# Presentation: 875069

## HAZARDOUS WASTE SAMPLING

- _[www.epa.gov/.../programs/er/resource/d1_04.htm](http://www.epa.gov/.../programs/er/resource/d1_04.htm)_

## SAMPLING RATIONALWHY DO WE SAMPLE

- TO CONFIRM COMPLIANCE
- VERIFICATION OF CLEAN UP
- MONITOR CLOSURE ACTIVITIES
- VERIFY WASTE IS NON-HAZARDOUS
- VERIFY HAZARDOUS WASTE MEETS LDR TREATMENT STANDARDS

## SAMPLING RATIONALWHY DO WE SAMPLE

- TO CONFIRM NON-COMPLIANCE
- IMPROPER HAZARDOUS WASTE DETERMINATION
- INDENTIFY SPILLS OF HAZARDOUS MATERIALS
- ILLEGAL DISPOSAL
- IMPROPER HAZARDOUS WASTE MANAGEMENT

## Slide 4

## Slide 5

## Slide 6

## Slide 7

## SAMPLES ARE A CHEMICAL PHOTOGRAPH OF THE SPECIFIC MATERIAL

- LIKE A PHOTOGRAPY, SAMPLE ANLYSIS PROVIDES A PICTURE OF THE CHEMICAL COMPOSITION OF A MATERIAL

## SAMPLE ANALYSIS PROVIDES STRONG SUPPORTING EVIDENCE, BUT SHOULD NEVER BE THE SOLE SOURCE OF EVIDENCE TO PROVE AN AREA OF CONCERN

## SAMPLES ANALYSIS PROVIDES STRONG SUPPORTING EVIDENCE, BUT SHOULD NEVER BE THE SOLE SOURCE OF EVIDENCE TO PROVE AN AREA OF CONCERN

- MSDS FOR MATERIAL IF AVAILABLE
- STATEMENTS FROM FACILITY REPRESENTATIVE
- PHOTOGRAPHS OF THE MATERIAL TO BE SAMPLED
- MANIFEST, BILL OF LADINGS, ETC THAT MAY SHOW HOW MATERIAL HAS BEEN MANAGED IN THE PAST
- OTHER FACILIITY RECORDS SUCH AS INTERNAL MEMOS, LETTERS, PHOTOGRAPHS, AND SAMPLE ANALYSIS

## WHEN IS SAMPLING NECESSARY

- CONFIDENCE IN RESPONSIBLE PARTY TO SAMPLE AND ANALIZE CORRECTLY IS LOW
- SITUATION IS VERY HIGH PROFILE AND VERY LIKEY TO END IN LITIGATION
- ALLEGED AREAS OF CONCERN ARE EXTREMELY SERIOUS AND/OR IMPACT TO THE ENVIRONMENT IS HIGH
- SAMPLE ANALYSIS ARE THE ONLY SOLUTION TO SETTLE OR FINAIZE SITUATION

## WHEN IS IT BEST NOT TO SAMPLE

- FACILITY HAS AGREED TO SAMPLE AND ANALYIZE THE MATERIAL IN QUESTION
- SAMPLE ANALYSIS ARE EXPENSIVE, WE HAVE A LIMITED BUDET. THE AVERAGE SAMPLE EVENT COST $2,000 TO $5,000.
- IN MANY CASES THE FACILITY CAN OBTAIN A FASTER TURN-AROUND TIME ON THE SAMPLES THEN WE CAN.
- IT IS HARD FOR A FACILITY TO DISPUTE THEIR OWN SAMPLE ANALYSIS.  HOWEVER IT IS IMPORTANT THAT FACILITY AGREES THAT SAMPLES ARE REPRESENTATIVE AND THAT CORRECT ANALYSIS WAS PERFORMED.

## WHEN IS IT BEST NOT TO SAMPLE

- THE NECESSARY EQUIPMENT NEEDED TO COLLECT THE SAMPLES IS NOT AVAILABLE.
- CONDITIONS ARE TOO DANGEROUS.

## Slide 14

## Slide 15

## WHEN IS IT BEST NOT TO SAMPLE

- UNCERTAINTY THAT SAMPLING AND ANALYSIS WILL PRODUCE THE RESULTS DESIRED
- MATERIAL IN QUESTION MAY HAVE BEEN ALTERED PRIOR TO SAMPLING
- EX. - PAINT WASTE MAY BE SO OLD THAT IT IS NO LONGER IGNITABLE OR CONTAIN THE SOLVENT THAT WOULD HAVE MADE IT A LISTED WASTE.
- MATERIAL SPILLED MAY NOT MATCH CURRENT MATERIAL IN SUPECTED TANK OR CONTAINER.
- AVAILABLE WASTE MAY NOT BE REPRESENTATIVE OF WASTE STREAM THAT IS IN QUESTION.

## Slide 17

## DECISION HAS BEEN MADE, WE ARE GOING TO TAKE SAMPLES

- WHAT ARE YOUR OBJECTIVES – WHAT DO YOU INTEND TO PROVE WITH THESE ANALYSIS.
- DO YOU HAVE THE NECESSARY EQUIPMENT TO CORRECTLY COLLECT THE SAMPLE.  THIS INCLUDES THE CORRECT PPE.

## DECISION HAS BEEN MADE, WE ARE GOING TO TAKE SAMPLES

- DO YOU HAVE ALL THE INFORMATION NEEDED TO DETERMINE WHAT TO SAMPLE AND WHICH ANALYISIS (METHOD) TO PERFORM
- CHEMICAL AND PHYSICAL STATE OF THE  MATERIAL TO BE SAMPLED.
- IS IT SOLID, LIQUID, OR GAS
- IS IT HOMOGENOUS OR MULTI-PHASED
- A GENERAL IDEA OR SUSPICION OF WHAT THE CONSTITUENTS OF CONCERN WILL BE.
- DOES IT CONTAIN LISTED WASTE CONSTITUENTS OR TCLP CONSTITUENTS OR BOTH - VOLATILES, SEMI-VOLATILES, METALS, CORROSIVES, ETC.

## DECISION HAS BEEN MADE, WE ARE GOING TO TAKE SAMPLES

- HOW MANY SAMPLES WILL YOU NEED TO COLLECT TO OBTAIN YOU OBJECTIVES.
- How many different waste streams are involved.
- How many containers, tanks, etc. are there in question
- DO YOU HAVE THE NECESSARY EQUIPMENT TO CORRECTLY COLLECT THE SAMPLE.  THIS INCLUDES THE CORRECT PPE.

## SITE SPECIFIC SAMPLING PLAN

- IN THE EVENT OF A LARGE SAMPLING PROJECT, SAMPLING PLAN SHOULD BE WRITTEN AND APPROVED PRIOR TO COLLECTION OF SAMPLES.
- IN THE EVENT OF A SMALL OR INPROMPT SAMPLING PROJECT, THE SAMPLING PLAN CAN BE PREPARED ON SITE.
- THIS PLAN CAN BE PREPARED AS AN INDIVIDUAL DOCUMENT OR INCORPORATED ON THE FIELD INTERVIEW FORM (FIF).

## Slide 22

## Slide 23

## CONTENTS OF A SAMPING PLAN

- IDENTIFY SAMPLING SITE(S).
- DESCRIPTION OF FIELD SCREENING TO BE CONDUCTED.
- DESCRIPTION OF WHAT IS TO BE SAMPLED AND HOW MANY SAMPLES ARE TO BE COLLECTED.
- LIST OF ANALYSIS TO BE PERFORMED ON EACH SAMPLE.
- SIZE, TYPE, AND NUMBER OF SAMPLE CONTAINERS TO BE USED FOR EACH SAMPLE.
- DESCRIPTION OF HOW EACH SAMPLE CONTAINER WILL BE LABELED AND WHAT PRESERATIVES (IF ANY) WILL BE USED

## CONTENTS OF A SAMPING PLAN

- DESCRPTION OF SAMPLING TOOLS AND HOW THE EQUIPMENT WILL BE CLEANED BEFORE USE
- TECHNIQUES TO BE EMPLOYED FOR COLLECTING EACH SAMPLE.
- QA/QC PROTOCOL TO BE USED INCLUDING USE AND HANDING OF CHAIN-OF-CUSTODY DOCUMENTS.
- DOCUMENT THE OFFERING AND HANDLING OF SPILT SAMPLES.
- DECONTAMINATION PROCEDURES OF EQUIPMENT, INCLUDING WASTE MANAGEMENT.

## SITE SAFETY PLAN

- LEVEL OF PROTECTION AND TYPE OF PPE TO BE USED AND RATIONALE FOR FINAL DECISION
- IDENTIFY POTENTIAL HAZARDS ESPECIALLY THOSE UNIQUE TO THIS SITE.
- MEDICAL MONITORING
- EMERGENCY PROCEDURES AND PHONE NUMBERS
- DECONTAMINATION OF PERSONEL

## FIELD SCREENING

- INITIAL SURVEY TO INDENTIFY HAZARDS
- VISABLE SITE SURVEY
- AIR MONITORING TO DETERMINE PROPER PPE
- INDENTIFY OTHER POTENTIAL HAZARDS
- HEAVY EQUIPMENT OPERATING IN THE AREA
- PEST SUCH AS DOGS, WASP AND SNAKES
- CONGESTED AREA – STACKED DRUMS, DEBRIS, ETC.

## FIELD SCREENING

- IDENTIFY POTENTIAL SAMPLE TARGETS
- IDENTIFY AREAS THAT ARE VISABLY CONTAMINATED AND MAY ALSO HAVE NOTICEABLE ODORS
- STAINED AND DISCOLORED SOIL
- DEAD OR STRESSED VEGETATION
- ERODED AREAS POSSIBLY CREATED BY SOME TYPE OF DISCHARGE

## FIELD SCREENING

- IDENTIFY POTENTIAL SAMPLE TARGETS
- USE OF AIR MONITORS AND METERS TO NARROW DOWN OR DETERMINE THE CONTAINERS, TANKS, ETC. THAT APPEAR TO CONTAIN THE HIGHEST CONCENTRATION OF CONSTITUENTS-OF-CONCERN
- TVA
- COMBUSTION GAS INDICATOR
- MUTI-GAS DETECTORS (PHD+)
- HALOGEN METER
- PH PAPER
- “DRAGER” TUBES
- SOIL VAPOR SMPLES