PART THREE - GATHERING ENVIRONMENTAL DATA © 2002 by CRC Press LLC CHAPTER 10 SITE INVESTIGATION AND REMEDIATION The site investigation and remediation process is usually the reason for site environmental data management. The results of the data management process can provide vital input in the decision- making process. This chapter provides an overview of the regulations that drive the site investigation and remediation process, some information on how the process works under the major environmental regulations, and how data management and display is involved in the different parts of the process. Related processes are environmental assessments and environmental impact statements, which can also be aided by an EDMS. OVERVIEW OF ENVIRONMENTAL REGULATIONS The environmental industry is driven by government regulations. These regulations have been enacted at the national, state, or local level. Nearly all environmental investigation and remediation activity is performed to satisfy regulatory requirements. A good overview of environmental regulations can be found in Mackenthun (1998). The following are some of the most significant environmental regulations: National Environmental Policy Act of 1969 (NEPA) – Requires federal agencies to consider potentially significant environmental impacts of major federal actions prior to taking the action. The NEPA process contains three levels of possible documentation: 1) Categorical Exclusion (CATEX), where no significant effects are found, 2) Environmental Assessment (EA), which addresses various aspects of the project including alternatives, potential impacts, and mitigation measures, and 3) Environmental Impact Statement (EIS), which covers topics similar to an EA, but in more detail. Clean Air Act of 1970 (CAA) – Provides for the designation of air quality control regions, and requires National Ambient Air Quality Standards (NAAQS) for six criteria pollutants (particulate matter, sulfur dioxide, carbon monoxide, ozone, nitrogen dioxide, and lead). Also requires National Emission Standards for Hazardous Air Pollutants (NESHAPs) for 189 hazardous air pollutants. The act requires states to implement NAAQS, and requires that source performance standards be developed and attained by new sources of air pollution. Occupational Safety and Health Act of 1970 – Requires private employers to provide a place of employment safe from recognized hazards. The act is administered by the Occupational Safety and Health Administration (OSHA). © 2002 by CRC Press LLC Endangered Species Act of 1973 (ESA) – Provides for the listing of threatened or endangered species. Any federal actions must be evaluated for their impact on endangered species, and the act makes it illegal to harm, pursue, kill, etc. a listed endangered or threatened species. Safe Drinking Water Act of 1974 (SDWA) – Protects groundwater aquifers and provides standards to ensure safe drinking water at the tap. It makes drinking water standards applicable to all public water systems with at least 15 service connections serving at least 25 individuals. Requires primary drinking water standards that specify maximum contamination at the tap, and prohibits certain activities that may adversely affect water quality. Resource Conservation and Recovery Act of 1976 (RCRA) – Regulates hazardous wastes from their generation through disposal, and protects groundwater from land disposal of hazardous waste. It requires criteria for identifying and listing of hazardous waste, and covers transportation and handling of hazardous materials in operating facilities. The act also covers construction, management of, and releases from underground storage tanks (USTs). In 1999, 20,000 hazardous waste generators regulated by RCRA produced over 40 million tons of hazardous waste (EPA, 2001b). RCRA was amended in 1984 with the Hazardous and Solid Waste Amendments (HSWA) that required phasing out land disposal of hazardous waste. Toxic Substances Control Act of 1976 (TSCA) – Requires testing of any substance that may present an unreasonable risk of injury to health or the environment, and gives the EPA authority to regulate these substances. Covers the more than 60,000 substances manufactured or processed, but excludes nuclear materials, firearms and ammunition, pesticides, tobacco, food additives, drugs, and cosmetics. Clean Water Act of 1977 (CWA) – Based on the Federal Water Pollution Control Act of 1972 and several other acts. Amended significantly in 1987. This act, which seeks to eliminate the discharge of pollutants into navigable waterways, has provisions for managing water quality and permitting of treatment technology. Development of water quality standards is left to the states, which must set standards at least as stringent as federal water quality standards. Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA, Superfund) – Enacted to clean up abandoned and inactive hazardous waste sites. Creates a tax on the manufacture of certain chemicals to create a trust fund called the Superfund. Sites to be cleaned up are prioritized as a National Priority List (NPL) by the EPA. Procedures and cleanup criteria are specified by a National Contingency Plan. The NPL originally contained 408 sites, and now contains over 1300. Another 30,000 sites are being evaluated for addition to the list. Emergency Planning and Community Right-to-Know Act of 1986 (EPCRA) – Enacted after the Union Carbide plant disaster in Bhopal, India in 1984, in which release of methyl isocyanate from a chemical plant killed 2,000 and impacted the health of 170,000 survivors, this law requires industrial facilities to disclose information about chemicals stored onsite. Pollution Prevention Act of 1990 (PPA) – Requires collection of information on source reduction, recycling, and treatment of listed hazardous chemicals. Resulted in a Toxic Release Inventory for facilities including amounts disposed of onsite and sent offsite, recycled, and used for energy recovery. These regulations have contributed significantly to improvement of our environment. They have also resulted in a huge amount of paperwork and other expenses for many organizations, and explain why environmental coordinators stay very busy. Bad regulations are more likely to be supplemented than repealed. Rich (1996) © 2002 by CRC Press LLC THE INVESTIGATION AND REMEDIATION PROCESS The details of the site investigation and remediation process vary depending on the regulation under which the work is being done. Superfund was designed to remedy mistakes in hazardous waste management made in the past at sites that have been abandoned or where a sole responsible party cannot be determined. RCRA deals with sites that have viable operators and ongoing operations. The majority of sites fall into one of these two categories. The rest operate under a range of regulations through various different regulatory bodies, many of which are agencies in the various states. CERCLA CERCLA (Superfund) gives the EPA the authority to respond to releases or threatened releases of hazardous substances that may endanger human health and the environment. The three major areas of enforcement at Superfund sites are: achieving site investigations and cleanups led by the potentially responsible party (PRP) or parties (PRP lead cleanups, meaning the lead party on the project is the PRP); overseeing PRP investigation and cleanup activities; and recovering from PRPs the costs spent by EPA at Superfund cleanups (Fund lead cleanups). The National Contingency Plan of CERCLA describes the procedures for identification, evaluation, and remediation of past hazardous waste disposal sites. These procedures are preliminary assessment and site inspection; Hazard Ranking System (HRS) scoring and National Priority List (NPL) site listing; remedial investigation and feasibility studies; record of decision; remedial design and remedial action; construction completion; operation and maintenance; and NPL site deletion. Site environmental data can be generated at various steps in the process. Additional information on Superfund enforcement can be found in EPA (2001a). Preliminary assessment and site inspection – The process starts with investigations of site conditions. A preliminary assessment (PA) is a limited scope investigation performed at each site. Its purpose is to gather readily available information about the site and surrounding area to determine the threat posed by the site. The site inspection (SI) provides the data needed for the hazard ranking system, and identifies sites that enter the NPL site listing process (see below). SIs typically involve environmental and waste sampling that can be managed using the EDMS. HRS scoring and NPL site listing – The hazard ranking system (HRS) is a numerically based screening system that uses information from initial, limited investigations to assess the relative potential of sites to pose a threat to human health or the environment. The HRS assigns a numerical score to factors that relate to risk based on conditions at the site. The four risk pathways scored by HRS are groundwater migration; surface water migration; soil exposure; and air migration. HRS is the principal mechanism EPA uses to place uncontrolled waste sites on the National Priorities List (NPL). Identification of a site for the NPL helps the EPA determine which sites warrant further investigation, make funding decisions, notify the public, and serve notice to PRPs that EPA may begin remedial action. Remedial investigation and feasibility studies – Once a site is on the NPL, a remedial investigation/feasibility study (RI/FS) is conducted at the site. The remedial investigation involves collection of data to characterize site conditions, determine the nature of the waste, assess the risk to human health and the environment, and conduct treatability testing to evaluate the potential performance and cost of the treatment technologies that are being considered. The feasibility study is then used for the development, screening, and detailed evaluation of alternative remedial actions. The RI/FS has five phases: scoping; site characterization; development and screening of alternatives; treatability investigations; and detailed analyses. The EDMS can make a significant contribution to the site characterization component of the RI/FS, which often involves a significant amount of sampling of soil water and air at the site The EDMS serves as a repository of the data © 2002 by CRC Press LLC as well as a tool for data selection and analysis to support the decision-making process. Part of the site characterization process is to develop a baseline risk assessment to identify the existing or potential risks that may be posed to human health and environment at the site. The EDMS can be very useful in this process by helping screen the data for exceedences that may represent risk factors. Record of decision – Once the RI/FS has been completed, a record of decision (ROD) is issued that explains which of the cleanup alternatives will be used to clean up the site. This public document can be significant for data management activities because it often sets target levels for contaminants that will be used in the EDMS for filtering, comparison, and so on. Remedial design and remedial action – In the remedial design (RD), the technical specifications for cleanup remedies and technologies are designed. The remedial action (RA) follows the remedial design and involves the construction or implementation phase of the site cleanup. The RD/RA is based on specifications described in the ROD. The EDMS can assist greatly with tracking the progress of the RA and determining when ROD limits have been met. Construction completion – A construction completion list (CCL) helps identify successful completion of cleanup activities. Sites qualify for construction completion when any physical construction is complete (whether or not cleanup levels have been met), EPA has determined that construction is not required, or the site qualifies for deletion from the NPL. Operation and maintenance – Operation and maintenance (O&M) activities protect the integrity of the selected remedy for a site, and are initiated by the state after the site has achieved the actions and goals outlined in the ROD. The site is then determined to be operational and functional (O&F) based on state and federal agreement when the remedy for a site is functioning properly and performing as designed, or has been in place for one year. O&M monitoring involves inspection; sampling and analysis; routine maintenance; and reporting. The EDMS is used heavily in this stage of the process. NPL site deletion – In this final step, sites are removed from the NPL once they are judged to no longer be a significant threat to human health and the environment. To date, not many sites have been delisted. RCRA The EPA’s Office of Solid Waste (OSW) is responsible for ensuring that currently generated solid waste is managed properly, and that currently operating facilities address any contaminant releases from their operations. In some cases, accidents or other activities at RCRA facilities have released hazardous materials into the environment, and the RCRA Corrective Action Program covers the investigation and cleanup of these facilities. Additional information on RCRA enforcement can be found in EPA (2001b). As a condition of receiving a RCRA operating permit, active facilities are required to clean up contaminants that are being released or have been released in the past. EPA, in cooperation with the states, verifies compliance through compliance monitoring, educational activities, voluntary incentive programs, and a strong enforcement program. The EDMS is heavily involved in compliance monitoring and to some degree in enforcement actions. Compliance monitoring – EPA and the states determine a waste handler’s compliance with RCRA requirements using inspections, record reviews, sampling, and other activities. The EDMS can generate reports comparing sampling results to regulatory limits to save time in the compliance monitoring process. Enforcement actions – The compliance monitoring process can turn up violations, and enforcement actions are taken to bring the waste handler into compliance and deter further violations. These actions can include administrative actions, civil judicial actions, and criminal actions. In addition, citizens can file suit to bring enforcement actions against violators or potential violators. © 2002 by CRC Press LLC One important distinction from a data management perspective between CERCLA and RCRA projects is that CERCLA projects deal with past processes, while RCRA projects deal with both past and present processes. This means that the EDMS for both projects needs to store information on soil, groundwater, etc., while the RCRA EDMS also might store information on ongoing processes such as effluent concentrations and volumes, and even production and other operational information. Other regulatory oversight While many sites are investigated and remediated under CERCLA or RCRA, other regulatory oversight is also possible. The EPA has certified some states to oversee cleanup within their boundaries. In some cases, other government agencies, including the armed forces, oversee their own cleanup efforts. In general, the technical activities performed are pretty much the same regardless of the type of oversight, and the functional requirements for the EDMS are also the same The main exception is that some of these agencies require the use of specific reporting tools as described in Chapter 5. ENVIRONMENTAL ASSESSMENTS AND ENVIRONMENTAL IMPACT STATEMENTS The National Environmental Policy Act of 1969 (NEPA), along with various supplemental laws and legal decisions, requires federal agencies to consider the environmental impacts and possible alternatives of any federal actions that significantly affect the environment (Mackenthun, 1998, p. 15; Yost, 1997, p. 1-11). This usually starts with an environmental assessment (EA). The EA can result in a determination that an environmental impact statement (EIS) is required, or in a finding of no significant impact (FONSI). The EIS is a document that is prepared to assist with decision making based on the environmental consequences and reasonable alternatives of the action. The format of an EIS is recommended in 40 CFR 1502.10, and is normally limited to 150 pages. Often there is considerable public involvement in this process. One important use of environmental assessments is in real estate transactions. The seller and especially the buyer want to be aware of any environmental liabilities related to the property being transferred. These assessments are broken into phases. The data management requirements of EAs and EISs vary considerably, depending on the nature of the project and the amount and type of data available. Phase 1 Environmental Assessment – This process involves evaluation of existing data about a site, along with a visual inspection, followed by a written report, similar to a preliminary assessment and site inspection under CERCLA, and can satisfy some CERCLA requirements such as the innocent landowner defense. The Phase 1 assessment process is well defined, and guidelines such as Practice E-1527-00 from the American Society for Testing and Materials (ASTM 2001a, 2001b), are used for the assessment and reporting process. There are four parts to this process: gathering information about past and present activities and uses at the site and adjoining properties; reviewing environmental files maintained by the site owner and regulatory agencies; inspection of the site by an environmental professional; and preparation of a report identifying existing and potential sources of contamination on the property. The work involves document searches and review of air photos and site maps. Often the source materials are in hard copy not amenable to data management. Public and private databases are available to search ownership, toxic substance release, and other information, but this data is usually managed by its providers and not by the person performing the search. Phase 1 assessments for a small property are generally not long or complicated, and can cost as little as $1,000. © 2002 by CRC Press LLC Phase 2 Investigation – If a Phase 1 assessment determines that the presence of contam- ination is likely, the next step is a Phase 2 assessment. The primary differences are that Phase 1 relies on existing data, while in Phase 2 new data is gathered, usually in an intrusive manner, and the Phase 2 process is less well defined. This can involve sampling soil, sediment, and sludge and installation of wells for sampling groundwater. This is similar to remedial investigation and feasibility studies under CERCLA. If the assessment progresses to the point where samples are being taken and analyzed, then the in-house data management system can be of value. Phase 3 Site Remediation and Decommissioning – The final step of the assessment process, if necessary, is to perform the cleanup and assess the results. Motivation for the remediation might include the need to improve conditions prior to a property transfer, to prevent contamination from migrating off the property, to improve the value of the property, or to avoid future liability. Monitoring the cleanup process, which can involve ongoing sampling and analysis, will usually involve the EDMS. © 2002 by CRC Press LLC CHAPTER 11 GATHERING SAMPLES AND DATA IN THE FIELD Environmental monitoring at industrial and other facilities can involve one or more different media. The most common are soil, sediment, groundwater, surface water, and air. Other media of concern in specific situations might include dust, paint, waste, sludge, plants and animals, and blood and tissue. Each medium has its own data requirements and special problems. Generating site environmental data starts with preparing sampling plans and gathering the samples and related data in the field. There are a number of aspects of this process that can have a significant impact on the resulting data quality. Because the sampling process is specific to the medium being sampled, this chapter is organized by medium. Only the major media are discussed in detail. GENERAL SAMPLING ISSUES The process of gathering data in the field, sending samples to the laboratory, analyzing the data, and reporting the results is complicated and error-prone. The people doing the work are often overworked and underpaid (who isn’t), and the requirements to do a good job are stringent. Problems that can lead to questionable or unusable data can occur at any step of the way. The exercise (and in some cases, requirement) of preparing sampling plans can help minimize field data problems. Field sampling activities must be fully documented in conformance with project quality guidelines. Those guidelines should be carefully thought out and followed methodically. A few general issues are covered here. The purpose of this section is not to teach field personnel to perform the sampling, but to help data management staff understand where the samples and data come from in order to use it properly. In all cases, regulations and project plans should be followed in preference to statements made here. Additional information on these issues can be found in ASTM (1997), DOE/HWP (1990a), and Lapham, Wilde, and Koterba (1985). Taking representative samples Joseph (1998) points out that the basic premise of sampling is that the sample must represent the whole population, and quotes the law of statistical regularity as stating that “a set of subjects taken at random from a large group tends to reproduce the characteristics of that large group.” But the sample is only valid if the errors introduced in the sampling process do not invalidate the results for the purpose intended for the samples. Analysis of the samples should result in no bias and minimum random errors. © 2002 by CRC Press LLC Types of Sampling Patterns Simple Random Sampling Judgment Sampling Grid (Systematic) Sampling Stratified Sampling Random Grid Sampling Two-Stage Sampling Known Plume Primary Stage Secondary Stage BA Figure 51 - Types of sampling patterns The size of the sample set is directly related to the precision of the result. More samples cost more money, but give a more reliable result. If you start with the precision required, then the number of samples required can be calculated: © 2002 by CRC Press LLC 22 2 )4/( sBN Ns n + = where n is the number of samples, N is the size of the population, s is the standard deviation of the sample, and B is the desired precision, such as 95% confidence. According to Joseph (1998), the standard deviation can be estimated by taking the largest value of the data minus the smallest and dividing by four. There are several strategies for laying out a sampling program. Figure 51, modified after Adolfo and Rosecrance (1993), shows six possibilities. Sampling strategies are also discussed in Sara (1994, p. 10-49). In simple random sampling, the chance of selecting any particular location is the same. With judgment sampling, sampling points are selected based on previous knowledge of the system to be sampled. Grid sampling provides uniform coverage of the area to be studied. Stratified sampling has the sample locations based on existence of discrete areas of interest, such as aquifers and confining layers, or disposal ponds and the areas between them. Random grid sampling combines uniform coverage of the study area with a degree of random selection of each location, which can be useful when access to some locations is difficult. With two-stage sampling, secondary sampling locations are based on results of primary stage samples. In the example shown, primary sample A had elevated values, so additional samples were taken nearby, while primary sample B was clean, so no follow-up samples were taken. Care should be taken so that the sample locations are as representative as possible of the conditions being investigated. For example, well and sample locations near roadways may be influenced by salting and weed spraying activities. Also, cross-contamination from dirty samples must be avoided by using procedures like sampling first from areas expected to have the least contamination, then progressing to areas expected to have more. Logbooks and record forms Field activities must be fully documented using site and field logbooks. The site logbook stores information on all field investigative activities, and is the master record of those activities. The field logbook covers the same activities, but in more detail. The laboratory also should keep a logbook for tracking the samples after they receive them. The field logbook should be kept up-to-date at all times. It should include information such as well identification; date and time of sampling; depth; fluid levels; yield; purge volume, pumping rate, and time; collection methods; evacuation procedures; sampling sequence; container types and sample identification numbers; preservation; requested parameters; field analysis data; sample distribution and transportation plans; name of collector; and sampling conditions. Several field record forms are used as part of the sampling process. These include Sample Identification and Chain of Custody forms. Also important are sample seals to preserve the integrity of the sample between sampling and when it is opened in the laboratory. These are legal documents, and should be created and handled with great care. Sample Identification forms are usually a label or tag so that they stay with the sample. Labels must be waterproof and completed in permanent ink. These forms should contain such information as site name; unique field identification of sample, such as station number; date and time of sample collection; type of sample (matrix) and method of collection; name of person taking the sample; sample preservation; and type of analyses to be conducted. Chain of Custody (COC) forms make it possible to trace a sample from the sampling event through transport and analysis. The COC must contain the following information: project name; signature of sampler; identification of sampling stations; unique sample numbers; date and time of collection and of sample possession; grab or composite designation; matrix; number of containers; parameters requested for analysis; preservatives and shipping temperatures; and signatures of individuals involved in sample transfer. © 2002 by CRC Press LLC [...]... as temperature, pH, and turbidity Then the sample is sent to the laboratory for analysis When the field and laboratory data are sent to the data administrator, the software should help the data administrator tie the field data to the laboratory data for each sampling event Key data fields for groundwater data include the site and station name, the sample date and perhaps time, COC and other field sample... large volume of data can be presented in an informative way Key data fields for air data include the site and station name, the sample date and time (or, for a sample composited over time, the start and end dates and times), how the sample was taken and who took it, transportation information if any, and any sample QC information such as duplicate and other designations OTHER MEDIA The variety of media... agriculture, and too often show up in drinking water There are several groups of herbicides, including bipyridilium compounds (diquat and paraquat), heterocyclic nitrogen compounds (atrazine and metribuzin), chlorophenoxyls (2,4-D and 2,4,5-T), substituted amides (propanil and alachlor), nitroanilines (trifluralin), and others By-products from the manufacture of pesticides and herbicides and the degradation... information is captured and stored in the EDMS One issue to keep in mind is that the volume of this information can be great, and care should be taken to prevent degradation of the performance of the system due to the potentially large volume of this data Sometimes it makes sense to store true operating data in one database and environmental data in another However, due to the potential overlap of retrieval requirements,... representative of the area under investigation, and standards should be used to calibrate the analyzer Air data issues Often air samples are taken at relatively short time intervals, sometimes as short as minutes apart This results in a large amount of data to store and manipulate, and an increased focus on time information rather than just date information It also increases the importance of data aggregation and. .. gravimetry, nephelometric, and radiochemical methods Titration is one of the oldest and most commonly used of the wet chemistry techniques It is used to measure hardness, acidity and alkalinity, chemical oxygen demand, non-metals such as chlorine and chloride, iodide, cyanide, nitrogen and ammonia, sulfide and sulfite, and some metals and metal ions such as calcium, magnesium, bromate, and bromide Titration... bailing, and development usually continues until the water produced is clear and free of suspended solids and is representative of the geologic formation being sampled Development should be documented on the Well Development Log Form and in the site and field logbooks Upgradient and background wells should be developed before downgradient wells to reduce the risk of cross-contamination Measurement of water... depending on the number of neutrons in the nucleus of each atom For example, radium224 and radium226 have atomic weights of 224 and 226, respectively, but are the same element and participate in chemical reactions the same way Different isotopes have different levels of radioactivity and different half-lives (how long it takes half of the material to undergo radioactive decay), so they are often tracked separately... recent history of exposure, and blood and urine analyses are widely used to track exposure to metals such as lead, arsenic, and cadmium Often this type of data is gathered under patient confidentiality rules, and maintaining this confidentiality must be considered in implementing and operating the system for managing the data Lead exposure in © 2002 by CRC Press LLC children (and pregnant and nursing... mothers) is of special interest since it appears to be correlated with developmental problems, and monitoring and remediating elevated blood lead is receiving much attention in some communities The data management system should be capable of managing both the blood lead data and the residential environmental data (soil, paint, water, and dust) for the children It should also be capable of relating . broken into phases. The data management requirements of EAs and EISs vary considerably, depending on the nature of the project and the amount and type of data available. Phase 1 Environmental Assessment. maintained by the site owner and regulatory agencies; inspection of the site by an environmental professional; and preparation of a report identifying existing and potential sources of contamination. significant contribution to the site characterization component of the RI/FS, which often involves a significant amount of sampling of soil water and air at the site The EDMS serves as a repository of the data © 2002