmental Health Services Department ~700 M Street, Suite 3~0 Bakersfield, California 93301 D~ar Mr. Gray: Enclosed are the results o£ the sludge sa~pLing and analy=e~ at the MacXe-vee Company property located at 4110 Wible Road, ~D. There is a small sump located about 42 feet north of the Mt. Piston Machine and Parts building. Sludge from this sump was camp!ed on January 16, 1992. The sump im about 8 feet wide and 10 long. Tt appears to be about ~.R lmm% deep. The thickness of the 61udge is aDout 1.b feet. The 6ump i~ covered Dy a 2.5 inch mteel pipe grate. The bottom of the ~ump appearc to be dirt. A 3 foot concrete apron borders the sump. Asphalt paving ewtends out from the apron. I ~as able to collect a sample of the sludge through the grate in the southern portion of the, sump (see Attachment A). The sludge was placed i~ a glass quart jar furnished by BC Laboratory. The jar ~as completely filled leaving little to no head space. The sample was placed o~ Dl~e ice and da]~vored to BC Laboratory for analy~es on January 16, 1992. The sample of mludge was analyzed for CAM 17 heavy metals, EPA Metho~ 8010/8020 constituents, total petroleum hydrocarbons (gas and diase! - Modified EPA Method 80~5), and oil and grease (EPA Method 413.1). This list of constituents varies from that in Mr. Terry Gray February 4, 1992 Page 2 your october 9, 1991 letter to Mr. Mackes~Y. The analyses changed after a discussion with you rmgarding'the classification' of this site if contaminated. I did not want to have to samDle the sludg~ due to ~om~ po~=ibla future ad4ed requirements. Attachment B ~how~ the result= of the chemical analyses. The CAM 17 analyses showed high levels of barium, coDDer, lead, and zinc. All the~a exceed STLC limit= but only lea~ exceeds the TTLC- limit. The sample contained 41,000 PDm oil and grease. The Method 8010/R0~0 anal~e~ sho~m~d typical gasoline ¢onstituent~] Thc=c were benzene, ~thyl benzene, toluene, o-xylene, and xylenes. T~e Denzene concentration ~a2 5 ppm and total ×ylene~ wa= 57 ppm. Total petroleum hydrocarbon concentrations ~or gasoline and diesel ~er, 300 ppm and 1,500 ppm, re=pectlvely. It appears, based on the above data, that the contaminate of most concern in the ~ludge is the lead (6,~30 ppm). If you have any question~ regarding the analysis of the sump sludge, please feel free to call. DRS/D$ cc: Mr. John Mackessy, Macke-Vee Company DUANE R. SMITH AND ASSOCIATES LABO RA'i iD RIES, INC. 4100 ATLAS CT. BAKERSFIELD, CALIFORNIA 933,~ PHONE ~ 327-4911 FA~ ~35) 327-1918 7101 ERUI1-VAJ~E EXT. AUUn.: DUAN~ R. ~MITH 805-589-7861 Date Reported:' 01/23/92 ~.Oe '1 Date Received, 0~/16/92 Sample Deecripcion: MR. aOM~ ~iACHE$$Y - 4110 WI~LE PD. ~D, B3~KERSFIELD, CA: ~1 QT JAR CONTA/NING SLUDGe TIGCEN O~ 01-16-92 · 10:30 BY DUD.NE SMITH TOTAL CONTAMINANTR (Title 22. ~rticle 11, California Code of Regulations} ~u~timony None Detected m~/k~ A,r~enic 12. mg/kg Barium 1~70. ~eryl!ium Fcne De~ected mg/k9 Ca(i~nium 20. mg/k~ C-nro~ium 1%%. mg/kg Cobalt 10. mg/k~ Copper 58%. mg/kg Lead 6830. mg/kg ~ercury Mune Detected mg/kg Molybdenum 19. Nickel 51. mg/kg Selenium N~ne Dut®ctud m~/k ~ilver None De£ec~ed m~/kg Thallium N~n~ Det~ct.d mg/k~ V~nadium 19. mg/kg Zinc 21~. mg/kg O{1 g Gr~a~ 4'1000. rag/kg Regulatory Crlteri~ Method 5T/Xi TTLC L_0_...k._ ~ _~/~._ ~lk~ 10, 1.0 1.0 1.0 t-0 5.0 1.0 5.0 0 ~ 5 0 ~ 0 I 0 10 1 0 I 0 20 SW-6010 15. ~00. £W-7060 5.0 500. $w-6010 1~0. 10000. EW-6010 0.75 75 Sw-6010 1.~ 100 aW-6010 560. 2500 $w-6010 80. 8000 SW-6010 25. 2500 5W-6010 5.0 1000 SW-7471 0.2 20 SW-6010 350. ~00 ~-6010 20. 2000 SW-77~U i.0 1~0 ~-~010 5.0 500. $Wo6010 7.0 7~0. $W-6010 ~%. 2~00. ~W-6010 250. S000. ~DA-41).I Co~ent: P.Q.L. - STLC . TTLC = Ail constituents reportsd sJDove are :La mg/~g (unle== other~ise stat=d} on an as received (~et) ~a~lu Basis. ;~,~ults reported represent totals [T'rLC] as Sample uubjec~ed to appropriate technique~ to ~etcrmlne ~otal lev=la. Practical ~n~itation L~it (re,ers to ~e 1,a~t ~ount of ~lyte ~=tectabl= Daseo on s~le ~{xe u~ed ~d ~alytical t~c~iqu= e~loyed. None Detected (ConStlLu~nt,.lf present, ~ould be 1,ss th~ the m~thod P.Q.L.). Sol,lc Threshold Lfm{t Total ~rcmhold L~mlt C~lcentration EPA . "Me=hods for ~hemical Analy~g of Water and Waotcs', EPA-600, 14J79-OZg. SW ~ "T-~t M~thodg fo~ ~waluat£n~ Solid Wastes F~¥sical/Chemical Sw 846, SepcemDer, Attachm'~.n t B LABO RAT )RIES, INC. 41~ &TLK$ CT., I~AKERSFIELD, CALII=ORNIA g~ PHONE (80~ 3274911 FAX (M~) 321'-Ig18 PurgeaDle Organic Analy~i~ D.R. ~KITH &ASSOCIATK~ Date of 7201 FRUZTVALE EXT. Report: BAK~RSFIR~. C~ 9]]09 Lab ~: 414-1 Attn.: DT/Ai~E R. SMIT~ 805-589-7861 Sample Description: MR. COH1~ ~IACHESSY - %110 Wi. BLE RD. ~D. BAKERSFIELD, CONTAINING SLUDGE TAKEN ON 01-16-92 m 10:30 BY DUAN£ SMITM Test Method: EPA Ph=thod 8010/8020 Sample Matrix: Sludge Date sampl0 Data R,,~I, Date Analymie Collected: Received · Lab: Completed: 01/16/~2 01/16/9~ 01/30/92 Analyslu Reporting Constituents .Resulr.~ Un%%s 5. mg/kg None De,coted '.mg/kg None Detected mg/k9 None Detected mg/k~ None Detected m~/kg Nc~e Detected None Detected mg/k~ ~one Detected Nom~ Detected None Detected mg/kg None Detected mg/kF None Detected m~/kg None Detected m~/kg' None Detected mg/ku None Detected m~/k~ None Detected mg/k9 None DeteCted mg/k9 ~one Detected mg/~g None Detected mg/k9 None Detected None Dc=coted mg/k~ 6. mg/kg ~one Detected mg/kg None Detectm~ mg/k9 15. mg/kg Non, Detected mg/kg ~on¢ Detected mg/kg None Petect,d mg/k~ None Detecte4 mg/kg None Detected mg/kg Reporting _J~vel- 3 3 3 3 3 3. 3 3 3 3 3. 3. 3. Attachmont B C~k~t,UULr~ LABORATORIES, INC. 4100 ATLAS CT. BAKERSFIELD, CALIFORNIA, 93,1~ PHONE (llOS) 327-4911 FAX.('80S} 327-1918 ~urgeable orgy:Lc ~alysie Pag h.g. SMIT~ & ASSOCIATES Dmte of 7201 FRUI~VAL~- ZXT. Report: 01/31/92 R~k'~SFIELD, CA 9130~ L~b $: 414-X Attn.: D[1ANE R. SMITM 805-589-7861 Sa_q~le Description: MI~..TORN MACHEEgY - 4110 V][BLE RD. ~D, BAF~FIELD, CA: ~1 QT JAR COSrfAINING SLUDGE TAKEN ON 01-1G-92 ~ 10:30 BY DUA~£ SMITH Minimum Analysis Reporting Reporting Constituents Result= . UnE~ Lcvcl o-xylene 9. mu/kg 3. m- & p-Xylcnco 48. n~3/kg To:al Xylenes 57. mO/kg 3. Total Tr~halomcthanes Mone Detecctd m~/k~ 3. California D.O.H.~. Cert. A%~achmcn% B LABORATORIES, INC. J. a. EGLIN. REO. CHEM. ENGI~. 4100 ATLAS CT., BAKERSFIELD. CAUFORNIA 9:3308 PHONE (SOS:) 3.27-4911 I=AX (~0S) 327'.1918 Pe =roleum ~ydroc=rDon8 D.R. SMIT~ & A~$OCIATEE Date Of 7201 FRUITVALE EXT. Report: 01/24/92 ~J~KERSFIELD, CA 91308 Lab #: Attn.: DUANE R. SMITM 805-585-7861 Sample Deecription: MR. JO}iN MACHESS¥ - ~110 WIBLE RD. ~D, BAKERSFIELD. CA: #1 QT Jf~R CONTATNING SLUDGE TILK~N ON 01-16-S2 % 10:30 BY DUAN£ SMI/]{ TEST ~-f14OD, TPM by D.O.H.S. / L.U.F.T. Zw~nual Method - Modifi,d EPA 8015 TEST PIE/HOD: TPH by D.O.H.S. / L.U.F.T. ]~anual Mc~hod - ~odlfied EPA 8015 Matrix: Date Sample Datm Rmmple Date Analysis Co]leered: Receivmd $ Lab: Cc~pleted: 0!/16/92 01/16/92 01/20/92 Miulmum A~alysi s Reporting Report ~TD~ti~ts Result~ ~qitc Level Total PeLzuleum Hydrocarbons (ga~) 300. mg/kg 100 Total PeL~ul=um Hydrocarhan~ (di~c~) 1500. mg/K~ 200. California D.O.M.S. Cert. ~llR~ DeDartment ~uper~i~or Received by: I --- Relinquished by: Company: Ouane ~. Smitfl & Associates 0 Corem.v: ,/.4/' /& Received by: DUANE R, C~mpan¥: SMITH & ASSOCIATES:~...u..?~ Photo 1: Sump with temporary cover. Mr. Piston Machine and Parts. Bakersfield, California ~ Photo 2: Sump with dike and temporary cover folded back. Mr. Piston Machine and Parts. Bakersfield, California SITE SAFETY PLAN ACKNOWLEDGMENT FORM I have been informed, understand, and will abide by the procedures set forth in the Health and Safety Plan for the Mr. Piston site in Bakersfield, California. Printed Name Signature Represents, g Date