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Module 3: Sources Exercise. Objectives of the Sources Exercise. Selecting source type Determining containment for each pathway Identifying substances associated with a source Determining source hazardous waste quantity. What are the HRS Source Types?. What is a source?

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objectives of the sources exercise
Objectives of the Sources Exercise
  • Selecting source type
  • Determining containment for each pathway
  • Identifying substances associated with a source
  • Determining source hazardous waste quantity
what are the hrs source types
What are the HRS Source Types?
  • What is a source?
    • A source is an area where a hazardous substance has been deposited, stored, disposed or placed
    • Soils that became contaminated as the result of hazardous substance migration
  • What are the HRS source types
    • Landfills, surface impoundments, buried/backfilledsurface impoundments, drums, tanks, non-drum containers, land farms, land treatment areas, contaminated soil, other
lpq facility background information
LPQ Facility – Background Information

(continued)

Located on County Route 220 just north and west of the intersection with County Route 228 at Lake White and 1.6 miles west of the city limits of Waverly in Pike County, Ohio.

Pike County is characterized by a cool temperate climate. Summers are warm and humid with daily temperatures reaching 80°F or higher. Daily high temperatures during winter are 25°F to 35°F. Annual precipitation for the area is 40.5 inches and the 2-year, 24-hour rainfall is 2.7 inches.

lpq facility background information1
LPQ Facility – Background Information

(continued)

LPQ property covers 14 acres of relatively flat terrain.

Site slopes from slightly over 600 feet mean sea level (MSL) in the west to about 580 feet MSL along its eastern border with Wintergreen Run, a minimal perennial stream.

An unnamed intermittent tributary of Wintergreen Run borders the northern side of the site.

Hills rise sharply to the west and north.

lpq facility background information2
LPQ Facility – Background Information

(continued)

  • One wetland exists on the LPQ property
    • Between the evaporation pond and Wintergreen Run
    • Extends into the intermittent creek along the northeastern edge of the property
    • On-site drainage system empties into this wetland
    • Is identified on the national wetlands inventory maps
  • A second wetland is downstream of the facility, on both sides of Wintergreen run.
    • No frontage along Lake White
    • Separated from the Lake by a raised gravel walking/biking trail that encompasses all of Lake White and is maintained as part of the Lake White State Park
lpq facility background information3
LPQ Facility – Background Information

(continued)

  • On-site facilities include
    • A small metal casting foundry
    • A milling shop
    • A plastics casting shop
    • An electroplating shop
    • A soldering and welding shop
    • A paint shop and
    • An engine rebuilding and maintenance facility for its fleet of trucks
  • The foundry has been closed since 1978
lpq facility background information4
LPQ Facility – Background Information

(continued)

  • Five identified sources at the site:
    • Large evaporation pond (now backfilled)
    • Existing waste pile on the facility property
    • Former waste pile in a current residential area adjacent to the site
    • Two areas of contaminated soil
      • One on the facility property
      • One in the residential area
  • Drainage ditches run around the facility waste pile and evaporation pond and through one of the areas of contaminated soil and empty into a wetland at the mouth of the intermittent stream.
lpq facility background information5
LPQ Facility – Background Information

(continued)

Founded in 1919 for the manufacture of race car parts for the owner, LouAnne Penelope Quickstep (LPQ).

Expanded as a parts manufacturer with the American automobile industry.

Foundry abandoned in 1978 when new air pollution regulations were enforced.

Company has increasingly relied on plastic casted parts for last 20 years, phasing out the metal casted parts.

In the 1970s, the company consolidated all of its operations at this Ohio facility.

lpq facility background information6
LPQ Facility – Background Information
  • Currently in Chapter 11 bankruptcy reorganization
  • Currently a minimum of four individuals at the facility during the day:
    • Two general maintenance workers
      • Maintain the physical plant
      • Do the yard work
    • Former general manager/owner of the company
    • Secretary/clerk
  • No RCRA permit application ever filed
  • Owner has no intent or money to fund any remedial actions
source characterization lpq facility
Source Characterization – LPQ Facility
  • What sources are located at the LPQ facility?
    • Evaporation pond
    • Existing waste pile (on facility property)
    • Former waste pile (on residential area adjacent to site)
    • Contaminated soil (on facility property)
    • Contaminated soil (on residential area adjacent to site)
source 1 characterization evaporation pond
Source 1 Characterization – Evaporation Pond

(continued)

  • What is the appropriate source type for Source 1 – evaporation pond?
    • Use page 42 of the HRS Guidance Manual to determine source types
source 1 characterization evaporation pond1
Source 1 Characterization – Evaporation Pond

(continued)

Are the source’s location and boundaries adequately described in the text and figures?

source 1 characterization evaporation pond2
Source 1 Characterization – Evaporation Pond

(continued)

  • Location
    • Depicted on the site layout map but called Evaporation Pond instead of a surface impoundment.
  • Boundaries
    • 600 feet long
    • 115 feet wide
    • Depth not provided
    • Length and width are provided on Figure, not depth
source 1 characterization evaporation pond3
Source 1 Characterization – Evaporation Pond

(continued)

  • Evaluating containment – Is Source 1 adequately contained to prevent releases to groundwater?
  • Using information from the SI report, we know….
    • RCRA permit did not mention a liner
    • Groundwater sampling results indicate PCE in MW-3S located immediately downgradient of Source 1
    • Soil sample (Soil-8) contained chromium, lead, DCE and PCE
    • Release is source-specific, solvents disposed of in Source 1
source 1 characterization evaporation pond4
Source 1 Characterization – Evaporation Pond

(continued)

Using HRS Table 3-2, we know…

source 1 characterization evaporation pond5
Source 1 Characterization – Evaporation Pond

(continued)

  • Containment factor value for Source 1 = 10
  • What supporting evidence would you like to have should this factor value be contested?
    • Well documented sampling data including adequate QA/QC
    • Photo documentation showing the surface impoundment was constructed with no liner
source 1 characterization evaporation pond6
Source 1 Characterization – Evaporation Pond

(continued)

  • Hazardous substances attributable to Source 1
    • Using HRS Section 2.2.2, what hazardous substances can be associated with this source and what is your evidence?
source 1 characterization evaporation pond7
Source 1 Characterization – Evaporation Pond

(continued)

  • Possible hazardous substances:
    • PCE – Attributable based on manufacturer’s information and sample results from Soil-8
    • DCE – Attributable based on being a breakdown product of PCE
      • Should provide a reference like the ATSDR Toxicological profile for PCE to document this
    • Chromium – Attributable as a constituent in foundry sand and also used in metal plating operations
    • Lead – Attributable as a constituent in foundry sand
    • Benzene – Attributable based on manufacture’s information
source 1 characterization evaporation pond tier a
Source 1 Characterization – Evaporation Pond – Tier A
  • Is there enough information to evaluate the evaporation pond under Tier A?
    • Yes
    • No
  • There is not enough information to adequately determine Tier A for the evaporation pond
    • No mass of CERCLA hazardous substances in the source
    • No concentration data
  • Tier A = 0
source 1 characterization evaporation pond tier b
Source 1 Characterization – Evaporation Pond – Tier B

(continued)

  • 1980 to 1986 LPQ purchased Disolv-O-Grease
    • Mass of 10 pounds per gallon
    • Purchased Disolv-O-Grease at a rate of about 10 gallons per week for about 50 weeks each year
  • During this 7-year period, LPQ generated about 200 gallons of waste that contained Disolv-O-Grease
  • Is there enough information to evaluate the evaporation pond under Tier B?
    • Yes
    • No
source 1 characterization evaporation pond tier b1
Source 1 Characterization – Evaporation Pond – Tier B

(continued)

  • Yes there is and here is how you do it:
    • 200 gal/week for 7 years
    • 190 gal = water, 10 gal = waste
    • 190 gal x 8.34 lbs/gal = 1,584.6 lbs
    • 10 gal x 10 lbs/gal = 100 lbs
    • 1,584.6 lbs + 100 lbs = 1,684.6 lbs
    • 1,684.6 lbs / 200 gal = 8.42 lbs/gal = average mass of wastestream
    • 200 gal/wk x 8.42 lbs/gal x 50 wks/yr x 7 yrs = 589,400 lbs
source 1 characterization evaporation pond tier b2
Source 1 Characterization – Evaporation Pond – Tier B

Use HRS Table 2-5 to determine appropriate factor

589,400 lbs / 5,000 lbs = 117.88

Tier B = 117.88

source 1 characterization evaporation pond tier c
Source 1 Characterization – Evaporation Pond – Tier C

(continued)

  • Is there enough information to evaluate the evaporation pond under Tier C?
    • Yes
    • No
  • What do we know…
    • Length = 600 feet
    • Width = 115 feet
    • Depth unknown but can use a conservative estimate of 1 foot
source 1 characterization evaporation pond tier c1
Source 1 Characterization – Evaporation Pond – Tier C
  • Yes there is and here is how you do it:
    • 600 ft x 115 ft x 1 ft = 69,000 ft3
    • 69,000 ft3 / 27 ft3/yd3 = 2,555.56 yd3
  • Use HRS Table 2-5 to determine appropriate factor
    • 2,555.56 yd3 / 2.5 yd3 = 1,022.22
  • Tier C = 1,022.22
source 1 characterization evaporation pond tier d
Source 1 Characterization – Evaporation Pond – Tier D

(continued)

  • Is there enough information to evaluate the evaporation pond under Tier D?
    • Yes
    • No
  • What do we know…
    • Length = 600 feet
    • Width = 115 feet
source 1 characterization evaporation pond tier d1
Source 1 Characterization – Evaporation Pond – Tier D
  • Yes there is and here is how you do it:
    • 600 ft x 115 ft = 69,000 ft2
  • Use HRS Table 2-5 to determine the appropriate factor
    • 69,000 ft2 / 13 ft2 = 5,307.69
  • Tier D = 5,307.69
source 1 characterization evaporation pond hazardous waste quantity
Source 1 Characterization – Evaporation Pond – Hazardous Waste Quantity
  • Select the highest hazardous waste quantity from the four tiers and assign it as the source hazardous waste quantity
    • Tier A = 0
    • Tier B = 117.88
    • Tier C = 1,022.22
    • Tier D = 5,307.69
  • Source hazardous waste quantity for the evaporation pond is 5,307.69 (Tier D)
source 2 characterization contaminated soil on facility
Source 2 Characterization – Contaminated Soil on Facility

(continued)

An area of discolored soil lies along the drainage ditch to the east of the parking lot, extending from the drainage tile under the driveway down into the intermittent creek.

At the drainage tile, the soil was stained orange, which faded to green as distance from the drain increased.

The bottom of the intermittent creek below the point of intersection with the ditch to the point of intersection with Wintergreen Run was also stained orange, and no vegetation was visible on the rocks and gravel, in contrast with about 100 feet above the intersection.

source 2 characterization contaminated soil on facility1
Source 2 Characterization – Contaminated Soil on Facility

(continued)

  • The concrete base of the building on the other side of the driveway was also stained and eroded, and a broken pipe leading to the drainage tile extended from the building wall.
    • This portion of the building formerly contained the metal plating operation.
    • The drainage pipe was observed inside the building to be connected to the floor drains for the electroplating baths.
source 2 characterization contaminated soil on facility2
Source 2 Characterization – Contaminated Soil on Facility
  • What is the appropriate source type for Source 2 – contaminated soil located on the facility property?
    • Use page 42 of the HRS Guidance Manual to determine source type

(continued)

source 2 characterization contaminated soil on facility4
Source 2 Characterization – Contaminated Soil on Facility

(continued)

Are the source’s location and boundaries adequately described in the text and figures?

source 2 characterization contaminated soil on facility5
Source 2 Characterization – Contaminated Soil on Facility

(continued)

  • Location
    • The area of contaminated soil is not specifically labeled on the site layout map, however, soil samples are labeled on the map which indicate the location of the contaminated soil
  • Boundaries
    • 12 to 20 feet wide
    • 300 feet long
source 2 characterization contaminated soil on facility6
Source 2 Characterization – Contaminated Soil on Facility

(continued)

  • Evaluating containment – Is Source 2 adequately contained to prevent releases to groundwater?
  • Using information from the SI report, we know…
    • Soil samples Soil-5 and Soil-6 contained concentrations of chromium, lead, and zinc in the surface soils
    • Stained soils were also observed in this area
  • Using HRS Table 3-2, we know…
source 2 characterization contaminated soil on facility7
Source 2 Characterization – Contaminated Soil on Facility

(continued)

Using HRS Table 3-2, we know…

source 2 characterization contaminated soil on facility8
Source 2 Characterization – Contaminated Soil on Facility

(continued)

  • Containment factor value for Source 2 = 10
  • What supporting evidence would you like to have should this factor value be contested?
    • Well documented sampling data with adequate QA/QC
    • Photographic documentation showing the stained soil
  • Possible hazardous substances:
    • Chromium – Attributable as a constituent of foundry sand and also used in metal plating operations
    • Lead – Attributable as a constituent of foundry sand
    • PCB – Used in automobile parts manufacturing
source 2 characterization contaminated soil on facility9
Source 2 Characterization – Contaminated Soil on Facility

(continued)

  • Is there enough information to evaluate the facility contaminated soil under Tier A?
    • Yes
    • No
  • No concentration data
  • Tier A = 0
source 2 characterization contaminated soil on facility10
Source 2 Characterization – Contaminated Soil on Facility

(continued)

  • Is there enough information to evaluate the facility contaminated soil under Tier B?
    • Yes
    • No
  • Mass of wastestream unknown
  • Tier B = 0
source 2 characterization contaminated soil on facility11
Source 2 Characterization – Contaminated Soil on Facility

(continued)

  • Is there enough information to evaluate the facility contaminated soil under Tier C?
    • Yes
    • No
  • What do we know…
    • Length = 300 feet
    • Width = 12 feet
    • Depth unknown but stained soil is at the surface, typically about 6 inches deep
source 2 characterization contaminated soil on facility12
Source 2 Characterization – Contaminated Soil on Facility

(continued)

  • Yes there is and here is how you do it:
    • 12 ft x 300 ft x 0.5 ft = 1,800 ft3
    • 1,800 ft3 ÷ 27 ft3/yd3 = 66.67 yd3
  • Use HRS Table 2-5 to determine appropriate factor
source 2 characterization contaminated soil on facility13
Source 2 Characterization – Contaminated Soil on Facility

(continued)

  • HRS Table 2-5:
    • 66.67 yd3 / 2,500 yd3 = 0.0267
  • Tier C = 0.0267
source 2 characterization contaminated soil on facility14
Source 2 Characterization – Contaminated Soil on Facility

(continued)

  • Is there enough information to evaluate the facility contaminated soil under Tier D?
    • Yes
    • No
  • What do we know…
    • Length = 300 feet
    • Width = 12 feet
source 2 characterization contaminated soil on facility15
Source 2 Characterization – Contaminated Soil on Facility

(continued)

  • Yes there is and here is how you do it:
    • 300 ft x 12 ft = 3,600 ft2
  • Use HRS Table 2-5 to determine the appropriate factor
    • 3,600 ft2 / 34,000 ft2 = 0.1059
  • Tier D = 0.1059
source 2 characterization contaminated soil on facility16
Source 2 Characterization – Contaminated Soil on Facility
  • Select the highest hazardous waste quantity from the four tiers and assign it as the source hazardous waste quantity
    • Tier A = 0
    • Tier B = 0
    • Tier C = 0.0267
    • Tier D = 0.1059
  • Source hazardous waste quantity for the contaminated soil on the facility is 0.1059 (Tier D)
source 3
Source 3
  • Based on a review of aerial photographs, and verified during discussions with the two maintenance workers at LPQ during the initial site investigation, the EPA learned that LPQ once used the area immediately north of the facility as a storage area.
  • During the SI field effort, it was noted that this area was now the location of six residences:
    • Three homes and three trailers
  • In walking through this area, the following was also observed:
    • A waste area consisting of a pile of rusty barrels and other packaging near the end of the local dirt road
    • Several areas did not support vegetation, especially along the drainage swales originating at the pile and running along the dirt road
source 3 characterization residential soil
Source 3 Characterization – Residential Soil

(continued)

  • Based on these observations, EPA decided to undertake a focused SI to sample this area
    • Collection of six additional soil samples
    • Waste area was no longer present when the field team returned to the site but an additional soil sample was taken at the former waste area location.
  • The contaminated soil in the residential area is 800 feet by 10 feet
source 3 characterization residential soil2
Source 3 Characterization – Residential Soil

(continued)

  • What is the appropriate source type for Source 3 – residential soil area?
    • Use page 42 of the HRS Guidance Manual to determine source type
source 3 characterization residential soil3
Source 3 Characterization – Residential Soil

(continued)

  • Are the source’s location and boundaries adequately described in the text and figures?
  • Location
    • The area of residential contaminated soil is identified on figure 6 of the SI report.
  • Boundaries
    • 800 feet wide
    • 10 feet long
source 3 characterization residential soil4
Source 3 Characterization – Residential Soil

(continued)

  • Evaluating containment – Is Source 3 adequately contained to prevent releases to groundwater?
  • Using information from the SI report, we know…
    • Soil samples Soil-5 and Soil-6 contained concentrations of chromium, lead and zinc in the surface soils
    • Stained soils were also observed in this area
  • Using HRS Table 3-2, we know…
source 3 characterization residential soil5
Source 3 Characterization – Residential Soil

(continued)

Using HRS Table 3-2, we know…

source 3 characterization residential soil6
Source 3 Characterization – Residential Soil

(continued)

  • Containment factor value for Source 3 = 10
    • Stained soil area can be traced back to the former waste pile
    • Sampling results from the stained soil indicate the presence of hazardous substances
  • What supporting evidence would you like to have should this factor value be contested?
    • Well documented sampling data including adequate QA/QC
    • Photo documentation showing the stained soil
  • Possible hazardous substances:
    • PCBs – Used in automobile parts manufacturing
source 3 characterization residential soil7
Source 3 Characterization – Residential Soil

(continued)

  • Is there enough information to evaluate the residential contaminated soil under Tier A?
    • Yes
    • No
  • No concentration data
  • Tier A = 0
source 3 characterization residential soil8
Source 3 Characterization – Residential Soil

(continued)

  • Is there enough information to evaluate the residential contaminated soil under Tier B?
    • Yes
    • No
  • Mass of wastestream unknown
  • Tier B = 0
source 3 characterization residential soil9
Source 3 Characterization – Residential Soil

(continued)

  • Is there enough information to evaluate the residential contaminated soil under Tier C?
    • Yes
    • No
  • What do we know…
    • Length = 10 feet
    • Width = 800 feet
    • Depth unknown but stained soil is at the surface, typically about 6 inches deep
source 3 characterization residential soil10
Source 3 Characterization – Residential Soil

(continued)

  • Yes there is and here is how you do it:
    • 10 ft x 800 ft x 0.5 ft = 4,000 ft3
    • 4,000 ft3 ÷27 ft3/yd3 = 148.15 yd3
  • Use HRS Table 2-5 to determine appropriate factor
source 3 characterization residential soil11
Source 3 Characterization – Residential Soil

(continued)

  • HRS Table 2-5:
    • 148.15 yd3 / 2,500 yd3 = 0.0593
  • Tier C = 0.0593
source 3 characterization residential soil12
Source 3 Characterization – Residential Soil

(continued)

  • Is there enough information to evaluate the residential contaminated soil under Tier D?
    • Yes
    • No
  • What do we know…
    • Length = 10 feet
    • Width = 800 feet
source 3 characterization residential soil13
Source 3 Characterization – Residential Soil

(continued)

  • Yes there is and here is how you do it:
    • 10 ft x 800 ft= 8,000 ft2
  • Use HRS Table 2-5 to determine the appropriate factor
    • 8,000 ft2 / 34,000 ft2 = 0.2353
  • Tier D = 0.2353
source 3 characterization residential soil14
Source 3 Characterization – Residential Soil
  • Select the highest hazardous waste quantity from the four tiers and assign it as the source hazardous waste quantity
    • Tier A = 0
    • Tier B = 0
    • Tier C = 0.0593
    • Tier D = 0.2353
  • Source hazardous waste quantity for the residential contaminated soil is 0.2353 (Tier D)
source 4 facility waste pile
Source 4 – Facility Waste Pile

(continued)

  • Composed mainly of foundry sand and contains remnants of sand castings
  • Sides are extensively eroded and waste material is exposed
  • Top supports a sparse cover of vegetation
  • Drainage ditches were observed around the pile
    • Workers stated ditches are inspected weekly and repaired as necessary
  • No trees or other form of windbreak are located around the facility pile
  • No response from the biogas detector was observed during the site inspection
source 4 facility waste pile1
Source 4 – Facility Waste Pile

(continued)

  • When investigating the edges of the facility pile, State personnel reported that they could identify that the pile had been used for disposal of all types of solid waste, including:
    • 5-gallon containers
      • Labels indicated chlorinated solvents and paint
    • Cardboard boxes
    • Metal shavings
    • Rags
    • Used car parts
    • Food containers
source 4 facility waste pile2
Source 4 – Facility Waste Pile

(continued)

  • Soil-7
    • Collected through the thickness of the facility pile.
    • Sample results indicated that chromium, PCE and DCE were present at different sampling intervals (intervals sampled were 0 to 1 foot, 5 to 6 feet and 10 to 11 feet.
    • Drillers indicated organic smells and, based on the soil core log, the presence of ashes, suggesting that the facility pile formerly was burned.
  • RP-2
    • Shallow groundwater sample alongside the facility pile
    • Contaminated with similar substances as found in the pile
source 4 facility waste pile3
Source 4 – Facility Waste Pile

(continued)

According to the unfiled RCRA permit application, the facility pile is 300 feet by 250 feet.

Pile extends about 10 feet above the surface and is basically trapezoidal in shape, with approximately 30 percent slopes on its edges, extending to the soil surface.

The pile rests on native soil with no liner.

Description is consistent with what was observed during the site inspection.

source 4 facility waste pile5
Source 4 – Facility Waste Pile

(continued)

  • What is the appropriate source type for Source 4 – facility waste pile?
    • Use page 42 of the HRS Guidance Manual to determine source type
source 4 facility waste pile6
Source 4 – Facility Waste Pile
  • Are the source’s location and boundaries adequately described in the text and figures?
  • Location
    • The facility waste pile is identified on figure 7 of the SI report.
  • Boundaries
    • 250 feet long
    • 300 feet wide
    • Depth unknown
source 4 facility waste pile7
Source 4 – Facility Waste Pile

(continued)

  • Evaluating containment – Is Source 4 adequately contained to prevent releases to groundwater?
  • Using information from the SI report, we know…
    • Pile is composed mainly of foundry sand and remnants of sand castings
    • Sides or extensively eroded and waste material is exposed
    • Soil sample Soil-7 collected from the pile contained hazardous substances including PCE, DCE and chromium
  • Using HRS Table 3-2, we know…
source 4 facility waste pile8
Source 4 – Facility Waste Pile

(continued)

Using HRS Table 3-2, we know…

source 4 facility waste pile9
Source 4 – Facility Waste Pile

(continued)

  • Containment factor value for Source 4 = 10
    • No liner present
    • Sampling results from the pile indicate the presence of hazardous substance migration
  • What supporting evidence would you like to have should this factor value be contested?
    • Well documented sampling data including adequate QA/QC
    • Photo documentation showing erosion of the pile
  • Possible hazardous substances:
    • PCE – from Soil-7 sample and facility operations
    • DCE – from Soil-7 sample and facility operations
    • Chromium – from Soil-7 sample and facility operations
source 4 facility waste pile10
Source 4 – Facility Waste Pile

(continued)

  • Is there enough information to evaluate the facility waste pile under Tier A?
    • Yes
    • No
  • No concentration data
  • Tier A = 0
source 4 facility waste pile11
Source 4 – Facility Waste Pile

(continued)

  • Is there enough information to evaluate the facility waste pile under Tier B?
    • Yes
    • No
  • Mass of wastestream unknown
  • Tier B = 0
source 4 facility waste pile12
Source 4 – Facility Waste Pile

(continued)

  • Is there enough information to evaluate the facility waste pile under Tier C?
    • Yes
    • No
source 4 facility waste pile13
Source 4 – Facility Waste Pile

(continued)

  • Is there enough information to evaluate the facility waste pile under Tier D?
    • Yes
    • No
  • What do we know…
    • Length = 250 feet
    • Width = 300 feet
source 4 facility waste pile14
Source 4 – Facility Waste Pile

(continued)

  • Yes there is and here is how you do it:
    • 250 ft x 300 ft= 75,000 ft2
  • Use HRS Table 2-5 to determine the appropriate factor
    • 75,000 ft2 / 13 ft2 = 5,769.23
  • Tier D = 5,769.23
source 4 facility waste pile15
Source 4 – Facility Waste Pile
  • Select the highest hazardous waste quantity from the four tiers and assign it as the source hazardous waste quantity
    • Tier A = 0
    • Tier B = 0
    • Tier C = 0
    • Tier D = 5,769.23
  • Source hazardous waste quantity for the facility waste pile is 5,769.23 (Tier D)
source 5 residential waste pile1
Source 5 – Residential Waste Pile

(continued)

Identified based on interviews with employees and review of aerial photographs

Currently no longer exists

Residential pile was approximately 30 feet by 30 feet

During the focused SI, the approximate center of the residential pile was sampled

source 5 residential waste pile2
Source 5 – Residential Waste Pile

(continued)

  • What is the appropriate source type for Source 5 – residential waste pile?
    • Use page 42 of the HRS Guidance Manual to determine source type
source 5 residential waste pile3
Source 5 – Residential Waste Pile

(continued)

  • Are the source’s location and boundaries adequately described in the text and figures?
  • Location
    • The residential waste pile is identified on figure 6 of the SI report.
  • Boundaries
    • 30 feet long
    • 30 feet wide
source 5 residential waste pile4
Source 5 – Residential Waste Pile

(continued)

  • Evaluating containment – Is Source 5 adequately contained to prevent releases to groundwater?
  • Using information from the SI report, we know…
    • Pile observed on past aerial photographs of the site
    • Soil sample Soil-A collected from the pile contained hazardous substances including PCBs
  • Using HRS Table 3-2, we know…
source 5 residential waste pile5
Source 5 – Residential Waste Pile

(continued)

Using HRS Table 3-2, we know…

source 5 residential waste pile6
Source 5 – Residential Waste Pile

(continued)

  • Containment factor value for Source 5 = 10
    • Sampling results from the pile indicate the presence of hazardous substance migration
  • What supporting evidence would you like to have should this factor value be contested?
    • Well documented sampling data including adequate QA/QC
    • Photo documentation showing the evidence of the former waste pile
  • Possible hazardous substances:
    • PCB – from Soil-A sample and facility operations
source 5 residential waste pile7
Source 5 – Residential Waste Pile

(continued)

  • Is there enough information to evaluate the residential waste pile under Tier A?
    • Yes
    • No
  • No concentration data
  • Tier A = 0
source 5 residential waste pile8
Source 5 – Residential Waste Pile

(continued)

  • Is there enough information to evaluate the residential waste pile under Tier B?
    • Yes
    • No
  • Mass of wastestream unknown
  • Tier B = 0
source 5 residential waste pile9
Source 5 – Residential Waste Pile

(continued)

  • Is there enough information to evaluate the residential waste pile under Tier C?
    • Yes
    • No
source 5 residential waste pile10
Source 5 – Residential Waste Pile

(continued)

  • Is there enough information to evaluate the residential waste pile under Tier D?
    • Yes
    • No
  • What do we know…
    • Length = 30 feet
    • Width = 30 feet
source 5 residential waste pile11
Source 5 – Residential Waste Pile

(continued)

  • Yes there is and here is how you do it:
    • 30 ft x 30 ft= 900 ft2
  • Use HRS Table 2-5 to determine the appropriate factor
    • 900 ft2 / 13 ft2 = 69.23
  • Tier D = 69.23
source 5 residential waste pile12
Source 5 – Residential Waste Pile
  • Select the highest hazardous waste quantity from the four tiers and assign it as the source hazardous waste quantity
    • Tier A = 0
    • Tier B = 0
    • Tier C = 0
    • Tier D = 69.23
  • Source hazardous waste quantity for the facility waste pile is 69.23 (Tier D)
source characterization source hwq
Source Characterization – Source HWQ

If you have multiple sources at a site, you determine the HWQ for all sources, add those together and assign the source hazardous waste quantity factor value

source characterization overall pathway hwq factor
Source Characterization – Overall Pathway HWQ Factor

a If the HWQ value is greater than 0, but less than 1, round it to 1 as specified in text

bForthe pathway, if hazardous constituent quantity is not adequately determined, assign a value as specified in the text; do not assign the value of 1.

(continued)

Use HRS Table 2-6 to determine the overall pathway HWQ factor value for the LPQ facility

source characterization overall pathway hwq factor1
Source Characterization – Overall Pathway HWQ Factor

Total HWQ for LPQ = 11,146.49

Using HRS Table 2-6, the source HWQ for LPQ = 10,000

source characterization waste characteristics factor category for a pathway
Source Characterization – Waste Characteristics Factor Category for a Pathway

(continued)

  • Select the most hazardous substance for the pathway being evaluated
    • Differs depending on the pathway
  • Multiply the toxicity or combined factor for the most hazardous substance for the pathway by the HWQ factor for the pathway
  • Use Table 2-7 to assign a value to the sum of the most hazardous substance and HWQ factor
source characterization
Source Characterization
  • Things to keep in mind
    • Ensure that the hazardous waste quantity for each source is correctly calculated and assumptions are properly documented and supported by primary reference materials
    • Show all intermediate calculations
next webinar session march 25 2014
Next Webinar Session – March 25, 2014
  • Module 4 of the Webinar Series:
    • Tuesday, March 25, 2014 from 1:00 p.m. to 3:00 p.m. Eastern
    • Will provide an overview of the groundwater pathway and will explain how it is evaluated and scored using the HRS.