Download version 0.1 of EM 1110-1-4006 Removal of Underground Storage Tanks USTs.pdf

Download version 0.1 of EM 1110-1-4006 Removal of Underground Storage Tanks USTs.pdf
CEMP-RT
Department of the Army
EM 1110-1-4006
U.S. Army Corps of Engineers
Engineer Manual
1110-1-4006
Washington, DC 20314-1000
Engineering and Design
REMOVAL OF UNDERGROUND
STORAGE TANKS (USTs)
Distribution Restriction Statement
Approved for public release; distribution is
unlimited.
30 September 1998
EM 1110-1-4006
30 September 1998
ENGINEERING AND DESIGN
Removal of Underground
Storage Tanks (USTs)
ENGINEER MANUAL
AVAILABILITY
Electronic copies of this and other U.S. Army Corps of
Engineers (USACE) publications are available on the
Internet at http://www.usace.army.mil/inet/usace-docs/.
This site is the only repository for all official USACE
engineer regulations, circulars, manuals, and other
documents originating from HQUSACE. Publications are
provided in portable document format (PDF).
DEPARTMENT OF THE ARMY
U.S. Army Corps of Engineers
Washington, D.C. 20314-1000
CEMP-RT
Manual
No. 1110-l-4006
EM 1110-l-4006
30 September 1998
Engineering and Design
REMOVAL OF UNDERGROUND STORAGE TANKS (USTs)
1. Purpose. The primary purpose of this Engineer Manual (EM) is to provide practical guidance for
removal of underground storage tanks (USTs). The manual addresses site evaluation, monitoring, testing,
removal, and site restoration. A secondary purpose is to provide information relative to remediation of
contaminated soil and groundwater.
2. Applicability. This EM applies to all USACE commands having Civil Works and/or Military Programs
with hazardous, toxic, or radioactive waste (HTRW) project responsibilities.
3. References. References are provided in Appendix A.
4. Distribution. Approved for public release, distribution is unlimited.
5. Discussion. This manual addresses tanks subject to Resource Conservation and Recovery Act
(RCRA) Subtitle I undergroundstorage tanks requirements, and is not intended for use in the
management of tanks that have stored RCRA Subtitle C hazardous wastes. Each UST project
progresses through an orderly sequence of phases. These phases include initial data gathering, initial
field investigations, tank removal, and site remediation. This manual is intended to guide qualified
technical personnel through the activities associated with each phase and provides steps for preparing
UST removal contract documents. This EM will help the designer to incorporate the proper requirements
into the project documents.
FOR THE COMMANDER:
5 Appendices
(See Table of Contents)
Chief of Staff
This manual supersedes EM 1110-3-178, dated 31 August 1993.
DEPARTMENT OF THE ARMY
U.S. Army Corps of Engineers
Washington, DC 20314-1000
CEMP-RT
Manual
No. 1110-1-4006
EM 1110-1-4006
30 September 1998
Engineering and Design
REMOVAL OF UNDERGROUND STORAGE TANKS (USTs)
Table of Contents
Subject
CHAPTER 1.
Scope
Quality Assurance/Quality Control
Closure Requirements
Definitions and Acronyms
Regulations
Job Qualifications and Training
Corrective Action Planning
Plan of Work
Report Requirements
CHAPTER 2.
Page
1-1
1-2
1-3
1-4
1-5
1-6
1-7
1-8
1-9
1-1
1-1
1-2
1-2
1-6
1-8
1-9
1-12
1-13
2-1
2-2
2-3
2-4
2-5
2-6
2-7
2-8
2-9
2-1
2-1
2-1
2-1
2-1
2-1
2-1
2-2
2-2
3-1
3-2
3-3
3-4
3-5
3-1
3-1
3-5
3-5
3-8
SITE COORDINATION
General
Environmental Coordinator
Site Representative
Utilities
Transportation Routes and Traffic
Fire Department Notification
Regulatory Agency
Excavations
Cultural Resources
CHAPTER 3.
Paragraph
GENERAL
TANK TIGHTNESS TESTING PROCEDURES
General
Methods
Regulations
Test Procedures
Precautions
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EM 1110-1-4006
30 SEP 98
Subject
Equipment
Materials
Operations, Procedures, and Instructions
Waste Disposal
Reporting and Documentation
CHAPTER 4.
4-1
4-1
4-2
4-2
4-5
4-6
5-1
5-2
5-3
5-4
5-5
5-6
5-7
5-8
5-1
5-1
5-6
5-20
5-24
5-25
5-26
5-26
6-1
6-2
6-3
6-4
6-5
6-6
6-7
6-1
6-1
6-2
6-7
6-9
6-10
6-10
7-1
7-2
7-1
7-2
SAMPLING DURING UST REMOVAL PROCEDURE
General
Field Screening for Soil Samples
Soil Sampling
Free Product Sampling
Waste Disposal
Reporting and Documentation Requirement
Department of Transportation Sample
Shipping Requirements
CHAPTER 7.
4-1
4-2
4-3
4-4
4-5
4-6
SITE CHARACTERIZATION
General
Subsurface Soil Gas Survey
Borehole Drilling/Soil Sampling
Well Installation
Aquifer Testing
Soil Testing
Survey
Waste Disposal
CHAPTER 6.
Page
3-10
3-11
3-11
3-13
3-13
UNDERGROUND STORAGE TANK (UST) INVESTIGATIVE REQUIREMENTS
General
Tank History/Information
Regulatory Issues
Tank Locations
Site Reconnaissance
Tank Contents Sampling
CHAPTER 5.
Paragraph
3-6
3-7
3-8
3-9
3-10
SITE SAFETY AND HEALTH PLAN REQUIREMENTS
General
Submittals
ii
EM 1110-1-4006
30 SEP 98
Subject
Medical Surveillance
Safety and Health Training
Personal Protective Equipment and Programs
Exposure Monitoring/Air Sampling Program
(Personal and Environmental)
Heat/Cold Stress Monitoring
Standard Operating Safety Procedures, Engineering
Controls, and Work Practices
Site Control Measures
Personal Hygiene and Decontamination
Equipment Decontamination
Emergency Equipment and First-Aid Requirements
Emergency Response and Contingency Procedures
(Onsite and Offsite)
Occupational Safety and Health Hazards Associated
With Tank Removal Processes
Logs, Reports, and Recordkeeping
CHAPTER 8.
Paragraph
7-3
7-4
7-5
7-6
7-7
7-9
7-18
7-8
7-9
7-10
7-11
7-12
7-18
7-31
7-32
7-33
7-33
7-13
7-36
7-14
7-15
7-37
7-40
8-1
8-2
8-3
8-4
8-5
8-6
8-7
8-8
8-9
8-1
8-1
8-2
8-9
8-14
8-14
8-14
8-14
8-16
9-1
9-2
9-3
9-4
9-5
9-6
9-1
9-1
9-1
9-1
9-4
9-4
SAMPLING AND ANALYSIS PLAN REQUIREMENTS
General
Plan Contents
Sample Packaging, Shipping and Chain-of-Custody
Sample Analysis and Data Reporting
Commercial Analytical Laboratory
Government Analytical Laboratories
Quality Assurance Laboratory
Sample Numbering System
Sample Documentation
CHAPTER 9.
Page
7-4
7-4
7-6
GENERAL EQUIPMENT DECONTAMINATION PROCEDURES
General
Precautions
Equipment
Operation, Procedures, and Instructions
Waste Disposal and Recyling
Waste Minimization During Decontamination Operations
iii
EM 1110-1-4006
30 SEP 98
Subject
CHAPTER 10. COMBUSTIBLE GAS MONITORING PROCEDURES
General
Precautions
Operations, Procedures, and Instructions
Paragraph
Page
10-1
10-2
10-3
10-1
10-2
10-2
11-1
11-2
11-3
11-4
11-1
11-1
11-3
11-6
12-1
12-2
12-3
12-4
12-1
12-1
12-2
12-5
13-1
13-2
13-3
13-4
13-5
13-1
13-1
13-16
13-18
13-18
14-1
14-2
14-3
14-1
14-1
14-2
14-4
14-4
CHAPTER 11. ORGANIC VAPOR MONITORING PROCEDURES
General
Precautions
PID Operations, Procedures, and Instructions
FID Operations, Procedures, and Instructions
CHAPTER 12. PRODUCT REMOVAL PROCEDURES
General
Operations, Procedures, and Instructions
Equipment
Waste Disposal and Recycling
CHAPTER 13. UNDERGROUND STORAGE TANK REMOVAL PROCEDURES
General
Removal of Underground Tanks
Tank Disposal
Waste Disposal and Recycling
Tank Coating Issues
CHAPTER 14. SLUDGE REMOVAL PROCEDURES
General
Operations, Procedures, and Instructions
Waste Disposal and Recycling
Reporting and Documentation Requirements Hazardous Waste
CHAPTER 15. SOIL REMOVAL, FREE-PRODUCT REMOVAL, AND BACKFILLING PROCEDURES
General
Precautions
15-1
15-2
iv
15-1
15-1
EM 1110-1-4006
30 SEP 98
Subject
Equipment
Soil Removal
Free Product Removal
Backfill, Compaction, and Testing
Special Waste Requirements
Paragraph
15-3
15-4
15-5
15-6
15-7
Page
15-2
15-2
15-6
15-6
15-8
CHAPTER 16. SITE RESTORATION PROCEDURES
General
Soil Remediation Processes
Backfill
Groundwater Remediation Processes
Waste Disposal
16-1
16-2
16-3
16-4
16-5
16-1
16-1
16-2
16-4
16-6
APPENDIX A. REFERENCES
A-1
APPENDIX B. STATE REGULATORY AGENCY CONTACTS
B-1
APPENDIX C. WELL OPENING PROCEDURES
C-1
APPENDIX D. HEAT/COLD STRESS MONITORING
D-1
APPENDIX E. CONFINED SPACE ENTRY
E-1
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EM 1110-1-4006
30 SEP 98
LIST OF FIGURES
Page
Figure
1-1
1-2
1-3
5-1
8-1
8-2
Flowchart for Clean Tank Closure
Flowchart for Leaking Tank Closure
UST Closure Checklist
Typical Soil-Gas Apparatus
Example of Sample Tag or Label
Example Chain of Custody Record Format
vi
1-4
1-5
1-11
5-5
8-4
8-8
EM 1110-1-4006
30 SEP 98
LIST OF TABLES
Table
3-1
3-2
3-3
4-1
4-2
4-3
5-1
7-1
7-2
8-1
8-2
8-3
10-1
11-1
11-2
11-3
13-1
13-2
14-1
15-1
D-1
E-1
Volumetric Leak Testing Methods
Nonvolumetric Leak Testing Methods
Major Variables Affecting Leak Detection
Geophysical Methods
Physicochemical Properties of Six Common
Hydrocarbon Mixtures
Used Oil Specification
Drilling Methods
Personal Protective Equipment
Action Levels for CGI Monitoring
Methods for Determination of Metals
Methods for Determination of Nonmetallic Analytes
Summary of Sample Container, Preservation, and
Maximum Holding Times
Combustible Gas Indicator (CGI) Equipment
and Supplies Checklist
Comparison of the FID and PID
Photoionization Detector (PID) Equipment and
Supplies Checklist
Flame Ionization Detector (FID) Equipment and
Supplies Checklist
Procedures for Purging Tanks
Procedures for Inerting Tanks
Procedures for Sludge Removal
Estimated Quantity of Soil to be Removed by
Tank Size (Average)
Cooling Power on Exposed Flesh Expressed as an
Equivalent Temperature under Calm Conditions
Confined Space Entry Permit
vii
Page
3-2
3-3
3-7
4-4
4-8
4-10
5-7
7-8
7-29
8-10
8-11
8-15
10-4
11-2
11-4
11-8
13-2
13-8
14-3
15-4
D-7
E-4
EM 1110-1-4006
30 SEP 98
CHAPTER 1
GENERAL
1-1. Scope. The manual covers tanks subject to Resource Conservation and
Recovery Act (RCRA) Subtitle I underground storage tank requirements and is
not intended for use in the management of remediation projects for tanks that
are believed to have been used to store RCRA Subtitle C hazardous wastes.
(Note: There is a regulatory distinction between a tank used to store
ignitable fuels and a tank used to store hazardous waste. Subtitle I, not
Subtitle C, applies to product tanks, even though hazardous wastes may be
generated from the tank upon removal from service. Therefore, generation of
hazardous waste from a tank does not preclude the use of this EM.)
Each UST project progresses through an orderly sequence of phases. These
phases include initial data gathering, initial field investigations, tank
removal, and site remediation. This manual will describe the activities
associated with each phase. It is intended to guide qualified technical
personnel who prepare UST removal contract documents. It will discuss how to
perform the necessary activities. Corps of Engineers Guide Specifications
(CEGS) 01351 Safety, Health, and Emergency Response (HTRW/UST), 01450 Chemical
Data Quality Control, 02115 Underground Storage Tank Removal, 02120
Transportation and Disposal of Hazardous Materials are to be used with this
manual. Additional references are included in Appendix A.
1-2. Quality Assurance/Quality Control. This engineering manual will help
the designer to incorporate the proper requirements for a quality job into the
project documents. This includes incorporating the safety and health
requirements of EM 385-1-1 Safety and Health Requirements Manual, ER 385-1-92
Safety and Occupational Health Document Requirements for Hazardous, Toxic and
Radioactive Waste (HTRW) and Ordnance and Explosive Waste (OEW) Activities
during removal activities. The requirements of ER 1110-1-263 Chemical Data
Quality Management for Hazardous, Toxic and Radioactive Waste Remedial
Activities, EM 200-1-3 Requirements for the Preparation of Sampling and
Analysis Plans, and EM 200-1-6 Chemical Quality Assurance should be followed
to assure quality analytical data. It will also aid the USACE's resident
engineer in assuring quality construction as required by ER 1180-1-6
Construction Quality Management through implementation of the USACE's Quality
Assurance and Contractor's Quality Control systems as discussed in EP 415-1260 Resident Engineer's Management Guide and EP 415-1-261 Quality Assurance
Representatives Guide.
1-1
EM 1110-1-4006
30 SEP 98
1-3. Closure Requirements. This guidance does not suggest that all of the
activities must be performed. Rather the reader must decide what activities
are required for each tank closure. This manual addresses the minimum tank
closure requirements based on applicable federal regulations and a review of
state requirements. In every case, the user of this manual must check the
requirements of the local environmental Implementing Agency (IA) and plan for
the specific coordination of activities specified in these IA requirements.
Questions as to the applicability of federal or state UST removal requirements
on active installations or Civil Works Facilities should be addressed to the
installation legal office or USACE district office (Civil Works), or if no
legal office exists, to the major command legal office to which the
installation or Civil Works Facility is assigned. Questions as to the
applicability of Federal or state UST removal requirements on former
installations should be addressed to the legal office of the USACE district
executing the work. A list of state UST contacts is provided in Appendix B to
assist in determining these local needs. Tank closure in place must be
approved by the appropriate command as detailed below prior to completion:
FUDS
Army
Air Force
Other Customers
-
Division Commander (DERP/FUDS Manual)
Active Installation; MACOM
Civil Works; District Commander/Operations Manager
MAJCOM/Installation; AFI 32-7044
Specific Guidance should be requested.
Figures 1-1 and 1-2 identify the generic steps in the UST removal process and
identify the applicable chapters in this manual for each step.
1-4.
Definitions and Acronyms.
ACGIH
ACO
AFI
API
ASTM
AWWA
B
BDL
CFR
CGI
CIH
COLIWASA
COR
-
American Conference of Governmental Industrial Hygienists
Administrative Contracting Officer
Air Force Instruction
American Petroleum Institute
American Standards of Testing and Materials
American Water Works Association
Analyte detected in the method blank
Analyte not detected at the laboratory reporting limit
Code of Federal Regulations
Combustible Gas Indicator
Certified Industrial Hygienist
Composite Liquid Waste Sampler
Contracting Officer's Representative
1-2
EM 1110-1-4006
30 SEP 98
CSP
DERP
DO
DOT
EM
EPA
FID
FSP
FUDS
GC
GPR
HTRW CX
-
IA
IDLH
IRP
IDW
J
-
LEL
-
MSDS
NA
NFPA
NIOSH
NIST
NR
ORP
OSHA
PEL
PID
POLs
POTW
QA
QAPP
QC
RCRA
SAP
SOP
-
Certified Safety Professional
Defense Environmental Restoration Program
Dissolved Oxygen
Department of Transportation
Electromagnetic
U.S. Environmental Protection Agency
Flame Ionization Detector
Field Sampling Plan
Formerly Used Defense Sites
Gas Chromatography
Ground Penetrating Radar
Hazardous, Toxic, and Radioactive Waste Center of Expertise,
located in the Northwest Division, Missouri River Region,
Omaha District
Implementing Agency
Immediately Dangerous to Life and Health
Installation Restoration Program
Investigation-Derived Waste
Analyte detected below the laboratory reporting limit,
concentration is estimated
Lower Explosive Limit - the lowest concentration of gas or
vapor in air by volume that can be ignited and cause an
explosion or flame propagation
Material Safety Data Sheet
Not Analyzed
National Fire Protection Association
National Institute for Occupational Safety & Health
National Institute of Standards Technology
Not Reported
Oxidation-Reduction Potential
Occupational Safety & Health Administration
Permissible Exposure Limit
Photoionization Detector
Petroleum, Oils, and Lubricants
Publicly Owned Treatment Works
Quality Assurance
Quality Assurance Project Plan
Quality Control
Resource Conservation and Recovery Act
Sampling and Analysis Plan
Standard Operating Procedure
1-3
EM 1110-1-4006
30 SEP 98
Regulatory Notification
Coordination
Excavation Permit
Local Fire Department
Tank Removal Permit
Traffic Control
Destruction Certification
Manifests
Site Safety & Health Plan
Documents
Sampling and Analysis Plan
Plans & Specifications
Active
Tank
Closure Report
In-Place
Closure
1-4
Tank
Tightness
Testing
Data
Gathering
Site
Investigation
Permits
Product
Removal &
Disposal
Tank
Removal &
Disposal
Overexcavation
Site
Restoration
Abandoned
In-Place
Tank
Soil
Treatment &
Disposal
Applicable
EM Chapters
23478910 11 -
Site Coordination
Tank Tightness Testing
Investigative Requirements
Safety & Health
Sampling and Analysis Plan
Decontamination
Combustible Gas Monitoring
Organic Vapor Monitoring
6 - Sampling During UST Removal
12 - Product Removal
13 - UST Removal
14 - Sludge Removal
15 - Contaminated Soil Removal
16- Site Restoration
FIGURE 1-1. FLOWCHART FOR CLEAN TANK CLOSURE
Report
Regulatory Notification
Coordination
Excavation Permit
Local Fire Department
Tank Removal Permit
Traffic Control
Destruction Certification
Manifests
Site Safety & Health Plan
Documents
Sampling and Analysis Plan
Closure Report
Plans & Specifications
Active
Tank
In-Place
Closure
Tank
Tightness
Testing
Data
Gathering
Site
Investigation
Permits
Product
Removal &
Disposal
Tank
Removal &
Disposal
Limited
Overexcavation
Expanded
Site
Investigation
Site
Remediation/
Restoration
Report
1-5
Abandoned
In-Place
Tank
Soil
Treatment &
Disposal
Applicable
EM Chapters
2 - Site Coordination
3 - Tank Tightness Testing
4 - Investigative Requirements
7 - Safety & Health
8 - Sampling and Analysis Plan
9 - Decontamination
10 - Combustible Gas Monitoring
11 - Organic Vapor Monitoring
6 - Sampling During UST Removal
12 - Product Removal
15 - Contaminated Soil Removal
5 - Site Characterization
16 - Site Remediation
17- Site Restoration
FIGURE 1-2. FLOWCHART FOR TANK CLOSURE REQUIRING REMEDIATION/RESTORATION
EM 1110-1-4006
30 SEP 98
13 - UST Removal
14 - Sludge Removal
EM 1110-1-4006
30 SEP 98
SOW
SSHO
SSHP
TCLP
TLV
TRPH
TWA
U
UEL
-
USACE
UST
-
VOA
VOCs
-
1-5.
Scope of Work
Site Safety and Health Officer
Site Safety and Health Plan
Toxicity Characteristic Leaching Procedure
Threshold Limit Value
Total Recoverable Petroleum Hydrocarbons
Time Weighted Average
Analyte not detected at the laboratory reporting limit
Upper Explosive Limit - the concentration of gas in air above
which there is insufficient oxygen available to support
combustion and explosion is unlikely
United States Army Corps of Engineers
Underground Storage Tank. This term describes any tank,
including underground piping that has at least 10 percent of
its volume below grade as defined by 40 CFR Part 280
Volatile Organic Analysis
Volatile Organic Compounds
Regulations.
a. RCRA Subtitle I. The Hazardous and Solid Waste Amendments of 1984
extended and strengthened the provisions of the Solid Waste Disposal
Act as amended by the RCRA of 1976. Subtitle I provides for the
development and implementation of a comprehensive regulatory program
for USTs containing regulated substances and releases of these
substances to the environment.
(1) Subtitle I defines underground storage tank as a tank system,
including its piping, that has at least 10 percent of its volume
underground. This term does not include any:
(a) Farm or residential tank of 1,100 gallons or less used for
storing motor fuel for noncommercial purposes.
(b) Tank used for storing heating oil for consumptive use on the
premises where stored; however, it is Army policy per AR
200-1, Chapter 4,to manage heating oil tanks 250 gallons
(946 liters) or larger similarly to Subtitle I underground
storage tanks.
(c) Septic tank.
1-6
EM 1110-1-4006
30 SEP 98
(d) Pipeline facility regulated under The Natural Gas Pipeline
Safety Act of 1968 or The Hazardous Liquid Pipeline Safety
Act of 1979 or an intrastate pipeline facility regulated
under state laws comparable to these acts.
(e) Surface impoundment, pit, pond, or lagoon.
(f) Storm water or wastewater collection system.
(g) Flow-through process tank.
(h) Liquid trap or associated gathering lines directly related
to oil or gas production and gathering operations.
(i) Storage tank situated in an underground area (such as
basement, cellar, mineworking, drift, shaft, or tunnel) if
the storage tank is situated upon or above the surface of
the floor.
(2) Regulated substances include but are not limited to petroleum
and petroleum-based substances comprised of a complex blend of
hydrocarbons derived from crude oil through processes of
separation, conversion, upgrading, and finishing such as motor
fuels, distillate fuel oils, residual fuel oils, lubricants,
petroleum solvents, and used oils.
(3) The following UST systems are excluded from the requirements of
this part:
(a) Any UST system holding hazardous wastes listed or identified
under Subtitle C of the Solid Waste Disposal Act, or a
mixture of such hazardous waste and other regulated
substances.
(b) Any wastewater treatment tank system that is part of a
wastewater treatment facility regulated under Section 402 or
307(b) of the Clean Water Act.
(c) Equipment or machinery that contains regulated substances
for operational purposes, e.g., hydraulic lift tanks and
electrical equipment tanks.
1-7
EM 1110-1-4006
30 SEP 98
(d) Any UST system whose capacity is 110 gallons or less.
(e) Any UST system that contains a de minimis concentration of
regulated substances.
(f) Any emergency spill or overflow containment UST system that
is expeditiously emptied after use.
b. RCRA Subtitle C. Subtitle C provides for the handling of hazardous
wastes as defined by RCRA. Specifically, a hazardous waste is a
waste that meets the following criteria:
(1) It exhibits any of the characteristics of hazardous waste
identified in 40 CFR Part 261 Subpart C. These characteristics
include:
(a) Ignitability.
(b)
Corrosivity.
(c)
Reactivity.
(d)
Toxicity.
(2) It is listed in Subpart D of 40 CFR Part 261. 40 CFR Part 261
also details exclusions to these criteria and should be
consulted for exact definitions.
1-6.
Job Qualifications and Training.
a. Training. By the time onsite activities are initiated, all personnel
entering into the exclusion area and contamination/reduction zone
(including the contractor) must complete the appropriate safety and
health training as required by 29 CFR 1926.65(e) and as outlined in
Chapter 7 of this manual. The contractor must provide, and have
available to the onsite project manager at all times, copies of all
certifications described above. This includes documentation of
having participated in the most recent refresher course, if required.
The contractor must also have available documentation of
certification in the UST testing method to be used and in UST removal
(if required by the state).
1-8
EM 1110-1-4006
30 SEP 98
b. Work History. The contractor must provide, and have available to the
onsite project manager at all times, work history of all personnel
employed by the contractor for the specific purpose of fulfilling the
tasks dictated by the subcontract and site-specific plans and
instructions. This should be construed to mean any personnel used
for purposes of administration or logistical support within the
confines of the exclusion/contamination reduction zone as determined
by the project manager.
c. UST Removal Experience. In addition, the tank removal contractor
must have a minimum of 2 years of tank removal experience and, if
applicable, must be trained and certified by the state in which the
removal is occurring.
d. Unqualified Personnel. Any personnel deemed unqualified by the
onsite project manager should be removed from the site.
1-7. Corrective Action Planning. The guidance in this manual is based on the
requirements of federal regulations, AR 200-1 for FUDS and Installation
Restoration Program (IRP) sites, and a review of state regulations. The IA
may either be the U.S. Environmental Protection Agency (EPA) in states which
have not adopted their own UST regulations, or a state agency where
regulations have been adopted, or a local agency. The reader is responsible
for determining the governing agency for each tank removal. Appendix B lists
the state UST agencies.
a. Release Response. A release is defined as any spilling, leaking,
emitting, discharging, escaping, leaching, or disposing from an UST
into groundwater, surface water, or subsurface soils. If there has
been a release of petroleum hydrocarbons into the environment, the
initial response requirements of 40 CFR 280.61 or the local IA
requirements must be followed. The IA must be notified within 24
hours of discovery or within another reasonable time period
determined by the IA. Simultaneously, Army Regulation 200-1 also
requires the reporting of spills through command channels to the
major Army command. After this, the requirements for initial
abatement and site check (40 CFR 280.62) must be met including a
report within 20 days of discovery or as required by the local IA.
Abatement activities include:
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EM 1110-1-4006
30 SEP 98
(1) Removal of regulated substances from the UST system to prevent
further release.
(2) Visual inspection to prevent further migration to surrounding
soils and ground water.
(3) Mitigation of fire and safety hazards posed by vapors or free
product
(4) Remedy of hazards posed by excavated or contaminated soils
exposed as a result of release confirmation.
(5) Measure for the presence of a release where most likely to be
present.
(6) Investigation for free product.
(7) Initiation of free product removal as soon as practicable.
If a release is confirmed, an Initial Site characterization report
consistent with 40 CFR 280.63 may be required. Check with the local
IA on the need for such a report and the deadline for submittal. You
may be required to submit the report within 45 days of release
confirmation or another reasonable time period as determined by the
IA. The IA will then make a determination of whether a Corrective
Action Plan with subsequent Remedial Action is required. This manual
does not address spill responses. Information regarding spill
response for Army installations is included in AR 200-1. Civil Works
guidance on spill response for Civil Works activities is included in
ER 200-2-3 and EP 200-2-3. Information concerning spill response
notification for Air Force facilities is included in Air Force
Instruction (AFI) 32-4002, Hazardous Material Emergency Planning and
Response Compliance, and AFI 32-7002, Environmental Information
Management System.
b. Tank Closure. Figure 1-1 details the steps that are typically
required for a clean tank closure, and Figure 1-2 details the
procedures for a closure that requires site remediation. Both
figures depict how these steps relate to coordination activities,
project documents, and the chapters contained in this manual. Figure
1-3 provides a checklist for tank closure.
1-10
EM 1110-1-4006
30 SEP 98
UST CLOSURE CHECKLIST
Date
Completed/
& Initials
1.
Have the major decision-makers been identified?
_____ Environmental Coordinator
_____ USACE District Office Contracting Representative
_____ Implementing Agency Contact
_____________
_____________
2.
_____________
3.
Has the tank been identified and located?
_____________
4.
Have the contents been identified?
_____________
5.
Has a visual site inspection been performed to identify potential
construction difficulties and/or signs of leakage?
_____________
6.
_____________
7.
Has an acceptable laboratory been identified and approved?
_____________
8.
Has a preliminary site investigation been conducted to determine
whether site remediation is required?
_____________
9.
_____________
10. Have provisions been made for product and sludge removal?
_____ Recycle of POLs
_____ Manifest for Waste Disposal
_____________
11. Have provisions been made for disposal of contaminated water?
_____ POTW Acceptance of Waters
_____ Recycle/Separation/Treatment
_____ Manifest Waste Disposal
_____________
12. Have the appropriate agencies been notified of exact date of tank
removal?
_____ Fire Department
_____ Implementing Agency
_____ Environmental Coordinator
_____________
13. Have action levels and screening methods been determined for excavation
of soils?
_____________
14. Have the methods for soil treatment and/or disposal been identified?
_____________
15. Have provisions been made for the tank ?
_____Destruction certification
_____Recycling
_____________
16. Have provisions been made for site restoration?
Is the tank history complete?
_____ As-built Drawings
_____ Utility Surveys
Have the planning documents been prepared and approved?
_____ Site Safety & Health Plan
_____ Sampling and Analysis Plan
_____ Project Work Plan
Have all permits been obtained?
_____ Excavation
_____ Tank Removal (regulatory agency permit)
FIGURE 1-3
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1-8. Plan of Work. The tank removal contractor shall develop, implement,
maintain, and supervise a comprehensive plan for tank removal and related
operations. The work plan should be based on project specification
requirements, work experience, the guidance provided in this manual, and the
latest versions of the following guidance references: API Recommended
Practice 1604, API Publication 2015, API Recommended Practice 2003, API
Publication 2217, and API Publication 2219. This work plan will provide the
USACE with the contractor's approach to performing the work. No work at the
site is permitted to commence until the work plan is approved. At a minimum,
the work plan should include:
a. Scheduling and operational sequencing.
b. Discussion of the approach for tank removal, tank cleaning, and tank
destruction procedures.
c. A Sampling and Analysis Plan (SAP) that describes sampling procedures
and lists analysis parameters, methods, and laboratory or
laboratories (as detailed in Chapter 8 of this manual). The SAP
should include data quality objectives.
d. Soil sampling locations and rationale for locations.
e. Explanation of how the analytical results will be used.
f. Identification of applicable regulatory requirements and permits
including methods to be used to control volatile organic compound
(VOC) emissions from decontamination fluids constituting RCRA
regulated hazardous waste.
g. Methods to be employed for residue, vapor, liquid, and contaminated
water removal; purging; and storage and methods proposed for control
of surface water.
h. Identification of waste, tank, and contaminated-soil transporters and
means of transportation.
i. Disposal facilities, alternate disposal facilities, and means of
disposal or remediation.
j. Borrow source.
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k. Spill prevention plan.
l. Spill contingency plan.
m. Decontamination procedures.
n. A statement that the contractor meets the qualification requirements.
1-9. Report Requirements. Typically a report is required by the IA for
documentation of tank removal. For each UST site, a Tank Closure Report
(Report) must be prepared and submitted. The Report must be prepared by the
tank removal contractor and should be submitted within 14 days of site work
completion to the COR with copies to the Installation Environmental
Coordinator or Civil Works Environmental Compliance Coordinator. Number of
copies required (for regulatory agency submittal) must be coordinated with the
Environmental Coordinator or Civil Works Environmental Compliance Coordinator
and included in the project specifications. The Report must be reviewed by
the designers with incorporation of comments by the contractor before the
Report is approved as final by the COR. Tank Closure Reports must include the
following information as a minimum:
a. A cover letter signed by a Certified Tank Remover certifying that all
services involved have been performed in accordance with the
requirements outlined in the specifications. The report shall
contain the name, address, and phone number of the primary contractor
and all subcontractors.
b. A narrative report describing what was encountered at each site,
including:
(1) Condition of the UST.
(2) Any visible evidence of leaks or stained soils.
(3) Results of vapor monitoring readings.
(4) Actions taken including quantities of materials treated or
removed.
(5) Reasons for selecting sample locations.
(6)
Sample locations.
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(7) Collection data such as time of collection and method of
preservation.
(8)
Procedures for backfilling site.
(9)
Whether or not groundwater was encountered.
(10) Date of removal or closure.
(11) Capacity and construction of tanks.
c. Notarized statement from the tank cleaning service, certifying the
tank is clean.
d. Copies of tank destruction certification, verifying that the tank has
been rendered useless.
e. Copies of all analyses performed for disposal.
f. Copies of all waste analyses or waste profile sheets.
g. Copies of all certifications of final waste disposal signed by the
responsible disposal facility official. The original of all
manifests must be returned to the generator.
h. Information on who sampled, analyzed, transported, and accepted all
wastes encountered and copies of manifests.
i. Copies of all analyses performed for verification that underlying
soil is not contaminated, with copies of the custody form for each
sample. All analyses must give the identification number of the
sample used. Sample identification numbers must correspond to those
provided on the one-line drawings.
j. Conversation records/correspondence between contractors,
subcontractors, and facility personnel or regulators.
k. Scaled one-line drawings referenced to a bench mark or other
permanent point showing tank locations, limits of excavation, limits
of contamination, underground utilities within 50 feet, sample
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locations, sample identification numbers, locations of stockpiled
soils, and sample locations with depths.
l. Progress Photographs. The contractor should provide color
photographs of four or more different views of the site showing such
things as the location of each tank, entrance/exit road, and any
other notable site conditions before work begins. After work has
been started at the site, the contractor should photographically
record activities at each work location daily. Photographs should be
3 by 5 inches and may include:
(1) Soil removal, handling, and sampling.
(2) Unanticipated events such as discovery of additional
contaminated areas.
(3) Soil stockpile area.
(4) Tank.
(5) Site- or task-specific employee respiratory and personal
protection.
(6) Fill placement and grading.
m. Post-construction Color Photographs. After completion of work at
each site, the contractor should photograph a minimum of four
different views of the site. Color prints should illustrate the
condition and location of work and the state of progress. The
photographs should be mounted and enclosed back-to-back in a doubleface plastic sleeve punched to fit a standard three-ring binder.
Each color print should have a corresponding information box, 1-1/2
by 3-1/2 inches. The box should be typewritten and arranged as
follows:
Project No.
Location
Contractor/Photographer
Photograph No.
Description
Direction of View
Contract No.
Date/Time:
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CHAPTER 2
SITE COORDINATION
2-1. General. The purpose of this chapter is to outline the site
coordination that must be performed prior to tank removal. The list should be
modified to satisfy the needs of each site.
2-2. Environmental Coordinator.
The environmental coordinator, or on Civil
Works facilities the facility manager, must be identified for each site where
a UST is to be removed. The coordinator will be the interface between the
regulatory agencies and the site. All impending work must be approved by the
environmental coordinator.
2-3. Site Representative. The site representative must be contacted to
determine if as-built drawings are available for the tanks, utilities, and
facilities in the immediate area of the UST. Other aspects of the UST history
should be investigated with the site representative, or on Civil Works
facilities the facility manager.
2-4. Utilities. Prior to excavation, all necessary excavation permits must
be completed. The utilities that must be located include but are not limited
to water, gas, electricity, communications, sewer, and fuel lines. Excavation
must not proceed until all utilities have been notified.
2-5. Transportation Routes and Traffic. Site representatives must be
contacted to determine approved transportation routes for contaminated soil,
excavated tanks, and backfill. If possible, the route should be one that is
not subject to heavy traffic. Traffic control requirements (pedestrian and
vehicular) around the excavation site and the transportation route must be
established prior to excavation.
2-6. Fire Department Notification. The local fire department must be given
sufficient notice to allow them to be present during tank excavation. The
local fire chief must be contacted to determine whether any local ordinances
apply during excavation.
2-7. Regulatory Agency. The governing regulatory authority requires
notification upon discovery of a leak and prior to UST removal. The
notification and permitting requirements must be completed for every tank
removal. Appendix B lists state offices to expedite this process.
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2-8. Excavations. Each site should be evaluated to determine the
appropriateness of leaving the excavation site open pending analytical
results. The environmental coordinator or facility manager should indicate
which sites may be left open. Barricades, safety fencing, or other precautions
are required adjacent to the excavation in accordance with EM 385-1-1.
2-9. Cultural Resources. The facility coordinator responsible for oversite
of archeological or cultural resources should be contacted prior to excavation
to insure that the potential UST site is not located in a sensitive area. In
the event that human remains or other cultural artifacts are accidentally
discovered, discontinue excavation activities and contact the facility
coordinator for cultural resources to initiate proper artifact removal.
2-2
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CHAPTER 3
TANK TIGHTNESS TESTING PROCEDURES
3-1. General. The purpose of underground storage tank (UST) integrity
tightness or tank tightness testing procedures is to determine the physical
integrity of UST. The EPA, under 40 CFR 280 Subpart D, has established
release detection requirements for all USTs. Tank tightness testing is used
to indicate whether an UST meets the applicable release standards. Tank
tightness testing should only be performed on tanks that are to be abandoned
in place or tanks that are to remain active. You should choose a tank
tightness test carefully to ensure that the test does not promote additional
contamination of the surrounding environment. Both volumetric and
nonvolumetric methods of tank tightness testing are described in this chapter.
Some of these methods may be used for pipe integrity testing; however, pipe
integrity testing is not the focus of this chapter.
3-2. Methods. Tank tightness testing can be performed in a variety of ways.
A tank tightness test is a precision test that can be volumetric or
nonvolumetric. A volumetric test measures volume changes quantitatively,
while a nonvolumetric test measures changes qualitatively. Some methods
require filling tanks to capacity, known as overfilling, where the fluid level
reaches the fill tube. In these tests, the integrity of the entire tank and
associated piping can be assessed. Other methods employ partially filled
tanks, where only the integrity of the filled portion of the tank can be
assessed. Tests can also be divided between constant-level and variable-level
tests. In constant-level tests, product is added or removed to maintain a
constant fluid level. Both overfilled and partially filled tanks can be used
in constant-level tests. Variable-level tests allow the fluid level to
fluctuate and are typically conducted on overfilled tanks. Tables 3-1 and
3-2 contain a summary of the various methods.
a. Volumetric. Most tank tightness test methods account for volume
changes as a function of product-level changes. A constant-level
volumetric test directly measures the volume added or subtracted from
a tank in order to maintain a constant level. A variable-level test
measures changes in the level of the product and converts these level
changes to volume changes using a height-to-volume conversion factor.
3-1
Method
Principle
Claimed
Accuracy, gal/h
Total Downtime for
Testing
Requires Empty
or Full Tank for
Test
Ainlay Tank Integrity
Testing
Pressure measurement by a coil-type manometer to determine product-level change in a
propane bubbling system.
0.02
10-12 h (filled a night
before 1.5-h testing)
Full
ARCO HTC Underground
Tank Detector
Level change measurement by float and light-sensing system.
0.05
4-6 h
No
Certi-Tec Testing
Monitoring of pressure changes resulting from product-level changes.
"Ethyl" Tank Sentry
Level change magnification by a J tube manometer.
EZY-CHEK Leak Detector
Pressure measurement to determine product-level change in an air bubbling system.
Fluid-static (standpipe)
Testing
Heath Petro Tite Tank and
Line Testing (Kent-Moore)
3-2
Helium Differential
Pressure Testing
0.05
4-6 h
Full
Sensitive to 0.02in level change
Typically 10 h
No
Less than 0.01
4-6 h (2 h waiting after
fillup, 1-h test)
Full
Pressurizing of system by a standpipe; keeping the level constant by product addition or
removal; measuring rate of volume change.
Gross
Several days
Full
Pressurizing of system by a standpipe; keeping the level constant by product addition or
removal; measuring rate of volume change; product circulation by pump.
Less than 0.05
6-8 h
Full
Leak detection by differential pressure change in an empty tank; leak rate estimation by
Bernoulli's equation.
Less than 0.05
Minimum 48 h
Empty
0.02
14-16 h1 (12 to 14 h
waiting after fillup)
Full
Mooney Tank Test
Detector
Measuring level change with a dip stick.
PACE Tank Tester
Magnification of pressure change in a sealed tank by using a tube (based
on manometer principle).
Less than 0.05
14 h
Full
PALD-2 Leak Detector
Pressurizing system with nitrogen at three different pressures; level measurement by an
electrooptical device; estimate of leak rate based on the size of leak and pressure difference
across the leak.
Less than 0.05
14 h (preferably 1 day
before, 1-h fill testing,
includes sealing time)
Full
Pneumatic Testing
Pressurizing system with air or other gas; leak rate measurement by change in pressure.
Tank Auditor
Principle of buoyancy.
Two-tube Laser
Interferometer System
Measuring level change by laser beam and its reflection.
Gross
Several hours
No
0.00001 in the
fill pipe; 0.03 at
the center of a
10.5-ft-diameter
tank
1.5-3 h
Typically full
Less than 0.05
4-5 h2
No (at existing
level)
1 Including the time for tank end stabilization when testing with standpipe.
2 Including 1 to 2 h for reference tube temperature equilibrium.
Source: USEPA 1986. Underground Storage Tank Leak Detection Methods: A State of the Art Review.
EPA/600/2-86/001.
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TABLE 3-1
VOLUMETRIC LEAK TESTING METHODS
TABLE 3-2
NONVOLUMETRIC LEAK TESTING METHODS
Method
Principle
Claimed Accuracy, gal/h
Total Downtime
for Testing
Requires Empty
or Full Tank for
Test
3-3
Acoustical Monitoring
System (AMS)
Sound detection of vibration and elastic waves generated by a leak in a
nitrogen-pressurized system; triangulation techniques to detect leak location.
Does not provide leak rate;
detects leaks as low as 0.01
gal/h.
1-2 h
No
Leybold-Heraeus Helium
Detector, Ultratest M2
Rapid diffusivity of helium; mixing of a tracer gas with products at the
bottom of the tank; helium detected by a sniffer mass spectrometer.
Does not provide leak rate;
helium could leak through 0.005in leak size.
None
No
Smith & Denison Helium
Test
Rapid diffusivity of helium; differential pressure measurement; helium
detection outside a tank.
Provides the maximum possible
Few–24 h
leak detection based on the size
(excludes sealing
of the leak (does not provide leak
time)
rates); helium could leak through
0.05-in leak size.
TRC Rapid Leak Detector
Rapid diffusion of tracer gas; mixing of a tracer gas with product; tracer gas
for Underground Tanks and detected by a sniffer mass spectrometer with a vacuum pump.
Pipes
Does not provide leak rate;
tracer gas could leak through
0.005-in leak size.
Vacuuming the system (5 lb/in2); scanning entire tank wall by ultrasound
device; noting the sound of the leak by headphones and registering it on a
meter.
VacuTect (Tanknology)
Applying vacuum at higher than product static head; detecting bubbling noise Provides approximate leak rate.
by hydrophone; estimating approximate leak rate by experience.
Varian Leak Detector
(SPY2000 or 938-41)
Similar to Smith & Denison.
Source: EPA/600/2-86/001, “Underground Storage Tank Leak Detection Methods: A State of the Art Review.”
Does not provide leak rate; a
leak as small as 0.001 gal/h of
air could be detected; a leak
through 0.005-in could be
detected.
Similar to Smith & Denison.
None
No
Few hours
(includes tank
preparation and
20-min test)
Empty
1h
No
Few–24 h
(excludes sealing
time)
Empty
EM 1110-1-4006
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Ultrasonic Leak Detector
(Ultrasound)
Empty
EM 1110-1-4006
30 SEP 98
b.
Nonvolumetric.
(1) Nonvolumetric tests can be divided into vacuum tests, probe
tests, and tracer tests. The vacuum test subjects the tank to a
slight vacuum, enough to counteract the fluid head within the
tank. When a leak is encountered, bubbles form at the leak,
separate at the tank, and undergo a volume pulsation of constant
frequency that can be used to determine leak size.
(2) The methods currently available for nonvolumetric tank testing
use either a type of vapor monitoring or conduct the test under
a vacuum. Neither method will provide an exact leak rate.
However, each method will provide an analysis of the system in
relation to the 0.1 gallons per minute (gpm) leak rate at a
probability of detection of 0.95 and a probability of false
alarm of 0.05. When selecting a nonvolumetric test method, make
sure the method is approved for the entire volume of the tank
and not just for the volume containing liquid on the day the
tank is tested.
c. Performance. The performance of a leak-detection test method is
measured by the accuracy and reliability of that test method in
determining whether or not a tank is leaking. The best performance
test methods are able to discriminate between the volume changes
produced by a leak (signal) and other volume changes that normally
occur in both nonleaking and leaking tanks (noise). This noise can
often be confused with the leak by masking or mimicking the signal of
the leak.
d. Results.
A leak-detection test has five possible outcomes:
(1) Correctly identified leak: an accurate test result where the
measured condition reflects actual conditions.
(2) Correctly identified tight tank: an accurate test result where
the integrity of a nonleaking tank is confirmed.
(3) A false alarm: an erroneous test result where the test
mistakenly indicates a leak.
(4) A missed detection: an erroneous test result where the test
mistakenly indicates that the tank is tight when it is leaking.
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(5) An inconclusive test that does not provide either positive or
negative evidence of a leak. Also, a positive result may or may
not indicate whether the leak is in the tank or the associated
piping.
3-3. Regulations. 40 CFR 280 Subpart D specifies the following general
release detection requirements for all UST systems in § 280.40:
a. Release Detection. "Owners and operators of new and existing UST
systems must provide a method, or combination of methods, of release
detection that:
(1) Can detect a release from any portion of the tank and the
connected underground piping that routinely contains product;
(2) Is installed, calibrated, operated, and maintained in accordance
with the manufacturer's instructions, including routine
maintenance and service checks for operability or running
condition; and
(3) Meets the performance requirements in § 280.43 or 280.44, with
any performance claims and their manner of determination
described in writing by the equipment manufacturer or installer.
In addition, methods used after December 22, 1990, except for
methods permanently installed prior to that date, must be
capable of detecting the leak rate or quantity specified for
that method in § 280.43 (b), (c), and (d) or 280.44 (a) and (b)
with a probability of detection of 0.95 and a probability of
false alarm of 0.05."
b. Tank Tightness Testing.
Section 280.43(c) specifies the following
tank tightness testing performance requirements: "Tank tightness
testing (or another test of equivalent performance) must be capable
of detecting a 0.1 gallon-per-hour leak rate from any portion of the
tank that routinely contains product while accounting for the effects
of thermal expansion or contraction of the product, vapor pockets,
tank deformation, evaporation or condensation, and the location of
the water table."
3-4. Test Procedures. A summary of attributes of reliable integrity
tightness testing methods has been developed by the EPA based upon research
performed on over 25 commercially available methods. The testing methods are
summarized in the following documents:
- Standard Test Procedures for Evaluating Leak Detection Methods:
Volumetric Tank Tightness Testing Methods, EPA/530/UST-90/004, March 1990.
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EM 1110-1-4006
30 SEP 98
- Standard Test Procedures for Evaluating Leak Detection Methods:
Nonvolumetric Tank Tightness Testing Methods, EPA/530/UST-90/005, March 1990.
- Standard Test Procedures for Evaluating Leak Detection Methods:
Pipeline Leak Detection Systems, EPA/530/UST-90/101, September 1990.
- List of Leak Detection Evaluations for Underground Storage Tank (UST)
Systems, EPA/510/B-97/004.
a. Documentation. Either the manufacturer or an independent third party
can perform the demonstration tests. However, some states do not
recognize results from demonstration tests performed by the equipment
manufacturer. When purchasing release detection equipment or having
a tank system tested, the organization providing the service or
equipment must provide the owner/operator of the system with the
manufacturer's documentation of equipment compliance with performance
standards outlined in 40 CFR 280.40(a). This documentation must be
retained at the facility to meet the record keeping requirements
outlined in 40 CFR 280.34.
b. Selection. Before selecting a tank tightness test method, check with
state and local agencies to make sure the proposed method was
adequately evaluated and demonstrated in the performance test report.
Some states have additional evaluation methods and standards. They
may require third-party testing or limit the release detection method
to certain size (capacity) tanks. The standards used to evaluate the
release detection method will be in the performance test report.
These reports will provide the following information about the test
equipment: method description, test results, the product used for
testing, techniques used for measuring temperature and level, how
data are acquired and recorded, limitation of the test method, and
certification of results. From this, a determination can be made
about the following:
3-6
TABLE 3-3
MAJOR VARIABLES AFFECTING LEAK DETECTION
Variable
Impact
3-7
Temperature Change
Expansion or contraction of a tank and its contents can mask leak and/or leak rate.
Water Table
Hydrostatic head and surface tension forces caused by groundwater may mask tank leaks partially or completely.
Tank Deformation
Changes or distortions of the tank due to changes in pressure or temperature can cause an apparent volume change when none exists.
Vapor Pockets
Vapor pockets formed when the tank must be overfilled for testing can be released during a test or expand or contract from temperature and pressure
changes and cause an apparent change in volume.
Product Evaporation
Product evaporation can cause a decrease in volume that must be accounted for during a test.
Piping Leaks
Leaks in piping can cause misleading results during a tank test because many test methods cannot differentiate between piping leaks and tank leaks.
Tank Geometry
Differences between the actual tank specifications and nominal manufacturer's specifications can affect the accuracy of change in liquid volume
calculations.
Wind
When fill pipes or vents are left open, wind can cause an irregular fluctuation of pressure on the surface of the liquid and/or a wave on the liquid-free
surface that may affect test results.
Vibration
Vibration can cause waves on the free surface of the liquid that can cause inaccurate test results.
Noise
Some nonvolumetric test methods are sound-sensitive and sound vibrations can cause waves to affect volumetric test results.
Equipment Accuracy
Equipment accuracy can change with the environment (e.g., temperature and pressure).
Operator Error
The more complicated a test method, the greater the chance for operator error, such as not adequately sealing the tanks.
Type of Liquid Stored
The physical properties of the liquid (including effects of possible contaminants) can affect the applicability or repeatability of a detection method
(e.g., viscosity can affect the sound characteristics of leaks in acoustical leak-detection methods).
Power Vibration
Power vibration can affect instrument readings.
Instrumentation
Limitation
Instruments must be operated within their design range or accuracy will decrease.
Atmospheric Pressure
A change in this parameter has the greatest effect when vapor pockets are in the tank, particularly for leak-rate determination.
Tank Inclination
The volume change per unit of level change is different in an inclined tank than in a level one.
Source: USEPA 1986. Underground Storage Tank Leak Detection Methods: A State of the Art Review. EPA/600/2-86/001.
EM 1110-1-4006
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(1) The amount of time required for the tank's contents to stabilize
after a delivery of product.
(2) The required test duration for collecting data to accurately
determine the condition of the tank.
(3)
Limitations of the test method (such as tank capacity).
(4) The actual minimum leak rate the test method can detect to a
probability of detection of 0.95 and a probability of false
alarm of 0.05.
(5) Whether a third party or the equipment manufacturer conducted
the performance test.
c. Performance. The performance claims for leak-detection devices
produced by commercial manufacturers will not be discussed in this
document.
Refer to EPA/625/9-89/009 Volumetric Tank Testing:
An
Overview and EPA/510/B-97/004 List of Leak Detection Evaluations for
Underground Storage Tank (UST) Systems and literature from individual
manufacturers for additional information on the performance of
specific commercially available devices.
3-5. Precautions. Table 3-3 summarizes the variables that can affect leak
detection. Three of the major variables are discussed below.
a. Noise. A tank tightness or volumetric test measures the change in
the volume of fluid in a tank, accounts for other sources of noise
(normally occurring volume changes), and attributes the adjusted
volume change (if it is above the threshold level) to a leak.
Therefore, it is essential that a test method differentiate between
and compensate for nonleak-related volume changes (noise) versus
actual leaks. There are five common nonleak-related product-volume
(or product-level) changes that are sources of ambient noise, some
potentially producing larger errors than others. Precautions are
incorporated in most reliable test methods to compensate for those
phenomena and to minimize the probability of false alarms.
(1) Thermal expansion or contraction of the product resulting from
product addition or removal during volumetric testing can be a
major source of noise and, thus, error in tank tightness
testing. Volume changes due to expansion and contraction of the
product in a filled tank may be as large as 3.8 L (1 gallon) per
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EM 1110-1-4006
30 SEP 98
hour. Reliable test methods compensate for this phenomenon by
requiring a waiting period following any tank additions prior to
measurement collection.
(2) Vapor pockets commonly occur in tanks and the associated piping
that have been filled to capacity. Temperature fluctuations and
pressure changes in the tank contents cause the expansion or
contraction of vapor pockets. Volume changes of trapped vapors
produce product-level changes that may be misinterpreted as
leaks. Vapor pockets as small as 38 liters (10 gallons) in a
38,000 liter (10,000-gallon) tank can influence test results.
In preparation for tightness testing, if vapor pockets of 40 to
80 liters (10 to 20 gallons) or more are suspected, the tank and
lines should be bled as a precaution.
(3) In addition to level, temperature, and pressure changes
associated with a product, the tank itself will exhibit
expansion and contraction, or structural deformation. This
deformation, in turn, causes the product level to change, which
could be mistaken as a leak. Both instantaneous deformation and
time-dependent relaxation of a tank occur. Reliable tank
testing procedures introduce a waiting period between product
addition and measurement collection as a precaution to allow the
tank deformation effects to subside.
(4) Minor volume fluctuations may result from the evaporation of
product from the fluid surface or condensation of product on
tank walls. This phenomenon is more likely to occur in tanks
that are not completely filled and contain air or vapor pockets.
Completely filling and bleeding tanks and lines prior to test
initiation are precautions that will minimize this type of
“noise.”
(5) Surface or internal waves may be caused by mechanical vibrations
or temperature boundary layers within a tank. These waves can
produce apparent level changes that could be mistaken for volume
changes or leaks. Infrequent sampling that does not detect this
wave phenomenon, known as biasing, can indicate a false result.
To prevent this, use reliable test methods such as frequent
sampling and averaging of data during the test. Perform tests
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during hours when local traffic, especially trucks, would be
less prevalent so the impact on test results would be minimized.
b. Groundwater. The location of the groundwater table at the time of
testing is another factor that can interfere with accurate tank
tightness testing. Unlike the five factors mentioned previously, the
groundwater level does not mimic a leak; however, it may have a
direct effect on the apparent size of the leak. Existing site
information (boring logs) should be used to estimate the depth to
groundwater rather than mobilizing a rig and crew to determine the
depth to groundwater. When the groundwater level is above the leak,
it can restrict or prevent the flow of product out of a tank, and a
leak can go undetected. As a precaution, it is important to monitor
the groundwater level with respect to the bottom of the tank each
time a tank tightness test is conducted. Best results are obtained
when the water table is below the tank. If the tank normally is
above the water table and recent precipitation has altered that
situation, consider delaying the test until the water table has
dropped and this potential interference is removed. If at all
possible, a test should not be conducted while the water table is
fluctuating. If this situation cannot be avoided, such as in a tidal
area, it should be understood that the test results will be less
accurate and reliable.
c. Volumetric Methods. Tank tightness testing using volumetric methods
should not be conducted through the fill pipe. Volumetric test
methods record temperature at various points along the diameter of
the tank and require precise measurements for the test to be valid.
The fill pipe would mask the true temperatures of these various
points along the tank diameter.
3-6. Equipment. Each commercially available leak detection method has two
components: equipment and procedures. Both the equipment (physical devices,
computer hardware, and instrumentation) and procedures (operator
responsibilities, computer software, theoretical and analytical approaches)
can vary from one method to another. This can result in variances in method
performance for different leak rates and threshold values.
a. Temperature/Volume. The majority of tank tightness test requirements
include equipment that measure the temperature and volume of the
product in a tank, such as thermistors and height or volume sensors.
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Some methods include arrays with multiple sensors that better
represent actual conditions vertically within the tank.
b. Data Measurement. The more sophisticated measurement and data
analysis equipment is often used to take frequent measurements that
can be statistically analyzed and provide a good representation of
actual conditions within the tank. This frequent measurement rate
and the resulting statistical analyses are typically facilitated by
computer equipment.
c. Additional Information. The reader is directed to manufacturers'
literature for details about specific test methods. EPA/625/989/009, Volumetric Tank Testing:
An Overview, is also recommended as
a source of information about a number of different methods that were
evaluated by the EPA.
3-7. Materials. Once a tank tightness test method has been selected, the
operator will provide the necessary equipment, handling/transferring
procedures, and training on material safety data sheets (MSDS) for the liquids
to be used. The only material that is typically necessary is additional
product to fill the tank.
To ensure an accurate test, use product identical in formulation to that which
is already in the tank. The added product should also be approximately the
same temperature as the product already in the tank to minimize volume
expansion or contraction due to temperature variations. If temperatures are
not identical, the required settling time prior to testing should be
sufficient to allow the temperatures to equalize.
It should be noted that topping off tanks with product may be difficult. The
Defense Fuel Supply Center that contracts for most of the Army's fuel has
stated they will not contract to have the tanks topped off. Individuals
responsible for performing the integrity testing will provide added fuel to
top off the tanks to be tested.
3-8. Operations, Procedures, and Instructions. There are three steps
involved in all tank tightness testing: preparation, testing, and analysis.
Although operations, procedures, and instructions will vary for each
commercial test method selected, the common elements of the methods are
described. The procedures for a particular test must be strictly followed to
assure the performance cited.
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a. Preparation.
(1) The tank is first filled to the level required for testing with
the same product at the same temperature as the tank contents.
A waiting period follows to allow temperature variations, wave
actions, and structural deformations to subside. If necessary,
the tank is bled to reduce vapor pockets.
(2) The sensor instrumentation is inserted into the tank. In the
case of overfilled tests, the tank is topped off by adding or
removing small amounts of product to bring the product to the
test level. A second waiting period is observed.
(3) Values are taken to determine the coefficient of thermal
expansion and/or the height-to-volume conversion. The watertable level is also measured if it is in the vicinity of the
tank and if there is a monitoring well.
b. Testing. The sensors inserted into the tank measure the temperature
and the level (or volume) of the product in the tank over time.
Often these two measurements are collected at the same rate. The
instrument readings are recorded either electronically or manually.
The test ends based on the data results. Often this is a function of
time, but sometimes the decision to end the test is controlled by
other measurements.
c. Analysis.
(1) Convert the level data to volume data and compensate for
temperature changes using procedures defined by the
manufacturer. Use these data to calculate a volumetric flow
rate of leakage from the tank.
(2) Compare this calculated volumetric flow rate to the
predetermined detection criterion for the test. If the
calculated volumetric flow rate exceeds the detection criterion,
a leak is suspected. If not, it is assumed that no leak is
present.
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3-9. Waste Disposal. Typically, no wastes are generated during integrity
tightness testing. If any product is spilled as a result of the testing, it
should be handled consistently with procedures outlined in Chapter 6.
3-10.
Reporting and Documentation.
a. Reporting. Owners and operators of UST systems must report suspected
releases based upon tank tightness test results to the implementing
agency within 24 hours, or another reasonable time period specified
by the implementing agency. This requirement is mandatory unless the
monitoring device is found to be defective and is immediately
repaired, recalibrated, or replaced, and subsequent monitoring does
not confirm the initial result.
b. Documentation.
(1) All UST system owners and operators must maintain records
demonstrating compliance with applicable regulations.
(2) The records must include the following:
(a) All written performance claims pertaining to any release
detection system used, including the manner in which these
claims have been justified or tested by the equipment
manufacturer or installer. Claims must be maintained for 5
years, or for another reasonable period of time determined
by the implementing agency, from the date of installation.
(b) The results of any sampling, testing, or monitoring must be
maintained for at least 1 year, or for another reasonable
period of time determined by the implementing agency. The
results of tank tightness testing must be retained until the
next test is conducted.
(c) Written documentation of all calibration, maintenance, and
repair of release detection equipment permanently located
onsite must be maintained for at least 1 year after the
servicing work is completed, or for another reasonable time
period determined by the implementing agency. Retain
schedules of required calibration and maintenance provided
by the release detection equipment manufacturer for 5 years
from the date of installation.
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CHAPTER 4
UNDERGROUND STORAGE TANK (UST)
INVESTIGATIVE REQUIREMENTS
4-1. General. This chapter discusses data gathering and investigative
techniques to determine where the tank is located and what has been in the
tank.
4-2. Tank History/Information. Prior to a UST removal, a history of the tank
characteristics should be assembled by the designer. It should be as detailed
as possible from readily available sources such as records, reports, and
interviews. Data gathering is important because the more information a
designer has prior to construction, the less surprises will be encountered
during removal. Items of specific interest and associated tasks include:
a. Existing Drawings. Review engineering drawings, preferably asbuilts, and interview the site personnel. Determine, if possible,
the tank and associated piping location, the dimensions and capacity
of the tank, material of construction, depth, corrosion protection
systems, presence or absence of ballast pads and tie downs, age, and
date tank was last used. In some instances, this information may be
on an installation's utility maps. If existing drawings cannot be
obtained, refer to later parts of this chapter for investigative
procedures to obtain tank information.
b. Inventory Control Records. Review inventory control records as a
source of information to determine the types of liquids stored in the
tank and whether the tank system has leaked.
c. Interviews. Determine from site personnel the location, magnitude,
and duration of any environmental releases associated with the UST.
Determine how the liquids were placed into and removed from the tank,
monitoring procedures followed, and the types of liquids stored in
the tank. Determine if abandoned tanks were filled with sand, water
or concrete at the time of abandonment. A list of previous employees
who may have worked in the area should be obtained from the
installation to facilitate this process.
d. Utilities. Locate all underground utilities including, but not
limited to, sanitary sewers, storm sewers, water lines, gas lines,
power lines, telephone lines, and all associated piping and
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appurtenances associated with the area immediately surrounding the
tank.
e. Site Characteristics. Determine depth, rate, and direction of
groundwater and soil characteristics from record searches if
possible. This information is not required for all removals, but it
is helpful information for the designer. If data is not available
and it is determined to be necessary for tank removal, refer to
Chapter 5 for investigative procedures.
4-3. Regulatory Issues. Federal, state, and local agencies will need to be
contacted well in advance of tank removal (a minimum of 30 days). Preferably,
the Environmental Coordinator should contact the applicable agencies. In many
cases the regulatory agency may want to have an individual onsite to observe
tank removal. Appendix B lists state agencies in charge of UST management.
In addition, state regulatory agencies can supply lists of licensed tank
removal/disposal firms and provide guidance for waste disposal and other
useful information. Tanks storing hazardous waste are regulated under 40 CFR
264/265 and are outside the scope of this document.
4-4.
Tank Locations.
a. As-Built Drawings. One source of information for locating USTs is
the construction drawings used to install the tank. In some
instances, this information may be on an installation's utility maps.
Once the drawings have been obtained, they should be field-verified
by the designer, if possible, to determine whether the tank is in the
location specified. You should recognize it may be difficult to
verify as-built drawings.
b. Visual Inspection. You may be able to locate tanks by visually
locating manholes, variations in concrete or asphalt, vent pipes,
fill pipes, and ground depression or elevation. In some instances
visual inspection by itself is not reliable. Insert a steel probe
into the ground to assist the visual inspection.
c. Geophysical Methods. In cases where documentation of tank locations
is questionable or nonexistent, the application of surface
geophysical methods has been a successful means of delineating
approximate tank boundaries. These methods can provide information
that would be otherwise unavailable without costly, and often
dangerous, ground-intrusive activity. In addition, the same types of
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geophysical data used to identify tank burials can often supply
useful information concerning local hydrogeologic conditions, and in
some instances, the extent of any gross contamination associated with
an UST system. The success of any single geophysical technique at a
given site is dependent on site-specific conditions. Therefore, it
is generally recommended that you apply more than one geophysical
technique to any single objective to accommodate situations where the
data from a particular method are deemed problematic. In such a
situation, the questionable data can often be quite useful when they
are used as a supplement to more definitive data.
Carefully review all pertinent background information and conduct a
site visit before designing any geophysical survey to make prudent
selections of techniques and to optimize the efficiency of the
survey. Several methods are discussed below and presented in Table
4-1. For more detailed information, the reader should consult EM
1110-1-1802 and ASTM PS78. Also the reader may refer to EPA/625/R92/007.
(1) Magnetometer Surveys. One of the most commonly used techniques
is magnetometry. Ferromagnetic objects, such as a steel tank,
produce variations, or anomalies, in the earth's magnetic field.
These aberrations are localized and can be mapped at the surface
using one of a variety of magnetometers. Magnetometer surveys
are relatively easy to implement, but interpretation of magnetic
data alone is not always straightforward. Ferromagnetic objects
at the surface (e.g., buildings, fences, automobiles) will
produce anomalies that may alter or mask anomalies caused by
ferromagnetic items beneath the ground. In addition, the
position of magnetic anomalies at the surface does not
necessarily mimic the position of their underground sources.
(2) Terrain Conductivity. Terrain conductivity is a function of the
type of subsurface material, its porosity, permeability, and the
fluids that fill the pore space. Accordingly, this
electromagnetic (EM) technique is applicable to assessment of
some natural hydrogeologic conditions as well as to mapping
contaminant plumes, trench boundaries and, of course,
identifying buried tanks. Similar to magnetic field surveys,
conductivity surveys are relatively fast and easy to perform.
The conductivity data are also susceptible to the same surficial
"interferences" (caused by cultural features) that can plague
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TABLE 4-1
GEOPHYSICAL METHODS
Method
Magnetometer (MAG)
Depth of Penetration
Resolution
Single 55-gallon drum, up to Good ability to locate
6 meters. Massive piles 55targets.
gallon drums, up to 20 meters.
Advantages
Quick, one-man operation.
Can readily detect buried ferrous objects (buried
drums or pipe lines).
Disadvantages
Large masses of ferrous objects
can have broad response
preventing precise location of
individual targets.
Susceptible to interference from
surface metallic objects such as
fences.
Will not detect materials with
low magnetic susceptibility
(i.e., nonferrous objects such as
fiber tanks).
Terrain Conductivity
Depth controlled by system
coil spacing 0.5 to 60 meters
typical.
4-4
Excellent lateral
No electrodes required–can be used on surfaces
resolution. Vertical
where electrode plants would be impossible.
resolution of two layers.
Thin layers may not be Very fast and efficient.
detected.
One or two man crew.
Can be conducted through fresh water.
Two-coil orientations and several intercoil
separations available to allow several depths of
investigation.
Ground Penetrating Radar (GPR)
One to ten meters
typical–highly site- specific.
Limited by fluids and soils
with high electrical
conductivity and by finegrained materials.
Greatest of all three
geophysical methods.
Depth inversion ability very
limited.
Relatively insensitive to
changes in conductivity in
highly resistive targets.
Highly conductive surface
materials limits depth of
penetration.
Resolution can be on the order of a few centimeters. Equipment is
cumbersome–usually requires
Provides a cross-section of subsurface.
flat surface.
Can detect buried drums–ferrous or nonferrous.
Can detect variations in soil type or moisture.
Can detect disturbed soil zones.
Can detect water table.
Depth of penetration seriously
limited by conductive material
such as clay or water.
Decreasing transmitter
frequency to increase
penetration decreases
resolution.
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magnetometer data. However, conductivity meters generally
provide much better lateral resolution over a buried target.
Further, effective penetration depths and sensitivity (to metal)
can be adjusted according to the objectives of the survey.
Shallow terrain conductivity data can provide lateral resolution
on the order of a few feet, which is usually sufficient for most
tank removals.
(3) Ground Penetrating Radar (GPR). If site conditions preclude the
use of magnetic and electromagnetic techniques, ground
penetrating radar (GPR) is also a viable, though more expensive,
means of identifying buried tanks. In fact, GPR can often
provide lateral resolution on the order of a foot or less and
thus minimize costly excavation. The GPR technique uses high
frequency radio waves to acquire subsurface information. From a
small transmitter antenna which is moved slowly across the
ground, energy is radiated downward below the surface, then
reflected back to a receiver antenna. Variations in the return
signal are continuously recorded in the instrument's console,
providing a continuous "cross-section" of shallow subsurface
conditions. An interface between materials having significantly
different electrical properties will be apparent on the radar
profile. Buried tanks and other discrete objects can be
identified providing they are of sufficient size to overcome the
inverse relationship between resolution and depth penetration.
The depth of penetration with GPR is highly site-specific and is
limited by subsurface attenuation of the radar waves; this
attenuation is accelerated in materials that have higher
electrical conductivities. Generally, better penetration is
achieved in dry, sandy, or rocky areas while poor results are
obtained in moist, clayey, or conductive soils.
4-5. Site Reconnaissance. During efforts to locate the tank, the following
items should also be noted by the designer:
a. Cover. Identify whether the tank is covered by grass, concrete,
asphalt, etc. If possible, determine thickness of cover by reviewing
as-built drawings or inserting a steel rod through the soil. This
information will be used in preparation of excavation requirements.
b. Building Proximity. Note where the tank is located with respect to
buildings. If the tank is located too close to a building to remove
safely, the option to close the tank in place must be evaluated. A
tank should be far enough away from buildings to allow the excavation
to be safely completed within the excavation criteria specified in
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Chapter 7. Note whether any subsurface structures, such as
basements, sewers, and other utilities are present where vapors can
collect.
c. Evidence of Leakage or Spillage. Visually inspect the area above and
surrounding the tank. Note whether there is any surface
contamination indicated by dark soil or stressed vegetation.
Evidence of leakage can sometimes be found in sanitary and storm
water manholes near USTs, in basement sumps, and in nearby surface
waters or groundwater seeps or springs.
d. Utilities. Verify the utility drawings or obtain verification from
the utility as to the exact location of underground or overhead
utilities. Note any deviations from the drawings. Evaluate any
effects of utility location on construction activities.
4-6. Tank Contents Sampling. The determination of the chemical composition
of the tank contents and an estimate of the volume of these contents is
crucial in the decision-making process to be performed by the USACE. This
task may be performed by USACE or a contractor. The objective of tank
sampling is to characterize tank contents and to separately identify those
tanks that contain only fuel oils, petroleum products, or related materials
from those that contain PCBs, contaminated oils, solvents, or other hazardous
waste constituents as defined in 40 CFR 260.10 and listed in 40 CFR 261
Appendix VIII.
If hazardous substances are found during design or predesign activities,
ensure adequate lead-time to plan appropriate construction activities. Also,
the USACE may recommend limiting subsequent chemical investigations at this
site to include only those analytes found in the UST. The results of these
analyses can also simply be used to determine the proper method of disposal,
including recycling for beneficial use. Many USACE Districts utilize
Indefinite Delivery/Indefinite Quantity (ID/IQ) UST Removal Contracts, which
include the sampling as a part of the removal process. These contracts make
assumptions based on information provided by the USACE District in a scope of
work and a site visit conducted jointly by the contractor and the USACE.
Refer to paragraph 4-2 regarding site investigative activities.
a. Typical properties exhibited by petroleum products are discussed
below. Petroleum products can be divided into the following general
groups:
-
Gasolines.
Middle distillates.
Heavier fuel oils and lubricating oils.
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(1) Gasolines are blends of petroleum-derived chemicals plus
additives that improve fuel performance and engine longevity.
Gasolines range in density from 0.72 to 0.78 g/cm3 and are less
viscous than water. Gasoline is immiscible in water; however,
there are many components of gasoline that readily dissolve upon
contact with water.
(2) The middle distillate group includes diesel fuel, kerosene, jet
fuel, and lighter fuel oils. These fuels may contain as many as
500 individual compounds; however, these compounds tend to be
more dense, less volatile, less mobile, and less water soluble
than gasoline materials.
(3) Heavier fuel oils are similar in composition and characteristics
to the middle distillates. These types of fuels are relatively
viscous and insoluble in groundwater and are relatively immobile
in the subsurface. See Table 4-2 for properties of six common
petroleum products.
b. High Concentration Hazard. Until the identity of UST contents is
known, all UST contents should be classified and treated as highconcentration waste for purposes of sample handling.
c. Overview. As a general guideline, the volume of liquid and sludge
content in the UST should be estimated before any sampling is done.
The USACE Contracting Officer's Representative (COR) can make a
decision regarding sampling once these quantities are known. The
USACE may have the option (depending on state and local regulations)
not to sample a layer and treat the entire layer as hazardous waste.
If this option is not exercised, the following sampling plan should
be employed.
(1) Only one liquid layer present: Collect subsamples at two
depths: near the surface (20 percent depth) and near the bottom
(80 percent depth). These two subsamples should be composited
to form a single sample for analysis.
(2) Two liquid layers present:
as a separate sample.
Sample each liquid layer and treat
(3) Empty tanks: Do not sample tanks found to be free of any liquid
phase. If there is reason to believe that an empty tank may
have held chemicals other than petroleum, oils, and lubricants
(POLs), consult the Center of Expertise (HTRW-CX)for guidance.
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TABLE 4-2
PHYSICOCHEMICAL PROPERTIES OF SIX COMMON HYDROCARBON MIXTURES
Product
Automotive Gasoline
No. 2 Fuel Oil
No. 6 Fuel Oil
4-8
Jet Fuel (JP-4)
Jet Fuel (JP-8)
Mineral Base
Crankcase Oil
N/A
Note:
Note:
Note:
Note:
Source:
=
Liquid
Density
(g/cm3)
(0.73)
0.72-0.76
[15.6]
(0.91)
0.81-0.92
[15]
(0.96)
0.93-1.06
[15]
0.75
0.80
0.84-0.96
[15]
Liquid
Viscosity
(cPoise)
(0.45)
0.36-0.49
[15.6]
(1.56)
1.15-1.97
[21]
(254)
14.5-493.5
[38]
0.829 [21]
1.98
275 [38]
Water
solubility
(mg/L)
(158)
131-185
[13-25]
3.2
~5
<300
Negligible
Negligible
Vapor
Pressure
(mm Hg)
(469)
263-675
[38]
(14.3)
2.12-26.4
[21]
(14.3)
2.12-26.4
[21]
91
50
N/A
Vapor
Density
(g/m3)
Flashpoint
(EC)
1,950
<2
109
>38
105
>38
400
N/A
N/A
-23
46
>38
Not Available
All values are approximate. Tank contents may be mixtures with varying characteristics.
Values for 20EC unless otherwise indicated. Brackets [ ] indicate a different
temperature in EC.
Values in parentheses are typical of the parameter.
Density of fuel vapors is greater than air so vapors will tend to collect in low places.
Compiled from various published and unpublished sources.
EM 1110-1-4006
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d.
Strategy for the Analysis of UST Contents. There are only a few
categories of liquids likely to be present in underground
storage tanks at most sites: (1) fuel oil/diesel (2) gasoline
(3) jet fuel (4) kerosene (5) heating oil (6) oily water (7)
chlorinated solvents (8) waste oil (9) herbicides and/or
pesticide/PCBs, (10) paint and plating waste/byproducts, and
(11) used oil. Sampling strategy will vary depending upon the
type of material stored and whether the material is intended for
recycle or disposal. Commercial chemicals and fuel products
recovered from an UST used for product storage that are still
suitable for use can still be used for their intended purpose.
They do not have to be disposed of as hazardous waste. For
these types of materials, analysis will be confirmatory in
nature to determine the product identity and purity. However,
fuel water mixtures that must be processed in order to be
usable, materials that can not be used for their intended
purpose, waste oils, used oils, and spent materials will require
analysis to characterize them for recycle or disposal.
(1) The analyses outlined here are intended to obtain enough
information to adequately identify the tank contents for proper
recycle/disposal in accordance with applicable federal and state
regulations. The analyses should help determine whether the
fluid in an UST is a useable product, is expected to become a
hazardous waste when removed for disposal, or is just oily water
that may be discharged to a nearby publicly owned treatment
works (POTW) or an oil-water separator.
(2) For used oily wastes, the sampling strategy begins with
consideration of EPA’s Standards for the Management of Used Oil,
40 CFR 279. To ensure oily waste is not subject to hazardous
waste regulation, sample for total halogens. If the result is
less than 1,000 mg/L halogens, then additonal testing would be
limited to parameters listed in Table 4-3. If more than 1,000
mg/L total halogens are detected, the oily waste is presumed to
be hazardous waste unless demonstrated otherwise. To pursue a
non-hazardous waste demonstration, Methods 8021 or 8260 may be
utilized to determine whether signficant amounts of halogenated
hazardous constituents from Appendix VIII of 40 CFR 261 are
present.
The basis for this testing is found in used oil standards in 40 CFR 279.
According to these standards, if oily waste contains greater than 1,000 mg/L
total halogens, it is presumed that listed hazardous waste was mixed into the
oil. The resultant mixture is then regulated as hazardous waste unless it can
be demonstrated that the source of the halogens was not hazardous waste. Once
the hazardous waste presumption is rebutted, use Table 4-3 to determine
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whether the oil is on-specification or off-specification. As can be seen from
Table 4-3, used oil can contain up to 4,000 mg/L total halogens and still be
considered on-specifiction used oil provided the hazardous waste presumption
has successfully been rebutted.
TABLE 4-3
USED OIL SPECIFICATION
Constituent/Property
Final Rule Allowable Level
Arsenic
5 ppm maximum
Cadmium
2 ppm maximum
Chromium
10 ppm maximum
Lead
100 ppm maximum
Total Organic Halogens
1,000 ppm rebuttable
4,000 ppm maximum
Flashpoint
100 degree F minimum
On-specification used oil can be burned in any type of burner. Offspecification used oil, on the other hand, is restricted to being burned in
devices listed in 40 CFR 279.61. This limits burning to industrial boilers;
industrial furnaces; utility boilers used to produce electric power, steam,
heated or cooled air, or other gases or fluids for sale; on-site space heaters
meeting the criteria of 40 CFR 279.23; and hazardous waste incinerators.
The used oil specification in Table 4-3, however, only applies to used oil.
It does not apply to fuel products. For fuel products the sampling strategy
will be based primarily on the requirements of the fuel purchaser/user.
Additionally, testing may be required to determine the Department of
Transportation (DOT) Proper shipping name for the fuel if sufficient knowledge
of the material is not available. Generally, testing for flashpoints and
boiling points of petroleum products will be sufficient to determine
applicable DOT shipping requirements.
For materials that are not petroleum fuels or used oils such as waste waters,
paint wastes, pesticides, PCBs, etc., the sampling strategy will be to analyze
the material to determine whether there are viable recycling and/or energy
recovery options and to determine whether the material is subject to
regulation under the Resource Conservation and Recovery Act (RCRA) or the
Toxic Substances Control Act (TSCA).
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e. Required Analyses.
(1) Analysis for used oil: Analyze each UST organic liquid sample
collected for total arsenic, total cadmium, total chromium,
total lead, total organic halogens, and flashpoint. Currently,
no EPA method correctly analyzes organolead in a liquid organic
matrix. The organic layer is not usually analyzed for total
recoverable petroleum hydrocarbons (TRPH) since it is usually
100 percent hydrocarbon (unless required by applicable
regulations). Analysis to determine fuel type is more
appropriate.
(2) Analysis for petroleum products: Characterization tests may be
provided by the receiving facility in accordance with state and
local regulations. Some facilities perform the work at the
receiving facility. Others require characterization tests prior
to shipment. The ignitability test requires only 2 mL of
sample. Ship samples as high concentration wastes. Adhere to
the USACE Sample Handling Protocol in EM 200-1-3, Appendix F
explicitly.
(3) Analysis for non-petroleum wastes such as waste waters, PCBs,
etc.: (NOTE: the scope of this EM does not include hazardous
waste tanks; however, hazardous wastes may be encountered
incidental to other activities such as when water intrudes into
a gasoline product tank. Therefore, this section is intended to
address these types of wastes.)
Aqueous layers in the tank may
be sampled for TRPH; RCRA characteristics including pH,
flashpoint, and TCLP constituents reasonably expected to be
present such as lead (or RCRA metals); PCBs; and volatile
organic compound analytes. VOC analysis requirements are
specified in 40 CFR 265.1084. If both organic and aqueous phases
are present, the USACE may elect to analyze each phase for
certain parameters selected from the complete list to minimize
redundancy. The laboratory used for these analyses should be
validated to ensure that it is capable of performing these
analyses correctly.
(4) Analysis for compliance with DOT requirements: Unless the
material is a known product, analysis will typically include pH,
flashpoint, and boiling point.
4-11
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f. Tank Accessibility.
(1) Underground storage tanks may not always be easily accessible
for testing during preconstruction activities. Tanks and their
filler caps may have been paved over or may be under debris.
The contractor for sample collection must consult with the
Contracting Officer’s Representative (COR) before removing soil
or debris to gain access to an UST. In cases where UST
accessibility is not possible, tank sampling may be deferred
until the construction phase. The construction contractor will
facilitate access to the tank by removing debris and dirt so
that a sampling subcontractor may collect samples during the
construction phase. You should recognize that if tank sampling
is deferred until construction due to limited accessibility, the
lack of information can lead to costly problems if surprises are
encountered. These problems may include contractor downtime,
contract modifications, and unexpected increases in
disposal/treatment costs. The tank should not be moved until
the tank contents can be characterized.
(2) Situations will arise in which UST access is not possible even
though the fill pipe is accessible. This may be the result of
corrosion. In this event, the field sampling supervisor should
contact the project manager for guidance.
g. UST Contents Sampling Instructions. These instructions provide a
reasonable method for sampling USTs and may be modified or replaced
with equivalent instructions to allow for site-specific constraints.
Sampling devices must be explosion proof. Acceptable sampling
devices include: peristaltic pumps, bladder pumps, weighted bottles,
Kemmerer samplers, bailers, or COLIWASAs (for small tanks). See EM
200-1-3 for guidance on sampling methods or refer to EPA/540/P-91/005
Compendium of ERT Surface Water and Sediment Sampling Procedures,
EPA/540/P-91/008 Compendium of ERT Waste Sampling Procedures, and
EPA/600/2-80/018 Samplers and Sampling Procedures for Hazardous Waste
Streams for additional information on these type of samplers. The
peristaltic pump provides the most convenient method of withdrawing a
sample from a tank and makes it easy to sample separate phases.
Instructions for sampling liquid layers in a tank are:
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EM 1110-1-4006
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(1) Wear personal protective equipment as specified in the Site
Safety and Health Plan.
(2) Remove the fill pipe cap with use of nonsparking tools.
(3) Determine depth of tank and depth of tank contents: Lower a
wooden stick (1" by 1" by 12') coated with water-indicating
paste (e.g., Kolor Kut™) to the bottom of the tank. Record the
following:
C
C
C
C
Distance from the bottom of the tank to the soil surface.
Total depth of the sludge layer (if this can be
determined by inspection of the stick).
Total depth of each layer of liquid in the tank.
Whether each layer is aqueous or nonaqueous.
(Chlorinated solvents are more dense than water; oil,
gasoline, etc. are less dense than water.) If the water
is on top, the water-indicating paste will not indicate
the presence of the heavier-than-water organic layer.
(4) Collect each separate stratified liquid and/or solid phase for
chemical analysis.
(5) To collect a sample using a peristaltic pump:
C
C
C
C
C
Fasten the tubing to the stick (used for measuring the
depth of the product) at the point from which the sample
is to be withdrawn.
Extend the stick into the tank until it reaches the
bottom.
Operate the pump to withdraw the sample directly into the
sample bottle.
Adjust the stick to withdraw a sample from another depth.
Other methods of sample collection are detailed below.
(a) Weighted Bottle. Carefully remove cork with a short, sharp
tug on the chain. Allow adequate time for the bottle to
fill. Additional guidance may be found in ASTM Standards D
4057 and E 300.
(b) Kemmerer Sampler. Seat the valve at the base of the
sampler. Lower the sampler into the tank. Unseat the valve
4-13
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at the desired depth. Additional guidance may be found in
EPA/540/P-91/005 (SOP #2013) and ASTM Standard D 4136.
(6) Remove the sampling device from the UST.
(7) Transfer the contents into the sample containers. Preserve as
appropriate. If only organic phase is being sampled, no
preservation or cooling is required. Samples must be packed and
shipped as high-level samples.
(8) Fasten the covers finger tight.
(9) Fill out field notebook, sample log sheet, labels, and chain-ofcustody forms (See Chapter 8 for details).
(10) Place in cooler at 4 degrees C. (Follow Chapter 8 for packaging
requirements, use of cans for high-hazard wastes, etc.)
(11) Decontaminate sampling equipment as described in Chapter 9 of
this manual.
h. Sludge Sampling.
(1) Sludge may be present at the bottom of the UST. Since storage
of RCRA-regulated waste is limited to 90 days without a permit,
it is important to characterize it early. If generator
knowledge is lacking, sludge analysis should include flashpoint
to determine if it meets the RCRA definition for the
characteristic of ignitability and should include TCLP analyses
for metals or other suspected TCLP constituents. Generally,
perform sludge sampling if:
(a) The tank contains no liquid or the liquids have been
removed.
(b) The tank is being removed and disassembled, and disposal
regulations for the sludge require sampling/analysis.
(c) Federal, state, and local regulations require sludge
analysis.
(2) Instructions for sampling sludge:
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(a) Wear personal protective equipment as required in the Site
Safety and Health Plan.
(b) Use an appropriate nonsparking sampling device such as a
polyethylene dipper (ASTM D 5358)or teflon COLIWASA (ASTM D
5495).
(c) Immediately transfer sludge from the sampling device to fill
the pair(s) of bottles required for VOAs. Fill as
completely as possible. Fasten the cover finger tight.
(d) Transfer the remainder of the sample into a stainless steel
mixing bowl. A stainless steel spoon or trowel may be used
to assist in this step.
(e) Repeat Steps (b) and (d) to obtain the required volume of
sludge. Refer to the Quality Control (QC) requirements in
Chapter 8. (For some samples it will be necessary to obtain
at least 48 oz. of sludge.)
(f) Quickly remove all nonsludge materials including stones and
vegetation from the mixing bowl.
(g) Composite (homogenize) the bowl contents with a stainless
steel spoon.
(h) Fill the 8-oz. wide-mouth glass bottles at least 3/4 full.
(i) Fasten the cover finger tight.
(j) Fill out field notebook, sample log sheet, labels, and
chain-of-custody forms.
(k)
Place in cooler at 4 degrees C.
(l)
Decontaminate sampling equipment as described in Chapter 9.
(3) QC split/duplicate samples.
requirements.
4-15
Refer to Chapter 8 for split sample
EM 1110-1-4006
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CHAPTER 5
SITE CHARACTERIZATION
5-1. General. This chapter discusses the investigation procedures that can
be employed if the contamination at the UST is more widespread than the
immediate tank area. Typically these procedures are above and beyond what is
required during a UST removal. These activities, if required, should be
performed under a separate contract from the UST removal so as not to slow
down the tank removal process yet avoid potential UST-removal contractor
delays. This chapter is included for guidance and completeness of this
manual. Additional guidance on site characterization may be found in
EM 200-1-3 and ASTM Standard Guides D 5730 and E 1912.
5-2. Subsurface Soil Gas Survey.
Soil gas surveys (also called field
hydrocarbon vapor tests) are a proven quick and economical in situ field
method for determining the presence of subsurface chemical contamination. The
soil-gas survey measures the relative concentration of volatile hydrocarbon
components in the vadose zone of the soil. Data obtained from these surveys
can be used to measure the relative magnitude of volatile hydrocarbons in the
soil and contaminant dispersion or migration trends. Quantitation is
accomplished with a gas chromatograph.
This information may help determine the need for quantitative soil sampling
and/or the need for monitoring well installation.
Two basic types of soilgas surveys commonly performed during UST site assessments are discussed
below.
a. Active soil gas survey. The first type is the active soil-gas survey
in which a probe is inserted into the subsurface and a volume of soil
gas is pumped out of the vadose zone into a sample collection device
for analysis. The gas samples are injected into a gas chromatograph
that has been calibrated with one or more of the analytes thought to
be present onsite.
b. Passive Soil Gas Survey. The second type is the passive soil-gas
survey in which a collection device is placed in the subsurface or on
the surface of the ground, allowing the atmosphere within the device
to come into compositional equilibrium with the soil atmosphere.
c. Comparison of Methods. Active soil-gas surveys can be completed in
as little as one day and are most commonly used. Passive soil-gas
surveys take several days or weeks to complete. While both methods
of soil gas sampling are applicable to sites contaminated by volatile
organic compounds (VOCs), passive soil gas sampling may also identify
some semivolatile organic compounds (SVOCs)(EPA/510/B-97/001).
Detailed guidance on typical soil-gas monitoring may be found in ASTM
D 5314.
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Soil gas sampling methods also include headspace measurements and flux chamber
measurements (EPA/600/8-87/036). Headspace sampling involves placing samples
of site soils into a sealed container and measuring the concentrations of
organics in the air above the soil (in the headspace) after some equilization
period. Flux chamber measurements are obtained by placing an open-bottomed
chamber on the soil surface and slowly passing a carrier gas over the soil
surface and collecting a sample of the air from the chamber for analysis.
a. Theory. The presence of VOCs in shallow soil-gas indicates the
observed compounds may either be in the vadose zone near the probe or
in groundwater below the probe. The soil gas technology is most
effective in mapping low molecular weight halogenated solvent
chemicals and petroleum hydrocarbons possessing high vapor pressures
and low aqueous solubilities. These compounds readily partition out
of the groundwater and into the soil as a result of their high
gas/liquid partitioning coefficients. Once in the soil gas, VOCs
diffuse vertically and horizontally through the soil to the ground
surface where they dissipate into the atmosphere. The contamination
acts as a source, and the aboveground atmosphere acts as a sink, and
typically a concentration gradient develops between the two. The
concentration gradient in soil gas between the source and ground
surface may be locally distorted by hydrologic and geologic
conditions (e.g., clays, perched water). However, soil gas mapping
generally remains effective because distribution of the contamination
is usually broader in areal extent than the local geologic barriers
and is defined using a large database. The presence of geologic
obstructions on a small scale tends to create anomalies in the soilgas– groundwater correlation but generally does not obscure the
broader areal picture of the contaminant distribution. A soil-gas
survey may be performed in the vicinity of each UST. Typically 5 to
10 ground probes are driven to depths similar to that of the bottom
of the UST or passive samples are placed around the UST location.
b. Limitations.
below:
Soil-gas methods do have limitations, as discussed
(1) Soil probing is more difficult if the UST is under a large
concrete pad.
(2) A positive result indicating site impacts are present in the
soil which could be related to contamination from other nearby
sources or from a recent spill.
(3) A positive result could occur (indicating soil contamination
when none exists at the location) if volatile hydrocarbons from
another source are migrating with and being released from the
groundwater.
5-2
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(4) Plant matter can cause false positive results.
(5) A false negative result, incorrectly indicating that the tank
has not leaked, may result if the UST leaked many years ago and
the volatile contaminants have largely degraded or dissipated or
if the leak involved nonvolatile liquids.
(6) Active soil gas may yield a false negative if rainfall or
snowmelt occurs just prior to the sampling. The infiltrating
water can drive contaminant vapors ahead of the infiltration
front and draw clean atmospheric air into the zone to be
sampled.
(7) Headspace methods may not yield samples representative of insitu vadose zone atmospheres. Large percentages of vapor phase
and moderate percentages of solute and sorbed phase contaminants
can be lost in the act of soil sampling.
(8) Driven probes tend to degrade natural soil permeability around
the body of the probe due to soil compaction concurrent with
insertion. This can be a severe limitation to active soil gas
extraction in moist, heavy clay soils.
(9) Soil characteristics such as high water saturation, soil
cements, clay content and organic matter content will negatively
impact results of surface flux chamber measurements by
restricting the rate of contaminant flux to the chamber.
(10) Humidity can affect the collection efficiency of the adsorbent
media in the sorbent samplers. Soil gas, even in the drier
climates, will be at a relatively high humidity condition.
(11) It is not possible to measure the efficiency of passive-sorbent
monitoring devices because the bulk volume of soil gas affected
by the sorbent trap cannot be measured.
(12) Sample collection by pumping soil gas from collection cans or
ground probes may disturb the equilibrium between the soil gas
and the gas sorbed on soil particles. This may cause dilution
and/or contamination of the sample by ambient air.
(13) High background concentrations may interfere with obtaining
accurate measurements when sampling with sorbents.
c. Field Equipment. A portable gas chromatograph with a photoionization
detector (PID) is sensitive to benzene, toluene, ethylbenzene, and
xylenes (BTEX) and decreasingly sensitive to nonaromatic hydrocarbons
(octane, etc.) and chlorinated hydrocarbons. The gas chromatograph
may also be equipped with a flame ionization detector (FID), which is
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EM 1110-1-4006
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also sensitive to hydrocarbons. The user should be aware of the
advantages and disadvantages of each type of detector. Each type of
detector has limitations related to the environment. The FID is
sensitive to severe changes in temperature, and the PID will not
function under conditions of high humidity.
d. Procedure for Conducting a Soil-Gas Survey with a Ground Probe. Use
these instructions as a general guide in conducting a soil-gas survey
using a ground probe near an UST.
(1)
Site calibration for a portable gas chromatograph. Ideally,
use commercially available vapor standards (low pressure,
bottled, standard calibration gas) for instrument calibration.
Inject the gas standard into the instrument with a gas-tight
syringe. (If commercial gas standards are not available, vapor
standards may be prepared in Tedlar bags filled with ultra-pure
air. Inject the analyte of interest into the Tedlar bags from
vapor obtained with a gas-tight syringe from the headspace
above a neat [pure, 100 percent] standard stored in a 40 mL VOA
vial with a septum cap. Prepare a new calibration standard
daily. It is generally preferable to use commercially
available calibration standard gases.)
More than one analyte may be of interest for the gas survey.
Any compound that may have been stored in the UST (e.g.,
gasoline or other volatile fuels; organic solvents such as
dichloroethane, trichloroethane, benzene, toluene, xylene,
methylene chloride, acetone; etc.) may be used to calibrate the
instrument so that quantitative results are obtained for that
analyte.
(2)
Typically, a hydraulic mechanism is used to drive and withdraw
sampling probes 1.5 to 3 m (5 to 10 feet) long. In unusually
hard soil, a hydraulic hammer may also be used. These probes
are typically fitted with detachable drive tips (see Figure 51).
(3)
Extract gas through the probe via a vacuum pump connected to
the tubing. Five sample probe volumes should be extracted
prior to sampling.
(4)
Remove a gas sample with the gas-tight syringe inserted into
the flexible tubing between the pump and the probe.
(5)
Inject the gas sample into the gas chromatograph.
5-4
EM 1110-1-4006
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Sample Cap
Vacuum Pump
Vacuum Gauge
Ground Surface
Section of Hollow
Steel Pipe
Vadose Zone
Expendable Point
Holder
Void Where Gas Vapor
is Drawn From
Expendable Drive
Point
Water Table
Figure 5-1 Typical Soil-Gas Apparatus
5-5
EM 1110-1-4006
30 SEP 98
(6)
Record the results in the field notebook. Note all
identifiable chemicals along with the concentration of each.
Also note significant unidentifiable peaks from each
chromatogram. Save the chromatograms as part of the field
documentation.
e. Decontamination. Dedicated sampling probes may be used in lieu of
field decontamination during the soil-gas survey. These probes may
then be cleaned (as described in Chapter 9) after the sampling event
but before leaving the site.
If dedicated probes are not used, the following decontamination
procedure should be followed.
(1) Decontaminate the probe between sample holes by removing visible
soil.
(2) Do not clean with water or any liquid because this will have an
effect on the gas chromatograph.
(3) Draw ambient air blanks through the probe and analyze by gas
chromatography to establish that cross-contamination is not
occurring.
(4) Another method that may be used for decontamination is baking
the volatiles off the probe using a portable heater.
5-3. Borehole Drilling/Soil Sampling. Soil borings and monitoring wells are
the primary means of assessing the extent of contamination from any
hydrocarbon phase. Borehole drilling is a method for collecting subsurface
soil samples and for subsequent well installation (discussed below).
Boreholes are completed to determine the nature and extent of contamination at
an UST site.
a. Methods. It is important to recognize that, while the primary focus
on drilling boreholes is for soil sample collection, borings are also
required for in-situ testing of subsurface materials and groundwater.
Table 5-1 presents types of drilling methods.
5-6
TABLE 5-1
DRILLING METHODS
Method
DirectPush
Drilling Principle
Advancing a sampling
device into the
subsurface by applying
static pressure,
impacts, or vibration
or any combination
thereof to the above
ground portion of the
sampler extensions
until the sampler has
been advanced its full
length into the
desired soil strata.
Depth
Limit
meters
(Ft.)
Advantages
Disadvantages
30 (100) Avoids use of drilling fluids Limited to fairly soft materials such as
and lubricants during
clay, silt, sand, and gravel. Compact,
drilling.
gravelly materials may be hard to penetrate.
Equipment highly mobile.
Disturbance of geochemical
conditions during
installation is minimized.
Drilling and well screen
installation is fast,
considerably less labor
intensive.
5-7
Does not produce drill
cuttings, reduction of
Small diameter well screen may be hard to
develop. Screen may become clogged if thick
clays are penetrated.
The small diameter drive pipe generally
precludes conventional borehole geophysical
logging.
The drive points yield relatively low rates
of water.
IDW.
EM 1110-1-4006
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TABLE 5-1
DRILLING METHODS
Method
Auger,
Hollowand
SolidStem
Drilling Principle
Successive 1.5-m (5ft) flights of spiralshaped drill stem are
rotated into the
ground to create a
hole. Cuttings are
brought to the surface
by the turning action
of the auger.
Depth
Limit
meters
(Ft.)
Advantages
45 (150) Fairly inexpensive. Fairly
simple and moderately fast
operation. Small rigs can
get to difficult-to-reach
areas. Quick setup time.
5-8
Can quickly construct shallow
wells in firm, nonclayey
materials.
No drilling fluid or
lubricants required.
Use of hollow-stem augers
greatly facilitates
collection of split-spoon
samples, and continuous
sampling is possible.
Small-diameter wells can be
built inside hollow-stem
flights when geologic
materials are cavey.
Disadvantages
Depth of penetration limited, especially in
cavey materials.
Cannot be used in rock or well-cemented
formations. Difficult to drill in cobbles
or boulders.
Log of well is difficult to interpret
without collection of split spoons due to
the lag time for cuttings to reach ground
surface.
Soil samples returned by auger flight are
disturbed making it difficult to determine
the precise depth from which the sample
came.
Vertical leakage of water through borehole
during drilling is likely to occur. Solidstem limited to fine-grained, unconsolidated
materials that will not collapse when
unsupported. Borehole wall can be smeared
by previously-drilled clay.
With hollow-stem flights, heaving materials
can present a problem. May need to add
water down auger to control heaving or wash
materials from auger before completing well.
TABLE 5-1
DRILLING METHODS
Method
Jetting
Drilling Principle
Washing action of
water forced out of
the bottom of the
drill rod clears hole
to allow penetration.
Cuttings brought to
surface by water
flowing up the outside
of the drill rod.
Depth
Limit
meters
(Ft.)
15
(50)
Advantages
Disadvantages
Relatively fast and
Somewhat slow with increasing depth.
inexpensive. Driller often
Limited to drilling relatively shallow
not needed for shallow holes. depth, small diameter boreholes.
In firm, noncavey deposits
where hole will stand open,
well construction fairly
simple. Minimal equipment
required.
Equipment highly mobile.
Extremely difficult to use in very coarse
materials, i.e., cobbles and boulders.
Large quantities of water required during
drilling process. A water supply is needed
that is under enough pressure to penetrate
the geologic materials present.
Use of water can affect groundwater quality
in aquifer.
5-9
Difficult-to-interpret sequence of geologic
materials from cuttings.
Presence of gravel or larger materials can
limit drilling.
Borehole can collapse before setting
monitoring well if borehole uncased.
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TABLE 5-1
DRILLING METHODS
Method
Cabletool
(percus
sion)
Drilling Principle
Hole created by
dropping a heavy
"string" of drill
tools into well bore,
crushing materials at
bottom.
5-10
Cuttings are removed
occasionally by
bailer. Generally,
casing is driven just
ahead of the bottom of
the hole; a hole
greater than 150 mm (6
inches) in diameter is
usually made.
Depth
Limit
meters
(Ft.)
Advantages
300+
Can be used in rock
(1,000 +) formations as well as
unconsolidated formations.
Can drill through cobbles and
boulders and highly cavernous
or fractured rock. Fairly
accurate logs can be prepared
from cuttings if collected
often enough. Driving a
casing ahead of hole
minimizes cross-contamination
by vertical leakage of
formation waters and
maintains borehole stability.
Recovery of borehole fluid
samples excellent throughout
the entire depth of the
borehole. Excellent method
for detecting thin waterbearing zones. Excellent
method for estimating yield
of water-bearing zones.
Excellent method for drilling
in soil and rock where lost
circulation of drilling fluid
is possible.
Core samples can be easily
obtained.
Excellent for development of
a well.
Disadvantages
The potential for cross-contaminated samples
is very high.
Decontamination can be difficult.
Heavy steel drive pipe used to keep hole
open and drilling "tools" can limit
accessibility. Cannot run some geophysical
logs due to presence of drive pipe.
Relatively slow drilling method.
Heavier wall, larger diameter casing than
that used for other drilling methods
normally used.
Temporary casing can cause problems with
emplacement of effective filter pack and
grout seal.
Heaving of unconsolidated sediment into
bottom of casing can be a problem.
TABLE 5-1
DRILLING METHODS
Method
Mud
Rotary
Drilling Principle
Rotating bit breaks
formation; cuttings
are brought to the
surface by a
circulating fluid
(mud). Mud is forced
down the interior of
the drill stem, out
the bit, and up the
annulus between the
drill stem and hole
wall.
5-11
Cuttings are removed
by settling in a "mud
pit" at the ground
surface and the mud is
circulated back down
the drill stem.
Depth
Limit
meters
(Ft.)
Advantages
1,500+
Drilling is fairly quick in
(5,000 +) all types of geologic
materials, hard and soft.
Borehole will stay open from
formation of a mud wall on
sides of borehole by the
circulating drilling mud.
Eases geophysical logging and
well construction.
Geologic cores can be
collected.
Can use casing-advancement
drilling method.
Borehole can readily be
gravel packed and grouted.
Virtually unlimited depths
possible.
Disadvantages
Expensive, requires experienced driller and
fair amount of peripheral equipment.
Completed well may be difficult to develop,
especially small diameter wells, because of
mud or filtercake on wall of borehole.
Lubricants used during drilling can
contaminate the borehole fluid and soil/rock
samples.
Geologic logging by visual inspection of
cuttings is fair due to presence of drilling
mud. Thus beds of sand, gravel, or clay may
be missed.
Location of water-bearing zones during
drilling can be difficult to detect.
Drilling fluid circulation is often lost or
difficult to maintain in fractured rock,
root zones, or in gravels and cobbles.
Difficult drilling in boulders and cobbles.
Presence of drilling mud can contaminate
water samples, especially the organic,
biodegradable muds.
EM 1110-1-4006
30 SEP 98
Overburden casing usually required.
Circulation of drilling fluid through a
contaminated zone can create a hazard at the
ground surface with the mud pit and crosscontaminate clean zones during circulation.
EM 1110-1-4006
30 SEP 98
TABLE 5-1
DRILLING METHODS
Method
Reverse
Rotary
Drilling Principle
5-12
Similar to hydraulic
rotary method except
the drilling fluid is
circulated down the
borehole outside the
drill stem and is
pumped up the inside,
just the reverse of
the normal rotary
method. Water is used
as the drilling fluid,
rather than a mud, and
the hole is kept open
by the hydrostatic
pressure of the water
standing in the
borehole.
Depth
Limit
meters
(Ft.)
Advantages
1500+
Drilling readily accomplished
(5,000 +) in soils and most hard rock.
Drilling is relatively fast
and for drilling large
diameter boreholes.
Borehole is accessible for
geophysical logging prior to
installation of well.
Creates a very "clean" hole,
not dirtied with drilling
mud.
Large diameter of borehole
permits relatively easy
installation of monitoring
well.
Can be used in all geologic
formations.
Very deep penetrations
possible.
Split-spoon sampling
possible.
Disadvantages
Drilling through cobbles and boulders may be
difficult.
Use of drilling fluids, polymeric
additives, and lubricants can affect the
borehole chemistry.
A large water supply is needed to maintain
hydrostatic pressure in deep holes and when
highly conductive formations are
encountered.
Expensive — experienced driller and much
peripheral equipment required. Hole
diameters are usually large, commonly 450 mm
(18 inches) or greater.
Cross-contamination from circulating water
likely.
Geologic samples brought to surface are
generally poor; circulating water will
"wash" finer materials from sample.
TABLE 5-1
DRILLING METHODS
Method
Drilling Principle
5-13
Air
Rotary
Very similar to
hydraulic rotary, the
main difference is
that air is used as
the primary drilling
fluid as opposed to
mud or water.
Sonic
(vibratory)
Employs the use of
high-frequency
mechanical vibration
to take continuous
core samples of
overburden soils and
most hard rock.
Depth
Limit
meters
(Ft.)
Advantages
1,500+
Can be used in all geologic
(5,000 +) formations; most successful
in highly fractured
environments.
Useful at most any depth.
Drilling in rock and soil is
relatively fast.
Can use casing-advancement
method.
Drilling mud or water not
required.
Borehole is accessible for
geophysical logging prior to
monitoring well installation.
Well development relatively
easy.
150
(500)
Disadvantages
Relatively expensive.
Cross-contamination from vertical
communication possible.
Air will be mixed with the water in the hole
and blown from the hole, potentially
creating unwanted reactions with
contaminants; may affect "representative"
samples.
Air, cuttings and water blown from the hole
can pose a hazard to crew and surrounding
environment if toxic compounds encountered.
Compressor discharge air may contain
hydrocarbons.
Organic foam additives to aid cuttings’
removal may contaminate samples.
Overburden casing usually required.
Can obtain large diameter,
continuous and relatively
undisturbed cores of almost
any soil material without the
use of drilling fluids.
Rock drilling requires the addition of water
or air or both to remove drill cuttings.
Can drill through boulders,
wood, concrete, and other
construction debris.
Extraction of casing can damage well screen.
Extraction of casing can cause smearing of
borehole wall with silt or clay.
Equipment is not readily available and is
expensive.
Can drill and sample most
softer rock with high
percentage of core recovery.
Reduction of IDW.
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Drilling is faster than most
other methods.
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TABLE 5-1
DRILLING METHODS
Method
AirPercussio
n Rotary
or Downthe-HoleHammer
Drilling Principle
Air rotary with a
reciprocating hammer
connected to the bit
to fracture rock.
Depth
Limit
meters
(Ft.)
600
(2,000)
Advantages
Very fast penetrations.
Useful in all geologic
formations.
Only small amounts of water
needed for dust and bit
temperature control.
Disadvantages
Relatively expensive.
As with most hydraulic rotary methods, the
rig is fairly heavy, limiting accessibility.
Overburden casing usually required.
5-14
Vertical mixing of water and air creates
Cross-contamination potential cross-contamination potential.
can be reduced by driving
casing.
Hazard posed to surface environment if toxic
compounds encountered.
Can use casing-advancement
method.
DTH hammer drilling can cause hydraulic
fracturing of borehole wall.
Well development relatively
The DTH hammer requires lubrication during
easy.
drilling.
Organic foam additives for cuttings’ removal
may contaminate samples.
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(1) Selection of the most appropriate method or combination of
methods must be dictated by the special considerations imposed
by multipurpose borings. For example, although the best
apparent method for well installation at a particular site may
be direct air rotary with driven casing, most air rotary
equipment allows sampling only by cuttings. If, in this case,
soil sampling is required, pilot (or separate) borings done with
equipment capable of providing adequate undisturbed samples may
be necessary. In addition, if drilling is to be conducted in an
area of perched or multiple aquifer systems, auger techniques
should not be used because of the possibility of crosscontamination; borings must be advanced using multiple casing
techniques that allow isolation of each aquifer encountered.
Additional guidance on drilling methods may be found in EM 11101-4000 and the following ASTM Standards:
D 2113 Practice for Rock Core Drilling and Sampling of Rock
for Site Investigation
D 5781 Guide for the Use of Dual Wall Reverse-Circulation
Drilling
D 5782 Guide for the Use of Direct Air Rotary Drilling
D 5783 Guide for the Use of Direct Rotary Drilling With
Water-Based Drilling Fluid
D 5784 Guide for the Use of Hollow-Stem Augers
D 5872 Guide for the Use of Casing Advancement Drilling
Methods
D 5875 Guide for the Use of Cable-Tool Drilling and
Sampling Methods
D 5876 Guide for the Use of Direct Rotary Wireline Casing
Advancement Drilling Methods
D 6286 Guide for Selection of Drilling Methods for
Environmental Site Characterization
(2) The planning, selection, and implementation of any drilling
program requires careful consideration by qualified, experienced
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personnel.
required:
At a minimum, the following general steps are
(a) Review existing site, area, and regional subsurface;
geologic; and hydrogeologic information including physical
and chemical characteristics.
(b) Develop project DQOs and a SAP.
1-3 for additional guidance.
See EM 200-1-2 and EM 200-
(c) Develop a site-specific safety and health program.
(d) Define the purpose of the drilling and sampling, select
drilling methods and general site layout, and prepare and
execute the drilling contract.
(e) Field implementation and decontamination includes continuous
inspection by qualified, experienced personnel.
(3) Selection and implementation of soil drilling and sampling
methods requires that specific consideration be given to the
following issues:
(a)
Prevention of contamination migration.
(b)
Maintenance of sample integrity.
(c)
Minimization of disruption of existing conditions.
(d)
Minimization of long-term impacts.
b. Equipment. Guidance on sampling equipment may be found in EM 200-1-3
and EM 1110-1-1906. Additional guidance may be found in ASTM D 6169.
Hollow stem auger drilling is frequently used and may include the
following:
(1) Hollow-stem auger and drill rig.
(2) Sampling tubes.
following:
Sampling systems may consist of either of the
(a) Continuous sampling tube systems consisting of 1.5m (5-foot)
long split or solid sampling tubes. Tubes can be used with
or without liners of various metallic and nonmetallic
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materials. Continuous samplers advance with the auger
flights.
(b) Split-spoon sampling consisting of 0.5m (18-inch) long split
spoons with basket-retainer shoe. Split spoons are driven
into the soil ahead of the auger using a drive hammer.
(3)
Stainless steel knives, spoons, and bowls.
(4)
Sample containers (see Chapter 8).
(5)
Ice.
(6)
Shipping coolers and supplies.
(7)
Decontamination equipment (see Chapter 9).
(8)
Logbook.
c. Procedures.
(1) Obtain any federal, state, or local permits required for
constructing wells or clearing the site for work or access.
Contact regulatory agencies to obtain their regulations
concerning submission of boring/well logs and samples.
(2) At each borehole the geologist must maintain a log that contains
at a minimum the following information:
(a)
Name of the project and site.
(b)
Hole number.
(c)
Location of the boring.
(d)
Type of drill rig and method of drilling.
(e)
Size and type of bit used.
(f)
Depth of each change of stratum.
(g)
Thickness of each stratum.
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(h) Identification of the material composing each stratum
according to the Unified Soil Classification System, or
standard rock nomenclature, as necessary.
(i)
Depth interval from which each formation sample was taken.
(j) Hole diameter and depth at which hole diameter (bit size)
changes.
(k)
Depth at which groundwater is first encountered.
(l) Depth to the static water level and changes in static water
level with hole depth.
(m)
Total depth of hole.
(n) Depth or location of any loss of drill water circulation,
loss of tools or equipment, and any other problems
encountered.
(o) Location of any fractures, joints, faults, cavities, or
weathered zones.
(p)
Reference elevation for all depth measurements.
(q)
Name of driller and geologist.
(r)
Standard Penetration Test blow counts, if applicable.
(s) Date(s) of drilling, including depths where work shifts
begin and end.
(3) To take a subsurface soil sample (after the sampler is retrieved
from the borehole), follow these steps:
(a) Set up decontamination, sampling preparation, and support
areas at borehole location.
(b) Decontaminate all equipment, samplers, and tools that will
come in contact with sample media (see Chapter 9 for
decontamination procedures). Record decontamination process
in logbook.
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(c) Inform driller of sample interval(s) for borehole and
oversee sampling process.
(d) Prepare and label all sample containers. If any volatiles
are analytes, have the volatiles containers available first.
Label containers with location, depth, analyte, date, and
time of sampling.
(e) Have the driller prepare the sampler for opening, but do not
allow the driller to completely open the sampler.
(f) With the sampler lying on a clean sheet of plastic, the
onsite geologist should open the sampler slowly. As the
sampler is being opened, the surface of the core should be
"sniffed" with a PID/FID. Position the probe of the
instrument approximately 25 mm (one inch) from the sample.
Record instrument readings in the logbook. If the PID/FID
reading is above background, a soil sample should be
collected from the anomalous interval. Consult with the
site manager to determine whether to submit for chemical
analyses.
(g) For those locations in which VOCs are analytes, VOC samples
must be collected immediately after the sampler is opened.
Using a sampling knife, cut off solid piece(s) (nominal 25
mm [one inch] in size) of sample and place piece(s) into the
container. Immediately close container and place on ice.
The container must not have any headspace if the sample is
to be analyzed for VOCs.
(h) Log the core, recording percent recovery, color, texture,
clay, sand, gravel content, and other notable
characteristics in the logbook.
(i) After logging, transfer sample to mixing bowl and thoroughly
homogenate the sample.
(j)
Fill remaining sample jars.
(k)
Prepare necessary QA/QC samples.
(l) Log all samples in field notebook; Include borehole ID
sample number, analyte(s), date, time, and collector
signatures.
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(m) Pack samples for shipment, prepare chain-of-custody records
and shipping documentation (see Chapter 8).
(n)
Ship samples as specified in Chapter 8.
(4) If the borehole is to be used for a well installation, follow
procedures outlined in Paragraph 5-4 below, otherwise grout the
borehole. The grout mixture should be composed of Portland
cement mixed to a ratio of 27 liters (7 gallons) of water per
sack of cement with a 3-percent bentonite powder additive.
Grout must be pumped into the borehole via a tremie pipe.
5-4.
Well Installation.
a. Purpose. The purpose of a monitoring well is to provide an access
point for measuring groundwater levels and to collect groundwater
samples that accurately represent in-situ groundwater conditions at
the specific point of sampling. Consult EM 1110-1-4000 for guidance
on monitoring well installation.
To procure accurate samples, follow these criteria:
(1)
Construct the well with minimum disturbance to the formation.
(2) Construct the well of materials that are compatible with the
anticipated geochemical and chemical environment.
(3)
Complete the well properly in the desired zone.
(4) Seal the well adequately with materials that will not interfere
with the collection of representative water-quality samples.
(5) Develop the well sufficiently to remove any additives associated
with drilling and provide unobstructed flow through the well.
b. Groundwater Sampling. Prior to well sampling, the task manager/field
team leader is responsible for collecting and reviewing information
about the well. This information should include: well construction
methods and materials, well logs, well size, well depth, screen
interval(s), and purpose of well (monitoring, water supply, etc.).
This information should accompany the field crew during sampling.
The following procedures should be followed during a groundwater
sampling event:
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(1) Set up decontamination, sample preparation, and support area at
wellhead. (This may be at the rear of a truck/van.)
(2) Decontaminate all equipment/instruments that will be placed into
well casing or come in contact with water samples. Record
decontamination process in logbook.
(3) Review well log for construction, size, and well depth. Record
information in logbook. Do not measure the total depth of the
well prior to sampling. Measuring to the bottom of the well
casing may cause re-suspension of settled solids from the
formation materials and require longer purging times for
turbidity equilibration. Measure the well depth after sampling
is complete.
(4) Using water-level probe, determine water level (ASTM D 4750).
Record in logbook.
(5) Calculate purge volume. NOTE: USACE well-purging procedures
specify including the volume of water in the filter (sand) pack
in purge-volume calculations. To prevent purging an
unnecessarily large volume of water, calculate height of water
column using water level and construction data. Also using
construction data, calculate volume of one casing plus filterpack volume (i.e., one purge volume) using the following
formula:
Volume (gallons) = Br2h (cu. ft). X 7.48 (gallons/cu. ft).
r =
h =
radius in feet (of either auger borehole or well
casing as described below).
height of water column in feet.
Because the water contained in the sand pack will be used in
the calculations, follow these steps:
(a) Calculate the total volume of the saturated portion of the
borehole. Use the radius of the overall borehole (sand
pack plus well casing) for the calculation. This is
Volume A.
(b) Calculate the total volume of the well casing.
radius of the well casing for the calculation.
Volume B.
5-21
Use the
This is
EM 1110-1-4006
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(c) Determine the volume of the saturated portion of the sand
(filter) pack. This is done by subtracting Volume B from
A and multiplying the result by a porosity factor of 0.35.
This will be Volume C, the sand-pack volume, as shown
here:
(Volume A – Volume B).35 = Volume C (sand-pack volume)
(d) Add Volumes B and C to produce volume of water for one
filter (sand) pack and well casing. That is:
Volume B + Volume C = Volume D, (filter-pack and casing
volume)
Record calculations and the purge volume (Volume D) in
logbook.
(6) The well should be purged of at least three casing and sand
(filter) pack volumes or until pH, temperature, specific
conductance, oxidation-reduction potential (ORP), dissolved
oxygen (DO), and turbidity are each at equilibrium. Equilibrium
is established when three successive readings are within:
C
C
C
C
C
C
±0.2 pH units.
±1 degree Celsius for temperature.
±3 percent for specific conductance.
±10mV for oxidation-reduction potential (ORP).
±10 percent for DO.
±10 percent turbidity.
Equilibrium will be established by three consecutive readings,
where one casing volume is pumped between each reading.
Multiply the filter-pack and casing volume by three to produce
the minimum purge volume. If well is purged dry before three
purge volumes, allow well to recover and then sample. See EM
200-1-3 for more guidance on well purging.
(7) Begin purging well using either bailer, submersible pump, or inplace pump.
(8) Collect all purge water in 55-gallon drums until the disposal
method can be determined based on water quality results. NOTE:
In some instances, purging rates must be kept below 500 mL/min
to avoid over pumping or pumping the well to dryness. Ideally,
wells should never be pumped to dryness.
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(9) Initiate sampling after purging has been completed. Label all
sample containers with well ID, date, and time of sampling,
analytes, and preservative. See Table 8-3 for sample bottle
requirements. If bioremediation is a potential treatment option,
samples should be collected for testing for nitrates, sulfates,
ferrous iron, and methane.
(10) Collect sample with a freshly decontaminated bailer.
bailer carefully into well to prevent aeration of well.
Lower
(11) Fill VOA containers first (add two drops HCl acid preservative
to containers prior to filling). Overfill container, put on
cap, and invert container to check for bubbles. If
bubbles are present, discard sample and refill. Place samples
on ice.
(12) Fill other organic analyte bottles next. Do not completely fill
the container. Leave approximately 10-percent volume as head
space. Mark the volume on the container with a grease pen.
Preserve as specified in preservation table. Place samples on
ice.
(13) Fill remaining inorganic analyte containers.
(14) Log all samples in field logbook; include well number,
identifier, analyte(s), date, time, and collector signatures.
Record time of purge, purge volume, and water quality
parameters in logbook.
(15) Pack samples for shipment; prepare chain-of-custody records and
shipping documentation.
(16) Ship samples as specified in Chapter 8.
c. Free Product. Properly installed and constructed monitoring wells can
be used both to delineate the extent of free product and monitor
temporal changes in free product accumulations. However, it is also
important to realize that monitoring wells are subject to significant
limitations in their ability to provide accurate measurements of the
thickness of free product in the surrounding soil. Free product can
accumulate in a well only if the well is open (i.e., screened) across
the zone of free product. Within a well with a properly positioned
screen, the thickness of free product typically fluctuates in
response to changes in water table elevation. Where wells are
initially installed with short screens (1.5 m [5 ft] or less),
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changes in the water table elevation may result in a dry well
(declining water table) or in a well that is screened below the zone
of free product (rising water table). Even in properly constructed
wells, the absence of free product may not necessarily indicate that
petroleum hydrocarbons are not present in the soil. Similarly to the
observation that water may take days or weeks to enter some
monitoring wells constructed in clayey soil, free product may not
initially appear in monitoring wells. Such a condition indicates that
the relative permeability with respect to free product is very low;
hence the mobility of the free product is also low. This may also
result in a lower calculated volume of free product.
(1) Record the thickness of free product, if encountered. Three
methods are commonly used to measure free product thickness in a
well: steel tape and paste, interface probes, and bailers.
The pastes used with the steel tape are sensitive to
hydrocarbons and water. Commercially available interface probes
sense the presence of both oil and water. The first two methods
are accurate to within about 3 mm (0.01 ft) and are convenient
for determining the elevation of the air/free product and
oil/water interfaces. Whenever possible, measurements should be
taken using either steel tape and paste or an interface probe.
A bailer is a transparent cylinder with a check valve at its
base. The bailer methods can significantly under- or overestimate the thickness of free product in the well and should
not be used for determining the elevations of air/free product
and free product/water interfaces. Disposable bailers, which are
commonly dedicated to monitoring wells containing free product,
typically collect an unrealistically small product thickness
because of the small size of the intake holes. The use of
bailers should be limited to verification of the presence of
free product in a well or collection of a small sample of it.
Bailers can be used to remove liquids from monitoring wells
during baildown tests that are designed to determine the rate of
free product recovery into wells. For more information on free
product measurement and recovery see EPA/510/R-96/001.
5-5. Aquifer Testing. After completion and development of all monitoring
wells, perform slug tests at each well to provide data to contribute to the
hydrogeologic characterization of the site. Slug tests provide data to
approximate hydraulic conductivity and transmissivity of the aquifer. The
slug test is a useful tool for estimating the areal variability of these
parameters within a given unit and does not require that any water be
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EM 1110-1-4006
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discharged from the tested well. Also, the test does not artificially induce
contaminant flow and can be performed on wells within known or suspected
groundwater contamination plumes. Further information on aquifer testing may
be found in EPA Groundwater Issue on Suggested Operating Procedures for
Aquifer Pumping Tests, EPA/540/S-93/503. Guidance for measuring well discharge
may be found in ASTM D 5737.
a. Procedure. To perform a slug test, a solid slug is introduced into
the well and changing water levels are measured with a transducer.
Water level and elapsed-time data can be recorded with a data logger
and pressure transducer. Both "rising heads" and "falling heads" are
recorded. Additional guidance on conducting a slug test may be found
in EPA/540/P-91/007 and ASTM D 4044.
b. Data. Data from the slug tests can be input from the strip logs into
a computer spreadsheet for review. After these data are checked for
accuracy, the data file can be transferred into a commercially
available program that calculates hydraulic conductivity (m/day
[gal/day/ft2]) and transmissivity (m2/day [gals/day/ft]) for the
aquifer.
5-6. Soil Testing. To determine an appropriate corrective action for
contaminated soil and/or groundwater, site-specific information relating to
the hydrologic and geologic characteristics of the site, as well as soil
chemistry, is needed. These characteristics include depth to groundwater,
soil temperature, moisture content, soil water field capacity in accordance
with ASTM D-2325, or ASTM D-3152, particle-size distribution, bulk density,
saturated and unsaturated hydraulic conductivity, dissolved oxygen, carbon
dioxide, total organic carbon, and total volatile hydrocarbons.
An example of the importance of these parameters is: a soil's hydraulic
conductivity directly affects a contaminant's mobility, while soil air
conductivity affects the mobility of the contaminant vapors. Air and
hydraulic conductivity varies from formation to formation in much the same
way, with formations of low hydraulic conductivity generally having low air
conductivity as well.
The procedures for collecting field samples for soil parameters are covered
extensively in many other publications and are not discussed in this manual.
Soil characterization data needs for different remedial technologies can be
found in EM 200-1-2.
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5-7. Survey. When there is a release from an underground storage tank, the
horizontal and vertical extent of the contamination must be determined. To
make an accurate determination of contamination extent, verify borehole and
monitoring well locations as well as the elevations of the monitoring wells.
Designers use this information to develop a site-specific groundwater contour
map, for calculating the groundwater gradient and flow rate, and a threedimensional model of the soil contamination. Coordinates and elevations
should be established for each well and boring location to a minimum of third
order survey. Elevations should be provided for each well casing to the
closest 5 mm (0.01 foot).
5-8.
Waste Disposal.
a. Disposal of Drill Cuttings. Cuttings must be tested using a PID/FID
to help determine contaminant status. Potentially contaminated
cuttings must be handled as described in "b. Collection and Testing
of Potentially Hazardous Materials" (below). Potentially
contaminated drill cuttings and/or vapors are defined as those
substances with PID/FID readings in excess of 5 ppm above background
levels. This assumes that the tanks being pulled are POL tanks and
that the primary contamination is from volatile contaminants. If
this is not the case, analytical results of actual soil samples must
be used. The implementing agency should provide guidance values for
soil disposal. Additional guidance may be found in EPA/540/G-91/009.
b. Collection and Testing of Potentially Hazardous Materials. Materials
generated during field activities must be placed in properly labeled
drums that are Department of Transportation (DOT)-approved for
transport of hazardous materials Follow these guidelines:
(1) Segregate all materials in separate drums (i.e., soil, water,
tyvek, and other similar materials).
(2) Secure drums at a designated staging area on wooden pallets,
pending receipt of analytical results.
(3) Label all drums adequately prior to moving them to the staging
area. Label drums in a permanent, waterproof manner in
accordance with the IA requirements. Drums must not be labeled
on the top. At a minimum, label drums as to type of material
contained, site number, and location boring numbers.
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The eventual disposal of the contents of these drums is
determined by the results of the associated analytical tests for
the project. Local regulations may preclude the use of drill
cuttings as backfill. Check with the local IA to determine if
non-contaminated drill cuttings need to be containerized and
disposed of offsite.
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CHAPTER 6
SAMPLING DURING UST REMOVAL PROCEDURE
6-1. General. The purpose of this chapter is to recommend sampling
procedures for the excavation of soils from UST sites and free-product
sampling procedures for spills or leaks that have occurred at UST sites.
objectives of the sampling are:
The
(1) To obtain soil, and water if present, from the surface and known
depths in the vicinity of the UST excavation for evaluation of
site characteristics.
(2) To detect the presence of any contaminants.
(3) To evaluate the potential for pollutant migration.
The contractor should be responsible for assessing specific situations for the
most appropriate response. Upon removal of USTs, pools of free product may
exist in the ground cavity. The origin of these pools is usually seepage from
the tank or spills associated with removal. Free-product pools should be
sampled to possibly determine the nature and source of these liquids.
Guidance for preparation of sampling plans can be found in EM 200-1-3.
6-2. Field Screening for Soil Samples. An organic vapor analyzer may be used
as a cost-effective screening device for soil samples. When this instrument
is equipped with a sampling probe and a flame ionization detector (FID) or a
photoionization detector (PID), it is capable of detecting volatile
hydrocarbons in the 1 to 1,000 ppm range. The results obtained are not
quantitative, however. The results from several soil samples are relative and
will allow the sampling team to select samples that are the most contaminated
with hydrocarbons. The presence of little or no organic vapor is possibly
indicative of noncontaminated soils. The USACE may use FID/PID results as the
criteria for deciding which soil samples should be analyzed by the more
expensive gas chromatography (GC) techniques (Method 8021 or Modified 8015).
Other screening methods such as immunoassay may also be used for soil tests.
a. Purpose. Field screening is done for a variety of reasons. The
technique is frequently used to screen soil samples for measurable
levels of volatile organics. For example, the results can be used to
select the most contaminated sample from a soil boring for complete
analysis by Method 8021. Field screening is often used as a
predesign activity to construct an effective sampling plan. The
FID/PID is also used during construction to delineate the extent of
excavation.
b. Field Equipment. A pint jar with metal ring-type lid is frequently
used for this screen. The sample is placed in the bottle and covered
with aluminum foil. The ring lid secures the foil. An organic vapor
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EM 1110-1-4006
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analyzer (such as the Century OVA) is used to measure volatile
organics.
c. Instructions for Headspace Analysis by FID/PID. This procedure is
used in categorizing soil based on the quantity of organic vapor
present and may be modified slightly.
(1) Stabilize and calibrate the FID/PID. Follow the manufacturer's
instructions. Some models are factory calibrated to methane and
should not be recalibrated. Other models require the use of a
calibration gas; follow the manufacturer's recommendations for
calibration (called "spanning") of the instrument (see Chapter
11).
(2) Place soil from the soil sampling equipment into the jar. Cover
with foil and secure ring cap. The pint jar should be at least
3/4 full.
(3) Place the jar in hot tap water (30 degrees C.) for 5 minutes.
An alternate method is to place the jar on the dashboard of a
vehicle with the defrost cycle on.
(4)
Remove the jar from the water or dashboard.
(5) Immediately insert the sampling probe through the foil and into
the headspace above the soil.
(6) Take the reading and record the value in the field logbook along
with the other particulars of the sampling point.
(7) Verify that the FID/PID is reading background before exposing
the probe to another sample.
6-3. Sampling. Guidance for soil and water sampling may be found in
EM 200-1-3.
a. Soil Sampling. Conduct soil sampling at the ground surface, including
the exposed walls and bottom of the excavation or within the mound of
excavated soil. Surface soil sampling typically refers to samples
collected between 0 and 300 mm (0 and 12 inches) from the surface.
Surface soil sampling may be accomplished with a trowel, a push tube,
a hand auger, or a backhoe. Soil samples may provide two types of
soil contaminant representation: grab and composite. These samples
may be collected in random locations from a grid pattern or in
selected areas believed to be contaminated (as evidenced by staining
or measurable volatile organic readings).
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(1) A grab sample is a discrete aliquot representative of a specific
location at a given point in time. The sample is collected at
one time and at one particular sampling point and depth.
(2) A composite sample is a nondiscrete sample composed of more than
one specific aliquot that may be collected at various sampling
locations, depths, and/or different points in time. The
aliquots are thoroughly mixed together, and the mixture
homogenized.
b.
Water Sampling. If water is present in the excavation, and has not
been determined to be groundwater, completely evacuate and dispose of
it in accordance with all applicable regulations. If within 24 hours,
the water recharges into the excavation to a level sufficient for
sample collection, collect a sediment-free sample as soon as
practicable. However, if water exists in the excavation and site
conditions warrant immediate backfilling (that is, collapsing side
walls or other safety issues), collect a water sample. Water sampled
directly from inside an excavation or from a soil boring is not
necessarily representative of normal groundwater conditions and
should not be evaluated as a groundwater sample. Such samples may,
however, be used to document the existence of a release (ASTM E
1599).
c. Equipment. Surface soil and water sampling require limited equipment
including the following:
C
C
C
C
C
C
C
C
C
C
C
C
C
d.
C
HNu or OVA or equivalent monitoring devices (Chapter 11).
CGI (see Chapter 10).
Backhoe.
Hand auger.
Stainless steel trowels.
Push tube.
Stainless steel knives and spoons.
Stainless steel mixing bowls.
Pond sampler.
Sample containers (see requirements in Chapter 8).
Decontamination equipment (see Chapter 9).
Personal protective equipment (respirator, etc.).
Tape measure.
Materials.
following:
Supplies required to perform soil sampling include the
C Preservation supplies (ice).
C Sample labels, custody seals, and chain-of-custody forms.
C Personal protective supplies (gloves, tyvek).
C Decontamination supplies (see Chapter 9).
Logbooks.
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e. Operations, Procedures, and Instructions.
(1) Notify and inform the selected analytical laboratory before
sampling of the estimated number of samples to be collected, the
analyses required. Special requirements, if any, and expected
sample arrival date. This information should be in the project
DQOs provided to the laboratory. In addition, many states have
developed required sampling patterns for obtaining samples from
excavations. Contact the state agency to determine any
requirements.
(2) Discuss (as a field team) the Site Safety and Health Plan (SSHP)
prior to initiating field activities. All monitoring and
protective equipment should be checked thoroughly at this time.
Personal protective equipment and health and safety standards
are specified for each activity in the SSHP.
(3) Set up decontamination, sample preparation, and support area at
a central location.
(a) Equipment Selection and Preparation. Decontaminate all
equipment, samples, and tools that will come in contact with
sample media. Record decontamination process in log book.
All sampling equipment must be made of inert and nonreactive
material (i.e., stainless steel, PTFE, glass), and if not
disposable, must be decontaminated before and between
sampling points. Disposable sampling equipment may be
thrown in the trash if not contaminated or drummed up and
disposed with the soil. The decontamination procedure may
vary depending on site and contaminant conditions. Chapters
7 and 9 outline decontamination procedures.
(b) Carry sampling equipment to sample location. Be sure all
equipment rests on plastic sheeting next to sample location.
Utilize an HNu or Organic Vapor Analyzer (OVA) or similar
instrument to detect any organic vapors being emitted during
excavation and sampling and a Combustible Gas Indicator
(CGI) to monitor oxygen levels.
(4) Sample Container Preparation. Prepare and label all sample
containers to be collected that day (sample containers are
discussed in Chapter 8). Label should identify sample location
ID, sample ID, depth, analyte, date, time of sampling, and any
preservatives added (preservatives are not usually required for
soil samples although some jurisdictions may require them,
especially for volatile analytes). Time of sampling and depth
should be added after sample is collected.
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(5) Selection of Sampling Location. Sampling locations and depths
required within the excavation are often selected to obtain the
most contaminated sample. Consult the Implementing Agency (IA)
to determine sample locations and depths. Soil samples should
be taken from the surface down to approximately 300 mm (12
inches) in depth. Under no circumstances is anyone to enter a
hole for the purpose of sampling. Soil samples are to be taken
from the bucket of the backhoe or other implement being used for
excavation. Samples should be collected from the native soil,
not any surrounding backfill. All backfill should be removed
during soil excavation.
(a) Worst-case locations include:
C Areas around the tanks and piping locations that record
the highest reading with the vapor monitoring equipment
or that look stained or discolored.
C The lowest point of the tank cavity, if this can be
determined, where the tank meets the piping.
C Beneath the fill lines. At least two surface soil
samples–one from either end of each tank–should be
collected when the tank(s) are removed.
(b) Samples collected may consist of random grid grab samples,
random grid composite samples, composite or grab of stained
soils, offsite clean soil, or grabs or composites from
runoff areas. Consult the Implementing Agency for further
guidance on excavation sampling as well as sampling from the
mound of excavated soil.
(c) If possible, an offsite sample should also be collected to
compare with the excavation samples. This "background"
sample should be collected in an undisturbed area. This may
be difficult to obtain in an industrialized area.
(6) Soil Sample Collection. Collect a sample using a stainless
steel trowel or spoon, hand auger, or similar device.
(a) Collect samples for volatile organic analysis (VOA) first to
minimize loss of the soil contaminants.
(b) Fill VOA containers directly from a trowel.
homogenize VOA samples.
Do not
(c) For samples subject to other than volatile analyses, place a
sufficient amount of soil in a stainless steel mixing bowl
or tray for homogenization. This includes composite
samples. Prior to homogenization, remove all twigs, stones,
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and other debris from the soil. With a stainless steel
spoon, the sample is scraped from the sides, corners, and
bottom of the tray; rolled to the middle of the tray; and
initially mixed. The sample should then be quartered and
moved to the four corners of the mixing vessel. Each
quarter of the sample should be mixed individually, then
rolled to the center of the container, and the entire sample
mixed again.
(d) Since excavation pits should not be entered, samples should
be collected by the use of a backhoe. The backhoe is to
scoop a bucket full of soil from the desired sampling
location. The sampler then collects a sample from the
center of the bucket.
(e) Local requirements may indicate the need to sample
groundwater if present in the excavation. If this is
required, sampling should be accomplished without entering
the excavation. A long handled dipper should be used to
collect the water sample.
(7) Sample Packaging. Place the sample in a sample container
appropriate for the type of analysis to be performed. Container
requirements are described in Chapter 8 and EM 200-1-3. The
latest version of SW-846, referenced in Chapter 8, should be
used to meet analytical requirements.
(a) Wipe the outside of the sample container to prevent the
spread of contamination. The sample container must not
contain any headspace. This no headspace requirement
applies to samples collected for volatile organic analyses
only. Log all samples in field logbook or on field sheets;
include sample location, sample ID number, analytes, date,
time, and signatures of samplers.
(b) As the samples are collected, place them in a Ziplock® bag
in an ice chest containing an ice substitute or regular ice
that has been double wrapped in plastic. Samples are kept
on ice to maintain their integrity. Each sample should be
individually wrapped to prevent possible crosscontamination. Highly contaminated soil samples must be
placed in metal cans (see Chapter 8). Sample temperature
should be maintained at 4 ± 2 degrees C.
(8) Decontamination. Refer to Chapter 9 for more information on
decontamination procedures.
(9)
Sample Shipping.
Refer to Chapter 8 for shipping requirements.
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6-4. Free-Product Sampling. This section applies to the sampling of residual
free-product pools in an UST excavation. Limit sampling to liquid free
product. Saturated soils or sludges should be sampled according to guidelines
described previously. Further guidance on the characterization of free product
may be found in EPA/510/R-96/001.
a. Precautions. Specific hazards in the excavation area include the
danger of subsidence both in the pit and of the sidewalls. It is
recommended that personnel never enter an excavation pit. Extreme
caution also must be exercised when approaching a pit to sample from
above, as sidewall subsidence occurs frequently and with no warning.
b. Equipment. Free-product sampling is an activity that requires
limited equipment, including the following:
C
C
C
C
C
C
C
C
HNu, OVA, or equivalent monitoring devices (see Chapter 11).
Backhoe (if needed).
Liquid sampling equipment.
Narrow-mouthed glass bottles.
Sample containers (see requirements in Chapter 8).
Decontamination equipment (see Chapter 9).
Personal protective equipment (respirator, etc.).
Tape measure.
c. Materials. In addition to the equipment listed in the preceding
section, the supplies required to perform free-product sampling
include the following:
C
C
C
C
C
C
Sample containers.
Preservative supplies (ice).
Sample labels, custody seals, and chain-of-custody forms.
Personal protective supplies (gloves, Tyvek®).
Decontamination supplies (see Chapter 9).
Logbook.
d. Operations, Procedures, and Instructions.
(1) Notify the selected analytical laboratory before sampling of the
estimated number of samples to be collected, the analyses that
will be required, special requirements (if any) and when it
should expect to receive the samples.
(2) Discuss (as a field team) the SSHP and the procedures outlined
by it prior to initiating field activities. All monitoring and
protective equipment should be checked thoroughly at this time.
Personal protective equipment and safety and health standards
are specified for each activity in the SSHP.
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(3) Set up decontamination, sample preparation, and support area at
a central location.
(4) Equipment Selection and Preparation. Decontaminate all
equipment, samples, and tools that will come in contact with
sample media. Record the decontamination process in logbook.
All sampling equipment must be made of inert and nonreactive
material (i.e., stainless steel, PTFE, glass), and if not
disposable, must be decontaminated before and between sampling
points. The decontamination procedure may vary depending on
site and contaminant conditions. Chapters 7 and 9 outline
decontamination procedures.
(5) Carry sampling equipment to sample location. Be sure all
equipment rests on plastic sheeting next to sample location.
Utilize an HNu, OVA, or similar instrument to detect any organic
vapors being emitted during excavation and sampling and a CGI to
monitor oxygen levels.
(6) Sample Container Preparation. Prepare and label all sample
containers (sample containers are discussed in Chapter 8).
Label should identify sample location ID, sample ID, depth,
analyte, date, time of sampling, and any preservatives added.
(7) Selection of Sampling Location. Sampling locations are often
selected based on equipment availability and proximity to the
sides of the excavation pit. Samples should be taken from each
pool occurring in an excavation pit. If only one large pool is
present, at least two samples should be taken from separate
locations within that pool.
(8) Sample Collection.
(a) Tools: Collect samples using clean, stainless
steel/glass/aluminum combination subsurface grab or COLIWASA
samplers. Equipment instructions are supplied by the
manufacturers.
(b) Containers: Samples collected with these types of equipment
must be transferred to sample bottles for shipment. Metal
containers with inner cap seals are preferable, but glass
may also be used.
(c) Methods: When necessary, a backhoe may be used to transport
a pool and surrounding soil to the surface for collection of
the free-product sample. Another technique is to pump out
the free product from the excavation into the sample jars
using a peristaltic pump. After water separation, samples
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should be transferred to metal or glass containers with
inner cap seals for transport.
(d) Separating free product: Often, free product will occur in
pools mixed with water from precipitation or ground seepage.
In these cases, attempts should be made in the field to
separate free product from the water to obtain an adequate
quantity for analysis. Generally, 250 mL (8oz) of product
is a sufficient amount for most analyses required. To
achieve separation, liquid in a narrow-mouthed glass bottle
must be allowed to settle until the water has clearly
dropped to the bottom section. Cap the opening and tilt the
bottle sideways until the floating phase portion floats
clear of the mouth. Much of the water can then be drained
away by simply uncapping the opening while tilting the
bottle. Repeat this procedure until the desired amount of
free-product sample is recovered. The residual water must
be disposed of according to individual facility guidelines.
(9) Sample Packaging. Place the sample in a sample container
appropriate for the type of analysis to be performed. Container
requirements are described in Chapter 8. The latest version of
SW-846, referenced in Chapter 8, should be used to meet
analytical requirements. Wipe the outside of the sample
container to prevent the spread of contamination. The sample
container must not contain any headspace. This applies to the
collection of organic samples for VOCs only. Log all samples in
the logbook; include sample location, sample ID number,
analytes, date, time, and signatures of samplers.
(10)
Chain-of-Custody.
Chapter 8.
Chain-of-custody procedures are described in
(11)
Decontamination. Decontaminate sampling equipment before and
after sampling. First clean equipment of gross contamination
then wash it with Alconox soap and distilled water. Rinse it
using deionized water and allow it to dry. Refer to Chapters 7
and 9 for more information on decontamination procedures.
(12)
Sample Shipping. Ship samples via an overnight carrier and
pack according to the DOT or International Air Transport
Association (IATA) procedures for the transport of samples.
Refer to Chapter 8 for more information on sample shipment.
6-5. Waste Disposal. Waste that is generated during sampling in and around
the UST(s) must be containerized and labeled according to its contents. The
waste must be packaged in DOT-approved containers for subsequent treatment or
disposal as outlined in Chapter 5.
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6-6.
Reporting and Documentation Requirement.
a. Use a field logbook to record:
C
C All activities performed, including names of samplers.
C Location and depths of samples.
C Dates and times when these activities were performed.
C Personnel contacted.
C Field conditions.
C Times of site arrival and departure.
C Soil color and texture.
C Instrument calibration information.
Any unusual circumstances. Information should be factual, as it
will be required for preparation of the Closure Report discussed
in Chapter 1. If logbook corrections are necessary, draw a single
line through the original entry, write the corrected entry
alongside it, and initial and date the correction.
b. Information not recorded in the logbook must be recorded on field
forms. In either case the following information must be recorded:
C
C
C
C
C
C
C
Site identification.
Type of samples.
Sample identification numbers.
Date and time collected.
Collector's name.
Field observations.
Measurements.
Record safety and health monitoring information in the field logbook
or on field data forms. Record everything so that events can be
reconstructed at a later date. This logbook, combined with copies of
the custody forms submitted to the laboratory with the samples, will
serve to document sampling activities.
c. Photographs are suggested. If photos are taken they need to be
labeled with the date, name of photographer, roll number, site name,
camera type and lens size, sequential number of photo, and general
direction. See EM 200-1-3 for additional information. Telephoto or
wide-angle shots cannot be used in enforcement proceedings because
they can distort the view.
6-7.
Department of Transportation Sample Shipping Requirements
a. Special consideration must be given to shipment of samples that are
regulated as hazardous materials by the Department of Transportation.
The following types of samples commonly encountered during UST
removal activities are potentially DOT-regulated hazardous materials:
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C
C
C
C
C
C
Tank contents.
Saturated soil samples.
Free product samples.
Water samples preserved with acid.
Decontamination fluids.
Sample preservatives such as methanol.
b. Definition of DOT Hazardous Material. Samples generated during UST
removal activities are regulated by DOT as hazardous materials most
commonly because they either meet the definition of a combustible
liquid, a flammable liquid, a corrosive liquid, or because they are
RCRA hazardous wastes. For example, samples of tank contents, freeproduct, or saturated soils having a flashpoint between 60.5oC
(141oF) and 93oC (200oF) are regulated as combustible liquids.
Materials having a flashpoint of less than 60.5 degrees C (141
degrees F) are regulated as flammable liquids. Water samples, which
have been acidified for preservation purposes, may meet the
definition of a DOT corrosive liquid. Spent decontamination fluids
utilizing nitric acid, methanol, or hexane may be regulated by DOT
because they are RCRA hazardous wastes. See Chapter 8 for sample
packaging, marking, and shipping requirements. See 49 CFR,
Subchapter C for details on Hazardous Materials Regulations.
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CHAPTER 7
SITE SAFETY AND HEALTH PLAN REQUIREMENTS
7-1.
General. A written site-specific safety and health plan is required to
protect onsite personnel, the environment, and potential offsite receptors
from the chemical and physical hazards particular to the UST site. The site
safety and health plan (SSHP) must address all potential hazards and must
present a plan of immediate action to protect all contractor's employees and
USACE personnel and/or property. The SSHP must be followed during
investigations, testing, repair/upgrade, removal, and all other UST-associated
work. The contractor must be required to provide to the USACE, or an
authorized representative, an SSHP before any work is initiated onsite in
fulfillment of the contract or subcontract for UST work as directed by USACE.
The contractor must utilize the services of a certified industrial hygienist
(CIH) or a certified safety professional (CSP) experienced in hazardous waste
site operations to oversee the development and implementation of the safety
and health documents required by this section.
a. References. All site investigation and UST removal activities and
safety and health documents must, at a minimum, comply with the
following regulations:
(1) Federal Acquisition Regulation (FAR) Clause 52.236-13:
Prevention.
Accident
(2) USACE, Safety and Health Requirements Manual; EM 385-1-1 (latest
revision).
(3) OSHA Construction Industry Standards, 29 CFR 1926, and General
Industry Standards, 29 CFR 1910; including but not limited to 29
CFR 1926.65 - Hazardous Waste Operations and Emergency
Response.
(4) NIOSH/OSHA/USCG/EPA, Occupational Safety and Health Guidance
Manual for Hazardous Waste Site Activities, October 1985.
(5) USACE, Guide Specification, CEGS-01350, Safety, Health, and
Emergency Response (HTRW).
(6) Other applicable federal, state, and local safety and health
requirements.
b. Personnel.
C
The SSHP must include but not be limited to:
Phone numbers of all emergency response personnel associated
with evacuation routes and assembly areas.
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C
C
C
C
Phone numbers and names of persons in the areas adjoining the
UST site.
A roster of all contractor's personnel onsite.
Detailed directions and a map to the nearest medical facility.
Other inclusions deemed necessary to ensure that all safety
requirements are addressed.
Because of the nature of the flammable or combustible liquids that are stored
in these tanks, hazardous conditions may arise in the work area during removal
and subsequent handling of tanks. For this reason, all personnel involved
onsite must be familiar with the potential hazards and know appropriate safety
and health measures to ensure a safe working environment.
7-2. Submittals. The following safety and health documents are required for
UST activities delineated in this manual. Avoid providing material of a
general nature that is not related to the UST project or site. Information
readily available in standard texts should be repeated only to the extent
necessary to meet the requirements of this scope. The Safety and Health
Program (SHP) should contain general information required by the referenced
OSHA standard and EM 385-1-1. By comparison, the SSHP should be a brief
document addressing site-specific safety and health requirements and
procedures based upon site-specific conditions. Reiteration of general
information contained in the SHP should be avoided in the SSHP.
a. Safety and Health Program. The contractor must submit a copy of the
SHP required by OSHA Standard 29 CFR 1926.65(b)(1) through (b)(4)
with the initial SSHP. Information contained in this written program
must be used by reference in the SSHP, as appropriate, to fulfill
site-specific plan detail requirements.
b. Site Safety and Health Plan. The contractor's SSHP required by 29
CFR 1926.65(b)(4) must be prepared by the contractor and submitted to
the contracting officer for review and approval prior to the
commencement of any onsite work by the contractor and/or
subcontractors. The level of detail provided in the SSHP should be
tailored to the type of work, complexity of site activities, and
anticipated hazards. All topics required by OSHA 29 CFR
1926.65(b)(4) and those described below must be addressed in the
SSHP. Where the use of a specific topic is not applicable to the
project, a negative declaration supported by a brief justification
must be given.
(1) Site Description and Contamination Characterization. Describe
the location, topography, and approximate size of the site; the
onsite jobs/tasks to be performed; and the duration of planned
site activities. Compile a complete list of the contaminants
found or known to be present in site areas. This listing should
be based on results of previous studies; or, if not available,
select the likely contaminants based on site history and prior
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site uses/activities. Include chemical names, concentration
ranges, media where found, locations onsite, and estimated
quantities/volumes to be impacted by site work, if known. In
addition, information should also be included for any other
chemicals brought onsite to complete any tank removal or site
characterization activities.
(2) Hazard/Risk Analysis. Identify the chemical, physical,
biological, and safety hazards of concern for each site task
and/or operation to be performed. Analyze these hazards and
develop procedures for their control. Selection of chemicals as
indicators of hazard must be based on media concentrations,
toxicity, volatility or potential for air entrainment at
hazardous levels, and frequency of detection.
Describe chemical and physical properties of selected
contaminants, sources and pathways of employee exposures,
anticipated onsite and offsite exposure-level potentials, and
regulatory (including federal, state, and local) or recommended
protective exposure standards. Specify and justify "action
levels" based upon airborne exposure hazards and direct skincontact potentials for upgrades/downgrades in levels of
personnel protection; for implementation of engineering and/or
work practice controls; for emergency evacuation of onsite
personnel; and for the prevention and/or minimization of public
exposures to hazards created by site activities.
Perform exposure monitoring/sampling as well as personnel
monitoring in accordance with paragraph 7-6 titled Exposure
Monitoring/Air Sampling Program. Compare the resulting data
with established "action levels." Initiate the appropriate
corrective actions as necessary.
(3) Accident Prevention. The contractor's SSHP will serve as the
Accident Prevention Plan (APP) and activity hazard analyses
(phase plans) as required by FAR Clause 52.236-13 and USACE EM
385-1-1. Thus, a separate APP is not necessary. Any additional
topics required by EM 385-1-1 must be addressed in an accident
prevention section of the contractor's SSHP. Daily safety and
health inspections must be conducted by the SSHO to determine if
operations are being performed in accordance with the
contractor's SSHP, USACE and OSHA regulations, and contract
requirements. In the event of an accident/incident, the
contractor must immediately notify the contracting officer's
representative (COR). Within two working days of any reportable
accident, the contractor must complete and submit to the
contracting officer (CO) an Accident Report on ENG Form 3394 in
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accordance with AR 385-40 and USACE supplements to that
regulation.
(4) Staff Organization, Qualifications, and Responsibilities. The
organizational structure must be discussed, including lines of
authority (chain of command) and overall responsibilities of the
contractor and all subcontractors for site activities, including
supervisor/employee relationships. Summarize the operational
and safety and health responsibilities and qualifications of
each key person identified. Specifically:
(a) A CIH or CSP with experience in hazardous waste site
operations must be responsible for the development,
implementation, and oversight of the contractor's SSHP and
SHP. The SHP and SSHP must be signed and dated by the CIH
or CSP prior to submittal.
(b) A fully trained and experienced SSHO, responsible to the
contractor and the CIH or CSP, may be delegated to implement
and continually enforce the safety and health program and
site-specific plan elements onsite.
(c) At least one person certified in First Aid/CPR by the Red
Cross, or equivalent agency, must be continuously present
onsite during site operations.
7-3. Medical Surveillance. All personnel performing onsite activities must
be participants in an ongoing medical surveillance program, meeting the
requirements of 29 CFR 1926.65(f) and ANSI Z-88.2. A description of the
general medical surveillance program is to be included in the contractor's
SHP. All medical surveillance protocols and examination results must be
reviewed, signed, and dated by a licensed physician who is certified in
Occupational Medicine by the American Board of Preventative Medicine, or who,
by necessary training and experience, is board eligible. The contractor's SHP
may only describe the content and frequencies of any additional medical
tests/examinations/ consultations determined necessary by the physician due to
probable site-specific conditions, potential occupational exposures, and
required protective equipment. Certification of participation in the medical
surveillance program, the date of last examination, and name of reviewing
occupational physician must also be included for each affected employee. The
written medical opinion from the attending physician required by 29 CFR
1926.65(f)(7) must be made available upon request to the COR for any site
employee.
7-4. Safety and Health Training. All personnel performing onsite activities
must have completed applicable training in accordance and compliance with 29
CFR 1926.65(e) and EM 385-1-1. In addition, site-specific training covering
site hazards, procedures, and all contents of the approved contractor SSHP
must be conducted by the SSHO for onsite employees and visitors prior to
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commencement of work or entering the site. The type, duration, and dates of
all employee training performed must be listed by employee name and certified
in the contractor SSHP. The following training information is general in
nature but should be included in the SSHP.
a. Basic, Refresher, Supervisory, and Site Training.
(1) No employee should be put into a hazardous field situation
without training that includes an opportunity to practice job
assignments in a nonhazardous situation. This section describes
training requirements.
(2) Before starting work on the site, an employee or subcontractor
must complete a 40-hour basic hazardous waste safety and health
training course that meets the requirements of 29 CFR
1926.65(e), the OSHA Standard for Hazardous Waste Operations and
Emergency Response. The training is to be documented with a
certificate signed by the course director. Basic training also
includes at least three additional days of field or operations
training under supervision. Supervisors are required to
complete eight additional hours of hazardous waste management
training.
(3) On an annual basis, employees are required to complete eight
hours of refresher training thereby meeting the requirements of
29 CFR 1926.65(e)(8).
(4) Employees should complete a site-specific safety
training/orientation that emphasizes:
C
C
C
C
C
C
C
C
C
C
C
C
C
C
C
Names of personnel responsible for site safety and health.
A discussion of the SSHP.
Site-specific safety and health hazards.
Exposure monitoring/personal exposure guidelines (e.g., PEL,
TLV, IDHL, odor threshold, etc.).
Fire extinguishers.
Designated work zones.
Phase safety plans.
The nature of site hazards.
Use of personal protective equipment (PPE).
Decontamination facilities and procedures.
Work practices by which employees can minimize risks from
hazards.
Site rules and regulations, including vehicle use.
Medical surveillance requirements, including recognition of
symptoms and signs of exposure.
Confined space entry procedures.
Emergency and fire response.
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C
C
C
Material safety data sheets (MSDSs).
Procedures for reporting hazardous conditions and practices.
Safety and Health training requirements.
b. Training for Subcontractors.
(1) Subcontractors are required to submit certification that they
have met OSHA requirements for basic, refresher, and supervisory
training before working on the site.
(2) The SSHO should be responsible for conducting a task-or
assignment-specific briefing for subcontractors seeking access
to the site to perform work.
(3) Training should be specific to the assignment or task and may
include the same topics discussed in the previous section.
(4) Subcontractors or authorized visitors may enter the site after
completing this orientation, providing that in addition to
meeting the training requirements, they possess appropriate
medical and respirator certifications.
c. Visitor Training. Visitors and other individuals seeking access to
the site must receive a briefing conducted by the SSHO as to their
safety-related responsibilities. This briefing (typically 5 to 10
minutes in length) should include:
C
C
C
C
Areas of site restriction.
Discussion of the site evacuation warning signal.
Discussion of the emergency egress route.
Other topics as deemed necessary by the nature of the visit.
7-5. Personal Protective Equipment (PPE). The contractor’s SSHP should
include a written PPE Program that in accordance with 29 CFR 1926.65 (g) (5)
and the respiratory protection program requirements of 29 CFR 1926.103. The
contractor SSHP must detail the minimum PPE ensembles (including respirators)
and specific PPE construction materials for each site-specific task/operation
to be performed based upon hazard/risk analysis. Components of levels of
protection (A, B, C, D, and modifications) must be relevant to site-specific
conditions, including heat and cold stress potential and safety hazards.
Site-specific procedures for onsite PPE use, limitations, training, fit
testing, cleaning, maintenance, inspection, and storage and disposal should be
included also.
a. Level of Protection. The level of protection for the majority of
site work tasks described in this UST Manual is anticipated to be
Modified Level D as described in Table 7-1. However, the SSHO may
upgrade to Level C if the "action levels" discussed in this plan are
exceeded. Work must cease pending a complete reevaluation of the
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site conditions by the CIH/CSP and SSHO should Level A and B
conditions be anticipated or required once onsite.
(1) Modified Level D. Employees and subcontractors will be required
to wear the PPE designated in Table 7-1 for tasks that the SSHO
determines to be Modified Level D. The SSHO is responsible for
determining if liquid contaminant exposure could occur. These
conditions may require taping of the joints at the wrist and
ankle.
See Table 7-1 for PPE descriptions for Levels A, B, and C.
Employees and subcontractors will be required to wear PPE as
dictated by task according to the SSHO.
b. Respiratory Protection Program.
(1) Employees and subcontractors are required to conform to the
respiratory protection requirements of OSHA 29 CFR 1926.103 and
EM 385-1-1. A written respiratory program as required by 29 CFR
1926.103(b)(1) should be incorporated as a part of the
contractor's/subcontractor's written SSHP and provided with the
SSHP to the contracting officer.
(2) Employees and subcontractors must be required to submit evidence
of respirator fit testing to the SSHO prior to performing tasks
with the potential for upgrade to Level C or Level B. The
documentation of qualitative and/or quantitative fit testing for
survey personnel wearing respirators must include the following
items for each individual: the manufacturer; the model; the
size; the NIOSH Testing and Certification Number; the test
results; the signature of the individual being tested; and the
signature of the staff member who performed the fit test.
(3) Before using a respirator, employees and subcontractors are
required to perform an inspection and checkout in accordance
with the manufacturer's instructions. All respirator users will
conduct positive- and negative-pressure leak testing each time
the respirator is worn to ensure satisfactory fit and valve
function. The user will perform the following tests:
(a)
Positive-pressure test: The user places the palm of
his/her hand over the exhalation valve and exhales
gently. If the respirator fits properly, the face piece
should swell slightly.
(b)
Negative-pressure test: The user covers both cartridges
with his/her hands and inhales gently. If the
respirator fits properly, the face piece should collapse
on his/her face.
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TABLE 7-1
PERSONAL PROTECTIVE EQUIPMENT
Level D
Work clothing, as dictated by the weather
Safety (steel toe/shank) shoes or boots
Chemical goggles or face shield
Hard hat
Nitrile, neoprene, or natural rubber gloves (use when
handling or contact may occur with contaminated soils or
similar incidents)
Modified
Level D
Work clothing as dictated by the weather
Safety (steel toe/shank) shoes or boots
Hard hat
Face shield (for pumping operations)
Chemical goggles (for tank interior decontamination
operations)
Saranex or polyethylene-coated tyvek (or equivalent)
Coveralls with hood (use when handling or contact may occur
with contaminated soils or material, tank contents, tank
interior decon, or other similar incidents)
Nitrile, neoprene, or natural rubber overboots (use when
handling or contact may occur with contaminated soils or
similar incidents)
Nitrile, neoprene or natural rubber gloves (use when
handling or contact may occur with contaminated soils or
similar incidents)
Level C
Same as for Modified Level D except for the addition of:
Full-face, air-purifying respirator equipped with organic
vapor cartridges
Level B
Same as for Modified Level D except for the addition of:
Pressure-demand, full-face SCBA or pressure-demand supplied
air respirator with escape SCBA
Level A
Pressure-demand, full-face SCBA or pressure-demand supplied
air respirator with escape SCBA
Fully encapsulating suit
Inner gloves
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(4) Facial hair (beards, sideburns, etc.) that interferes with the
sealing surface of a respirator or interferes with its valve
function is not permitted. A "one-day" growth of beard is
considered to be interference.
(5) Contact lenses must not be worn onsite. Each individual who
requires visual correction must be provided with the appropriate
corrective lenses that are made to be mounted inside a full face
piece.
(6) Employees and subcontractors are required to clean and disinfect
their respirators thoroughly after each use or at the end of the
day's activities. Respirator wipes may be used in the
intervals.
(7) Respirators must be stored away from dust, sunlight, heat,
extreme cold, excessive moisture, damaging chemicals, and
sources of mechanical damage.
7-6. Exposure Monitoring/Air Sampling Program (Personal and Environmental).
Where there may be employee exposures to, and/or offsite migration potentials
of, hazardous airborne concentrations of hazardous substances, then
appropriate direct-reading (real-time) air monitoring and integrated timeweighted average (TWA) air sampling must be conducted in accordance with
applicable regulations (OSHA, EPA, state). Both air monitoring and air
sampling must accurately represent concentrations of air contaminants
encountered on and leaving the site's exclusion/contamination reduction or
support zones as deemed appropriate for the type of monitoring performed.
Follow these guidelines for monitoring:
(1) Utilize sampling and analytical methods following NIOSH (for
onsite personnel and site perimeter locations) and/or EPA (for
site perimeter or offsite locations) criteria.
(2) Use laboratories successfully participating in and meeting the
requirements of the American Industrial Hygiene Association's
(AIHA) Proficiency Analytical Testing (PAT) or Laboratory
Accreditation programs for personnel sample analysis.
(3) Perform meteorological monitoring onsite as needed and use it as
an adjunct in determining perimeter and any offsite
monitoring/sampling locations. Where perimeter monitoring/
sampling is not deemed necessary, provide a suitable
justification for its exclusion.
(4) Conduct noise monitoring as needed, depending on the site hazard
assessment.
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(5) Compare all monitoring/sampling results to "action levels"
established pursuant to "Hazard/Risk Analysis," in paragraph 7-2
above to determine acceptability and need for corrective action.
As a minimum, develop action levels by taking into account the
PELs, TLVs, odor thresholds, explosive limits of and monitoring
instrument responses to the contaminants where this information
is available.
Minimum action levels for benzene and gasoline (where applicable) and percent
oxygen and lower explosive limits (LELs) must be as follows:
Benzene
0-1 ppm
1-25 ppm
> 25 ppm
Level D/Modified Level D
Level C/Modified Level C
Shut down operations and ventilate the area
Gasoline
0-30 ppm
30-1,000 ppm
> 1,000 ppm
Level D/Modified Level D
Level C/Modified Level C
Shut down operations and ventilate the area
Oxygen Monitoring
19.5%-22%
< 19.5%
>22%
Normal operations
Level B, shut down operations and ventilate the
area
Shut down operations and ventilate the area
LEL
< 10%
> 10%
Normal operations with monitoring
Shut down operations and ventilate the area
a. Exposure Monitoring.
(1) The SSHO should perform exposure monitoring to ensure that
employees and subcontractors are not exposed to chemical
contaminants above established exposure limits.
(2) Conduct personal monitoring by taking breathing zone and general
area measurements using direct reading instruments during work
tasks that have the potential for exposure. When personnel are
working on or near tanks or within trenches/excavations, the
contractor should implement routine personnel air surveillance
for the presence of air contaminants (gasoline, benzene, oxygen
level, LEL, etc.). Air monitoring will be required whenever
personnel enter a confined space or continuously during tank
vapor purging/inerting. (For the purposes of this manual,
purging means any method employed by the contractor to reduce
the atmosphere in the tanks to less than 10 percent of the LEL.
Inerting refers to methods used to reduce the oxygen content in
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the tank to less than or equal to 8 percent.) Air monitoring
will ensure that personnel are not exposed above OSHA PELs or
ACGIH TLVs, whichever is more stringent.
(3) Follow these guidelines for environmental monitoring:
(a)
Conduct environmental monitoring by taking general area
measurements using direct reading instruments during
work tasks that have the potential to produce airborne
contaminants that may migrate offsite.
(b)
Conduct confined space monitoring for all excavations
greater than five feet in depth and continuously during
the time workers are present in excavations.
(c)
Conduct air monitoring in storage tanks to ensure the
tank has been adequately purged. The contractor must
test all areas (top, middle, bottom) of the tanks in the
event stratification has occurred.
When monitoring to ensure personnel safety, both oxygen content and LEL
readings are required. When obtaining LEL readings, first verify the oxygen
content of the space to provide for proper operation of combustible gas
indicators. Oxygen levels less than 19.5 percent constitute IDLH conditions.
(If the inerted nature of the tank is to be determined, only oxygen readings
are required. Forced fresh air ventilation will be required when
appropriate.)
Whenever air monitoring within the exclusion zone indicates Level C, PPE is
required, as well as routine air monitoring at the boundary of the exclusion
zone. The SSHO must expand the exclusion zone as necessary to ensure air
concentrations do not exceed Level D action levels at the exclusion zone
boundary.
(4) Cold climates present special problems for monitoring
instruments and monitoring in general. Instruments must be
calibrated frequently and must be allowed time to warm up.
Meters must be calibrated for the conditions of the vapor
mixture to be measured and calibrated at the temperatures to be
used. A rise in temperature of 10 degrees requires a calibration
recheck and area resampling.
b. Exposure Monitoring Equipment.
(1) The presence of organic vapors throughout the site area and in
breathing zones must be determined using a real-time vapor
monitoring instrument such as a PID or FID.
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(2) Equipment used for real-time environmental monitoring include
Photoionization Detectors (PID), Flame Ionization Detectors
(FID), and Combustible Gas Indicators (CGI). Many CGIs are also
equipped to monitor oxygen and hydrogen sulfide levels in the
atmosphere. This type of instrument is recommended for
environmental monitoring and required for confined space work.
Other monitoring equipment that may be necessary (depending on
site conditions) is direct-reading colorimetric indicator/
detector tube systems for measuring benzene. All instruments
should be maintained and calibrated according to manufacturers'
guidelines.
c. Phase Safety Plans. The following sections contain phase safety
plans and are indicative of activities encountered in UST work. Each
site will be different and, therefore, will contain different
hazards. Each specific task will require separate descriptions. The
following are examples of typical task descriptions:
(1)
Surveying.
(a)
Task Description. Workers survey various sites for
surface features and locations and elevations of all new
monitoring wells.
(b)
Physical Hazards. Uneven terrain. Unsure footing,
especially in wet conditions. Tick and snake bites.
Rodents. Debris. Poisonous plants. Vegetation in some
areas can hide hazards. Vehicle traffic. Overhead
obstructions in buildings.
(c)
Exposure Hazards. Refer to the hazard analysis
paragraphs (7-14) of this chapter for exposure hazards
relative to UST work.
(d)
Level of Protection. Refer to the action levels
discussed previously for the applicable action level for
PPE.
(e)
Standard Procedures. The SSHO is required to measure
the ambient air concentrations, check the site for
physical hazards, and authorize the surveyor to begin
surveying. The appropriate protective clothing is worn
in accordance with the action levels specified. In some
cases, Level C may be required, particularly in areas of
significant contamination.
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(2)
Soil-Gas Survey.
(a)
Task Description. A soil-gas survey may be performed to
investigate underground contamination from volatile
chemicals (such as industrial solvents, cleaning fluids,
and petroleum products) by looking for their vapors in
the shallow soil.
(b)
Physical Hazards. Uneven terrain. Unsure footing,
especially in wet conditions. Tick and snake bites.
Rodents. Debris. Vegetation in some areas can hide
hazards. Poisonous plants. Vehicle traffic. Heavy
equipment is involved (i.e., medium-sized vehicle with
lab equipment, sampling equipment, and a moderate-sized
hydraulic press to drive sampler into soil). General
safety precautions around heavy equipment should be
observed.
(c)
Exposure Hazards. Refer to the appropriate portions (714) of this chapter for the exposure hazards. The
borehole provides a conduit for hazardous vapors or
fluids to reach the surface.
(d)
Level of Protection. Refer to the action levels
discussed previously to determine the action level for
PPE.
(e)
Standard Procedures.
-
Wear the appropriate protective clothing in
accordance with the action levels specified. In
some cases, Level C may be required, particularly in
areas of significant contamination.
-
Wear leather gloves during activities that involve
handling drill rig components and samples.
-
Know the location of underground and overhead
utilities (electric lines, gas lines, and so forth).
An installation representative, who is knowledgeable
about the location of buried utilities, must approve
all drilling and/or soil sampling locations.
-
Do not wear loose fitting clothing or jewelry.
-
Constrain long hair.
-
Do not touch or go near moving parts.
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(3)
-
Know the location of "Emergency Shut Off" switches.
Should field maintenance on the drill rig be
required, follow lockout/tagout procedures
appropriate to the equipment and established in
accordance with 29 CFR 1910.147.
-
Stay away from operating equipment, particularly if
the rig is located on unstable terrain.
-
Minimize exposure time if close observation is
required to complete an inspection.
-
Allow properly equipped and protected personnel to
respond in the event of an accident (hitting a gas
line or drilling into heavy contamination).
Immediately leave the area.
-
Do not smoke or use spark-producing equipment around
drilling operations, because flammable gasses may be
released from the subsurface environment.
-
Do not work during a rain storm because lightning
could strike the rig. Heavy rain can increase the
risk of sliding and falling, decrease visibility,
and may make the equipment more hazardous to
operate.
Well Installation.
(a) Task Description. Monitoring wells are one method that may
be used to provide an access point for measuring groundwater
levels and to collect groundwater samples that accurately
represent in-situ groundwater conditions at the specific
point of sampling.
(b) Physical Hazards. Uneven terrain. Unsure footing,
especially in wet conditions. Tick and snake bites.
Rodents. Debris. Vegetation in some areas can hide
hazards. Vehicle traffic. In addition, the following
physical hazards may exist:
-
A major hazard of air rotary drilling can occur if
the air compressor hose breaks loose and flies
around uncontrollably, causing damage to equipment,
serious injury, or death.
-
Explosion potential. Use of hollow-stem auger in
methane- or gasoline-soaked soils represents a
potential explosion.
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-
Stacked pipes can pose a hazard if one pipe falls
and the stack collapses.
-
Heavy equipment is involved (i.e., drill rig,
compressor, water truck, flat-bed for drill rods).
General safety precautions around heavy equipment
should be observed.
-
Hoisting the rope with a windlass during sampling
provides a potential for injury if something slips
or breaks.
-
The weight used to drive the split-spoon is located
overhead where disintegrating metal can fly anywhere
if something breaks.
-
Other physical dangers include: heavy rotating
components, hoisting heavy materials overhead,
material falling from the mast, and exposure to hot
engine parts.
(c) Exposure Hazards. Refer to paragraphs 7-14 of this chapter for
information on exposure hazards. In addition:
-
Cuttings, drilling liquids, and groundwater may be
contaminated. The presence of hazardous
constituents should be evaluated, and the fluids
managed accordingly. Avoid direct contact with
these materials.
-
The borehole provides a conduit for hazardous vapors
or fluids to reach the surface. For example,
methane in a landfill, vapors from buried drums, and
contaminated groundwater can all be conveyed up the
borehole. Respiratory and dermal protection may be
needed.
-
Rotary drilling with air can cause stripping of
hazardous volatiles that may be present in the soil,
and these vapors will be concentrated at the
wellhead. For this reason, rotary air drilling may
present a more serious inhalation hazard than
drilling with other fluids.
(d) Level of Protection. Refer to the action levels discussed
previously for the appropriate PPE.
(e)
Standard Procedures.
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-
Wear the appropriate protective clothing in
accordance with the action levels specified. Wear
gloves during activities that involve handling drill
rig components and samples. In some cases, Level C
may be required, particularly in areas of
significant contamination.
-
Monitor all drilling activities with a CGI for
explosive gases. Readings should be collected in
the borehole whenever a sample is collected or
drilling is stopped.
-
Use common sense. Drill rigs are heavy equipment
and should be respected as such.
-
Know the location of underground and overhead
utilities (electric lines, gas lines, and so forth).
-
Walk completely around the rig before raising the
drill rig mast in the vicinity of power lines.
Determine the minimum distance from any point on the
drill rig to where the nearest power line will be
when the mast is raised and/or being raised. Do not
raise the mast or operate the drill rig if this
distance is less than 6 meters (20 feet).
-
Minimum protective gear includes steel-toed shoes,
hearing protection, hard hats, and eye protection.
-
Do not wear loose-fitting clothing or jewelry.
-
Constrain long hair.
-
Do not touch or go near moving parts.
-
Know the location of "Emergency Shut Off" switches.
The driller and the SSHO must check the emergency
kill-switch operation prior to commencing a drilling
and/or sampling study and during the daily
maintenance check. All malfunctions must be
documented and reported to the project manager. All
malfunctions must be repaired before drilling and/or
sampling operations are permitted.
-
Stay away from operating equipment, particularly if
the rig is located on unstable terrain. If close
observation is required to complete an inspection,
minimize exposure time.
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(4)
-
In the event of an accident (hitting a gas line or
drilling into heavy contamination), allow properly
equipped and protected personnel to respond.
Immediately leave the area.
-
Do not smoke or use spark-producing equipment around
drilling operations because flammable gases may be
released from the subsurface environment.
-
Do not work around a drill rig during a thunderstorm
because lightning could strike the rig. Heavy rain
can increase the risk of sliding and falling,
decrease visibility, and may make the equipment more
hazardous to operate by decreasing friction on the
rope around the windlass.
-
Wear the appropriate respiratory and dermal
protection if exposure to hazardous vapors or
contaminated cuttings and fluids is a possibility.
Groundwater Sampling.
(a) Task Description. Groundwater wells at various sites are
developed, sampled, and the water level measured.
(b) Physical Hazards. Metallic well parts can cut hands.
Uneven terrain. Unsure footing, especially in wet
conditions. Tick and snake bites. Rodents. Debris.
Vegetation in some areas can hide hazards. Vehicle traffic.
(c) Exposure Hazards. Refer to the appropriate portion of this
chapter for exposure hazards. (See paragraphs 7-14.)
(d) Level of Protection. Refer to the action levels discussed
previously for the appropriate PPE at the specific site.
(e) Standard Procedures. Refer to Appendix C for the procedure
for opening and sampling wells. Wear the appropriate
protective clothing in accordance with the action levels
specified. In some cases, Level C may be required,
particularly in areas of significant contamination.
(5) Soil Sampling.
(a) Task Description. Collect soil samples at intervals during
well installation, and collect soil borings at specified
locations.
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(b) Physical Hazards. Refer to above for the hazards of
drilling rigs. Uneven terrain. Unsure footing, especially
in wet conditions. Tick and snake bites. Rodents. Debris.
Vegetation in some areas can hide hazards. Vehicle traffic.
(c) Exposure Hazards. Refer to the appropriate portion of this
chapter for exposure hazards. (See paragraphs 7-14.)
(d) Level of Protection. Refer to the action levels discussed
previously to select the proper action level for PPE.
(e) Standard Procedures. Wear the appropriate protective
clothing in accordance with the action levels specified.
Gloves are worn during sampling activities. In some cases,
Level C may be required, particularly in areas of
significant contamination.
7-7. Heat/Cold Stress Monitoring. Implement heat-and/or cold-stress
monitoring protocols as appropriate. Determine work/rest schedules based upon
ambient temperature, humidity, wind speed (wind chill), solar radiation
intensity, duration and intensity of work, and protective equipment ensembles.
Develop minimum required physiological monitoring protocols that will affect
work schedules. In cases where impervious clothing is worn (full body),
follow the NIOSH/OSHA/USCG/EPA Occupational Safety and Health Guidance Manual
for Hazardous Waste Site Activities protocol for prevention of heat stress.
Commence heat-stress monitoring at temperatures of 70 degrees F. and above.
Where impervious clothing is not worn, the most current published ACGIH heatstress standard threshold limit values (TLV) must be used. To help prevent
frostbite and hypothermia, reference and follow the most current published
ACGIH cold-stress standard as a minimum. See Appendix D for heat- and coldstress procedures.
7-8. Standard Operating Safety Procedures, Engineering Controls, and Work
Practices. The elements outlined below must be addressed in the SSHP as a
minimum.
a. Site Rules/Prohibitions.
(1)
Buddy System.
(a) USACE safety and health policy requires each employee
entering a hazardous waste operation to be accompanied by a
"buddy." A buddy provides co-worker/partner with
assistance; observes partner for signs of exposure;
periodically checks the integrity of partner's PPE; and
notifies the SSHO if help is needed.
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(b) Because the buddy must provide help, the buddy must be in
sight or hearing of the employee, and be prepared to enter
any area the employee enters. Thus, the buddy must be fully
certified to work in the level of protection that the
employee is working in, and must have the appropriate PPE
available. Personnel should not enter any area to assist
their buddy unless another backup is available in the case
of an emergency.
(c) Personnel who can provide emergency assistance in the event
of injury or illness can serve as a buddy. Persons able to
serve as buddies include: USACE personnel; subcontractor
employees; federal, state, and local regulatory agency
employees; and facility operators and their employees.
(d) Persons not
the general
wearing the
persons not
in the work
able to serve as buddies include: members of
public or reporters, clerical staff, persons not
level of protection used in the work area, and
certified to wear the level of protection used
area.
(e) The use of buddies other than USACE personnel is approved
only on a case-by-case basis by the CIH/CSP or the SSHO.
The buddy must agree to, and be aware of, the
responsibilities of a buddy as defined above.
(2)
General Safety and Health Rules.
(a) All USACE and subcontractor personnel assigned to work on
the site must be provided with a copy of the SSHP and must
attend a daily safety briefing before commencing work.
(b) MSDSs for all chemicals brought to the site must be filed
onsite. All project personnel will be informed of their
location and availability.
(c) No one will be permitted to work alone on the site—the buddy
system will be followed.
(d) Eating, drinking, chewing gum or tobacco, smoking, or any
practice that increases the probability of hand-to-mouth
transfer and ingestion of material is prohibited in any
investigation area.
(e) Hands and faces must be thoroughly washed upon leaving the
work area and before eating, drinking, or other activities.
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(f) Whenever decontamination procedures for protective clothing
are in effect, the entire body must be thoroughly washed as
soon as possible after the protective clothing is removed.
(g) Medicine and alcohol can increase the effects of exposure to
toxic chemicals. Personnel using prescription drugs must
inform the doctor prescribing the medicine of potential
contact with toxic materials. Field employees taking overthe-counter drugs within a day before work on a site must
inform a physician of intentions to perform hazardous waste
operations while using the drug.
(h) Alcoholic beverage intake will be prohibited during the work
day. Personnel under the influence of recreational or
illegal drugs will not be allowed onsite and may face
disciplinary action.
(i)
Wearing of contact lenses onsite is prohibited.
(j) Wearing of beards by individuals assigned to tasks that
require or may require respirators will be prohibited. A
one-day growth of facial hair that interferes with
respirator-to-face seal is considered to be a beard.
(k) All personnel working in exclusion zones must process
through decontamination before eating, drinking, and/or
smoking.
(l) Before initiating any nonroutine operation, personnel must
consult SSHO about safety and health requirements for the
operation.
(3) Site Safety Practices. Historically, one of the major causes of
physical injuries at sites is slips and falls. To prevent this
hazard, pick up tools, parts, and other equipment. Grease
droppings, oils, and sludge must be cleaned up as soon as
possible. Use warning signs, railings, and in-place covers to
protect against low piping, open tanks, and open manholes or
hatches. The simple knowledge of proper lifting techniques can
save many strained or injured backs. There are a host of
general practices that require training to ensure personnel
safety during operation of the site. A few are detailed below:
(a) Do not run except in emergencies.
(b) Do not operate moving equipment unless instruction in its
use has been given, and use is authorized by the SSHO. Only
properly licensed personnel will be authorized to move heavy
equipment.
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(c) Do not perform onsite equipment maintenance unless specific
lockout/tagout instructions are given by the SSHO and
specific lockout/tagout procedures for the equipment are
established and followed.
(d) Observe driving regulations within the site. These include
wearing seat belts at all times when the vehicle is in
motion and maintaining speeds under 15 miles per hour.
(e) Remove safety equipment or supplies from their normal
location after SSHO authorization.
(f) Position safety devices, safety guards, and chains in place
before equipment operation.
(g) Improvised staging and structures are not permitted.
(h) Carry a portable two-way radio for emergency and related use
(applies to all USACE personnel). The SSHO should always
carry a two-way radio.
(i)
Keep hand tools and special tools clean and in good repair.
(j) Have the SSHO mark and inspect temporary lines, power cords,
and outlets prior to use.
(k) Locate buried cables and underground utilities prior to
intrusive activities (such as excavation).
(l) Use the correct tool for the particular job in the proper
manner.
(m) Carry materials and tools with concern for overloads and
balance; these items must be securely held.
(n)
Avoid movement with obscured vision.
(o)
Practice good housekeeping at all times.
(p) Use solvents and volatile liquids for periodic cleaning,
etc., with SSHO authorization. Follow proper storage and
disposal guidelines.
(q) Do not practice "horseplay:" any frivolous behavior that
increases the probability of an accident.
b. Material Lifting.
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(1) Many types of objects are handled in normal operation and
maintenance at sites. Care should be taken in handling heavy or
bulky items because they are the cause of a considerable number
of accidents. Be certain employees know the following
fundamentals of proper lifting to avoid back injuries:
(a) Consider the size, shape, and weight of the object. A
worker should not lift more than one person can handle
comfortably.
(b) Place the feet far enough apart for good balance and
stability. THE FOOTING SHOULD BE SOLID.
(c) Get as close to the load as possible.
bent at the knees.
(d)
Keep the back as straight as possible.
(e)
Grip the object firmly.
The legs should be
(f) Straighten the legs from their bend to lift the object.
(g) Never carry a load you cannot see over or around.
(h) Set the object down by positioning yourself like you lifted;
the legs are bent at the knees and the object lowered.
(2) When two or more workers are required to handle an object,
coordination is essential to ensure that the load is lifted
uniformly and that the weight is equally divided between
workers. Each worker, if possible, should face the direction in
which the object is being carried. In handling bulky or heavy
items, the following guidelines should be followed to avoid
injury to the hands and fingers:
(a)
Have a firm grip on the object.
(b) Make sure the hands and object are free of oil, grease, or
water that might prevent a firm grip.
(c) Inspect the item for metal slivers, jagged edges, burrs, and
rough or slippery surfaces.
(d)
Wear gloves when possible.
(e) Keep fingers away from any points that may cause the fingers
to be pinched or crushed, especially when setting the object
down.
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c. Fall Protection.
(1) Falls are the second largest cause of physical injuries.
Besides the fall hazards within the site, ladders and platforms
present an accident hazard. Refer to procedures specified in
the USACE Safety and Health Requirements Manual (EM 385 1-1) for
the use of ladders.
(2) Platforms and scaffolds must be inspected before use, so that
they comply with the USACE Safety and Health Requirements Manual
(EM 385 1-1).
d. Hand Tools.
(1) Refer to USACE Safety and Health Requirements Manual (EM 385-11) for guidance in the use of hand tools. Only use tools that
are in good condition. Improper and defective tools contribute
to accidents. Observe the following safe practices:
(2) Use tools in the manner for which they were designed to prevent
injuries.
(3)
Be sure of footing before using any tool.
(4) Do not use tools that have split handles, mushroom heads, worn
jaws, or other defects.
(5)
Do not use makeshift tools or improper tools.
(6) Make sure that tools cannot fall on someone below when working
overhead. Tie the tools to a line, if necessary.
(7) Use non-sparking tools where there is a possibility of explosive
vapors or gases.
e.
Hoses.
Observe the following rules when using hoses:
(1) Inspect hoses for defects, cuts, loose clamps, improper
fittings, etc., before use.
(2) Never apply air from an air hose to any part of the body or
clothing.
(3)
Use only standard fittings for all hoses.
(4)
All quick makeup connections must be secured.
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f.
Electrical Safety.
(1) Guidance for electrical safety appears in the USACE Safety and
Health Requirements Manual (EM 385-1-1). Most equipment at the
site uses electricity as the power source. Only use equipment
designed and installed in compliance with the National
Electrical Code Fire Code No. 70 (1985), NFPA, on the site.
Maintaining field equipment requires exposure to electrical
hazards that may result in shock or death unless safe practices
are strictly followed. When working with electricity, it must
always be assumed that there is sufficient voltage and current
present to cause injury.
(2) All lockout and tagging of circuits must comply with the
provisions of 29 CFR 1926.417 and EM 385-1-1. No work will be
performed on any energized electrical circuits. De-energize
electrical circuits by opening the circuit breaker or
disconnecting the switch feeding them. Where no circuit breaker
or disconnect switch exists, employ other methods to de-energize
the circuit. After the circuit has been de-energized, test it
with a voltage tester to make sure there is no voltage present.
Before work starts on the circuit, lock the disconnect switch or
circuit breaker in the open position with the worker's safety
lock. Attach a warning tag to the switch or breaker with the
worker's name on it.
(3) When work is to be performed on electrically driven equipment,
lock the motor disconnect switch or circuit breaker to that
equipment in the open position with the worker's safety lock.
Attach a warning tag to the switch breaker with the worker's
name on it. Before work starts on the equipment, the worker
must attempt to operate the equipment to make sure it is
inoperative. Adhere to applicable lockout/tagout procedures in
compliance with 29 CFR 1910.147 and EM 385-1-1.
(4)
Workers will adhere to the following general rules:
(a) Survey the work area to determine whether any part of an
electrical power circuit, either exposed or concealed, is
located such that the performance of work could bring any
person, tool, or machine into physical or electrical contact
with it.
(b) Acquire the SSHO’s permission to open an electrical control
panel.
(c)
Do not use a part of the body to test a circuit.
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(d) Avoid contact with grounding conductors like water, pipes,
drains, or metal objects when working on electrical
equipment or wiring.
(e) Wear an electrical protection ensemble specified by the SSHO
when performing electrical work near grounding conductors.
(f) Do not bypass or disconnect electrical safety devices.
(g)
Use only approved extension cords.
(h) Use only tools with insulated handles.
(i) Use only portable electrical devices with ground fault
circuit interruption (GFCI) protection when utilizing
temporary electrical systems.
(j)
Do not use metal-cased flashlights.
(k)
Do not wear jewelry.
(l) Use grounded or double-insulated electric tools.
(m) Keep all electric motors, switches, and control boxes clean
at all times.
g. Mechanical Equipment Safety.
(1) The SSHO must inspect all mechanical equipment before it is
allowed on the site.
(2) Accidents in using machinery and mechanical devices can be kept
to a minimum by designing each job to prevent accidents. When
any mechanical equipment is purchased, consider all points that
affect safety; past accident experience with the kind of
equipment should serve as a guide, and desirable safety features
should be specified and included in the original design.
(3) The SSHO should ensure that rules and safety practices in the
use of mechanical devices are regularly followed and that the
equipment is in proper working order, in keeping with all the
safeguards that have been adopted.
(4) Safety guards are furnished for protection.
regulations must be followed:
The following
(a) Remove guards only after equipment has been shut down,
tagged, and locked out of service in accordance with 29 CFR
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1910.147 and EM 385-1-1.
completed.
Replace guards as soon as work is
(b) Make sure guards are in place and operative when using
machinery.
(c) Be thoroughly familiar with equipment before attempting to
operate it.
(d)
Do not stand on moving equipment while it is in operation.
h. Equipment Startup and Operation. Rules for safe operation of
mechanical equipment may be summarized as follows:
(1) No machine will be lubricated or adjusted while in motion,
unless its manufacturer specifies this practice, and it is
deemed prudent by the SSHO.
(2) Belts, ropes, or other moving parts of equipment must not be
guided or controlled by hand or foot.
(3) Do not operate machines unless they are in good working
condition. The mechanical equipment operators should perform
daily maintenance checks. All malfunctions must be documented
and reported to the SSHO and the project manager. All
malfunctions will be repaired before operations are permitted.
(4) Operators of mechanical equipment must place themselves in a
"safe" position before putting the equipment into operation.
(5) Shut off power and lock the equipment securely against all
motion prior to repairs or adjustments. A warning sign must
also be attached to the lock.
(6) Never oil line shafting while in motion, unless its manufacturer
specifies this practice.
(7) The SSHO must authorize machine and apparatus operation.
(8) No person should use equipment without prior instruction or
experience.
(9) Provide adequate clearance at machine installation; passageways
must be kept free of stumbling hazards.
(10) Illuminate machines adequately.
(11) Keep steps, handrails, and floors free from grease and debris.
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i. Excavations and Trenching. All site excavations and trenching must
comply with the provisions of EM 385-1-1 and 29 CFR 1926 Subpart P,
Excavations.
(1)
Excavations.
(a) To prevent injury and property damage during excavation
work, pre-excavation conditions (superimposed loads, soil
structure, and hydrostatic pressure, etc.) study to evaluate
changes that might occur or situations that might develop,
and plan the job ahead. Conduct all excavating work in
conformance with EM 385-1-1 and 29 CFR 1926.650 through
1926.653, including requirements for shoring or continuously
sloping excavations in which employees are exposed to danger
from moving ground.
(b) The presence of underground facilities, such as utility
lines (water, electricity, gas, or telephone), tanks,
process piping, and sewers is a major hazard. If these are
dug into, undercut, or damaged in any way, there may be
injury or death to workers, interruption of service,
contamination of water, disruption of processes, and
expensive delays. Before excavation, the location of
various utilities and their approximate depth below ground
must be coordinated through the installation or local
private utility district and marked by stakes in the ground.
Contents of buried tanks and piping should be indicated on
the location markings. If the contents are flammable or
toxic, have proper protective equipment readily available in
case of rupture. Indicate the bottom depth of the tank.
Make sure clearance to adjacent overhead transmission and
distribution electrical lines is sufficient for the movement
of vehicles and operation of construction equipment. The
requirements stated in EM 385-1-1, 29 CFR 1926 and the
National Electric Safety Code must be followed by the
contractor.
(c) Excavated, stockpiled materials or tank and equipment must
not be placed closer to the edge of the excavation than a
distance equivalent to one-half the maximum depth of
excavation. Tarpaulins, sheeted barricades, or low built-up
board barricades must be used to confine material to the
immediate area.
(d) Barricade excavations to prevent employees and others from
falling into it. When an excavation must remain open for
duration of the construction work, use barricades, fences,
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horses, and warning signs. If the excavation must remain
open during periods when the work site is unoccupied (i.e.,
overnight, over a weekend, and other similar off periods),
place lighted barricades around the excavation to alert
personnel and prevent them from falling into the trench.
See EM 385-1-1 for safe access requirements.
(e) Any excavation greater than or equal to 1.2 meters (4 feet)
deep must be provided with two means of access to facilitate
safe entrance and exit. Space the means of access so that
no worker in the excavation will be more than 7.5 meters (25
feet) from one of them. Make accesses extend from the
bottom of the trench to at least 1 meter (3 feet) above the
surface of the ground.
j. Explosive Atmospheres, Ignition Sources, and Hot Work.
(1)
Some potential causes of explosions and fires include:
(a)
Chemical reactions that produce explosion, fire, or heat.
(b)
Ignition of explosive or flammable chemicals.
(c)
Ignition of materials due to oxygen enrichment.
(d)
Agitation of shock- or friction-sensitive compounds.
(e)
Sudden release of materials under pressure.
(2) Explosions and fires may also arise spontaneously. However,
more commonly, they result from site activities, such as moving
drums, accidentally mixing incompatible chemicals, or
introducing an ignition source (such as a spark from equipment)
into an explosive or flammable environment. Explosions and
fires not only pose the obvious hazards of intense heat, open
flame, smoke inhalation, and flying objects, but may also cause
the release of toxic chemicals into the environment. Such
releases can threaten both personnel onsite and members of the
general public living or working nearby.
To protect against these hazards, the following should be done:
C
Conduct initial entry and periodic monitoring in accordance
with 29 CFR 1926.65(h).
C
Monitor for explosive atmospheres and flammable vapor using
a CGI.
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C
Keep all potential ignition sources away from an explosive
or flammable environment.
C
Use nonsparking, explosion-proof, intrinsically-safe
equipment.
C
Follow safe practices when performing any task that might
result in the agitation or release of chemicals. Action
levels for CGI monitoring appear in Table 7-2.
TABLE 7-2
ACTION LEVELS FOR CGI MONITORING
EXPLOSION HAZARD
Limit
0 - 10%
>10%
Action Guide
No explosion hazard; work proceeds
Explosion hazard; evacuate, vent
OXYGEN DEFICIENCY HAZARD
Limit
<19.5% Oxygen
19.5 - 22% Oxygen
>22% Oxygen
Action Guide
Oxygen deficient; use supplied air
No oxygen deficiency hazard; work proceeds
Potential explosion hazard; evacuate, vent
Reference: EM 385-1-1
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(3)
No ignition sources (e.g., cigarette lighters, matches, or other flameproducing items) other than those required for the completion of the
project, will be permitted in the exclusion- or the contaminationreduction zones. To eliminate potential ignition sources, follow these
guidelines:
(a) Barricade and post work zones before any work is done that
might release vapors.
(b) Stop burning or other work that might be a source of
ignition.
(c) Eliminate all ignition sources from the area where flammable
vapors may be present or may travel.
(d) Keep work zones free of all ignition sources from the time
tank removal starts until the tank(s) is/are inerted,
residues have been removed, and the tanks' interiors have
been decontaminated.
(e) Post signs warning vehicles and other ignition sources to be
kept out of the area.
(f) Do not perform work if the wind direction carries vapors
into areas outside the work zones where they might produce a
hazardous condition, nor perform work when an electrical
storm is threatening the work site. Sparks caused by
friction or electrostatic effects may also be an ignition
source in flammable atmospheres, especially at low humidity.
Proper grounding of metal objects and/or electrical
equipment, together with the use of sparkless tools and
localized humidity adjustment, may reduce this hazard.
(4)
Hot work on the tanks may be conducted only:
(a)
When inerted and
(b)
To the extent necessary to begin dismantling the tanks.
After decontamination of the tanks' interiors, hot work must not be performed
unless combustible gas/oxygen monitoring indicates atmospheres within and
immediately surrounding the tanks are noncombustible as defined in this
chapter and Chapter 13. The hot-work prohibition includes welding, grinding,
sawing, or other similar operations that could be expected to potentially
generate combustion-producing temperatures or sparks, or that could produce
potentially hazardous fumes or vapors. If hot work is to be conducted, the
contractor must obtain a permit from the contracting officer prior to
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conducting such work and will designate an individual at each hot-work site as
a fire watch. This person's sole responsibility will be to monitor the hot
work and have immediate access to the fire extinguisher located at each hotwork site. The contractor must obtain a new permit at the start of each work
shift during which hot work will be conducted.
k. Illumination. The SSHO should ensure that all work areas will be
lighted to not less than the illumination intensities listed in 29
CFR 1926.65(m) and EM 385-1-1. To ensure this, work activities must
be restricted to daylight hours.
l. Confined Space Entry Program. The confined space procedures detailed
in Appendix E must be adhered to where applicable.
m. Drug-Free Work Environment. All UST projects shall comply with the
Drug-Free Workplace Act requirements.
7-9. Site Control Measures. Personnel not directly involved with the project
will not be permitted to enter the work zones.
a. Work Zones. The exclusion zones should include an area 7.5 meters
(25 feet) from the storage tank location and excavations. At the
exclusion zone perimeter, the contractor must establish a
contamination-reduction zone. Within the contamination-reduction
zone, equipment and personnel should be cleaned following the
guidelines provided in this chapter and Chapter 9. The contractor's
site office, parking area, and other support facilities must be
located outside the exclusion zone and the contamination-reduction
zone, in the support zone. The minimum level of personal protection
must be indicated in the SSHP. The boundaries of the work zones must
be clearly demarcated and posted by the contractor. A site map must
be included in the SSHP outlining the extent of work zones and
support facilities. The contractor must maintain a register of all
personnel visiting, entering, or working on the site.
b. Signs. Warning zones should be posted at the exclusion zone
perimeter stating:
Hazardous Area - Keep Out
Danger - No Smoking
Authorized Personnel Only
The signs must be printed in large, bold letters on contrasting
backgrounds. Signs should be visible from all points where entry
might occur and at such distances from the restricted areas that
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employees may read the signs and take the necessary protective steps
before entering.
c. OSHA Jobsite Posters.
site.
OSHA jobsite posters must be posted at each
d. Vehicle Operation. Site personnel are expected to comply with all
relevant traffic safety laws. They must obey the applicable speed
limits. Whenever operating a moving vehicle, personnel must wear the
seat belts provided.
7-10.
Personal Hygiene and Decontamination.
a. Decontamination.
(1) Decontaminate personnel who have come in contact with
contaminated materials; they must not exit the work zones
without first being decontaminated. Contaminated materials
include soils that show visible evidence of being discolored or
contaminated, decontamination fluids, and equipment that has
come in contact with these types of soils or decontamination
fluids.
(2) Use suitable detergent as the decontamination solution and
rinse. Items should be rinsed with clean water after washing.
When temperatures fall to 32E F. or below, mix an additive into
the decontamination solutions to prevent freezing.
(3) Personnel who inadvertently become contaminated should
immediately wash all contaminated areas. Clothing that is to be
reused should be processed through the wash/rinse cycle three
times and should be visually inspected by the SSHO to ensure no
contamination remains. Any clothing that cannot be
decontaminated in this manner must be discarded with the
disposable clothing.
(4) Containerize and dispose of used wash and rinse solutions as
contaminated fluids.
b. Sanitation. In accordance with 29 CFR 1926.65(n), sanitary
facilities must be provided to include drinking (potable) water,
washing facilities, fire-fighting water, and toilet facilities. In
addition, employees should be provided a clean area for food
handling, as appropriate.
(1) Potable Water.
potable water.
The SSHO must identify the closest source of
If not sufficiently close, potable water should
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be provided in tightly closed containers equipped with a tap.
Sanitary, disposable cups should be provided, with a container
to dispose used cups.
(2) Washing Facilities. The SSHO must identify washing facilities
located at the site that will allow workers to wash after
decontamination, prior to leaving the site. Soap and disposable
towels, with a container to collect the towels, should also be
provided.
c. Toilet Facilities. The SSHO must identify toilet facilities to be
located onsite for workers.
7-11. Equipment Decontamination.
procedures.
7-12.
Refer to Chapter 9 for decontamination
Emergency Equipment and First-Aid Requirements.
a. Equipment. The following items, as appropriate, must be immediately
available for onsite use:
(1) Fire Extinguisher. Select and size fire protection based on
site hazards; at the minimum, a Class 20A/20BC extinguisher
shall be readily available onsite during all site activities.
The fire extinguisher must be kept with the field crew during
any drilling activity.
(2) First-Aid Kit. Keep 16-unit first-aid kits in the support zone.
Additionally, a minimum of two First-Aid/CPR-qualified employees
must be onsite during project operations.
(3) Portable Eye Wash.
available onsite.
(4)
b.
Portable eye-wash stations must be readily
Portable Radios. If deemed necessary, portable two-way radios
should be used as the communication link between each active
site and the SSHO in case of emergency or related matters.
Communications and Notification Protocols.
(1) Include emergency telephone numbers in the SSHP. Post these
numbers and keep them readily available to members of the field
crew. Discuss emergency communication in the safety meeting
prior to initiating the field work. Each member of the field
crew should know the location of the closest telephone.
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(2) Site notification protocols are listed below. Mitigate the
emergency, then notify the appropriate emergency response
service.
(a) In the case of a fire or explosion, call the local fire
department.
(b) In the case of an accident or injury, the nearest hospital
should be used.
c.
Evacuation Procedures.
(1) Withdrawal From Immediate Work Area. Withdrawal to a safe,
upwind location will be required if any of the following occur:
(a) If concentrations of volatile organics, combustibles, or
toxic gases exceed the action levels.
(b) Occurrence of a minor incident. Field operations should
resume after first-aid and/or decontamination procedures
have been administered.
(c)
Heavy equipment or monitoring instrument malfunctions.
(2) Withdrawal From Specific Site. The specific site will be
evacuated in the following cases:
(a) Explosive levels of combustible gases exceed 10 percent of
the LEL.
(b)
A major accident or injury occurs.
(c)
Fire and/or explosion occurs.
(3) The SSHO should establish a safe refuge point and announce its
location in the daily meeting.
(4)
d.
Drill evacuation procedures on a periodic basis.
Contingency Procedures.
(1) If an employee working in a contaminated area is injured or
exposed:
(a) Move the employee to a clean area (on a stretcher, if
needed).
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(b) Call for the necessary emergency medical response services
(ambulance, fire, hospital, or poison control center) as
detailed in the SSHP.
(c)
Remove evidently contaminated clothing (if possible).
(d) Administer first aid, if you are qualified, and the
situation warrants it.
(e)
Evacuate other persons threatened by the condition.
(f)
Arrange transportation to local emergency medical facility.
(2) Emergency first-aid treatment is administered only by trained
individuals and only to prevent further injury until
professional treatment can be obtained.
(3) If the injury to the worker is chemical in nature (e.g.,
overexposure), institute the following first-aid procedures as
soon as possible:
Injury
Treatment
Eye Exposure
If contaminated solid or liquid gets into the eyes, wash
eyes immediately at one of the emergency eyewash stations
using large amounts of water and lifting the lower and upper
eyelids occasionally. Obtain medical attention immediately.
Skin Exposure
If contaminated solid or liquid gets on the skin, remove
contaminated clothing and wash the contaminated skin
promptly using soap or mild detergent and water. Obtain
medical attention immediately if there are any symptoms of
exposure.
Breathing
If a person inhales large amounts of a gas or vapor, move
individual to fresh air at once. If the person cannot
breathe, provide artificial respiration. Keep the affected
person warm and at rest. Obtain medical attention
immediately.
Swallowing
If contaminated solid or liquid has been swallowed, contact
the poison control center. Obtain medical attention
immediately.
Provide the emergency medical facilities established for the site with a copy
of the SSHP.
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(4) In the event of an emergency situation requiring evacuation of
field personnel working within an exclusion zone, the following
procedures should be followed:
(a) The SSHO should evacuate all personnel using a prearranged
air-horn signal.
(b) Personnel leaving exclusion zones should exit through the
contamination reduction zone unless that brings them closer
to the hazard. They will decontaminate as planned unless
the delay would pose an unreasonable risk to their safety.
(c) The SSHP identifies a signal for site evacuation. Equipment
necessary to give that signal must be onsite. Practice a
streamlined decontamination procedure to be used in the
event of an evacuation. Practice evacuation procedures.
(5) In the event of an explosion or fire at the site, the SSHO will
take the following minimum actions:
(a) Evacuate all unnecessary personnel to a prearranged
reassembly point (the safe refuge point).
(b) Request emergency response assistance from the fire
department and from hospitals, poison control centers, etc.
(c)
Notify the appropriate personnel.
7-13. Emergency Response and Contingency Procedures (Onsite and Offsite).
The contractor SSHP shall contain an emergency response plan in compliance
with 29 CFR 1926.65(p), which addresses the following elements, as a minimum:
-
Pre-emergency planning and procedures for reporting incidents to
appropriate government agencies for potential chemical exposures,
personal injuries, fires/explosions, environmental spills and
releases, discovery of radioactive materials.
-
Personnel roles, lines of authority and communications.
-
Posted instructions and a list of emergency contacts: physician,
nearby medical facility, fire and police departments, ambulance
service, federal/state/local environmental agencies, CIH/CSP,
Contracting Officer.
-
Emergency recognition and prevention.
-
Site topography, layout, and prevailing weather conditions.
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-
Criteria and procedures for site evacuation including emergency
alerting procedures/employee alarm system, emergency PPE and
equipment, safe distances, places of refuge, evacuation routes, site
security and control.
-
Specific procedures for decontamination and medical treatment of
injured personnel.
-
Route maps to nearest pre-notified medical facility.
-
Criteria for initiating community alert program, contacts, and
responsibilities.
-
Critique of emergency responses and follow-up.
7-14. Occupational Safety and Health Hazards Associated With Tank Removal
Processes. Workers should be aware of appropriate health precautions. When
high concentrations of petroleum hydrocarbon vapors are inhaled, symptoms of
intoxication, ranging from simple dizziness to excitement or unconsciousness,
may result, and are similar to those produced by alcohol or anesthetic gases.
If such effects occur, move the individual to fresh air. For minor effects of
exposure, breathing fresh air or oxygen results in rapid recovery. If
breathing has stopped, apply artificial respiration promptly, and obtain
medical attention as soon as possible.
Subparagraphs b. and c. below contain special toxicity considerations for
benzene and tetraethyl lead, which may be present in petroleum products or
wastes found in underground storage tanks. Exercise care to minimize exposure
to these substances during the handling of underground petroleum-storage
tanks.
a. Precautions. Tests have shown that prolonged or repeated exposure to
some petroleum substances, in liquid or vapor form, may cause serious
illness, including cancer, in laboratory animals. Although the
significance of these test results to human health is not fully
understood, exposure to petroleum substances should be minimized.
The following health precautions are suggested:
(1)
Avoid skin contact and inhalation of vapors.
(2) Keep petroleum liquids away from eyes, skin, and mouth; they can
be harmful or fatal if inhaled, absorbed through the skin, or
ingested.
(3) Use soap and water or waterless hand cleaner to remove any
petroleum product that contacts skin. Do not use gasoline or
similar solvents to remove oil and grease from skin.
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(4) Promptly wash petroleum-soaked clothes and avoid using soaked
leather goods. Properly dispose of rags.
b.
(5)
Keep work areas clean and well-ventilated.
(6)
Clean up spills promptly.
Benzene.
(1) High occupational exposures to benzene have been associated with
various human blood disorders, including an increased risk of
leukemia. Very high levels have also been known to affect the
central nervous system. Benzene administered by mouth has
induced cancer in laboratory animals in long-term tests.
Benzene is rapidly absorbed through the skin.
(2) The OSHA imposes limits on occupational exposure.
1926.1128.
See 29 CFR
c. Tetraethyl Lead. This organic form of lead can cause diseases of the
central and peripheral nervous systems, the kidney, and the blood.
Skin absorption of this compound is a major route of entry into the
body. The ACGIH time-weighted average is 0.1 milligrams per cubic
meter for general room air. The permissible exposure level (PEL) in
OSHA's Occupational Safety and Health Standards (29 CFR 1910.1000,
Table Z-1) is 0.075 milligrams per cubic meter.
d.
Flammability and Combustibility Considerations.
(1) Flammable or combustible vapors are likely to be present in the
work area. The concentration of vapors in the tank, the
excavation, or the work area may reach the flammable (explosive)
range before venting is completed and a safe atmosphere is
reached. Therefore, precautions must be taken to:
(a) Eliminate all potential sources of ignition from the area
(for example, smoking materials, nonexplosion-proof
electrical and internal combustion equipment).
(b) Prevent the discharge of static electricity during venting
of flammable vapors.
(c) Prevent the accumulation of vapors at ground level. Refer
to American Petroleum Institute (API) Publication 2015 and
Recommended Practice 2003 for general precautionary measures
to follow during tank sampling, product removal, vapor
purging, inerting, excavating, and tank decontamination.
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(2) A CGI should be used to check for hazardous vapor concentrations
(see Chapter 10, Combustible Gas Monitoring Procedures). All
open-flame and spark-producing equipment within the vapor hazard
area should be shut down. Electrical equipment (for example,
pumps and portable hand tools) used in the area must be
explosion-proof in accordance with NFPA 70B Class I, Division I,
Group D or otherwise approved for use in potentially explosive
atmospheres.
e. Tank Safety and Health Work Practices and Procedures. Task-specific
safety and health practices and procedures should be followed during
the project in conformance with OSHA, USACE, and other applicable
standards such as API Publications and Practices, and the following
considerations:
(1) Tank Contents Sampling. Personnel accomplishing this activity
will initially wear Level D PPE as a minimum.
(2) Transfer of Materials out of Storage Tank(s).
guidelines for material removal:
Use the following
(a) Wear, minimally, Modified Level D PPE if you are engaged in
material transfer activities or are within 7.5 meters (25
feet).
(b) Remove liquids and residues from the tank(s) following the
procedures outlined in Chapter 12 titled Product Removal
Procedures using explosion-proof or air-driven pumps.
(c) Ground and bond all pumps, motors, and hoses to prevent
electrostatic-ignition hazards.
(d) It may be necessary to use a hand pump to remove the last
few millimeters of liquid from the bottom of the tanks.
(e) If a vacuum truck is used for removal of liquids or
residues, the area of operation for the vacuum truck must be
vapor-free. Locate the truck upwind from the tank and
outside the path of probable vapor travel. API Publication
2219 and these guidelines will govern the vacuum truck
operation and safety practices.
(f) Collect tank residues in drums, tanks, or tank trucks
labeled according to DOT Standard 49 CFR Part 171 and Parts
1 and 2 and then dispose of them properly (Chapter 14).
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(3) Inerting Procedures. Following the removal of the tank's
contents BUT PRIOR TO EXCAVATION OF THE TANKS AND TANK
PREPARATION ACTIVITIES, insert the tanks in accordance with the
tank inerting procedures presented in Chapter 13 of this manual.
If dry ice is used, it should be introduced in the amount of at
least 1.36 Kg (3 pounds) per 378 liters (100 gallons) of tank
capacity. Skin contact with dry ice must be prevented by
wearing heavy cloth gloves. Inerting must be sufficient to
lower the oxygen content to less than or equal to 8 percent.
The contractor must confirm that the oxygen content of the tank
is less than 8 percent before proceeding with additional
activities on the tank (e.g., excavation).
(4) Excavating. Initially Level D PPE will be required for all
personnel involved in tank excavation or within 15 meters (50
feet) of such operations. Modified Level D PPE will be used by
personnel who may come into contact with the tank's contents or
materials/soils that are contaminated with the tank's contents.
Excavation of the tank including tank preparation, removal,
decontamination, demolition, and disposal should be in
accordance with the guidelines listed in Chapter 13 of this
manual.
(5) Decontamination of Tank Interior. Use API Publication 2015 to
govern safety practices and procedures for the cleaning of the
tanks. At a minimum, Modified Level D PPE should be used by
personnel conducting decontamination operations.
7-15. Logs, Reports, and Recordkeeping. Develop, maintain, and submit the
following logs, reports, and records to the COR at the conclusion of the site
work.
a.
Safety Inspection Reports.
(1) Daily Safety Checklist. Conduct job-site safety inspections on
a daily basis by the SSHO.
(2) Weekly Safety Report. The SSHO should submit a cumulative daily
safety checklist to the CIH/CSP for the preceding week. The
SSHO should prepare a short cover memorandum describing any
problems and/or deficiencies and how they were corrected.
b. Injury/Illness/Accident Reports. Injuries, illnesses, and accidents
involving employees and subcontractors will be reported to the USACE
using ENG FORM 3394.
c.
Medical, Respirator Fit Test, and Training Certifications.
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(1) Medical, respirator fit test, and training certifications for
USACE employees who work on the site should appear in Appendix A
of the SSHP.
(2) If additional employees work on the site, their certifications
should be forwarded to the USACE by the CIH/CSP.
(3) Medical, respirator fit test, and training certifications for
subcontractors should be forwarded to the USACE by the CIH/CSP
as they are contracted to work on the site.
d. Training Logs. Document site-specific training, including
subcontractor, "tool box," and visitor training.
e. Monitoring Results. Document direct reading instrument (DRI)
monitoring results in the logbook.
f. Visitor's Log. An employee, subcontractor, and visitor log should be
maintained by the SSHO.
g. Phase Out Reports. Upon completion of the project, the CIH/CSP
should prepare a phase-out report to include:
(1) Summary of air monitoring data.
(2) Decontamination certification.
(3) Summary of accidents/injuries/illnesses.
(4) Other appropriate information.
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CHAPTER 8
SAMPLING AND ANALYSIS PLAN REQUIREMENTS
8-1. General. Read this chapter for preparation guidelines for the Sampling
and Analysis Plan (SAP). The SAP includes a Field Sampling Plan (FSP) and
Quality Assurance Project Plan (QAPP). The FSP describes field activities,
and the QAPP describes the laboratory-related activities of analysis,
laboratory quality control and reporting. See EM 200-1-2 and EM 200-1-3 for
additional guidance.
Plan requirements apply to all projects whether at active installations,
through the Installation Restoration Program (IRP), Formerly Used Defense
Sites (FUDS), or at Civil Works facilities. The plan’s objective is to assure
quality data in order to classify an UST as one that has not produced chemical
contamination allowing removal by the local district or, as an UST that has
caused soil or groundwater chemical contamination requiring further
evaluation3 or remediation.
8-2.
Plan Contents.
The SAP must include the following items:
a. Title Page. The title page must contain the project name, project
location, contract number, phase, date, and contractor's name and
address, if applicable.
b. Table of Contents.
c. Project Description. The scope of work and relevant background
material, as applied to the collection of chemical data, must be
briefly described. Any description of toxic or hazardous substances
that may be encountered at the site should be included, if known. In
addition, a brief description of the site conditions, such as geology
and surface water, should be included.
d. Chemical Data Quality Objectives. Briefly describe the level and
extent of chemical data required to support decisions during the
project. EM 200-1-2 has guidance concerning preparation of Data
Quality Objectives. The data must provide a basis for decision
making related to the tank, its contents, and any releases to the
environment. The data must allow decisions to be made regarding
future site remediation, determination of whether contamination is a
result of Department of Defense (DOD) activities, and determination
of disposal methods for all wastes generated onsite. Finally, the
results must be determined in a manner that complies with all
applicable federal, state, and local regulations governing USTs.
e. Project Organization and Functional Area Responsibility. The
following functions must be fulfilled. In smaller projects, one
person may have multiple responsibilities.
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(1) Contracting Officer's Representative (COR) represents the USACE
and serves as liaison between the USACE and the contractor.
(2) Contractor's Project Manager reviews and approves field
operations procedures, assures that these procedures meet
quality control (QC) objectives, and provides technical insight.
(3) Contractor's Field Sampling Supervisor is responsible for the
management of the field sampling team during onsite activities.
(4) Field Technician/Project Chemist is responsible for collecting,
packaging, and shipping samples.
(5) QC Program Manager is responsible for maintaining all aspects of
QC during field operations.
(6) Site Safety and Health Officer (SSHO) is responsible for the
safety of all site personnel and for ensuring that all field
operations are in compliance with the Site Safety and Health
Plan (See Chapter 7).
f. Field Activities. Include discussion of the proposed field
activities in the SAP document, along with the following information,
as applicable:
C
C
C
C
C
C
C
C
List of field equipment, containers, and supplies.
Sampling locations.
Sampling procedures.
Field screening.
Quality control samples.
Quality assurance samples.
Sample documentation.
Spill reporting requirements.
g. Chain-of-Custody and Transportation. Include discussion of the
documentation and shipping requirements. See paragraph 8-3 below for
details.
h. Laboratory Activities. Discuss the laboratory procedures and methods
followed in the SAP. See Paragraph 8-4 for details.
8-3. Sample Packaging, Shipping, and Chain-of-Custody. The USACE furnishes
detailed guidance regarding sample handling in Sample Documentation and
Shipment Instructions (Appendix F of EM 200-1-3). It must be provided by the
COR. Follow this protocol explicitly with the exception of those details in
which the protocol disagrees with more stringent state or local regulations.
The fundamental details of sample handling as they pertain to UST actions are
summarized in this section.
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a. Low-, Medium-, and High-Concentration Samples. All nonaqueous
samples taken from the tank contents must be considered as highconcentration samples and handled accordingly. All aqueous samples
exhibiting evidence of contamination (appearance, odor, OVA results)
must be treated as medium-concentration samples. All other
nonaqueous and aqueous samples should be considered as lowconcentration samples unless there is reason to believe otherwise.
b. Receipt for Samples. The current site owner, operator, or agent-incharge is legally entitled to the following:
(1)
A receipt describing the samples obtained from the site.
(2) A portion of each sample equal in weight or volume to the
portion retained, (i.e. split sample) if requested. If the
samples are refused, refusal should be noted on the receipt for
samples. The samples should then be disposed as investigationderived waste.
c. Sample Labeling. Each sample bottle must be labeled. Write the
sample number on the can lid. The label must not soak off or become
illegible if exposed to water for the time it takes to ship the
samples to the laboratory. Use indelible ink to mark the labels.
Include the following on each label:
C
C
C
C
C
C
C
C
C
Date.
Time of collection.
Site name.
A brief description of the sample.
Type of sample (grab, composite).
Preservatives used.
Analyses required.
Sample number as assigned in the field.
Sampler's signature.
See Figure 8.1 for appropriate label or tag formats.
forms that meet your specific needs.
Create local
Special consideration must be given to DOT labeling requirements for
any sample suspected to exhibit a DOT hazard class. For example,
nitric acid containing mixtures exhibiting a DOT corrosive
characteristic at the packing group I or II level are required to be
labeled with a “cargo aircraft only” label as well as a “corrosive”
label.
d. Sample Packaging. Proper sample packaging assures that samples will
arrive at the laboratories in acceptable condition and that sample
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Preservative:
Designate
__________________
Comp.
|
Grab
Yes
No
ANALYSIS
BOD Anions
Solids
(TSS)(TDS)(SS)
Time
Month
Day
Year
COD TOC Nutrients
Phenolics
| Sampler (Signature)
Mercury
Metals
Cyanide
Oil & Grease
Project Code
Station Code
Organics GCC/MS
Station
Location
Priority
Pollutants
Volatile Organics
Pesticides
Mutagenicity
Bacteriology
Remarks:
Tag No.
Lab Sample No.
FIGURE 8-1. EXAMPLE OF SAMPLE TAG OR LABEL
validity and integrity have not been compromised. This section
provides guidelines for sample packaging activities. Give special
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EM 1110-1-4006
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consideration to DOT packaging requirements for samples exhibiting or
suspected to exhibit a DOT hazard class.
(1) Tape all sample bottles shut with strapping tape. The only
exception to this rule applies to samples for volatile organic
analysis. The string from the numbered tag, if used, should be
secured around the lid. Mark the level of all liquid samples on the
bottle with a grease pencil to provide a reference level
that
could be used to identify a leaking container.
(2)
Place each bottle in a clear plastic bag (Ziploc® or
equivalent) through which the sample tag and label are visible
and seal the bags.
(3)
Ship samples of medium- and high-concentration wastes in metal
cans inside the cooler. More than one bottle may be placed in
each can as long as they do not touch one another.
For packages containing materials suspected to meet a DOT
hazard class, the package (bottle, can, and cooler) must meet
DOT performance-oriented packaging requirements for combination
packaging (or must meet conditions for an applicable limited
quantity exception). Also, to comply with DOT regulations
(unless specifically excepted by regulation) mark outer
packages with “This Side Up” (along with an orientation arrow);
the DOT proper shipping name and hazard class for the material
such as "Flammable Liquid N.O.S. UN 1993" or "Corrosive Liquid
N.O.S. UN 1760;" and the shipper’s or consignees’s name and
address.
Place an appropriate hazard class label and a “cargo aircraft
only” label, if applicable, on the package.
Refer to EM 200-1-3, Appendix F, Sample Documentation and
Shipment Instructions for further details regarding the
shipping of high-concentration samples.
(4)
Place the samples in steel or reinforced plastic coolers for
shipment to the laboratories. Line coolers with about 75 mm (3
inches) of cushioning material (only 25 mm (1 inch) under cans)
such as Styrofoam peanuts. Place the sample bottles, contained
in plastic bags, in such a fashion that they will not touch
during shipment. Cover sample bottles with additional packing
material to at least halfway up. Place sealed bags of ice (or
ice substitute) near, but not touching, the samples. Ice
should also be placed above the samples.
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(5)
Before closing the cooler, place a chain-of-custody record (see
Figure 8-2 for example format) in a waterproof plastic bag and
tape it to the inside of the cooler lid. Create local forms
that meet your specific needs. Appropriate additional
documentation may be sent along with the chain-of-custody forms
to the laboratory. Chain-of-custody procedures are discussed
in detail later in the chapter.
(6)
Shut the cooler and secure it by wrapping strapping tape
completely around the cooler at a minimum of two locations.
Tape the drain shut.
e. Sample Shipping.
(1)
Attach shipping labels to the top of the cooler.
(2)
Number and sign custody seals and affix on the front right and
back left of cooler. Cover custody seals with wide, clear
tape.
(3)
Affix labels "This Side Up" (with appropriate arrow) on all
four sides and "Fragile" labels on at least two sides.
(4)
Place the proper shipping name and identification number (i.e.,
"Flammable Liquid N.O.S., UN 1993") on all sides of the cooler,
as appropriate.
(5)
Inform the shipper of the nature of the contents to determine
applicable DOT requirements. Complete hazardous material
shipping documents, also known as bill of ladings, for all
shipments of medium and high concentration samples.
(6)
If the samples are shipped using a limited quantity exception
indicate on the bill of lading (i.e., “Ltd Qty” or “limited
quantity”).
(7)
The shipper must ensure that the samples will arrive at the
laboratory by the next day.
(8)
Include additional information with sample shipments utilizing
the RCRA sample exclusion, in 40 CFR 261.4(d) or equivalent
state regulation. This would apply, for example, to ignitable
waste samples. The following must accompany the sample: (1)
the sample collector’s name, address, and telephone number; (2)
the lab’s name, address and telephone number; (3) the quantity
of the sample; (4) the date of shipment; and (5) a description
of the sample.
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(9)
Consider maximum weight restrictions applicable to some
shippers when filling coolers.
(10) It is acceptable for personnel from the contractor's sampling
team or from the analytical laboratory to transport samples
from the field to the analytical laboratory as long as the
delivery time is comparable to that available from commercial
carriers. If this option is exercised, the SAP must explain in
sufficient detail how and when sample custody will be
transferred.
(11) QA samples must be shipped by a commercial carrier that
provides overnight delivery from the field to the QA laboratory
or delivered personally.
(12) The field sampling supervisor must notify (by telephone) the
sample custodians at the contractor’s analytical laboratory and
the QA laboratory of the intended sample arrival time. Make
this notification least 2 working days in advance of delivery.
Avoid weekend deliveries unless prearranged.
(13) For more information on regulations regarding shipping of
hazardous materials, refer to Title 49, Subchapter C, of the
Code of Federal Regulations.
f. Chain-of-Custody. A custody form is used to track samples from the
field to the laboratory and through the course of the analytical
work.
(1) Chain-of-custody is initiated in the field when samples are
first placed in coolers for shipping. The custody forms are
filled out by the contractor's sampling team. Custody is
maintained during shipping with the custody seal. The chain-ofcustody is continued in the laboratory from the time of sample
receipt to the time the sample is discarded.
(2) List only one site per custody form. If the contractor is
sampling at two or more different UST sites, each site must be
tracked with an independent custody form. Ship the original
with the samples and keep a copy for the sampling contractor's
files.
(3) In the laboratory, a record of sample custody is maintained as
follows:
8-7
Chain of Custody No.
Project No./Title
Analyses
Project Point of
Contact
Phone
Number
Scope of Work Document(s):
Date
Time
Sample Identification
# of
Bottles
Matrix
Comments
8-8
Samples
Preserved?
Yes
(1)
No
Date
Time
Relinquished by
Date
Time
Received by
Date
Time
Relinquished by
Date
Time
Received by
Date
Time
Relinquished by
Date
Time
Received by
FIGURE 8.2. Example Chain-of-Custody Record
EM 1110-1-4006
30 SEP 98
Chain of Custody (COC) Record
EM 1110-1-4006
30 SEP 98
(a)
All incoming samples are received by a sample custodian who
shall indicate receipt by signing the accompanying custody
forms. The sample custodian files these forms with the
project file as a permanent record.
(b)
The laboratory manager is notified of receipt of samples
and notifies the various analytical groups of the required
analytical work. Individuals from each analytical group
maintain the chain-of-custody while checking out samples,
performing the extractions and analyses, and returning the
samples to the sample custodian.
(4) See Figure 8-2 for an example format of a chain-of-custody
record. Create local forms that meet your specific needs; be
sure to include the name and location of the company or
laboratory.
8-4. Sample Analysis and Data Reporting. Describe planned sample analysis
activities in the SAP. Include required analyses, methods, the analytical
laboratory selected, and the vague particulars of data reporting.
This section provides general requirements regarding approved methods, data
reporting, and laboratory validation. The contractor is bound to follow all
site-specific requirements as set forth in the Scope of Work (SOW) and should
use this section only as a guide to fill in details not explicitly stated in
the SOW.
a.
Methods for Sample Analysis. Perform all sample analyses of water
or soils using standard EPA methods as listed in Tables 8-1 and 82. All procedures specified must be followed exactly with no
deviations unless modifications are specifically authorized by the
designated project QA laboratory. All method QC requirements will
be followed explicitly. The running of QC duplicates, spike
samples, and method blanks must be in accordance with the
laboratory QA/QC plan as set forth in the Laboratory Quality
Management Manual (LQMM), or at least the rate specified in the
method. At a minimum, this rate will be 1 in 20, but at least 1
per batch. The laboratory is required to report internal QC data
(instrument blanks, method blanks, spike matrix recoveries, and
internal duplicates, etc.) for a minimum of 5 percent of the
project samples.
The USACE encourages the use of their samples for internal QC
checks (matrix spike recovery or internal duplicate). If a USACE
sample is selected for an internal QC check for a batch that
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EM 1110-1-4006
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TABLE 8-1 METHODS FOR DETERMINATION OF METALS
(RCRA and Priority Pollutants) by Atomic Absorption and Inductively Coupled
Plasma
Digestion and Analysis Method4
Soil/Sediment
Groundwater2
Surface Water2
GF
H
3050/7060
Inc3/7061
Inc3/7060
Inc3/7061
206.2
206.3
Barium (Ba)
DA
GF
ICP
3050/7080
3050/6010
3005/7080
3005/6010
208.2
208.2
200.7
Cadmium (Cd)
DA
GF
ICP
3050/7130
3050/7131
3050/6010
3005/7130
3020/7131
3005/6010
213.1
213.2
200.7
Chromium (Cr)
DA
GF
ICP
3050/7190
3050/7191
3050/6010
3005/7190
3020/7191
3005/6010
218.1
218.2
200.7
Iron (Fe)
DA
GF
ICP
3050/7380
3050/6010
3005/7380
3005/6010
236.1
236.2
200.7
Lead (Pb)
DA
GF
ICP
3050/7420
3050/7421
3050/6010
3005/7420
3020/7421
3005/6010
239.1
239.2
200.7
Manganese (Mn)
DA
GF
ICP
3050/7460
3050/6010
3050/7460
3050/6010
243.1
243.2
200.7
Mercury (Hg)
CV
Inc3/7471
Inc3/7470
245.1
Selenium (Se)
GF
H
3050/7740
Inc3/7741
Inc3/7740
Inc3/7741
270.2
270.3
Silver (Ag)
DA
GF
ICP
Inc3/7760
3050/6010
Inc3/7760
3005/6010
272.1
272.2
200.7
Sodium (Na)
DA
GF
ICP
3050/7770
3050/6010
3005/7770
3005/6010
273.1
273.2
200.7
Metal
Arsenic (As)
Technique
1
NOTES:
1
Abbreviations:
Plasma
CV = Cold Vapor; DA = Direct Aspiration; GF = Graphite
Furnace; H = Hydride; ICP = Inductively Coupled
2
(a) Any water sample may be analyzed by SW-846 methods. Groundwater samples must be analyzed by the SW-846 methods.
Surface water and other water samples (drinking, silo, leachate, etc.) may be analyzed by the 200-series or the SW-846
series methods.
(b)
Other extraction procedures may be appropriate instead of those listed. Methods 3010 (for flame and ICP) and 3020 (for
graphite furnace) are used as extraction procedures for Total Metals and are used in EP TOX or TCLP extractions.
Method 3040 is used to extract metals from oily wastes (greases, waxes, etc.).
(c)
All 200 series methods are from EPA 600/4-79-020 (1983) Methods for Chemical Analysis of Water and Wastes; all other
methods are from SW-846 (1986), Test Methods for Evaluation of Solid Waste (including all promulgated updates).
3
Method-specific extraction procedure is incorporated into method. For arsenic this involves digestion by 3050 followed by
additional digestion in the method. For silver, digestion by 3050 is used with modification: approximately twice as much
HCl is used. 4Latest promulgated versions of referenced methods should be used.
8-10
EM 1110-1-4006
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TABLE 8-2
METHODS FOR DETERMINATION OF NONMETALLIC ANALYTES
Part 1.
Organic Analytes8
Extraction and Analysis Methods
Organic Analytes
Technique1
Soil/Sediment
Groundwater2
Surface Water2
3
6013
Halogenated
Volatile Organics
GC
5030/8021
5030/8021
Aromatic Volatile
Organics (or BTEX)
GC
5030/8021
5030/80213
6023
PCBs
GC
3540/8082
3550/8082
3510/8082
3520/8082
608
GC/MS
Inc4/8260
Inc4/8260
624
Volatile Organics
Part 2.
Miscellaneous Analytes8
Preparation and Analysis Methods
Technique1
Soil/Sediment
TRPH5
IR
9071/418.15
Fuel Constituents
GC
Misc. Analytes
EP Toxicity-Metals
pH
418.1
418.1
1010 or 1020
9045
Reactivity
TCLP-Metals
Surface Water2
Modified EPA Method 8015
Ignitability
Corrosivity
Groundwater2
9040/1110
9040/1110
(Sections 7.3.3 and 7.3.4 of SW-846)
13106
13106
Federal Register6,7
9045
9040
NOTES:
1
Abbreviations: DA = Direct Aspiration; GC = Gas Chromatograph; GC/MS = Gas Chromatograph/Mass Spectroscopy; IR = Infrared
Spectroscopy.
2
(a) Any water sample may be analyzed by SW-846 methods. Groundwater samples must be analyzed by the SW-846 methods. Surface
water and other water samples (drinking, silo, leachate, etc.) may be analyzed by the 200-series or the SW-846 series
methods.
(b) All 300-600 series methods are from EPA 600/4-79-020 (1983) Methods for Chemical Analysis of Water and Wastes; all other
methods are from SW-846 (1986), Test Methods for Evaluation of Solid Waste (including all promulgated updates).
3
Direct injection may be used for high concentrations of contaminants in water. It is preferable to use Method 8260. If Method
8015, 8021, 601, or 602 is used, it is necessary to confirm results with a dual-column injection or a validation by GC/MS.
4
Method-specific extraction procedure is incorporated into method.
5
Some states require specific methods other than those cited here for the determination of petroleum hydrocarbons. In these
cases, the state-required methods should be used. If the cited method for Total Recoverable Petroleum Hydrocarbons is used,
follow extraction through Step 7.11 and then dilute with Freon-113 to 100 mL.
6
Extraction procedure only.
Analysis (Table 8-1) must follow.
7
Federal Register March 29, 1990 (SW-846, 3rd Ed. 1311). TCLP leachates are analyzed by one or more of the following methods:
6010, 7060, 7470 and 7740. Scope must specify which analyses are to be performed on TCLP leachate extracts.
-
-
Internal Quality Control: The number and types of internal QC checks shall be defined clearly in the SAP. The USACE
requirements are basically the same as those given in the EPA method. The only significant difference is that the USACE
encourages (Section 5.1) that its samples be treated as an independent set so that all applicable QC checks are applied to
the set of USACE samples even though the USACE sample size may be small. A list of all applicable checks must be
enumerated in the SOW and SAP in order to assure the USACE that the analytical laboratory is aware of these requirements
for internal QC checks. These include:
Limits of data acceptability and corrective action to be taken when these limits are exceeded must be described.
Corrective Action: The feedback system in place to deal with problems identified by these internal QC checks must be
described. Personnel responsible for executing this corrective action must be identified.
The methods for determining precision, accuracy, and instrument sensitivity (detection and quantitation limits) must be
described.
Procedures for calibration and the frequency of calibration checks for laboratory instrumentation shall be described.
8
Latest promulgated versions of referenced methods should be used.
8-11
EM 1110-1-4006
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contains samples from another client, the USACE requests a copy of the
results obtained.
The detection limits stated in the SOW (or by the nominal values given
for each method) must be met by the contractor's laboratory. All samples
must be extracted (or digested) and analyzed within the specific holding
times specified by each method. All analyses must be performed by the
designated laboratory (or laboratories) and may not be subcontracted.
b. QA and QC Frequency. Normally for most smaller USTs, the number of
QA/QC field check samples is limited to the following:
(1)
For the tank water samples: Collect one sample in triplicate.
One sample set may be collected for rinsate verification and sent
to the contractor's laboratory and QA laboratory. Provide one
pair of trip blanks for each cooler that contains aqueous samples
for VOA.
(2)
For the high-concentration organic samples and sludge samples:
Collect one sample in triplicate.
c. Data Reporting. The USACE requirements for reporting the analytical
data were established to effectively report analytical results along
with the appropriate QC information needed to assess reliability.
These requirements are based on simplified contract laboratory program
(CLP) or EPA SW-846 or other performance-based methods deliverables
package. See EM 200-1-3 and EM 200-1-6 for general information.
(1)
General Requirements. The contractor and the analytical
laboratory must concur on how certain data reporting requirements
are to be handled. Details describing each of the following data
reporting requirements must be given in the SAP and approved
prior to the start of work.
(a)
Data computations. All units of expression and equations
required to calculate concentrations or the values of
measured parameters must be provided.
(b)
Unusual results. Plans for treating outliers or other
results that appear unusual or questionable.
(c)
Loss of control. Plans for treating data and reanalysis of
samples that have been handled during periods of loss of
analytical control.
(d)
Data handling. Description of the data management systems:
collection of raw data, data storage and conversion, data
and calculations review, and data quality assurance
documentation.
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(2)
(e)
Personnel. Identify all personnel that will be involved in
the data reporting sequence for this specific project.
(f)
Precision, Accuracy, and Completeness. Procedures to assess
these parameters of the analytical data must be described.
The laboratory must maintain appropriate control charts.
Sample Description. The laboratory is asked to supply a brief
physical description of the sample. The following guidelines
should be used.
(a)
Water Samples.
(b)
Soil/Sediment/Sludge Samples.
artifacts.
(c)
Recommended Descriptive Terms.
C
C
C
(3)
Coloration, texture, and
Coloration: red, orange, yellow, green, blue, violet,
black, grey, brown, white, colorless, etc; dark or
light.
Clarity: clear, cloudy, opaque.
Texture: fine (powdery), medium (sand), coarse (large
crystals or rocks).
Data Qualifications. These symbols are used to qualify the
analytical results, as necessary. They should be used in place
of or adjacent to the appropriate analytical result.
-
(4)
Coloration and clarity.
U
J
= Analyte not detected at the laboratory reporting limit
= Analyte detected below the laboratory reporting
limit, concentration is estimated
B
= Analyte detected in the method blank
NA = Not analyzed
NR = Not reported
BDL = Analyte not detected at the laboratory reporting
limit
Internal Quality Control Reporting. The laboratory should report
the results for the following quality control samples:
(a)
Laboratory Method Blanks
(b)
Surrogate Spike Recovery
(c)
Matrix Spike Samples
(d)
Lab Duplicates
(e)
Lab Control (Blank Spike) Samples.
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d. Holding Times. Table 8-3 summarizes the maximum holding times,
preservation requirements, and bottles (containers) for various analytes.
All of the bottles must be obtained precleaned from an EPA-approved
supplier. These values are established by the EPA. Exceeding the
maximum holding time would jeopardize the validity of the analytical
results. During construction, the SOW may require very short turnaround
times for analysis because of the nature of the project phase. The
analytical laboratory selected as a contractor must agree to abide by
these analysis turnaround times.
e. Detection and Quantitation Limits. The SOW may specify required
detection or quantitation limits based on state and local requirements
and on a Record of Decision. If these limits are not specified, it is to
be assumed that the nominal values provided by SW-846 or the CLP User's
Guide apply.
8-5. Commercial Analytical Laboratory. USACE validation of the project
laboratory is optional for UST work. The project manager may request
validation by the HTRW-CX or accept state validations at his or her discretion.
If the project involves HTRW factors the project manager should request
validation by the HTRW-CX. The laboratory validation process takes several
weeks with the time required depending primarily on how promptly the laboratory
responds.
The USACE laboratory validation process for UST projects is
described in a memo from CEMP-RT dated 14 September 1993, titled “Hazardous,
Toxic & Radioactive Waste (HTRW) - Policy Guidance on Validation of Commercial
Analytical Chemistry Laboratories”.
8-6. Government Analytical Laboratories. Chemical analyses may be performed
by USACE laboratories when sampling is performed by government personnel.
8-7. Quality Assurance Laboratory. The USACE Design District responsible for
the UST action will propose the use of a USACE or other referee laboratory as
the project's quality assurance laboratory if QA samples are to be collected.
8-8. Sample Numbering System. UST samples collected under contract with the
USACE must be numbered using a USACE numbering system as described below:
aaaa-bbbb-cccc
aaaa = Four-character designation of the project name
bbbb = Four-character designation of the sampling subsite
cccc = Four-number character sequential numerical designation starting
with '0001' for the first sample and incrementing by one for each
subsequent sample.
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TABLE 8-3
SUMMARY OF SAMPLE CONTAINER, PRESERVATION, AND MAXIMUM HOLDING TIMES
Maximum Holding Times
Parameter1
Matrix
Container2
Preservation3
Extraction
Analysis
4
Water
Volatiles
Water
PCBs
6
Water
Metals
Water
TRPH
Soils
Volatiles
2 X 40 mL G,
Septa vials
Ice to 4 EC
HCl to pH<2
-
2 X 1 L5 amber G
Ice to 4 EC
7 d
40 d
1 X 1 L P
HNO3 to pH<2
-
6 mo6
2 X 1 L G
Ice to 4 EC
HCl to pH<2
-
28 d
2 X 4 oz
(or 2 X 120 mL) G,
Septa lids
Ice to 4 EC
-
14 d
14 d
Soils/Sediments
PCBs
1 X 8 oz G
(or 1 X 240 mL)
Ice to 4 EC
7 d
40 d
Soils/Sediments
Metals/
TRPH
1 X 8 oz G
(or 1 X 240 mL)
Ice to 4 EC
(TRPH only)
-
6 mo6
(TRPH: 28 d)
2 X 40 mL G,
Septa vials
Ice to 4 EC
-
14 d
1 X 40 mL G, Septa
vial
Ice to 4 °C
-
High Concentration
Wastes
Volatiles
High Concentration
Wastes
PCBs
Product
All
1 X 250 mL G7
-
NOTES:
1
Abbreviation:
TRPH = Total Recoverable Petroleum Hydrocarbon.
2
All containers must have Teflon-lined seals (Teflon-lined septa for VOA vials). G = Glass; P =
High-density polyethylene. Samples for analysis for volatiles must have septa lids.
3
Sample preservation will be done in the field immediately upon sample collection.
4
When only one holding time is given, it implies total holding time from sampling until analysis.
5
Triplicate sample sets are required on at least 5 to 10 percent (but at least one) sample so
that the laboratory can perform all method QC checks for SW-846 methods.
6
Total Recoverable Metals for water samples.
Holding time for Hg is 28 days in glass.
7
Collect only one 250 mL sample.
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The following abbreviations should be used to designate the nature of each
sample:
TK
SS
SW
SL
SB
MW
SD
-
Tank
Surface Soil Boring
Surface Water
Sludge
Subsurface Soil
Monitoring Well
Sediment
8-9. Sample Documentation. Each sampling team or individual performing a
particular sampling activity is required to record pertinent information in a
bound field logbook with prenumbered pages. All entries shall be made with
indelible ink. Mistakes must be crossed out with a single line, corrected,
initialed, and dated.
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CHAPTER 9
GENERAL EQUIPMENT DECONTAMINATION PROCEDURES
9-1. General. This chapter describes the procedures for the decontamination
of field equipment potentially contaminated in conjunction with UST removal.
This process recommends but does not necessarily dictate the proper
decontamination methods for any given situation. The contractor will be
responsible for assessing specific situations for the most appropriate
response. Decontamination is performed as a QA measure and a safety
precaution. It prevents cross-contamination among samples and helps maintain
a clean working environment for the safety of all field personnel and any
others who may be affected.
Decontamination is mainly achieved by rinsing with liquids that include
detergent solutions, potable water, deionized water, nitric acid, methanol,
and hexane. Equipment is allowed to air-dry after being cleaned or is wiped
dry with paper towels. Equipment can then be reused immediately. Steam
cleaning should be used whenever visible contamination exists and for large
machinery/vehicles. The reader should refer to EM 200-1-3 for additional
guidance on decontamination. Also, guidance may be found in ASTM Standard
Practices D 5088 and D 5608.
9-2. Precautions. It is important to ensure that investigation-derived
wastes are not being generated as a result of decontamination chemicals.
9-3. Equipment.
limited to:
-
Materials used for decontamination may include but are not
Wash basins (approximately 75 liters [20 gallons]).
Buckets (10 to 20 liters [3 to 5 gallon]).
Brushes.
Squeeze bottles/spray cans.
Alconox or equivalent detergent.
Methanol.
Nitric acid.
Hexane.
Potable water of known quality.
Deionized water.
Aluminum foil.
9-4. Operations, Procedures, and Instructions. Field personnel responsible
for equipment decontamination should be familiar with all safety rules and
regulations, the use of equipment and procedures for decontamination of
equipment, and the standard practices governing equipment decontamination.
a.
Operations.
(1) Decontaminate all equipment prior to field use.
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(2) Clean the equipment on the assumption that it is highly
contaminated until enough data are available to allow an
accurate assessment of the level of contamination.
(3) Have an adequate supply of rinsing liquids and all materials.
Perform decontamination in the same level of protective clothing
as sampling activities unless a different level of protection is
specified by the project manager.
(4) Collect and hold all decontamination liquids until they can be
properly disposed. The procedure for full field decontamination
must be followed without deviation unless specified by the
project manager.
b. Decontamination Staging Area. A staging area may be required for
decontamination of drilling rigs and heavy equipment. The staging
area must be constructed to:
(1) Allow easy access for equipment to move in and out of the
staging area.
(2)
Contain all wash waters and any spray.
(3) Allow collection of all wash water into 55- gallon drums or
tanks.
(4)
Minimize cross-contamination.
Typically, a decontamination area consists of a plastic-lined area that drains
to a sump where a submersible pump can remove the decontamination water and
deposit it in drums, tanks, or in the sanitary sewer.
c.
Decontamination Steps.
(1) The purpose of the initial decontamination step is to remove
gross contamination. Remove any solid particles from the
equipment or material by brushing and then rinsing with
available potable water. Use only water that is known to be
contaminant-free. Record the source of the water in the field
logbook and collect a sample for analysis if the source has not
been analyzed. For drilling equipment, steam cleaning is
necessary.
(2) Wash equipment with soap or detergent solution.
(3) Rinse with potable water by submerging or spraying.
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(4) Use an optional rinse with a solvent (methanol) to dissolve and
remove soluble organic contaminants. Hexane may be used to
dissolve waste lubricating oils, tars, and bunker fuels.
(5) Use an optional rinse with a diluted nitric acid solution to
dissolve and remove soluble inorganic metals.
(6)
Rinse thoroughly with distilled water.
(7) Air-dry equipment or rinse with nanograde methanol to expedite
drying.
(8) Samples of drippings from the last rinse in Step 6 may be
collected and analyzed to verify and document the effectiveness
of the decontamination procedure. This type of sample is called
an equipment/rinsate blank. The results of these analyses are
not usually available for at least one week after they arrive in
the laboratory. It is, therefore, important to thoroughly
decontaminate all equipment to prevent cross-contamination of
samples and prevent the detection of contaminants in the rinsate
blank.
(9) Allow item to completely air-dry prior to any use. Cover item
if it is not intended for immediate use. Place large items on a
clean sheet of plastic.
(10) Wrap the item in aluminum foil if it is not going to be used
immediately. Larger items should be wrapped in clean plastic
sheets until they are ready for use.
d.
Post-Operation Procedures-Field.
(1) Decontaminate as much sampling equipment as possible and
properly discard expendable items that cannot be decontaminated.
Proper disposal shall include onsite drumming of liquids and
solids in approved 55-gallon drums for temporary storage prior
to subsequent disposal.
(2) Prepare the rinsate blank sample and transport it according to
all federal, state, local, and USACE regulations and/or
requirements.
(3) Store drums of rinse water/solids after decontamination in a
secure area.
e.
Post-Operation Procedures-Office.
(1) Inventory equipment and supplies. Repair or replace all broken
or damaged equipment. Replace expendable items. Return
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equipment to the equipment manager and report incidents of
malfunction or damage.
(2) Contact the analytical laboratory to ensure the samples arrived
safely and that instructions for analyses are clearly
understood.
(3) After receiving the results of the laboratory analyses, arrange
for the disposal of wastes generated during the investigation.
9-5.
Waste Disposal and Recycling.
a. Waste that is generated during equipment decontamination will likely
consist of wastewater. Package wastewater in DOT-approved 55-gallon
containers for shipment to a disposal facility.
b. Occasionally, solvents such as hexane are utilized in the
decontamination process. Hexane decontamination fluid, which is
ignitable, is ordinarily regulated as a RCRA hazardous waste; however,
opportunities for recycling do exist. Federal regulation allow RCRA
characteristic waste, such as hexane, to be mixed with used oil and
burned as used oil fuel provided the resultant mixture does not exhibit
any RCRA hazardous characteristic. In other words, hexane containing
decontamination fluid can be mixed into used oil provided the flashpoint
of the resultant mixture is greater than 60 degrees C (140 degrees F)
and the mixture does not exceed threshold concentrations for TCLP
constituents. This is permissible according to federal regulation, but
may be prohibited by individual states. Alternatively, the hexane can
be disposed of by burning for energy recovery at a permitted RCRA TSDF.
c. Occasionally, methanol is used for decontamination. Minimize use of
methanol because it is regulated as a listed hazardous waste.
9-6 Waste Minimization During Decontamination Operations. To prevent the
generation of excessive volumes of decontamination fluids, implement an active
waste minimization policy to circumvent the generation of large quantities of
decontamination fluid. Activities that could be implemented to reduce
wastewater volume include the use of low flow water applicators during
decontamination.
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CHAPTER 10
COMBUSTIBLE GAS MONITORING PROCEDURES
10-1. General. This chapter describes combustible gas indicators (CGIs),
their operation, and correct monitoring procedures.
a. Purpose. Combustible gas indicators (or explosimeters) are used to
determine the potential for the combustion or explosion of unknown
atmospheres. Combustible gas monitoring is performed to determine
when an explosion hazard exists in the UST work environment. A
typical CGI determines the level of organic vapors and gases present
in an atmosphere as a percentage of the lower explosive limit (LEL)
or the upper explosive limit (UEL) by measuring the change in
electrical resistance in a Wheatstone bridge circuit. A Wheatstone
bridge circuit is a four-arm bridge circuit used to measure the
electrical resistance of an unknown resistor by comparing it with a
known standard resistance.
b. Units. CGIs provide readouts in units of percent LEL, in parts per
million (ppm) combustible gases by volume, or both. The more
explosive the calibration gas (the lower the LEL), the more sensitive
the indication of explosivity, resulting in a greater margin of
safety. The operator should be familiar with the LEL concentrations
for specific gases to effectively use instruments that provide data
only in ppm combustible gases (by volume).
c. Calibration. Instruments can be purchased that are factorycalibrated for gases like butane, pentane, methane, or petroleum
vapors, (methane calibration is the most common). The LEL of methane
is 5 percent methane by volume in air; therefore, an air mixture
containing 5 percent methane will be read as 100-percent LEL and is
explosive. When combustible gases other than methane are sampled,
the relative response of the detector must be considered.
Recalibration to other gases may be possible (see the manufacturer's
recommendations). National Institute of Standards Technology (NIST)
traceable calibration gases should be used. The relative sensitivity
of the detector and the differences in LEL for different gases will
produce varying meter responses. When possible, the gas used for
calibration should be as similar as possible to the gas that will be
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measured. Calibrate or at least do zeroing checks under field
conditions.
10-2. Precautions.
During the course of UST activities, workers may be
exposed to petroleum hydrocarbon liquids, vapors, and possibly other hazardous
wastes. Personnel involved in combustible gas monitoring should be familiar
with the potential hazards and appropriate safety and health measures. This
is accomplished by reading the SSHP, consulting with the project manager, and
observing good safety practices.
All analyzers and testing equipment used in locations that may have flammable
atmospheres must be approved, per NFPA 70, for the hazardous location (by
Class and Division) and the hazardous substance (by Group) in that location.
It is important that manufacturers' recommendations be followed, including
calibration procedures.
10-3. Operations, Procedures, and Instructions. Site personnel responsible
for combustible gas monitoring should be familiar with all safety rules and
regulations as detailed in the SSHP and the use of equipment and procedures
for monitoring combustible gas.
a. Instrument Requirements. Guidelines for instrument use include the
following:
(1) Use only those instruments that are certified safe for use in
atmospheres containing vapors or gases in concentrations greater
than 25 percent of the LEL. Some are not certified safe for
operation in the atmospheres they can detect. The instrument
manufacturer's operating manual should be consulted to determine
safety certification in specific atmospheres.
(2) CGIs do not indicate if a given atmosphere contains hazardous or
toxic compounds nor do they indicate whether an atmosphere is
oxygen deficient.
(3) Do not use the CGI in atmospheres containing silicanes,
silicones, or other compounds containing silicon because these
substances seriously impair the instrument response.
(4) If the detector has a platinum filament, its sensitivity may be
reduced by exposure to gases like leaded gasoline vapors
(tetraethyl lead), sulfur compounds (mercaptans and hydrogen
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sulfide), and sulfide compounds. An inhibitor filament that
will nullify the effect of leaded gasoline vapors is available
on some commercial units. Consult the instrument manufacturer's
operating manual to determine the instrument's ability to
function in leaded gasoline atmospheres.
(5) Use an oxygen detector in conjunction with a CGI. Select a unit
with this feature and follow the operating manual to use the
oxygen detector. This is especially important when atmospheres
are monitored within enclosed spaces or where oxygen-deficient
atmospheres (< 19.5 percent) may exist. A CGI may give a false
"safe" reading in an oxygen-deficient atmosphere.
(6) Calibarate CGI instruments frequently using a NIST traceable
calibration gas. Unusually high concentrations of sulfur
dioxide, fluorine, chlorine, bromine, iodine, and oxides of
nitrogen interfere with measurement. Consult the manufacturer's
operating manual for calibration frequency. Also, frequent
calibration will be necessary if several known organic species
are present. Maximum accuracy requires a recalibration for each
gas.
(7) Do calibration and zeroing checks under field conditions.
b. Instrument Preparation. Assemble the equipment and supplies listed
in Table 10-1. Perform a minimal check of the CGI in the office to
ensure that it is functioning properly. Obtain the CGI, its
operating manual, and a supply of NIST traceable gas. Methane is the
factory calibration gas, but other gases may be used for specific
requirements.
Perform the equipment checks below.
(1) Make sure the instrument is clean and serviceable, especially
sample lines and detector surfaces.
(2) Check the battery charge level. If in doubt, charge the battery
as described in the operating manual. Some units have chargelevel meters, while others have only low-charge alarms.
(3) Turn the unit to the "on" position and allow the instrument
sufficient warmup time.
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(4) Verify that the sample pump is operable when the analyzer is on.
The pump can usually be heard when operating.
TABLE 10-1
COMBUSTIBLE GAS INDICATOR (CGI)
EQUIPMENT AND SUPPLIES CHECKLIST
CGI
Battery Charger for CGI
Oxygen Sensor
Battery Charger for Oxygen Sensor
Spare Gas-Detector Filaments
Spare Batteries for CGI
Jeweler's Screwdrivers for Internal Adjustment
Calibration Kit
A) Spare gas cylinder (NIST traceable calibration
gas)
B) Valve attachment
C) Flexible tubing (tygon)
D) Cylinder to encapsulate sensor probe
Probe Extensions
(5) With the intake assembly in combustible gas-free ambient air,
zero the meter by rotating the zero control until the meter
reads 0 percent LEL. For instruments with an additional oxygen
meter, adjust the dial to 21 percent oxygen in nonhazardous
locations.
(6) Calibrate the unit against a known concentration of a
calibration gas, like methane, by rotating the calibration
control (span or gain) until the meter reads the same
concentration as the known standard.
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(7) Some instruments require internal calibrating with a small
screwdriver. Consult the operating manual before calibration.
With this model, it is also necessary to maintain the proper
flow rate during calibration. Connect a flow meter between the
CGI and the calibration gas cylinder to monitor the flow rate.
(8) Most models are equipped with three meters that read percent
oxygen, percent LEL, and ppm. The ppm dial is often not used in
the field unless a photoionization detector (PID) or flame
ionization detector (FID) is not available, as the PID/FID
instruments are considered to be more accurate.
c.
Documentation Preparation.
(1) Obtain a logbook.
(2) Record results of the equipment check in the logbook.
d.
Field Preparation.
(1) Instrument Check. Before using the CGI in the field, follow the
procedures described in the instrument preparation section. You
may need to make additional adjustments. If necessary, adjust
the alarm setting to the appropriate combustibility limit. The
action level or the point when activities are halted and
personnel are removed from the immediate vicinity, as detailed
in the SSHP, is usually less than 25 percent of the LEL for the
gases that are present.
(2) Record necessary calibration data in the logbook and include the
information listed below:
C
C
C
C
C
C
C
Date and time of arrival at the site.
Site identification.
Instrument, model number, and serial number.
Date/time calibrated.
Calibration gas used, including manufacturer and lot
number.
Calibration location.
Operator's signature.
e. Field Measurements.
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(1) Calibrate the CGI daily before use in the field. See the
manufacturer's manual for calibration procedures.
(2) Position the CGI intake assembly close to the area in question
to get an accurate reading. For readings taken downhole during
drilling, there will be a slight delay between positioning the
intake tubing downhole and registering accurate meter readings
because of the time required for the sample to travel the length
of the tube.
(3) Interpret CGI meter readings according to one of three typical
instrument responses:
(a) The meter indicates 0.5 LEL (50 percent). This means that
50 percent of the concentration of combustible gas required
to reach an unstable combustible situation is present.
(b) The meter needle stays above 1.0 LEL (100 percent). This
means that the concentration of combustible gas is greater
than the LEL and less than the UEL. Therefore, the
concentration is immediately combustible and explosive.
(c) The meter needle rises above the 1.0 LEL (100 percent) mark
and then returns to zero. This response indicates that the
ambient atmosphere has a combustible gas concentration
greater than the UEL.
(4) Evacuate the area if any of the following events occur:
(a)
Sounding of the GCI alarm
(b) Readings that reach the action levels designated in the SSHP
(c)
Malfunctioning of the CGI
(d) Condition encountered or suspected that indicates oxygen
enrichment or depletion of the atmosphere (specially
designed units are available for operation in those
atmospheres).
(5) Keep in mind these important factors during CGI use:
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(a) Slow, sweeping motions of intake or cell assembly will help
ensure that problem atmospheres are not bypassed. Cover an
area from the ground to the breathing zone and areas where
maximum concentrations may be expected (for example,
downhole during drilling).
(b) Operating the unit in temperatures outside the recommended
operating range may compromise the accuracy of readings or
damage the instrument. Check the operating manual for the
temperature limitations of each particular model.
(c) Many CGIs are not designed for use in oxygen-enriched or depleted atmospheres.
(d) Calibrate the equipment and charge the battery after each
field use. See the operating manual for details.
(e) The operator should fully understand the operating
principles and procedures for the specific CGI in use.
f.
Post Operations.
(1)
Field.
(a) Carefully clean the outside of the CGI with a damp
disposable towel to remove any visible dirt when the
activity is completed or at the end of the day. Return the
CGI to a secure area and place on charge.
(b) Ensure that all equipment is accounted for, decontaminated,
and ready for shipment.
(2)
Documentation.
(a) Record any uncompleted work (such as additional monitoring)
in the logbook.
(b) Complete logbook entries, verify the accuracy of entries,
and sign/initial all pages.
(c)
Review data collection forms for completeness.
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(3)
Office.
(a) Deliver original forms and logbooks to the document control
officer (with copies to the project manager and files).
(b) Inventory equipment and supplies. Repair or replace all
broken or damaged equipment. Replace expendable items.
Return equipment and report incidents of malfunction or
damage.
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CHAPTER 11
ORGANIC VAPOR MONITORING PROCEDURES
11-1. General. This chapter describes monitoring of organic vapors using a
portable PID and FID in the UST work environment. Both PIDs and FIDs are
useful as general survey instruments at UST sites. A PID is capable of
detecting and measuring real-time concentrations of many organic vapors in the
air. A PID is similar to a FID in application. Equipment calibration should
be done at the frequency and in accordance with the written manufacturer’s
instructions. Table 11-1 describes the application comparisons between a PID
and an FID. Other types of measuring devices such as colorimetric or
immunoassay can be used, but they do not provide the continuous readout of the
PID or FID instruments.
a. PID. A PID responds to most vapors that have an ionization potential
less than or equal to that supplied by the ionizing ultraviolet (UV)
lamp in the detector. Several lamps are available for the PID, each
having a different source wave length and subsequent different
ionization potential. For this reason, the selection of the
appropriate lamp is essential in obtaining useful field results.
Although it can be calibrated to a particular compound, the
instrument cannot distinguish between detectable compounds in a
mixture of gases. Therefore, it indicates an integrated response to
the mixture.
b. FID. An FID is useful as a general screening tool to detect the
presence of most organic vapors. It can detect pockets of gaseous
hydrocarbons in depressions or confined spaces and can screen an area
for the presence of elevated levels of vapor-phase organics. The FID
will respond to most organic vapors as they form positively charged
ions when burned in a hydrogen flame. The magnitude of the response
is a function of the detector sensitivity and the ionization
properties and concentration of the particular compound. As a
result, the response must be compared with the response generated by
a known concentration of a standard gas. The sample concentration is
then reported as the ppm-equivalent of the standard gas. Most units
are calibrated with methane; however, almost any gaseous hydrocarbon
that produces a response can be used. Many models also have built-in
calibration circuits to ensure that the electronic response remains
constant in all ranges.
11-2. Precautions. Personnel involved in the procedures outlined in this
chapter should be familiar with the potential hazards and know in the
appropriate safety and health measures needed to ensure a safe working
environment. During the course of UST activities, workers may be exposed to
petroleum hydrocarbon liquids and vapors and other hazardous wastes. Good
safety practices should be observed by all individuals using this procedure.
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TABLE 11-1
COMPARISON OF THE FID AND PID
FID
PID
Response
Responds to many organic gases
and vapors, especially low
molecular weight hydrocarbons.
Responds to many organic and some
inorganic gases and vapors,
especially heavy hydrocarbons.
Application
In survey mode, detects total
concentrations of gases and
vapors. In GC mode, identifies
compounds.
In survey mode, detects total
concentrations of gases and
vapors. Some compounds possible
if GC column and standards are
used.
Limitations
Does not respond to inorganic
gases and vapors with a higher
ionization potential than the
flame detector. No temperature
control.
Does not respond to methane or
inorganic aliphatic chlorinated
solvents. Does not respond
properly in presence of water
vapor (high humidity). Does not
detect a compound if probe (lamp)
has a lower energy than
compound's ionization potential.
Calibration
Gas
Methane and others.
Benzene (1,3-butadiene) and
others.
Ease of
Operation
Requires experience to interpret
correctly, especially in GC mode.
Fairly easy to use and interpret.
More difficult in the GC mode.
Detection
Limits
0.1 ppm (methane).
0.1 ppm (benzene), depends on
lamp voltage.
Response Time
2-3 sec (survey mode).
3 sec for 90 percent of total
concentration.
Maintenance
Periodically clean and inspect
particle filters, valve rings,
and burner chamber. Check
calibration and pumping system
for leaks. Recharge battery
after each use.
Clean UV lamp frequently. Check
calibration regularly. Recharge
battery after each use.
Useful Range
0-1,000 ppm.
0-2,000 ppm.
Service Life
8 hours; 3 hours with strip-chart
recorder.
10 hours; 5 hours with stripchart recorder.
11-2
EM 1110-1-4006
30 SEP 98
Monitor potentially toxic or potentially explosive vapors to determine when an
explosive or toxic hazard exists in the work environment.
11-3. PID Operations, Procedures, and Instructions. Site personnel
responsible for organic vapor monitoring should be familiar with all safety
rules and regulations and the procedures for operating equipment.
a. Limitations.
(1) The PID is a nonspecific total vapor detector. It cannot be
used to identify substances; it can only quantify substances.
(2) The PID must be calibrated to a specific compound.
(3) The PID does not respond to certain low molecular weight
hydrocarbons such as methane and ethane.
(4) Certain models of PID instruments are not intrinsically safe.
Refer to the manufacturer's operating manual for use in
potentially flammable or combustible atmospheres.
(5) A PID should be used in conjunction with a CGI.
(6) Electrical power lines or power transformers close to the PID
instrument may cause measurement errors. Under these
circumstances, refer to the operating manual for proper
procedures.
(7) High winds and high humidity will affect measurement readings.
Certain models of PID instruments become unusable under foggy or
high humidity conditions.
(8) The lamp must be periodically cleaned to ensure ionization of
the air contaminants.
(9) Consult the manufacturer's operating manual to determine the
instrument's response to various chemicals.
b. Calibration. Transport of calibration gas cylinders by passenger and
cargo aircraft is guided by the U. S. Code of Federal Regulations, 49
CFR Parts 100-177. Benzene is a typical calibration gas included
with a PID. Benzene is classified as a nonflammable gas, UN1556, and
the proper shipping name is "compressed gas." It must be shipped in
cargo aircraft only.
c. Instrument Preparation. Assemble the PID equipment and supplies
listed in Table 11-2. Perform the startup procedures and operational
checks described below.
11-3
EM 1110-1-4006
30 SEP 1998
(1)
Assemble the instrument and check battery according to
manufacturer's instructions. Turn on the PID.
(2)
Zero the instrument using zero-calibration air or ambient
air.
(3)
Calibrate the instrument according to the manufacturer's
specifications. At a minimum, instruments should be
calibrated daily at field conditions.
(4)
Contact the carrier that will transport equipment and
hazardous materials to obtain information on regulations and
specifications.
TABLE 11-2
PHOTOIONIZATION DETECTOR (PID)
EQUIPMENT AND SUPPLIES CHECKLIST
Photoionization Detector (PID)
Operating Manual
Probes:
9.5eV_____, 10.2eV_____, and 11.7eV_____
Battery Charger for PID
Spare Batteries
Jeweler's Screwdriver for Adjustments
Tygon Tubing
NIST Traceable Calibration Gas
(type: _________________________)
"T" Valve for Calibration
Intake Assembly Extension
Strap for Carrying PID
Teflon Tubing for Downhole Measurements
Plastic Bags for Protecting the PID from Moisture
and Dirt
11-4
EM 1110-1-4006
30 SEP 98
d. Documentation Preparation.
(1) Obtain a logbook.
(2) Record results of the equipment check in the logbook.
e. Field Preparation.
(1) Follow the startup procedures and operational check as described
in Section 11.3. Check the calibration of the instrument
against a known sample of calibration gas. If the calibration
is outside manufacturer's specifications, recalibrate the
instrument.
(2) Follow the instructions in the operating manual explicitly to
obtain accurate results. As with any field instrument, accurate
results depend on the operator's knowledge of the manual.
(3) Position the PID intake assembly close to the monitoring area
because the low sampling rate allows for only very localized
readings. Do not immerse the intake assembly in fluid under any
circumstances.
(4) Monitor the work activity as specified in the SSHP while taking
care not to permit the PID to be exposed to excessive moisture,
dirt, or contamination. Conduct the PID survey at a slow-tomoderate rate of speed and slowly sweep the intake assembly (the
probe) from side to side.
(5) Evacuate the area if the preset alarm sounds. Operators using
supplied air systems may not need to evacuate the work area, but
they should frequently observe the levels indicated by the
instrument.
(6) Static voltage sources like power lines, radio transmissions, or
transformers may interfere with measurements. See the
operator's manual for a discussion of necessary considerations.
f. Post Operation.
(1) Field.
(a) Carefully clean the outside of the PID with a damp
disposable towel to remove any visible dirt when the
11-5
EM 1110-3-178
30 SEP 98
activity is completed or at the end of the day.
PID to a secure area and place on charge.
Return the
(b) Ensure that all equipment is accounted for and
decontaminated.
(2) Documentation.
(a) Record any uncompleted work (such as
in the logbook.
additional monitoring)
(b) Complete logbook entries, verify the accuracy of entries,
and sign/initial all pages.
(c) Review data collection forms for completeness.
(3)
Office.
(a) Deliver original forms and logbooks to the document control
officer with copies to the project manager and files.
(b) Inventory equipment and supplies. Repair or replace all
broken or damaged equipment and charge the batteries.
Replace expendable items. Return equipment and report
incidents of malfunction or damage. If necessary, replenish
supplies of the NBS traceable calibration gas.
11-4. FID Operations, Procedures, and Instructions. Site personnel should be
familiar with all safety rules and regulations and procedures for operating
equipment.
a. Limitations.
(1) The FID does not respond to nongaseous organic compounds such as
some pesticides, polynuclear aromatic hydrocarbons (PAHs), and
polychlorinated biphenyls (PCBs).
(2) Most portable FIDs use the sample gas as combustion air for the
detector flame and are designed to operate in ambient
atmospheres with oxygen concentrations of approximately 21
percent. This design precludes the sampling of process vents,
poorly ventilated or sealed containers, or any sample gas with a
hydrocarbon concentration sufficient to reduce the available
oxygen or saturate the detector. Optional equipment is
available to supply oxygen from a compressed gas cylinder or
11-6
EM 1110-1-4006
30 SEP 98
introduce sample gas through a dilution system with a known
dilution factor.
(3) Concentrations beyond the greatest scale factor of the
instrument or in excess of 30 percent of the LEL of the sample
component require system modification. If system modifications
are required, consult the manufacturer's operating manual.
b. Calibration. FID instruments usually have a negligible response to
carbon monoxide (CO) and carbon dioxide (CO2). Their structures
preclude the production of appreciable ions in the detector flame so
other organic materials may be analyzed in the presence of CO; and,
as with the PID, the FID responds differently to different compounds.
Because the instrument is factory-calibrated to methane, all relative
responses are given in percentages with methane at 100. Therefore,
the identity of the chemical of interest must be ascertained before
its concentration can be determined.
In addition, the FID unit requires a trained individual to maintain
and operate the unit. Department of Transportation regulations
prohibit the carrying of compressed hydrogen gas on passenger
aircraft. When the FID instrument is transported on a passenger
aircraft, the hydrogen gas contained in the instrument must be
emptied before loading. Transport of an FID or extra cylinders of
hydrogen gas or calibration gas by cargo aircraft must comply with
the regulations stipulated in 49 CFR Parts 100-177. Consult the
shipper for any recent changes in this procedure.
c. Instrument Preparation. Assemble the equipment and supplies listed
in Table 11-3. Perform the startup procedures and functional checks
described below. The purpose of these checks is to verify that an
instrument will function properly (for example, the batteries are
serviceable, and the instrument can be zeroed and calibrated) in the
field. If problems develop, obtain a replacement unit and perform
the same functional checks.
(1) Turn the instrument on and allow adequate warmup time.
(2) Check the battery charge level indicator. If it is not fully
charged, recharge the battery as described in the manual.
(3) Turn on the pump and check for leaks by covering the sample
inlet and observing the rotameter. The indicator ball should
drop to zero.
11-7
EM 1110-3-178
30 SEP 98
(4) With the pump operating, open the hydrogen gas storage tank
valve and the supply regulator to allow fuel gas to flow into
the detector chamber.
(5) Depress the igniter switch, observe the indicator needle for
positive response, and listen for a pop. If the flame fails to
light, depress the igniter switch again. Once the detector
flame is lit, the unit is ready for use. Before lighting the
detector flame, always be sure that the combustion gas flow
(usually sample gas) is started. If the detector fails to
light, check over the instrument battery and gas levels and
start again at Step 1. If the instrument still does not light,
contact the project manager.
TABLE 11-3
FLAME IONIZATION DETECTOR (FID)
EQUIPMENT AND SUPPLIES CHECKLIST
Flame Ionization Detector (FID)
Probe
Extension
Operating Manual
Battery Charger
Spare Batteries
Jeweler's Screwdriver for Adjustments and
Calibration
Refueling Hose for Hydrogen Cylinder
NIST Traceable Calibration Gas
(type: _________________________)
(6) If the instrument has internal calibration capability, perform
the instrument calibration according to the procedures described
in the operating manual.
d. Documentation Preparation.
(1)
Obtain a logbook.
(2)
Record equipment checking results in the field logbook.
11-8
EM 1110-1-4006
30 SEP 98
(3) Obtain a sufficient number of the appropriate data collection
forms.
e. Field Preparation. Before using the FID in the field, perform the
following instrument checks to ensure that the equipment was not
damaged during transport.
(1) Follow the instrument checkout procedures described above in
office preparation.
(2) If calibration to a specific hydrocarbon species is desired,
complete this procedure according to the manufacturer's operating
instructions.
(3)
Calibrate the FID daily before each use in the field.
(4) Hold the sample probe in the area in question.
rate allows for only very localized readings.
The low sample
(5) A slow sweeping motion should help prevent the bypassing of
problem areas. Make sure the batteries are recharged within the
time frame specified in the operator's manual. The usual length
of operating time between charges is 8 to 12 hours.
(6) Perform FID monitoring at 1.5-meter (5-foot) intervals downhole,
at the headspace, and in the breathing zone during drilling
activities. In addition, where elevated organic vapor levels are
encountered, monitoring may be performed in the breathing zone
during actual drilling. When the activity does not require
drilling (like surface sampling), only record readings in the
breathing zone. Consult the SSHP for the specific monitoring
instructions.
(7) Check for an alarm on the unit that signals the operator if the
detector flame goes out. If the alarm sounds, evacuate the work
area, relight the flame in a known safe area, and reenter the
site.
(8) Monitor fuel and combustion air supply gauges regularly to
ensure sufficient gas supplies.
(9) Clean sample probe or in-line filters (in front of the
detector), when high background readings occur or after
prolonged use. Use pipe cleaners to clean the probe and apply
clean air blown backwards through the probe to clean the
filters. Do not use organic solvents because the detector may
become saturated by the solvent.
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EM 1110-3-178
30 SEP 98
(10)
Perform the routine maintenance described in the operating
manual. Because the FID unit contains pressurized gas
supplies, leak-check procedures must be regularly performed.
Leaking hydrogen gas is explosive.
(11)
Modify the system if concentrations beyond the maximum fullscale capability of the instrument or in excess of 30-percent
LEL of the sample component occur. Similar modification may be
necessary for sampling in oxygen-deficient atmospheres. This
usually entails increasing the combustion air to the
detector by sample dilution or by an independent air supply. A
dilution system apparatus is required to supply a filtered,
controlled air supply for analyzers that use the sample gas
stream as the source of combustion air. A dilution system can
dilute a gas stream by ratios up to 100:1 through the selection
of various critical orifices.
f. Post Operations. See paragraph 11-3f.
process applies to both FIDs and PIDs.
11-10
The same post-operations
EM 1110-1-4006
30 SEP 98
CHAPTER 12
PRODUCT REMOVAL PROCEDURES
12-1. General. This chapter describes the procedures that should be followed
for removal of product from an UST after the tank's contents have been
characterized by reviewing records and/or by chemical analysis. Sampling is
usually recommended for tanks that are no longer in use or that have
experienced a change in use over their lifetimes. The only time when a UST
would not be sampled is when the tank is currently in service, and the
contents stored over its service life are well-documented.
12-2.
Operations, Procedures, and Instructions.
a. Precautions. During the course of product removal, workers may be
exposed to petroleum hydrocarbon liquids, vapors, or wastes. All
precautions should be observed by all individuals using this
procedure for product removal from USTs. Site personnel responsible
for product removal should be familiar with:
(1) All safety rules and regulations (consult the SSHP for specific
safety instructions).
(2) The use of equipment and procedures for removing product from
tanks.
(3) The handling and disposal of the types of products likely to be
encountered.
(4) API Publications:
1604, 2003, 2015, 2217,
2219, and NFPA 327.
(5) Transportation of fuel and fuel products.
b. Documentation.
(1) Obtain a field logbook to record all activities performed,
personnel contacted, time and dates when these activities were
performed, field conditions, and any unusual circumstances.
(2) Keep information factual and objective.
(3) Enter information not recorded in the logbook on field forms.
In either case, record the following information:
C
C
C
C
Site identification
Date and time specific activities took place
Personnel names
Field observations.
12-1
EM 1110-1-4006
30 SEP 98
Photographs are suggested; if photos are taken, records must indicate the name
of photographer, site name, camera type and lens size, and general direction.
This information will be included in the Tank Closure Report discussed in
Chapter 1 of this manual.
c. Procedures.
(1)
Observe any special precautions.
(2) Perform limited excavation (per requirements in EM 385-1-1) to
access the piping. Flush and drain piping into the tank, being
careful to avoid any spillage to the surrounding area.
Disconnect piping (except the vent line) from the tank and cap
or remove the piping.
(3) Take a sample for offsite analysis if tank contents are unknown.
Generally, the contents of an active tank are known. See Chapter
6 for sampling of tank contents.
(4) Vent the tank properly by ensuring all vent pipes are open to
the atmosphere, then pump or drain residual product to the
lowest possible level through the water-draw or pumpout
connection.
12-3. Equipment. Vacuum tank trucks, along with explosion-proof or airdriven pumps, provide a fast and efficient method for removing and hauling
product from USTs.
a. Precautions
(1) The vacuum truck operator should be trained to identify or
recognize hazards connected with truck operations including
spills, hose failures, and discharges of flammable and toxic
vapor.
(2) The truck operator should be provided with and trained in the
use of all required personal protective equipment. In addition,
the tank operator should be trained in recognition of
potentially flammable conditions and fire prevention, first aid,
and the proper use of portable fire extinguishers and other fire
extinguishing techniques.
(3) Department of Transportation regulations in 49 CFR 172 Subpart H
require the truck operator to be trained and tested on the
hazardous materials regulations. Training must include general
awareness of the hazardous materials regulations, safety
training, driver training, and function specific training. The
truck operator should be knowledgeable in and compliant with
applicable state and local hazardous material regulations as
12-2
EM 1110-1-4006
30 SEP 98
well as the following portions of the Code of Federal
Regulations:
(a) 49 CFR Parts 170-178 and 390-397 Transportation. (This
material has been compiled by National Tank Truck Carriers
in their publication: Cargo Tank Hazardous Material
Regulations.)
(b) 40 CFR 263 Standards Applicable to Transporters of Hazardous
Waste.
(c) 40 CFR 279 Standards Applicable to the Management of Used
Oil (when applicable).
b. Truck Inspection and Operating Procedures. The truck operator should
complete this inspection checklist before the truck is operated:
(1) All valves are operating freely.
(2)
Floats for liquid-level indicators are working properly.
(3) Rubber stoppers on scrubber shutoffs are in good condition and
seated properly.
(4) Dome gaskets are in good condition and seated tightly when the
domes are closed (this can be checked by applying pressure to
the tank).
(5) Hoses, connections, and fittings are in good condition, and the
materials of construction are appropriate for the application.
(6) All connections and other equipment are leak-free and in good
working order.
c. Internal Valves. Internal valves are not required on tanks that have
been specifically exempted by the U. S. Department of Transportation;
however, a copy of the exemption must be carried on the truck.
d. Operating Environment.
(1) Because truck engines are an ignition source, they should be
operated upwind of any pickup point and outside path of vapor
travel.
(2) If there is any question whether the area is gas-free, a gas
test should be performed using a CGI before any operation is
started. The area must be vapor free.
12-3
EM 1110-1-4006
30 SEP 98
(3) A vacuum truck should be permitted into a diked tank area only
after the area has been tested and found to be gas free.
(4) In the area where product will be discharged from the vacuum
truck, vapor travel and sources of ignition must be considered.
e. Static Electricity. With nonconductive hose, any exposed metal, such
as a hose flange, can accumulate static electricity and act as an
ignition source if the metal touches or comes close to ground.
Therefore, if nonconductive hose is used to discharge a flammable
liquid into an open area (such as a pit or an open tank) or
discharged where any source of flammable material is present near the
hose's exposed metal parts, the metal parts shall be bonded, the hose
and the tank or receiving vessel shall be bonded, and the bonding
system shall be grounded. (Refer to NFPA 30, Flammable and
Combustible Liquids Code).
As it is difficult to distinguish between conductive and
nonconductive hose and both may be used, it is recommended that all
exposed metal on any hose be grounded. Exception to this would be a
closed system with tight connections at both ends of the hose. An
alternative to grounding in such cases is verifying, by means of
electrical testing, that the hose is conductive.
f. Cargo Tank Vacuum Loading. The truck operator should utilize the
following procedure when loading a cargo tank:
(1) Attach the suction hose from the inlet valve to the load source.
(2)
Close all valves.
(3)
Start the vacuum pump.
(4)
Position the four-way valve to pull a vacuum on the cargo tank.
WARNING: When volatile flammable or toxic liquids are loaded, the vacuum pump
exhaust should be extended downwind by attaching a length of hose sufficient
to allow venting to a hazard-free area away from people, ignition sources, and
so forth.
(5)
When the tank is full, close the inlet valve.
(6) Bleed off the vacuum by opening the bleeder valve, equalizing
the tank pressure.
(7) Close and cap the bleeder valve. Open the inside and outside
scrubber (liquid entry preventer); drain valves. Catch any
liquid for proper disposal.
12-4
EM 1110-1-4006
30 SEP 98
CAUTION: To prevent liquids and solids from entering the vacuum pump, neither
the inside nor the outside scrubber drain valves should be opened while the
unit is under vacuum.
12-4. Waste Disposal and Recycling. Two types of waste associated with
product-removal operations include product and contaminated water from rinsing
activities.
a. Product Disposal. (Note: The scope of this EM is limited to
petroleum, oil, and lubricant tanks; therefore, this discussion does
not include other types of products). In many instances, product
removed from tanks can be reused onsite if the fuel characteristics
meet the facility's specifications. If the fuel does not meet the
specifications, (e.g., because of excessive amounts of water or
sludge in the fuel), it can be shipped to a recycler for reclamation.
Prior to shipment, a determination on the regulatory status of the
material must be made. It may be regulated as a hazardous waste if
it is ignitable, fails TCLP, or meets criteria for a state-regulated
waste. On the other hand, it may be excluded from regulation if it
can still be used as a fuel or if recycled in a manner that excludes
it from regulation as a hazardous waste.
(1) When the petroleum, oil, lubricant (POL) is not subject to
regulation as a hazardous waste, options for recycling include:
(a) Use for its intended purpose directly. For example it can
be burned as a fuel in a boiler, in an industrial furnace,
or in a space heater. It could also be burned in an engine
used to operate a free-product recovery system.
(b) Use for its intended purpose after being re-processed. For
example, fuel/water mixtures can be physically separated on
site to recover the fuel. Since it is not regulated as
hazardous waste, processing does not require an RCRA Part B
permit.
(c) Use as an additive for paving or roofing asphalt. Whereas
hazardous wastes are prohibited from being used as
ingredients for products placed on the land (unless specific
conditions are met), this prohibition does not apply to nonhazardous wastes.
(d) Use as a substitute for a commercial product. For example,
it could be used as form release agent for concrete
production.
(2) When the POL is ignitable or fails TCLP, the following options
for disposal and/or recycling should be considered:
12-5
EM 1110-1-4006
30 SEP 98
(a) Use for its intended purpose without first processing. Fuel
that can still be used for its intended purpose is not
subject to RCRA regardless of whether or not it exhibits a
hazardous characteristic.
(b) Process it to become a useable fuel. However, the facility
that processes the waste must be a permitted RCRA treatment,
storage, and disposal (TSD) facility.
(c) Mix with used oil and burn as used oil provided the mixture
does not exhibit any RCRA hazardous characteristic. Note,
however, that this is permissible according to federal
regulation, but may be prohibited by individual states.
(d) Burn for energy recovery at a permitted TSD facility.
(e) Use as an effective substitute for an ingredient in a
commercial chemical product provided the resultant product
is not applied to the land or burned for energy recovery.
However, it can be recycled into a product applied to the
land if the following three criteria are met:
(1) The recyclable material has undergone a chemical
reaction in the course of producing the product so as
to become inseparable by physical means;
(2) the product meets land disposal restriction treatment
standards; and
(3) the product is produced for the general public’s use.
b. Contaminated Water. Contaminated water can be disposed of in several
different ways. Some DOD facilities may discharge to an oil/water
separator. A second method is to discharge it to the local publicly
owned treatment works (POTW) or an industrial wastewater treatment
facility. Contact the facility environmental coordinator and the
local POTW to determine discharge requirements for the facility.
Another method of disposal is to ship the water/product mixture to a
recycler. The reader should recognize that this may be a more
expensive option due to shipping costs. Any method of disposal needs
careful and precise documentation, including laboratory analytical
results, disposal facility approval and certification, and the proper
paperwork to track the removal and disposal of the waste.
12-6
EM 1110-1-4006
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CHAPTER 13
UNDERGROUND STORAGE TANK REMOVAL PROCEDURES
13-1. General. This chapter recommends procedures for the removal, storage,
and offsite disposal of UST systems that have contained flammable or
combustible fluids. All such work must be accomplished in accordance with
federal, state, and local requirements as well as accepted safety standards.
Before initiating work, the appropriate government agencies should be
consulted concerning applicable regulatory and permit requirements. This
chapter is not considered to be all inclusive due to the differences in state
regulatory requirements. USACE Guide Specifications and other helpful
guidance references are included in Chapter 1.
13-2.
Removal of Underground Tanks.
a.
Preparation.
(1) Observe the safety precautions as described in Chapter 7.
(2) Notify the Implementing Agency a minimum of 30 days prior to
tank removal. Obtain a tank removal permit from the local fire
chief or proper authorities and notify the environmental
coordinator of the day and time when work will begin at least 3
days in advance. Typically, local regulations require a local
fire official representative to be onsite before work may begin.
Notify proper fire authorities as they require.
(3) Remove all liquids from the tank following the procedures
outlined in Chapter 12.
b. Purging Tanks. Purging or ventilating a tank replaces or dilutes the
flammable vapors in the tank with air. The goal of tank purging is
to reduce the flammable vapors in the tank to below one percent of
the LEL. Tanks shall be purged for confined space entry but not for
removal purposes. However, it is important to recognize that the
tank may continue to be a source of flammable vapors even after
following the purging procedures.
Confined space entry into the tanks should not be attempted unless
absolutely necessary, but it may be required to effectively remove
sludge from the tank. Consult NFPA 326, Safe Entry into Underground
Storage Tanks, for tank entry and Table 13-1, which summarize the
procedures for tank purging as well as associated advantages and
disadvantages.
13-1
EM 1110-1-4006
30 SEP 98
TABLE 13-1
PROCEDURES FOR PURGING TANKS
Procedure
!
Venting vapors
This must be
done at least
3.7 m (12 feet)
above grade and
1 m (3 feet)
above roof
lines.
Advantage
!
Ventilation is
usually the
first method of
choice for removing
flammable
atmospheres since it
can be accomplished
with the least cost.
13-2
Disadvantage
!
The work area must be
free from sources of
ignition.
!
All venting of
flammable vapors must
be into a safe
location and should
be monitored to
ensure that a vapor
buildup does not
occur.
!
Ventilation must be
ongoing to maintain
flammable vapors
below 10 percent LEL.
!
It may not be
possible to
adequately ventilate
a tank that contains
residuals of highly
flammable liquids or
sludge.
!
Venting without
forced
flammable vapor
removal will not work
unless the access to
the tank is located
on the top of the
tank.
!
Venting is time
consuming.
!
Purging is a
temporary procedure.
Product trapped in
bottom sludge and
wall scale
regenerates flammable
vapors inside the
tank.
!
Venting cannot be
used for tank removal
purposes.
EM 1110-1-4006
30 SEP 98
TABLE 13-1 (continued)
PROCEDURES FOR PURGING TANKS
Procedure
!
Ventilation via an
eductor-type air
mover usually
driven by
compressed air
Advantage
Disadvantage
! Tanks equipped with
fill (drop) tubes
that are not
removable can be
purged efficiently by
this method.
! Vapors must be
discharged at a minimum
of 3.7 m (12 feet)
above grade.
! All precautions must
be taken to minimize
the hazards of
ignitability and static
electricity. Air
movers must be
inherently bonded to
the vessel being
ventilated.
! Exhaust fumes will
need to be vented at a
minimum height of 3.7
m (12 feet) above
grade and 1 m (3 feet)
above any adjacent
rooflines.
! To avoid rupturing the
tank, air pressure in
the tank must not
exceed 34.5 KPa (5
psi) so the size of
vent openings as well
as the air pumping
rate must be
considered.
13-3
EM 1110-1-4006
30 SEP 1998
TABLE 13-1 (continued)
PROCEDURES FOR PURGING TANKS
Procedure
!
Ventilation via a
diffused air
blower
Advantage
!
Generally,
blowing into
the tank rather
than exhausting
from the tank
is more
effective.
!
Ventilation via
diffused air
blower is
relatively
inexpensive.
Disadvantage
! Irregular-shaped
containers may not be
thoroughly purged by
this method if the
airstream leaves
pockets that cannot be
effectively reached
with the uncontaminated air.
! All precautions must be
taken to minimize the
hazards of ignition by
static electricity.
Air movers must be
inherently bonded to
the vessel being
ventilated.
! Fill (drop) tubes must
be removed to allow
proper diffusion of the
air in the tank.
! Air supply must come
from a compressor that
has been checked to
ensure a clean air
supply that is free
from volatile vapors.
! To avoid rupturing the
tank, air pressure in
the tank must not
exceed 34.5 KPa (5
psi).
! Exhaust fumes will need
to be vented at a
minimum height of 3.7 m
(12 feet) above grade
and 1 m (3 feet) above
any adjacent rooflines.
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TABLE 13-1 (continued)
PROCEDURES FOR PURGING TANKS
Procedure
! Use of commercial
emulsifiers
Advantage
! Completely miscible
in water.
! Aids in the
elimination of
flammable vapors.
! Biodegradable.
! Displacement of
vapors with water
! One of the safest and
simplest methods.
Disadvantage
! Regulatory
requirements for
treatment and disposal
of the water must be
determined.
! Biosolve is an
expensive material to
purchase.
! Regulatory
requirements for
treatment/disposal of
water used in the
vapor-freeing process
may make this method
cost-prohibitive.
! The liquid previously
contained in the tank
must be readily
displaced by or be
soluble in water.
! In accordance with
USACE guide
specifications,
purging methods
utilizing liquids
shall not be allowed.
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(1) Exhaust flammable vapors from the tank by one of two methods of
tank ventilation listed below.
(a) One method is ventilation using an eductor-type air mover,
usually driven by compressed air. However, the USACE does
not approve this method. Therefore, it is presented in this
manual only for completeness of information. The eductortype air mover must be properly bonded to prevent the
generation and discharge of static electricity. When using
this method, the fill (drop) tube should remain in place to
ensure ventilation at the bottom of the tank. Tanks
equipped with fill (drop) tubes that are not removable are
purged by this method. An eductor extension is used to
discharge vapors a minimum of 3.7 meters (12 feet) above
grade or 1 meter (3 feet) above adjacent roof lines,
whichever is greater.
(b) Ventilation with a diffused air blower is a second method.
When using this purging method, it is imperative that the
air-diffusing pipe is properly bonded to prevent the
discharge of a spark. Fill (drop) tubes must be removed to
allow proper diffusion of the air in the tank. Air supply
should be from a compressor that has been checked to ensure
a clean air supply that is free from volatile vapors. Air
pressure in the tank must not exceed 34.5 KPa (5 psi) gauge
to avoid tank failure.
(2) One of the safest and simplest methods for purging a tank is to
fill the tank with water. However, in certain areas, regulatory
requirements for treatment/disposal of water used in the vaporfreeing process may make this method cost-prohibitive. Purging
methods using liquids will not be used on USACE projects due to
generation of excessive volumes of waste. The method is
presented here for completeness. Before employing the method
described below, consult local regulations.
(a) Fill the tank with water until the floating product nears
the fill opening. Remove the floating product and place it
in a suitable container for proper disposal. Care should be
exercised to ensure that neither product nor water is
spilled into the tank excavation.
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(b) Observe normal safety precautions filling the tank with
water because flammable vapors will be expelled through both
the vent and fill openings, but primarily at the fill
opening. To minimize this escape of vapor through the fill
opening, temporarily cap the opening.
(c) Pump out the water and dispose of it in accordance with
local regulations when the tank is free of vapor.
(3) Another purging method that has been used with success and is an
approved method in some states is the use of commercial
emulsifiers and volatile fuel encapsulators. These products are
completely miscible in water, aid in the elimination of
flammable vapors, and are biodegradable. Regulatory
requirements for treatment and disposal of the water must be
determined prior to using this method.
(a) Standing outside the tank, rinse the tank with a three- to
six- percent solution of the product using a pressure
sprayer through a manway opening.
(b) Measure explosive concentrations at several levels within
the tank. If readings are greater than 20 percent of the
LEL, rinse the tank again.
(c) When LEL readings are acceptable, pump out the water in the
tank for disposal.
c. Inerting Tanks. Inerting displaces the flammable atmosphere of the
tank with an inert or nonreactive gas such as nitrogen or carbon
dioxide. Inerting is achieved when the oxygen content is lowered to
below 8 percent oxygen by volume, which is the amount of oxygen
needed by most petroleum products to support combustion. Table 13-2
summarizes the procedures and advantages/disadvantages for tank
inerting. Inerting is the only option available when removing tanks
from the ground.
Always exercise caution when handling or working around tanks that
have stored flammable or combustible liquids. Before initiating work
in the tank area or on the tank, a Combustible Gas Indicator (CGI)
should be used to assess vapor concentrations in the tank and work
area. CGI operation is detailed in Chapter 10.
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TABLE 13-2
PROCEDURES FOR INERTING TANKS
Procedure
!
Displacement of
vapors with dry
ice, carbon dioxide
gas
Advantage
Disadvantage
!
When inerting with
dry ice, the static
electrical problems
that are encountered
with gas cylinder
inerting are not
encountered.
!
This method
cannot be used if
the tank is to be
entered for any
reason as the tank
atmosphere will be
oxygen-deficient.
!
Dry ice is readily
available and
relatively
inexpensive.
!
The dry ice
vaporization
releases flammable
vapors.
!
Exhaust fumes from
inerting should be
vented at a minimum
height of 3.7 m (12
feet) above grade
and 1 m (3 feet)
above any adjacent
roof lines.
!
Air pressure in the
tank must not exceed
34.5 KPa (5 psi)
gauge.
!
There is no momentum
for vapors in the
tank to move toward
the vent so inerting
takes longer and may
be less effective
than inerting with
compressed gas.
!
Pockets of vapors
can be trapped in
the tank if
distribution of the
inert gas in the
tank is incomplete.
!
Oxygen may be reintroduced into the
tank unless all
holes are
effectively plugged,
except for the vent
line.
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TABLE 13-2 (continued)
PROCEDURES FOR INERTING TANKS
Procedure
! Inerting with an
inert gas such as
CO2 or N2
The concentration
of oxygen in the
tank can be reduced
to a level
insufficient to
support combustion
by replacing the
oxygen with an
inert gas.
CO2 is generally
the gas of choice
since its density
is greater than air
causing it to
settle to the tank
bottom pushing
oxygen up and out
of the tank.
Advantage
!
!
!
Inert gases may be
used to remove the
flammable vapors from
containers under
certain conditions
without the hazards
incidental to having
the vapor-air mixture
in the tank space
pass through the
flammable range.
Inerting with CO2 or
nitrogen from
cylinders is
generally faster than
dry ice due to better
distribution of the
inert gas.
Disadvantage
!
This method cannot
be utilized if the
tank is to be
entered for any
reason, as the tank
atmosphere will be
oxygen-deficient.
!
The gas must be
introduced through a
single tank opening
and under low
pressure < 34.5 KPa
(5 psi).
!
Compressed gases may
create a potential
ignition hazard as
the result of the
development of
static electrical
charges. The
discharge device
must, therefore, be
grounded.
!
Exhaust fumes from
inerting should be
vented at a minimum
height of 3.7 m (12
feet) above grade
and 1 m (3 feet)
above any adjacent
roof lines.
!
Inerting with gas
can be expensive.
!
Compressed CO2 has a
much larger
temperature
difference with the
outside atmosphere
than bottled
nitrogen. This
difference leads to
condensation, which
increases the
generation of static
electricity.
!
Oxygen may be reintroduced into the
tank unless all
holes are completely
plugged, except for
the vent line.
Inerting can be
completed in a short
period of time.
13-9
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(1) Flammable and combustible vapors may be inerted with an inert
gas such as CO2 or N2. This method should not be utilized if the
tank is to be entered for any reason, as the tank atmosphere
will be oxygen deficient. The inert gas should be introduced
through a single tank opening at a point near the bottom of the
tank, at the end of the tank opposite the vent. If necessary,
excavate around the vicinity of the tank to access the
connection. When inert gases are used, they should be
introduced under low pressure to avoid the generation of static
electricity. When using CO2 or N2, pressures in the tank should
not exceed 5 psi gauge. The process of introducing compressed
gases into the tank may create a potential ignition hazard as
the result of the development of static electrical charges. The
discharging device must, therefore, be grounded. CO2
extinguishers should not be used for inerting flammable
atmospheres because explosions have resulted from the
discharging of CO2 fire extinguishers into tanks containing a
flammable vapor-air mixture.
(2) If the method described above is not practical, the vapors in
the tank may be displaced by adding solid carbon dioxide (dry
ice) to the tank in the amount of at least 1.36 Kg (3 pounds)
per 378 liters(100 gallons) of tank capacity. The dry ice
should be crushed and distributed evenly over the greatest
possible area in the tank to promote rapid evaporation. As the
dry ice vaporizes, flammable vapors will flow out of the tank
and may surround the area. Therefore, where practical, plug all
tank openings except the vent after introducing the solid CO2
and continue to observe all normal safety precautions regarding
flammable or combustible vapors.
(3) Monitoring of oxygen concentrations within the tank should be
done during the inerting operation. Inerting has been
satisfactorily accomplished when the oxygen content is less than
8 percent. If vapor reduction is not occurring satisfactorily
and the onsite official allows, pour water down each pipe to
which dry ice was added. This will distribute the dry ice and
release more CO2. If vapor reduction is not adequate after the
above procedures have been followed, repeat dry ice application
using half of the original dry ice quantity per volume.
13-10
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d. Testing.
(1) The tank atmosphere and the excavation area should be
continuously tested for percent oxygen and combustible gas
during the tank excavation and removal operations. Follow these
guidelines to test:
(a) Take such tests with a CGI with an oxygen meter that is
properly calibrated according to the manufacturer's
instructions (typically on pentane or hexane in air) and
which is thoroughly checked and maintained in accordance
with the manufacturer's instructions.
(b) Use a person completely familiar with the use of the
instrument and the interpretation of the instrument's
readings to do the test.
(c) Take readings at the bottom, middle, and upper portions of
the tank and clear the instrument after each reading. If
the tank is equipped with a nonremovable fill tube, readings
should be taken through another opening.
(2) Follow these procedures to ensure the tanks remain properly
inerted:
(a) Test the tank vapor space by placing the indicator probe
into the fill opening with the drop tube removed. Liquid
product must not enter the probe.
(b) Readings of less than 8 percent oxygen must be obtained
before the tank is considered safe for removal from the
ground. Oxygen readings that rise above 8 percent during
removal activities will require additional tank inerting
before removal activites can continue.
e. Associated Piping Inerting. In preparation for tank removal, the
type of tank appurtenances must be evaluated. Different types of
tank configurations include those with removable extractor valves,
angle check valves, nonextractor angle check valves, direct connect
lines, and other connecting lines. Remove any check valves to
prevent backflushing of the pipe lines. All piping must be inerted
before tank removal begins. These lines may have a manhole that
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allows access from the surface without excavation, or excavation may
be required for access. Confined space precautions will be followed
if employees are required to enter tanks, manholes, or excavations.
(1) Removable Extractor Valves. Procedures for inerting different
types of tank configurations are discussed first followed by
procedures common to all.
(a) Access tank connections via manhole or by excavation.
(b) Remove each extractor valve riser cap and remove the
extractor valve using the proper tool.
(c) Recap and tighten each extractor valve riser cap.
(2) Nonextractor Angle Check Valves, Direct Connections and Other
Connecting Lines.
(a) Access connections via manhole or by excavation.
(b) Inert all piping before tank removal begins.
(c) Disconnect the fuel line from the angle check valve and
disconnect other lines from the tank.
(d) Catch any liquids from the lines in a container and properly
dispose of liquids.
(e) Attach a reducing bell to the suction or connecting line to
reduce the line diameter to 20 mm (3/4-inch).
(f) Remove angle check valve or appurtenance from the tank, if
possible.
(g) Attach a 20 mm (3/4-inch) gasoline-rated hose to the 20 mm
(3/4-inch) end of the bell reducer and insert the free end
of the hose into the nearest bung opening in the tank.
(3) Common Pipe Inerting Procedures.
steps.
Use N2 or CO2 for the following
(a) Disconnect the piping at the dispenser or building.
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(b) Make connections such that the piping system may be
backflushed with the selected inert substance.
(c) Pressurize the line with the substance so that the fluid in
the pipeline will be backflushed into the UST. If the tank
connections are of the extractor-valve type, repeat the
backflushing process with each line that is connected to the
UST. If the lines are of the direct-connect type, continue
until the hose discharge is observed to be exhausting clean
inert substance. The procedures must be repeated for each
additional line.
f. Tank Removal.
(1) Remove liquids and residues from the tank as detailed in Chapter
12.
(2) If excavation has not already been performed for piping access,
remove concrete or asphalt cover. Excavate underlying soils
down to the top of the tank. Segregate these soils from those
underlying the tank to reduce disposal volumes if these upper
soils have no visual or odor contamination. Excavation should
be deep and wide enough to allow access to all associated piping
and appurtenance tank connections.
(3) Remove the fill pipe, gauge pipe, vapor recovery truck
connection, submersible pumps, and other tank fixtures. Remove
the drop tube, except when it is planned to purge the tank by
using an eductor as described previously. Cap or remove all
nonproduct lines, such as vapor recovery lines, except the vent
line. The vent line should remain connected until the tank is
purged. Temporarily plug all other tank openings so that all
vapors will exit through the vent line during the inerting
process.
(4) After the tank has been inerted and before it is removed from
the excavation, cap or plug all pipes or bungs at or as near as
possible to the tank. Cut any tank hold-down straps. Use a
nonsparking cutter, such as pipe cutters, to avoid the
generation of any sparks during pipe cutting.
13-13
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The plug or cap sealing the vent tube must have a 3-mm (1/8inch) hole drilled through the tube. This hole will allow
expansion and contraction of the gases contained within the tank
due to temperature variations without subjecting the tank to
excessive differential pressure caused by temperature changes.
The tank should always be positioned with this vent plug on top
of the tank during subsequent transport and storage.
(5) To remove the tank:
(a) Attach pulling chain to the tank eyelets or any secure hooks
or rungs, or use nylon slings that will support the tank
weight.
(b) Remove tank from excavation, using appropriate lifting
device in accordance with requirements of EM 385-1-1.
Front-end loaders and backhoes cannot be used for lifting
unless they are equipped with a factory attached hook
designed with adequate lift capacity for the tank, and the
tank does not exceed the published lifting capacity for the
equipment.
(c) Set tank on the ground and stabilize with wooden blocks.
Keep the ventilation cap with the 3-mm (1/8-inch) hole on
top.
(6) Visually inspect the outside of the tank and use screwed
(boiler) plugs to plug any and all corrosion holes in the tank
shell.
(7) Recheck the oxygen content within the tank as before and
reinitiate inerting procedures, if required. It is vital that
the internal tank atmosphere be insufficient to support ignition
as sparks are possible, and a tank above ground can cause great
damage to life and property if ignition occurs.
(8) Remove external scale and attached soil from the tank.
Nonsparking tools must be used at all times in the vicinity of
the tank until such time as the tank interior and exterior
surfaces are decontaminated.
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(9) See Chapter 15 (Soil and Free-Product Removal Procedures) for
further excavation procedures concerning soil samples and
contamination soil excavation.
(10) Contain spills or drips during removal using absorbent booms or
other methods required by the Implementing Agency. If you
observe contamination (i.e., saturated soil or free product)
from previous operation or removal, consult local environmental
officials, the fire marshal, or the EPA for assistance and
requirements. See API Bulletin 1628 for further information.
g. Sludge Removal. Remove sludge and decontaminate the interior and
exterior of the tank prior to tank removal from the work site. The
contractor should submit in the SSHP plans and procedures, including
materials and supplies, for safely and effectively opening the tanks,
cleaning all surfaces of the interior of the tanks, and disposing of
the sludge and decontamination fluids.
Restrictions include the following:
(1) No volatile organic solvents should be permitted for
decontamination procedures.
(2) The Implementing Agency must be consulted to determine if any
requirements exist for determining when the tank is considered
clean.
(3) No personnel should be permitted to enter any of the storage
tanks at any time except by following the confined space
guidelines as provided in Appendix E of this manual or unless
the tank ends have been removed.
Refer to Chapter 14 for sludge removal and tank cleaning procedures.
Collect and dispose of decontamination fluids as outlined in Chapter
9.
h. Free-Product Removal. Many times during tank removals, the
excavation area fills up with free product and/or water. Remove this
product and water prior to tank removal or soil excavation. Refer to
Chapter 5 for installation of monitoring wells in free product,
Chapter 6 for sampling free product, and Chapter 15 for free product
procedures.
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i. Tank Ballast Pads. Concrete ballast pads and associated hold down
straps are installed to counteract buoyant forces in high groundwater
areas. Ballast pads are difficult and expensive to remove. Concrete
ballast pads may be left in place under most circumstances unless
significant contamination is present and it cannot be remediated by
in-situ methods, or the user requires the pads removal.
13-3.
Tank Disposal.
a.
Tank Storage.
(1) Label tanks if they will be stored prior to disposal. Label
after removal from the ground but prior to removal from the
site.
Label requirements include the following:
(a) Regardless of the condition of the tank, the label should
contain a warning against certain types of reuse.
(b) The former contents and present vapor state of each tank,
including vapor-freeing treatment and date should be
indicated.
(c) The label should be similar to the following in legible
letters at least two (2) inches high:
TANK HAS CONTAINED LEADED GASOLINE*
NOT VAPOR FREE
NOT SUITABLE FOR STORAGE OF FOOD OR
LIQUIDS INTENDED FOR HUMAN OR ANIMAL
CONSUMPTION
DATE OF REMOVAL: MONTH/DAY/YEAR
*Or other flammable/combustible liquid.
example, DIESEL.
Use the applicable designation, for
(2) Tanks that have held leaded motor fuels (or whose service
history is unknown) should also be clearly labeled with the
following information (see API Publication 2015A for additional
guidelines):
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TANK HAS CONTAINED LEADED GASOLINE
LEAD VAPORS MAY BE RELEASED IF HEAT
IS APPLIED TO THE TANK SHELL
(3) Remove tanks from the excavation site as promptly as possible
after vapor-freeing and sludge removal procedures have been
completed, preferably on the day of tank removal from the
excavation. If a tank remains at the excavation site overnight
or longer, additional vapor may be released from any liquid
absorbed in the tank walls or residues remaining in the tank.
(4) Decontaminate the tank as indicated in Paragraph 13-2e and
Chapter 14 prior to removal from the excavation site. Check
with a CGI to ensure that the LEL does not exceed 10 percent of
the LEL and the oxygen content of the tank atmosphere is not
greater than 8 percent.
(5) Secure the tank on a truck for transportation to the storage or
disposal site with the 1/8-inch vent hole located at the
uppermost point on the tank. Tanks should be transported in
accordance with all applicable federal, state, and local
regulations.
(6) Store tanks in secured areas on the premises of persons familiar
with any attendant hazards and where the general public will not
have access. A fenced yard, separate from other facilities, is
preferred.
b.
Disposal Criteria.
(1) Tanks should not be reused. Whether sold to a scrap dealer or
disposed of at an approved facility, tanks must be cut into
small pieces smaller than 1.5m2 (16 ft2). The dissection can
occur at the excavation site, at a centrally located contractor
staging area, or at a licensed tank decommissioning/disposal
facility. The contractor should submit the dissection method
and location as part of the work plan.
(2) Tanks that have been lined internally or coated externally with
epoxy-based or similar materials may not be accepted by scrap
13-17
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processors. Prior inquiries should be made as to the
requirements of the scrap processor.
c.
Disposal Procedures.
(1) After a tank has been vapor-freed, render it unsuitable for
future use as a storage tank by puncturing or cutting with
nonspark-producing methods. The USACE-recommended practice is
cutting tanks into sections no larger than 1.5 m2 (16 ft2).
Recycle or landfill only if scrap processors refuse to accept
the tank sections.
(2) Assign all tanks a unique identifier for all records and
reporting.
(3) Use a bill of sale to transfer tank ownership. This bill of
sale should be submitted with the Tank Closure Report discussed
in Chapter 1.
(4) Consult current federal, state, and local regulations prior to
disposal to determine if special procedures or preparations are
required.
(5) Physically clean metal tanks that are going to be sold as scrap
metal after they are inerted and cut open. Cleaning can consist
of high pressure or steam rinse, triple rinse, or
scraping/scrubbing. Methods are detailed in Chapter 14.
13-4. Waste Disposal and Recycling. Free product, sludge, and rinse waters
are typical wastes generated during tank removal. Federal, state, and local
requirements must be followed for proper disposal. Options for managing
wastes generated during tank removal will be similar to those discussed in
section 12-4 regarding tank contents.
13-5. Tank Coating Issues. The exterior of metal USTs are frequently coated
with coal-tar type coatings. Historical data indicates that the coating
materials occasionally contain hazardous substances such as asbestos,
polychlorinated biphenyls, lead, and cadmium. The presence of PCBs and
asbestos make it difficult to recycle the tanks as scrap metal. If the
coating contains PCBs and/or asbestos that cannot be easily removed because of
regulatory constraints or safety issues, it may be more cost effective to
dispose of the tanks within a chemical waste landfill.
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CHAPTER 14
SLUDGE REMOVAL PROCEDURES
14-1. General. This chapter describes the removal procedure for any
remaining sludge in the underground storage tank (UST). This chapter
recommends but does not necessarily dictate the proper procedure for sludge
removal in any given situation. Typically, the contractor is responsible for
assessing specific situations for the most appropriate response.
14-2.
Operations, Procedures, and Instructions.
a.
Contractors, subcontractors, and employees responsible for sludge
removal should be familiar with:
(1) Confined space entry (confined space should be avoided if at all
possible).
(2) All safety rules and regulations (consult SSHP for specific
instruction/requirements).
(3) Use of equipment and procedures for removing tanks.
(4) Handling and disposal of the sludge likely to be encountered.
(5) API Publications:
2003, 2015, 2217, and 2219.
b. Documentation.
(1) Use field logbook to record all activities performed, personnel
contacted, dates and times when these activities were performed,
field conditions, and any unusual circumstances.
(2) Keep information factual and objective.
(3) Enter information not recorded in the logbook on field forms.
In either case, record the following information:
C
C
C
C
Site identification
Date and time specific activities took place
Personnel names
Field observations
Photographs are suggested. If photos are taken, record name of
photographer, site name, camera type and lens size, and general
direction for enclosure in the Tank Closure Report.
c. Procedures. Minimize activities requiring personnel entry into
tanks. However, when such entry is necessary, follow safety and
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health precautions for tank entry as outlined in Chapter 7 and
Appendix E, Confined Space Entry, including the additional
precautions necessary for tanks that have stored leaded gasoline.
(1) Remove sludge by various methods or by a combination of methods,
depending on the construction of the tank and the number and
size of shell openings. These methods are summarized in Table
14-1 and are discussed below. If at all possible, use
procedures that do not require tank entry.
(a) The preferred method of sludge removal is to remove the end
walls of the tank. Remove the sludge by flushing it from
the tank with a high-pressure, low-volume water stream,
collect, and containerize it. This method eliminates
problems with confined space entry, explosive atmospheres,
and allows easier cleaning of the tank. Any method of
removing residual material that minimizes the time that
workers must spend inside the tank contributes to the safety
of the operation.
(b) The tank may be swept and washed down with a water-hose
stream.
(c) The sludge may be washed or swept into piles and removed
from the tank with buckets or wheelbarrows.
(d) If necessary, any remaining liquids may be removed from the
tank with an absorbent, such as sawdust or spent clay, and
may be disposed of as a solid waste.
(e) Vacuum tank trucks provide a fast and efficient method for
removing and hauling sludge from tanks. Follow these
guidelines when using vacuum trucks:
C
Be sure the area in which the vacuum tank truck
operates is vapor-free.
C
Locate the truck upwind from the tank and outside
the path of probable vapor travel.
C
Consider vapor travel and sources of ignition where
sludge will be discharged from the vacuum truck
For specifics of vacuum truck safety precautions and
operation, refer to Chapter 12.
14-3. Waste Disposal and Recycling. Sludges that cannot be vacuumed should
be transferred to a lined, 55-gallon drum or another suitable container.
Small quantities of water may be added to the tank to facilitate removal.
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TABLE 14-1
PROCEDURES FOR SLUDGE REMOVAL
Procedure
Advantage
Disadvantage
Flushing with high
air pressure.
Minimizes confined
space activities.
Not labor intensive.
Requires an outlet at
the bottom of the
tank, or self-priming
pumps, or steam- or
water-operated
eductor. Increases
potential for static
charge buildup in the
nozzle, which could
trigger an explosion.
Flushing with water.
Same as above. No
special equipment is
required.
Same as above, with
the potential for
creation of even
larger waste
quantities.
Mechanically
sweeping or scraping
into piles and
removing with
buckets.
Minimizes waste
quantity. No special
equipment is
required.
Labor-intensive in a
confined space
environment.
Application of an
absorbent such as
sawdust or spent
clay.
Can be disposed as a
solid waste.
Effective for small
quantities or
residuals. Increases
waste quantity.
Material still has to
be mechanically
removed.
Vacuum truck.
Minimizes waste
quantity. Minimizes
confined space
activities. Not
labor-intensive.
Area of truck
operation must be
vapor-free.
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Test tank sludge for hazardous characteristics outlined in 40 CFR 261 Subpart
C. The test results determine the requirements for the final disposal. At
some installations, disposal services may be available through the local
Defense Reutilization and Marketing Office (DRMO). This typically involves
completion of a turn-in document for each container of hazardous waste as well
as coordination either directly with the DRMO Contracting Officer
Representative or coordination via the installation environmental office.
Suggested disposal methods include cement kilns, incineration,
solidification, landfill disposal, or shipment to a temporary storage and
disposal facility.
Options for recycling of petroleum tank sludges are similar to those discussed
in Section 12-4.
14-4.
Reporting and Documentation Requirements-Hazardous Waste.
a. Notification and Application. All facilities that generate, store,
transport, treat, or dispose of hazardous wastes must file a form
notifying the EPA. Unless notification has been given to EPA, waste
may not be stored, transported, treated, or disposed. All facilities
that store, treat, or dispose of sludge must apply for an EPA permit.
b. Development of a Plan. Each facility that generates sludge must
develop a plan for the storage, treatment, and disposal of its
sludge. If storage, treatment, or disposal is to occur onsite, the
facility is then considered to be the operator of a hazardous-wastemanagement facility and must obtain a permit to operate such a
facility. A plan must, therefore, be developed to operate the
facility. If the facility decides to dispose of the sludge offsite,
no permit is required as long as the facility stores the material in
appropriate containers and ships it offsite within 90 days of
generation; however, 40 CFR 262.34 specifies storage requirements
before shipment.
c. Shipping Hazardous Waste. Before shipping RCRA hazardous waste to an
offsite facility, the facility that generated the waste is required
to prepare and sign a manifest that identifies the facility,
identifies the waste by its EPA and DOT hazardous waste number and
name, identifies the offsite facility that will handle the material,
and specifies the total quantity in the shipment. The facility
should be certain that the transporter and the selected facility have
EPA identification numbers and permits to engage in hazardous-wastemanagement activities.
d. Documentation. The regulations impose extensive recordkeeping and
reporting requirements. Facilities that generate sludge must
maintain copies of all manifest documents and records and must also
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submit annual reports. Additional reporting requirements are
detailed in 40 CFR 262, Subpart D and 40 CFR 268.7.
e. Requirements for Transporters. Persons engaged in the offsite
transportation of the sludge must comply with EPA's specific
regulations for the transportation of hazardous wastes, which govern
notification, manifest, and recordkeeping. Persons transporting the
sludge must also comply with the DOT regulations set forth in 49 CFR.
f. State Programs. RCRA authorizes the states to conduct their own
hazardous-waste programs in lieu of the federal RCRA program. Any
state whose program has been approved by EPA may itself carry out the
functions delegated to EPA under the act and may specify additional
and more rigorous requirements. Consequently, facilities that
generate sludge and who plan to dispose of sludge should have their
plans reviewed by their state's environmental agency to ensure
compliance.
g. Specific Facility Standards. Specific requirements governing
storage, treatment, and disposal of hazardous wastes are updated
continually by EPA, and operators should consult the most up-to-date
publications for details about items such as security, monitoring,
contingency plans, and emergency procedures.
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CHAPTER 15
SOIL REMOVAL,
FREE-PRODUCT REMOVAL, AND BACKFILLING PROCEDURES
15-1. General. This chapter discusses the procedures for excavation of soils
and any associated free product when small quantities of hydrocarboncontaminated soils require treatment or disposal. An example is removal of
soils when small releases have occurred and are confined to the tank
excavation; these soils can be removed or treated onsite. The amount of soil
to be removed is dictated by the volume of released hydrocarbon, the depth and
area of liquid hydrocarbon penetration, the ease with which the soil can be
removed and properly treated, available funding, and the state or local
regulatory requirements.
This guidance is only intended for removing small, reasonable amounts of
contaminated soil and free product in the excavation. Refer to Chapter 5 for
the definition of contaminated soil. If it appears that extensive
contamination is present that cannot be cleaned up by the provisions described
in this EM, the reader should proceed with corrective action plan procedures.
15-2.
Precautions.
Keep the following precautions in mind:
a. Petroleum-contaminated soil may be flammable or combustible and can
be a source of potentially explosive vapor. Care must be taken, both
during and following excavation, that vapor or liquid from the soil
is not allowed to accumulate in a confined area and pose a fire or
explosion hazard.
b. Digging should be done with extreme care to avoid sparking from
stones and igniting the product.
c. Equipment should operate slowly, with due regard for the danger of
explosion. In certain circumstances, moving the earth may ventilate
the saturation area sufficiently to relieve the vapor concentration,
allowing movement and activity to proceed safely.
d. If the soil is to be stored onsite after excavation, cover or store
in a bermed or otherwise contained area (such as stored on and
covered by polyethylene sheets) so that leached petroleum product
cannot be released into surrounding soil, surface water, or
groundwater.
e. The contractor should have spill response materials available as
required by guide spec 02120 referenced in paragraph 1-4.
f. Offsite transport and disposal of contaminated soil must be in
accordance with state and local regulations. Excavation of
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contaminated soil creates increased exposure potential for site
personnel, the public, and the environment.
g. In confined spaces, air-vapor concentrations should be monitored to
ensure that hazardous levels are not reached.
15-3.
Equipment.
a. Soil. Transportation of contaminated soil requires conventional
earth-moving equipment.
Many types of equipment are available for excavation, loading, and
removal of soils. Standard construction equipment is typically
employed, but consider factors such as safety, depth of
contamination, and soil stability. Backhoes with 0.38 m3 (0.5 CY)
capacity have a maximum reach of 8 meters (26 feet) and a maximum
excavation depth of 5 meters (16 feet). Larger backhoes with 2.7 m3
(3.5 CY capacity) have the ability to remove soils at depths of up to
14 meters (45 feet) at maximum digging angles of 45 degrees.
The major hauling cost factor is the distance to the disposal
facility. Site-specific conditions, community and interstate
relations, and regulatory measures affect disposal costs. In some
states the contaminated soils are considered a special hazardous
waste and must be handled, hauled, and disposed of accordingly.
b. Free Product. Free product may be removed using positive
displacement pumps or vacuum trucks. In some instances, if the
amount of free product is small, absorbent booms may be used to
collect the product. Additional guidance on the recovery of free
product may be found in EPA/510/R-96/001.
15-4.
Soil Removal.
Excavation guidelines include the following:
a. Excavate the hole downward and outward in consultation with the
governing agency or Environmental Coordinator.
b. Proceed until all the soils contaminated above regulatory limits have
been removed or until a reasonable amount of excavation has occurred.
The designer should specify a maximum cubic yardage of contaminated
soil excavation from each tank area without prior approval from the
contracting officer's representative (COR). If a minimum additional
amount of contaminated soil requires removal to result in a clean
closure, the contractor will obtain approval from the COR to perform
the additional excavation. The bid form can identify a minimum
quantity of soil to be removed with a second quantity of soil to
cover a worst-case scenario.
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c. Perform appropriate verification testing in accordance with the IA
requirements if widespread contamination is present.
d. Backfill the excavation with clean fill. Clean fill is typically
defined as fill that has no evidence of contamination, or has
contamination levels below regulatory limits. The IA must be
consulted to define the requirements of clean fill.
e. See Chapter 16 for more details. These excavations will be done
safely according to the local codes and regulations governing safe
excavations and EM 385-1-1 and 40 CFR 1926.650–1926.653. Table 15-1
provides an estimated quantity of soil that is typically removed from
an UST excavation based on tank size.
f. Contaminated Soil. If the soil in the excavation is contaminated,
follow these steps:
(1) Prepare an area to store the excavated soil. This can be
achieved by placing 6-mil or heavier polyethylene sheeting on
the ground and placing excavated soil on top. This prevents
contaminants in the excavated soils from migrating into the
uncontaminated soils.
(2) Cover this stockpile after work each day by a similar sheet of
polyethylene to protect the excavated soils from infiltration
due to precipitation and to help contain vapors released.
(3) Make provisions to divert surface runoff from soil stockpiles,
as well as surface runon, to reduce the amount of contaminated
water.
(4) An alternative method, and in some areas a requirement, is to
place the excavated soils directly into 55-gallon drums.
Coordinate with the local implementing agency regarding approved
stockpiling procedures.
g. Sampling. After tank removal has been completed, the soil in the
bottom of the excavation should be sampled according to federal and
state requirements.
(1) Take these samples, at a minimum, from the bottom of the
excavation from the end locations of the tanks (see Chapter 6).
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TABLE 15-1
Estimated Quantity of Soil to be Removed by Tank Size (Average)
15-4
Tank Size
liters (gallons)
Tank Diameters
meters (feet)
Tank Length
meters (feet)
Excavation Size
cubic meters (Bank CY)
Volume of Tank
CM (CY)
Estimated Soil Excavated
CM (Bank CY)
1,890 (500)
1.22 (4.00)
1.83 (6.00)
31 (40)
2.13 (2.79)
28.5 (40)
3,780 (1,000)
1.22 (4.00)
3.50 (11.50)
46 (60)
11.41 (5.35)
40.5 (55)
7,570 (2,000)
1.93 (6.33)
2.80 (9.17)
61 (80)
8.18 (10.70)
52.0 (70)
11,350 (3,000)
1.93 (6.33)
4.17 (13.67)
76 (100)
12.18 (15.93)
65.5 (85)
15,140 (4,000)
1.93 (6.33)
5.18 (17.00)
92 (120)
15.15 (19.81)
76.0 (100)
18,925 (5,000)
2.44 (8.00)
4.32 (14.17)
103 (135)
20.16 (26.37)
84.0 (110)
22,700 (6,000)
2.44 (8.00)
5.05 (16.58)
115 (150)
23.60 (30.87)
93.0 (120)
30,280 (8,000)
2.44 (8.00)
6.73 (22.08)
145 (190)
31.43 (41.11)
113.0 (150)
37,850 (10,000)
2.90 (9.50)
6.02 (19.75)
165 (215)
39.64 (51.85)
124.0 (160)
45,420 (12,000)
2.90 (9.50)
6.91 (22.67)
183 (240)
45.50 (59.51)
137.0 (180)
56,780 (15,000)
2.90 (9.50)
9.07 (29.75)
230 (300)
59.71 (78.10)
168.0 (220)
75,700 (20,000)
2.90 (9.50)
11.51 (37.75)
279 (365)
75.77 (99.10)
202.5 (265)
Assumptions:
1.
2.
3.
4.
5.
Amount of fill over tank is 1 meter (3 feet).
Soil around perimeter of tank to be excavated is 1 meter (3 feet) (the width of a backhoe bucket).
Stained soil under tank extends down 0.7 meters (2 feet).
Tank volume calculation does not account for domed ends.
Formula for excavation size:
((tank diameter + 5ft)*(tank length + 6 ft)*(tank diameter + 6 ft))/27 CF/CY (Conversion from CY to CM is 0.76455).
6. Formula for tank volume:
(Tank length*pi*tank diameter^2/4)/27CF/CY
(Conversion from CY to CM is 0.76455).
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(2) Take samples with a backhoe and containerize in small vessels,
such as a plastic bag or jar for field testing as detailed in
Chapter 6. These tests will characterize the extent of
contamination and subsequent excavation and help in the
segregation of clean and uncontaminated soils. It must be noted
that these field tests are not a substitute for the laboratory
analytic tests that must be done. Field tests are used to
differentiate between clean soils and those that are suspected
to be contaminated.
(3) Submit samples for analytic tests. Laboratory confirmation
based on samples collected from excavation bottoms and soil
stockpiles is necessary in most states to confirm clean closure.
Check with the IA for specific requirements.
h. Landfilling Requirements. A common remedial action for excavated
soils has been disposal in landfills. Varying interpretations exist
regarding classification of hydrocarbon-contaminated soils as
hazardous or nonhazardous. Levels of contaminants allowable for
landfilling under applicable regulations must be determined in
developing a sound disposal strategy.
i. Onsite Treatment. Various treatment and disposal options for
excavated soil containing petroleum hydrocarbons are available but
decisions must be based on and in accordance with state and local
regulations. Treatment of soils may require an air permit for
volatile organic compounds from the state agency that has
jurisdiction. The methods of onsite treatment and soil replacement
discussed below can be viable if approved by the regulatory agencies.
Refer to EPA/530/UST-88/001 for additional information.
(1) Land treatment (landfarming). Land treatment is a process by
which contaminated soils are removed and spread over an area to
enhance naturally occurring processes such as biodegradation and
volatilization. A centralized location, such as a landfill,
airfield, or other isolated location should be used for land
treatment.
(2) Aeration/enhanced volatilization. Soil aeration by mixing and
exposure to air can reduce hydrocarbon concentrations to
acceptable levels. This process may be as simple as overturning
the soils with excavation equipment, tillers, or shakers to
increase volatilization or enhancing vapor removal by forced or
passive venting with an engineered venting system.
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(3) Thermal treatment. Incineration and high temperature stripping
of residual hydrocarbons are methods employed in some
circumstances for the onsite treatment of soils. Treatment
costs and local air quality regulations are major factors
controlling the use of these techniques. Examples of thermal
treatment technologies include low-temperature thermal
desorption or asphalt kilns. When an asphalt kiln is used, the
unit should be proven clean prior to processing any soil.
(4) Isolation/containment. Isolation/containment is a process in
which the impacted soils are isolated through the use of caps,
slurry walls, grout curtains, or cutoff walls.
(5) Soil slurry bioreactor. The soil-slurry-bioreactor process
entails mixing a variety of agents into the soil to encourage
microbial activity.
j. Asphalt Incorporation. Asphalt incorporation is a process whereby
soils containing residual hydrocarbons are incorporated into hot
asphalt mixes as a partial substitute for aggregates. During the
heating of the mixture, the more volatile components are vaporized,
and the remaining compounds are incorporated into the asphalt
mixture. This alternative is normally a viable disposal option only
when an asphaltic paving project is ongoing within the project area.
An active project is normally necessary to lead to a demand for the
contaminated soil material as an asphalt admixture.
k. Excavation Liner. In some instances, a 6-mil liner is placed in the
excavation and then the contaminated soil is placed back in the
excavation. Check with the IA prior to using this method.
15-5. Free-Product Removal. Free product should be removed, not for
remediation purposes, but to prevent further damage to the environment. If
possible, the excavation should be sloped to allow pooling of the free
product. A pump or vacuum truck can then be used to remove the free product
from the excavation. Refer to Chapter 12 for operation of product removal
equipment and waste disposal.
15-6. Backfill, Compaction, and Testing.
a. Backfilling.
(1) Coordinate with the customer concerning the option of leaving
excavations open pending the return of laboratory test results.
Laboratory turn-around time plays a critical role in the
duration that an excavation must be left open. If field
analysis is allowed by the regulatory authority, this will
reduce or eliminate turn-around time concerns.
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(2) Secure open excavations and stockpile areas while awaiting
confirmation test results.
(3) Backfill excavations immediately after confirmation test results
have been approved. If contaminated material removal is part of
a larger project, suitable backfill material, as well as topsoil
and grading requirements are specified in CEGS 02221-Excavating,
Filling, and Backfilling for Buildings or CEGS 02222-Excavating,
Filling and Backfilling for Utility Systems.
In situations
that involve only tank removal, grading, backfill, and
compaction should be addressed in CEGS 02115-Removal of
Underground Storage Tanks. Special information concerning
allowable contaminant levels should be included in those
specifications if used.
b. Backfill Material. In many cases, the degree of engineering control
of the materials used as backfill may not need to be as stringent as
described below.
In other cases, such as under pavements, special
compaction and material requirements may apply, and the
specifications will need to be revised to address these special
requirements or another specification section should be referenced.
(1) Obtain backfill material from a location defined by the user or
if using an off-site source, verify through analytical testing
to ensure contamination is not present above regulatory levels
for suitable backfill.
(2) Test off-site backfill for contamination in accordance with CEGS
01450-Chemical Data Quality Control. Backfill should be
classified in accordance with ASTM D 2487 as GW, GP, GM, GC, SW,
SP, SM, SC, MH, CL, or CH and should be free from roots and
other organic matter, trash, debris, snow, ice or frozen
materials. If off-site backfill is used, soil classification
test results should be approved prior to bringing the material
on-site.
(3) Test backfill material for Atterberg limits ASTM D 4318, grainsize distribution, and compaction characteristics ASTM D 698,
ASTM D 1557 at a frequency of once per 3,000 cubic meters (3,000
cubic yards) or a minimum of one test per borrow source. Offsite backfill should not be used until chemical and physical
test results have been submitted and approved.
c. Compaction.
(1) Place approved backfill in developed areas in lifts with a
maximum loose thickness of 200 mm (8 inches), compacted to 90
percent maximum dry density for cohesive soils, or 95 percent
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maximum dry density for cohesionless soils in accordance with
ASTM D 698 or D 1557.
(2) Perform density tests at a frequency of once per 930 square
meters (10,000 square feet) per lift. A minimum of one density
test should be performed on each lift of backfill placed. In
open areas without special compaction requirements, a maximum
density of 85 percent using 300-mm (12-inch) lifts will be
acceptable. A method specification is also frequently used in
which a prescribed number of passes using a specified piece of
equipment is required.
d. Density Testing. Determine field in-place dry density in accordance
with ASTM D 1556, ASTM D 2167, or ASTM D 2922. If ASTM D 2922 is
used, a minimum of one in ten tests must be checked using ASTM D 1556
or ASTM D 2167.
15-7. Special Waste Requirements. Though petroleum-contaminated soils that do
not exhibit a RCRA hazardous waste characteristic are not subject to hazardous
waste regulation, many states may still regulate them as “special wastes.”
Typically, these soils are either placed in special waste management units or
are treated to below certain concentration levels before final disposal.
Implementing agencies may also be able to assist in identifying any special
handling requirements. Consult individual state regulations. A list of
contacts is provided in Appendix B.
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CHAPTER 16
SITE RESTORATION PROCEDURES
16-1. General. This chapter identifies procedures and sources of information
you will find helpful when selecting the appropriate corrective action for a
particular UST site. Both soil and water contamination are addressed using
in-situ and ex-situ remediation options. Contact the facility coordinator to
determine unique site-specific requirements.
16-2. Soil Remediation Processes. Studies in the literature use different
nomenclature to describe remediation methods. A recent EPA study classified
the primary technologies into five categories.
a. In-Situ Treatment. In-situ treatment includes technologies such as
vapor extraction, volatilization, air/vacuum extraction, in-situ soil
venting, in-situ bioremediation, isolation/containment, and passive
remediation.
b. Landfilling.
disposal.
This method includes all options using landfill
c. Land Treatment. Land treatment includes landfarming, ex-situ
bioremediation, land application, land spreading, passive aeration,
aeration, and ex-situ soil venting.
d. Thermal Treatment. Thermal treatment includes incineration, lowtemperature thermal stripping, and treatment in asphalt plants.
e. Other. This category encompasses all other technologies such as soil
washing, solidification/stabilization, or other technologies that do
not fit into the other categories listed.
f. Selected references are as follows:
(1) Pope and Matthews. Bioremediation Using the Land Treatment
Concept, EPA 600/R-93/164. August 1993.
(2) Bioventing Performance and Cost Summary.
Environmental Excellence. July 1994.
Air Force Center for
(3) Guide for Conducting Treatability Studies Under CERCLA:
Biodegradation Remedy Selection, EPA/540/R-93/519a. August 1994.
(4) “Quick Reference Fact Sheet.” Guide for Conducting Treatability
Studies Under CERCLA: Biodegradation Remedy Selection,
EPA/540/R-93/519b. August 1994.
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(5) Leeson, A. and Hinchee, R.E., et al. “Principles and Practices
of Bioventing.” Volume 1: Bioventing Principles EPA/540/R-95/534a
Columbus: Battelle Memorial Institute.
(6) Leeson, A. and Hinchee, R.E., et al. “Principles and Practices
of Bioventing.” Volume 2: Bioventing Design EPA/540/R-95/534b.
Columbus: Battelle Memorial Institute.
(7) Technologies and Options for UST Corrective Actions: Overview of
Current Practice, EPA/542/R-92/010. August 1992.
(8) U. S. Air Force Remediation Handbook for POL-Contaminated Sites,
U. S. Air Force. December 1993.
(9)
Soil Vapor Extraction and Bioventing, EM 1110-1-4001.
g. Survey of Remediation Practices. The findings from a 1992 22-state
survey (EPA/542/R-92/010) of petroleum-contaminated soil
treatment/disposal practices revealed landfilling as the primary
corrective action method used at 55 percent of the sites surveyed,
followed by in-situ treatment at 19 percent, thermal treatment at 13
percent, land treatment at 11 percent, and other technologies at 2
percent.
Thermal treatment using asphalt plants was used at 61 percent of the
sites, followed by low-temperature thermal treatment at 39 percent
and incineration at less than 1 percent of the sites.
Land treatment corrective action sites most often used aeration (50
percent), followed by land farming (36 percent), and land application
(13 percent).
Approximately 37 percent of the corrective action sites reported
required some sort of groundwater corrective action as well.
Information addressing remediation of groundwater sources is included
in paragraph 16-4.
16-3. Backfill. Begin backfilling only after authorization from the
Environmental Coordinator or IA and after the excavation area contaminants are
determined to be below the remediation concentrations. This authorization
should be issued within 24 to 48 hours after excavating is complete to allow
time for laboratory analysis of the soils. Some exceptions should be noted,
such as IA regulations and proximity to residential areas or other areas with
restricted access.
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a. Methods. Individual site conditions will determine the methods of
backfill. Some of the options are detailed below.
(1) Backfill clean holes (as determined by lab analyses) with clean
fill.
(2) Leave potentially contaminated holes open until confirmation
sampling results have been obtained.
(3) Backfill potentially contaminated holes with granular backfill
while awaiting analytical results in areas where safety is a
concern.
(4) Place polyethylene liner in contaminated holes prior to
backfilling.
(5) Backfill all holes with granular backfill regardless of
contamination.
(6) Leave heavily contaminated holes open. The IA and the
Environmental Coordinator must be contacted to determine the
best option for the site.
b. Backfill.
(1) Use backfill as specified in CEGS Section 02315-Excavation,
Filling, and Backfilling for Buildings or Section 02316Excavation, Filling, and Backfilling for Utilities Systems.
(2) Perform density tests by an approved commercial testing
laboratory or by facilities furnished by the contractor.
(3) Determine moisture density relations in laboratory tests in
accordance with ASTM D 1557, Method B, C, or D or ASTM D 3017.
(4) Determine field in-place density in accordance with ASTM D 1556,
ASTM D 2167, or ASTM D 2922.
(5) Material. The source of backfill material must be determined to
be free of contamination through chemical analysis prior to
placement of clean fill in the excavated area.
(6) Exceptions. If the soil excavation sample results indicate the
site is not remediated, yet the limits of practical excavation
have been reached, place a 6-mil or heavier polyethylene
sheeting in the hole prior to backfilling. This polyethylene
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sheeting will allow clean backfill placed in the hole to remain
free of contamination.
c. Grading. All areas disturbed by construction must be uniformly
smooth graded. The finished surface should be reasonably smooth,
compacted, free from irregular surface changes, and maintained free
of trash. Prepare surface for seeding or asphalt/concrete as
required and specified in applicable USACE guide specifications.
16-4. Groundwater Remediation Processes. This section presents corrective
action technologies for the removal of free product and for remediation of
petroleum-contaminated groundwater.
a. Free-Product Recovery. There are typically two approaches for
recovery of free product: trench systems and wells. The choice is
usually based on site specific conditions. After collection, the
free product is separated from the groundwater and disposed of or
recycled. The remaining petroleum-contaminated groundwater is
treated using a variety of methods and discharged to a publicly owned
treatment works (POTW) or discharged to the environment. Specific
technologies include skimmers, oleophilic-hydrophobic separators,
free-product recovery with water table depression, vapor
extraction/groundwater extraction, dual phase (liquid and vapor)
recovery, and oil-water separation. Whichever option is selected, a
permit to discharge must be negotiated with the IA.
b. Groundwater Remediation. Groundwater remediation can be accomplished
either in-situ or ex-situ depending on the site characteristics. Insitu methods are preferred, if possible, and include such methods as
air sparging, intrinsic remediation, and introduction of oxygen or
nutrients.
The second, more conventional ex-situ methods include conventional
pump-and-treat processes such as granular activated carbon (GAC) and
air stripping, which are easily mobilized and readily available from
a variety of suppliers in close proximity to most sites. Many times
air stripping and GAC are used together to prolong the life of the
carbon. Other options for ex-situ treatment include ultraviolet
oxidation, biological treatment, or simply discharging to a POTW.
c. Selected references are as follows:
(1) Cleanup of Releases From Petroleum USTs: Selected Technologies,
EPA/530/UST-88/001. April, 1988.
(2) Diagnostic Evaluation of In-Situ SVE-Based System Performance,
EPA/600/R-96/041, NTIS PB96-163537. March, 1996.
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(3) Engineer Design of Free-Product Recovery Systems,
EPA/600/R-96/031, NTIS PB96-153556. 1996.
(4) How to Effectively Recover Free Product of Leaking UST Sites,
EPA/510/R-96/001. September, 1996.
(5)
In-situ Air Sparging, EM 1110-1-4005
(6) In-Situ Air Sparging: Evaluation of Petroleum Industry Sites and
Considerations for Applicability, Design and Operation, API
Publication Number 4609. American Petroleum Institute. April, 1995.
(7) In-Situ SVE-Based Systems for Free-Product Recovery and Residual
Hydrocarbon Removal, EPA/600/R-96/042, NTIS PB96-163605. 1996.
(8) Remediation Technologies Screening Matrix and Reference Guide,
EPA/542/B-94/013, NTIS PB95-104782. October, 1994.
(9) Rifai, H.S. “Modeling Natural Attenuation Using Bioplume II/III
Model,” Presentation at the U.S. Air Force Center for Environmental
Excellence, Environmental Restoration Technology Transfer Symposium.
November, 1994.
(10) Standard Guide for Corrective Action for Petroleum Releases,
ASTM E 1599. 1994.
(11) Standard Guide for Risk Based Corrective Action Applied at
Petroleum Release Sites, ASTM E 1739. 1995.
(12) Test Plan and Technical Protocol for Bioslurping. AFCEE,
Technology Transfer Division. Draft copy. January 30, 1994.
(13) Technical Protocol for Implementing the Intrinsic Remediation
with Long-Term Monitoring Option for Natural Attenuation of
Dissolved-Phase Fuel Contamination in Groundwater. AFCEE. 1994.
(14) Soil Bentonite Slurry Trench Cutoff, Corps of Engineers Civil
Works Guide Specification (CWGS) 02214.
(15) Chemical Feed Systems, Corps of Engineers Guide Specification
(CEGS) 11242.
(16)
Water Softeners, Cation Exchange (Sodium Cycle), CEGS 11250.
(17)
Air Stripping Systems, CEGS 11301.
16-5
EM 1110-1-4006
30 SEP 98
(18) Prefabricated Biochemical Wastewater Treatment Plant, CEGS
11390.
(19)
Low Permeability Clay Layer, CEGS 02377.
(20)
Soil-Bentonite Slurry Trench for HTRW Projects, CEGS 02260.
(21) Solidification/Stabilization of Contaminated Material, CEGS
02160.
(22)
Groundwater Monitoring Wells, CEGS 02522.
(23)
Piping; Off-Gas, CEGS 02150.
(24)
Fans/Blowers/Pumps; Off-Gas, CEGS 11215.
(25)
Downflow Liquid Activated Carbon Adsorption Units, CEGS 11225.
(26)
Chemical Feed Systems, CEGS 11242.
(27)
Air Stripping Systems, CEGS 11301.
(28)
Plate and Frame Filter Press System, CEGS 11360.
(29)
Filtration System, CEGS 11393.
(30)
Vapor Phase Activated Carbon Adsorption Units, CEGS 11226.
(31)
Advanced Oxidation Processes (AOP), CEGS 11377.
(32)
Thermal (Catalytic) Oxidation Unit, CEGS 11378.
16-5. Waste Disposal.
and 14.
Disposal requirements are identified in Chapters 12
16-6
EM 1110-1-4006
30 SEP 98
APPENDIX A
REFERENCES
a.
Required Publications.
FAR 52.236-13
Accident Prevention
Code of Federal Regulations
29 CFR 1910
General Industry Standards
29 CFR 1910.120
Hazardous Waste Site Operations and Emergency
Response
29 CFR 1926
Construction Industry Standards
40 CFR 260
Hazardous Waste Management System:
40 CFR 261
Identification and Listing of Hazardous Waste
40 CFR 262
Standards Applicable to Generators of Hazardous
Waste
40 CFR 263
Standards Applicable to Transporters of Hazardous
Waste
40 CFR 266
Standards for the Management of Specific Hazardous
Wastes and Specific Types of Hazardous Waste
Management Facilities
40 CFR 268
Land Disposal Restrictions
40 CFR 280
Technical Standards and Corrective Action
Requirements for Owners and Operators of
Underground Storage Tanks (UST)
49 CFR Subtitle B
Chapter I Research and Special Programs
Administration, Department of Transportation
(Parts 100-199)
A-1
General
EM 1110-1-4006
30 SEP 98
49 CFR Subtitle B
Chapter III Federal Highway Administration,
Department of Transportation (Parts 390-399)
Environmental Protection Agency (EPA)
EPA QA/G-5
EPA Guidance for Quality Assurance Project Plans
EPA QA/R-5
EPA Requirements for Quality Assurance Project Plans
for Environmental Data Operations
EPA/510/B-97/001
Expedited Site Assessment Tools for Underground
Storage Tank Sites
EPA/510/B-97/004
List of Leak Detection Evaluations for UST Systems
EPA/510/R-96/001
How to Effectively Recover Free Product At Leaking
Underground Storage Tank Sites
EPA/530/UST-88/001 Cleanup of Releases from Petroleum USTs:
Selected Technologies
EPA/530/UST-90/004 Standard Test Procedures for Evaluating Leak
Detection Methods: Volumetric Tank Tightness
Testing Methods
EPA/530/UST-90/005 Standard Test Procedures for Evaluating Leak
Detection Methods: Nonvolumetric Tank Tightness
Testing Methods
EPA/530/UST-90/101 Standard Test Procedures for Evaluating Leak
Detection Methods: Pipeline Leak Detection Systems
EPA/530/SW-89-031
RCRA Facility Investigation (RFI) Guidance
EPA/540/G-91/009
Management of Investigation-Derived Wastes During
Site Inspections
EPA/540/P-87/001
A Compendium of Superfund Field Operations Methods
EPA/540/P-91/005
Compendium of ERT Surface Water and Sediment
Sampling Procedures
A-2
EM 1110-1-4006
30 SEP 98
EPA/540/P-91/007
Compendium of ERT Groundwater Sampling Procedures
EPA/540/P-91/008
Compendium of ERT Waste Sampling Procedures
EPA/540/R-93/519
Guide for Conducting Treatability Studies Under
CERCLA: Biodegradation Remedy Selection
EPA/540/R-95/534
Principles and Practices of Bioventing
EPA/540/S-93/503
Groundwater Issue (Feb. 93); Suggested Operating
Procedures for Aquifer Pumping Tests
EPA/540/2-91/003
Soil Vapor Extraction Technology Reference Handbook
EPA/542/B-94/013
Remediation Technologies Screening Matrix and
Reference Guide
EPA/542/R-92/010
Technologies and Options for UST Corrective Actions:
Overview of Current Practice
EPA/600/2-80/018
Samplers and Sampling Procedures for Hazardous
Waste Streams
EPA/600/7-84/064
Geophysical Techniques for Sensing Buried Wastes and
Waste Migration
EPA/600/2-86/001
Underground Tank Leak Detection Methods: A State-ofthe-Art Review
EPA/600/2-90/011
Assessing UST Corrective Action Technologies: Site
Assessment and Selection of Unsaturated Zone
Treatment Technologies
EPA/600/4-84/076
Characterization of Hazardous Waste Sites-A Methods
Manual: Volume II. Available Sampling Methods
EPA/600/8-87/036
Soil Gas Sensing for Detection and Mapping of
Volatile Organics
EPA/600/R-96/031
UST Corrective Action Techologies: Engineering
Design of Free-Product Recovery Systems
A-3
EM 1110-1-4006
30 SEP 98
EPA/600/R-96/041
Assessing UST Corrective Action Technologies:
Diagnostic Evaluation of In-Situ SVE-Based System
Performance
EPA/600/R-96/042
In-Situ SVE-Based Systems for Free-Product Recovery
and Residual Hydrocarbon Removal
EPA/625/9-89/009
Volumetric Tank Testing: An Overview
EPA/625/R-92/007
Use of Airborne, Surface, and Borehole Geophysical
Techniques at Contaminated Sites: A Reference
Guide
EPA/600/R-93/164
Bioremediation Using the Land Treatment Concept
EPA 600/4-79-020
Methods for Chemical Analysis of Water and Waste
(1983)
EPA SW-846
Test Methods for Evaluation of Solid Waste (1986)
(including all promulgated updates)
Department of the Air Force
Air Force Institute (AFI) 32-4002 Hazardous Material Emergency Planning
and Response Compliance
Air Force Institute (AFI) 32-7002 Environmental Information Management
System
Remediation Handbook for POL-Contaminated Sites (December 1993)
Technical Protocol for Implementing the Intrinsic Remediation with
Long-Term Monitoring Option for Natural Attenuation of Dissolved-Phase
Fuel Contamination in Groundwater, AFCEE (1994)
Test Plan and Technical Protocol for Bioslurping, AFCEE
Bioventing Performance and Cost Summary, AFCEE
Department of the Army
AR 200-1
Environmental Protection and Enhancement
A-4
EM 1110-1-4006
30 SEP 98
AR 385-40
Accident Reporting and Records
ER 200-2-3
Environmental Compliance Policies
ER 385-1-92
Safety and Occupational Health Document Requirements
for Hazardous, Toxic, and Radioactive Waste
(HTRW) and Ordnance and Explosive Waste
(OEW) Activities
ER 1110-1-263
Chemical Data Quality Management for Hazardous,
Toxic, and Radioactive Waste Remedial Activities
ER 1180-1-6
Construction Quality Management
EP 200-2-3
Environmental Compliance Operations and Maintenance
Procedures
EP 415-1-260
Resident Engineer's Management Guide
EP 415-1-261
Quality Assurance Representatives Guide
EP 415-1-266
Resident Engineer’s Management Guide for
HTRW Projects
EM 200-1-1
Validation of Analytical Chemistry Laboratories
EM 200-1-2
Technical Project Planning (TPP) Process
EM 200-1-3
Requirements for the Preparation of Sampling and
Analysis Plans
EM 200-1-6
Chemical Quality Assurance for HTRW Projects
EM 385-1-1
Safety and Health Requirements Manual
EM 1110-1-1802
Geophysical Exploration for Engineering and
Environmental Investigations
EM 1110-1-1906
Soil Sampling
A-5
EM 1110-1-4006
30 SEP 98
EM 1110-1-4000
Monitoring Well Design, Installation, and
Documentation at Hazardous, Toxic and/or
Radioactive Waste Sites
EM 1110-1-4001
Soil Vapor Extraction and Bioventing
EM 1110-1-4005
In-Situ Air Sparging
CEGS 01351
Safety, Health, and Emergency Response
(HTRW/UST)
CEGS 01450
Chemical Data Quality Control
CEGS 02115
Underground Storage Tank Removal
CEGS 02120
Transportation and Disposal of Hazardous Materials
CEGS 02150
Piping; Off-Gas
CEGS 02160
Solidification/Stabilization of Contaminated
Material
CWGS 02214
Soil Bentonite Slurry Trench Cutoff
CEGS 02260
Soil-Bentonite Slurry Trench for HTRW Projects
CEGS 02315
Excavation, Filling, and Backfilling for Buildings
CEGS 02316
Excavation, Filling, and Backfilling for Utilities
Systems
CEGS 02377
Low-Permeability Clay Layer
CEGS 02522
Ground-water Monitoring Wells
CEGS 11215
Fans/Blowers/Pumps; Off-Gas
CEGS 11225
Downflow Liquid-Activated Carbon Adsorption Units
CEGS 11226
Vapor Phase Activated Carbon Adsorption Units
CEGS 11242
Chemical Feed Systems
A-6
EM 1110-1-4006
30 SEP 98
CEGS 11250
Water Softeners, Cation Exchange (Sodium Cycle)
CEGS 11301
Air Stripping Systems
CEGS 11360
Plate and Frame Filter Press System
CEGS 11377
Advanced Oxidation Processes (AOP)
CEGS 11378
Thermal (Catalytic) Oxidation Unit
CEGS 11390
Prefabricated Biochemical Wastewater Treatment
Plant
CEGS 11393
Filtration System
CEMP-RF
Memorandum
Policy Guide for Underground Storage Tanks (USTs)
on Formerly Used Defense Sites (FUDS), July 31,
1990
NIOSH/OSHA/
USCG/EPA
Occupational Safety and Health Guidance Manual for
Hazardous Waste Site Activities, October 1985
American National Standards Institute (ANSI)
ANSI Z-88.2
Respiratory Protection
American Petroleum Institute (API)
Publication 1628
A Guide to the Assessment and Remediation of
Underground Petroleum Releases
Publication 2015
Cleaning Petroleum Storage Tanks
Publication 2217
Guidelines for Confined Space Work in the Petroleum
Industry
Publication 2219
Safe Operation of Vacuum Trucks in Petroleum Service
Publication 4609
In-Situ Air Sparging: Evaluation of Petroleum
Industry Sites and Considerations for
Applicability, Design, and Operation
A-7
EM 1110-1-4006
30 SEP 98
Recommended
Practice 1604
Removal and Disposal of Used Underground Petroleum
Tanks
Recommended
Practice 1631
Interior Lining of Underground Storage Tanks
Recommended
Practice 2003
Protection Against Ignitions Arising out of Static,
Lightning, and Stray Currents
American Society for Testing and Materials (ASTM), Annual Book of ASTM
Standards, 100 Barr Harbor Dr., West Conshohocken, PA 19428-2959
D698
Standard Test Method for Laboratory Compaction
Characteristics of Soil Using Standard Effort
(12,400 ft-lbf/ft3 (600 kN-m/m3))
D1556
Standard Test Method for Density and Unit Weight of
Soil in Place by the Sand-Cone Method
D1557
Standard Test Method for Laboratory Compaction
Characteristics of Soil Using Modified Effort
(56,000 ft-lbf/ft3 (2,700 kN-m/m3))
D2113
Practice for Diamond Core Drilling for Site
Investigation
D2167
Standard Test Method for Density and Unit Weight of
Soil in Place by the Rubber Balloon Method
D2325
Standard Test Method for Capillary-Moisture
Relationships for Coarse- and Medium-Textured
Soils by Porous-Plate Apparatus
D2487
Standard Test Method for Classification of Soils for
Engineering Purposes
D2922
Standard Test Methods for Density of Soil and SoilAggregate in Place by Nuclear Methods (Shallow
Depth)
D3017
Standard Test Method for Water Content of Soil and
A-8
EM 1110-1-4006
30 SEP 98
Rock in Place by Nuclear Methods (Shallow
Depth)
D3152
Standard Test Method for Capillary-Moisture
Relationships for Fine-Textured Soils by
Pressure-Membrane Apparatus
D4044
Standard Test Method (Field Procedures) for
Instantaneous Change in Head (Slug Tests) for
Determining Hydraulic Properties of Aquifers
D4057
Standard Practice for Manual Sampling of Petroleum
Products
D4136
Standard Practice for Sampling Phytoplankton With
Water-Sampling Bottles
D4318
Standard Test Method for Liquid Limit, Plastic
Limit, and Plasticity Index of Soils
D4750
Standard Test Method for Determining Subsurface
Liquid Levels in a Borehole or Monitoring Well
D5088
Standard Practice for Decontamination of Field
Equipment Used at Nonradioactive Waste Sites
D5126
Standard Guide for Comparison of Field Methods for
Determining Hydraulic Conductivity in the
Vadose Zone
D5314
Standard Guide for Soil Gas Monitoring in the
Vadose Zone
D5358
Standard Practice for Sampling With a Dipper or Pond
Sampler
D5495
Standard Practice for Sampling With a Composite
Liquid Waste Sampler (COLIWASA)
D5608
Standard Practice for the Decontamination of Field
Equipment Used at Low-Level Radioactive Waste Sites
A-9
EM 1110-1-4006
30 SEP 98
D5730
Standard Guide to Site Characterization for
Environmental Purposes With Emphasis on Soil,
Rock, Vadose Zone, and Groundwater
D5737
Standard Guide for Methods for Measuring Well
Discharge
D5743
Standard Practice for Sampling Single or Multilayered Liquids, With or Without Solids, in Drums
or Similar Containers
D5781
Guide for the Use of Dual Wall Reverse-Circulation
Drilling
D5782
Guide for the Use of Direct Air Rotary Drilling
D5783
Guide for the Use of Direct Rotary Drilling With
Water-Based Drilling Fluid
D5784
Guide for the Use of Hollow-Stem Augers
D5831
Standard Test Method for Screening Fuels in Soils
D5872
Guide for the Use of Casing Advancement Drilling
Methods
D5875
Guide for the Use of Cable-Tool Drilling and
Sampling Methods
D5876
Guide for the Use of Direct Rotary Wireline Casing
Advancement Drilling Methods
D6001
Standard Guide for Direct Push Water Sampling for
Geoenvironmental Investigations
D6169
Standard Guide for Selection of Soil and Rock
Sampling Devices Used With Drill Rigs for
Environmental Investigations
D6286
Standard Guide for Selection of Drilling Methods for
Environmental Site Characterization
A-10
EM 1110-1-4006
30 SEP 98
E300
Standard Practice for Sampling Industrial Chemicals
E1599
Standard Guide for Corrective Action for
Petroleum Releases
E1739
Standard Guide for Risk-Based Corrective Action
Applied at Petroleum Release Sites
E1912
Standard Guide for Accelerated Site Characterization
for Confirmed or Suspected Petroleum Releases
PS78
Provisonal Standard Guide for Selecting Surface
Geophysical Methods
National Fire Protection Association (NFPA), Batterymarch Park,
Quincy, MA 02269
b.
30
Flammable and Combustible Liquids Code
70
National Electrical Code
70B
Electrical Equipment Maintenance
326
Procedure for Safe Entry of Underground Storage
Tanks
327
Standard Procedure for Cleaning or Safeguarding
Small Trucks and Containers
Related Publications.
Hazardous Liquid Pipeline Safety Act of 1979 (49 U.S.C.A. 2001, et
seq.).
Natural Gas Pipeline Safety Act of 1968 (49 U.S.C.A. 1671, et seq.).
Solid Waste Disposal Act, Public Law 89-272, Title II, as added by
Public Law 94-580, Resource Conservation and Recovery Act, 42
A-11
EM 1110-1-4006
30 SEP 98
U.S.C. 6921 et seq.,
Oct. 21, 1976, as amended by the Hazardous
and Solid Waste Amendments (HSWA) of 1984, Public Law 98-616, 42
U.S.C. 6901 et seq.
Heath, Ralph C. and Frank W. Trainer. Introduction to Groundwater
Hydrology. National Water Well Association, 1988.
Johnson, P.C., C.C. Stanley, M. W. Kemblowski, D. L. Byers, and J. D.
Colthart. “A Practical Approach to the Design, Operation,
and Monitoring of In-Situ Soil-Venting Systems.” Groundwater
Monitoring Review 10(2) (1990): 159-177.
National Truck Carriers.
Cargo Tank Hazardous Material Regulations
Rifai, H.S. “Modeling Natural Attenuation Using BioplumeII/III Model,”
Presentation at the U.S. Air Force Center for Excellence,
Environmental Restoration Technology Transfer Symposium, November,
1994.
A-12
EM 1110-1-4006
30 SEP 98
APPENDIX B
STATE REGULATORY AGENCY CONTACTS
Alabama (EPA Form), Alabama Department of Environmental Management,
Ground Water Section/Water Division, 1751 Congressman W.L. Dickinson
Drive, Montgomery, Alabama 36130, 205/271–7823
Alaska (EPA Form), Department of Environmental Conservation, Box 0,
Juneau, Alaska 99811–1800, 970/465–2653
American Samoa (EPA Form), Executive Secretary, Environmental Quality
Commission, Office of the Governor, American Samoan Government, Pago
Pago, American Samoa 96799; Attention: UST Notification
Arizona (EPA Form), Attention: UST Coordinator, Arizona Department of
Environmental Quality, Environmental Health Services, 2005 N. Central,
Phoenix, Arizona 85004
Arkansas (EPA Form), Arkansas Department of Pollution Control and
Ecology, P.O. Box 9583, Little Rock, Arkansas 72219, 501/562–7444
California (State Form), Executive Director, State Water Resources
Control Board, P.O. Box 100, Sacramento, California 95801, 916/445–1533
Co1orado (EPA Form), Section Chief, Colorado Department of Health, Waste
Management Division, Underground Tank Program, 4210 East 11th Avenue,
Denver, Colorado 80220, 303/320–8333
Connecticut (State Form), Hazardous Materials Management Unit,
Department of Environmental Protection, State Office Building, 165
Capitol Avenue, Hartford, Connecticut 06106
Delaware (State Form), Division of Air and Waste Management, Department
of Natural Resources and Environmental Control, P.O. Box 1401, 89 Kings
Highway, Dover, Delaware 19903, 302/726–5409
District of Columbia (EPA Form), Attention: UST Notification Form,
Department of Consumer and Regulatory Affairs, Pesticides and Hazardous
Waste Management Branch, Room 114, 5010 Overlook Avenue SW., Washington,
DC 20032
Florida (State Form), Florida Department of Environmental Regulation,
Solid Waste Section, Twin Towers Office Building, 2600 Blair Stone Road,
Tallahassee, Florida 32399, 904/487–4398
Georgia (EPA Form), Georgia Department of Natural Resources,
Environmental Protection Division, Underground Storage Tank Program,
B-1
EM 1110-1-4006
30 SEP 98
3420 Norman Berry Drive, 7th Floor, Hapeville, Georgia 30354, 404/
656–7404
Guam (State Form), Administrator, Guam Environmental Protection Agency,
P.O. Box 2999, Agana, Guam 96910, Overseas Operator (Commercial call
646–8863)
Hawaii (EPA Form), Administrator, Hazardous Waste Program, 645
Halekauwila Street, Honolulu, Hawaii 96813, 808/548–2270
Idaho (EPA Form), Underground Storage Tank Coordinator, Water Quality
Bureau, Division of Environmental Quality, Idaho Department of Health
and Welfare, 450 W. State Street, Boise, Idaho 83720, 208/334–4251
Illinois (EPA Form), Underground Storage Tank Coordinator,
Division of Fire Prevention, Office of State Fire Marshal, 3150
Executive Park Drive, Springfield, Illinois 62703–4599
Indiana (EPA Form), Underground Storage Tank Program, Office of
Environmental Response, Indiana Department of Environmental Management,
105 South Meridian Street, Indianapolis, Indiana 46225
Iowa (State Form), UST Coordinator, Iowa Department of Natural
Resources, Henry A. Wallace Building, 900 East Grand, Des Moines, Iowa
50219, 512/281–8135
Kansas (EPA Form), Kansas Department of Health and Environment, Forbes
Field, Building 740, Topeka, Kansas 66620, 913/296–1594
Kentucky (State Form), Department of Environmental Protection, Hazardous
Waste Branch, Fort Boone Plaza, Building #2, 18 Reilly Road, Frankfort,
Kentucky 40601, 501/564–6716
Louisiana (State Form), Secretary, Louisiana Department of Environmental
Quality, P.O. Box 44066, Baton Rouge, Louisiana 70804, 501/342–1265
Maine (State Form), Attention: Underground Tanks Program, Bureau of Oil
and Hazardous Material Control, Department of Environmental Protection,
State House—Station 17, Augusta, Maine 04333
Maryland (EPA Form), Science and Health Advisory Group, Office of
Environmental Programs, 201 West Preston Street, Baltimore, Maryland
21201
Massachusetts (EPA Form), UST Registry, Department of Public Safety,
1010 Commonwealth Avenue, Boston, Massachusetts 02215, 617/566–4500
B-2
EM 1110-1-4006
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Michigan (EPA Form), Michigan Department of State Police, Fire Marshal
Division, General Office Building, 7150 Harris Drive, Lansing, Michigan
48913
Minnesota (State Form), Underground Storage Tank Program, Division of
Solid and Hazardous Wastes, Minnesota Pollution Control Agency, 520 West
Lafayette Road, St. Paul, Minnesota 55155
Mississippi (State Form), Department of Natural Resources, Bureau of
Pollution Control, Underground Storage Tank Section, P.O. Box 10385,
Jackson, Mississippi 39209, 601/961–5171
Missouri (EPA Form), UST Coordinator, Missouri Department of Natural
Resources, P.O. Box 176, Jefferson City, Missouri 65102, 314/751–7428
Montana (EPA Form), Solid and Hazardous Waste Bureau, Department of
Health and Environmental Science, Cogswell Bldg., Room B–201, Helena,
Montana 59620
Nebraska (EPA Form), Nebraska State Fire Marshal, P.O. Box 94677,
Lincoln, Nebraska 68509–4677, 402/471–9465
Nevada (EPA Form), Attention: UST Coordinator, Division of Environmental
Protection, Department of Conservation and Natural Resources, Capitol
Complex 201 S. Fall Street, Carson City, Nevada 89710, 800/992–0900,
Ext. 4670, 702/885–4670
New Hampshire (EPA Form), NH Dept. of Environmental Services, Water
Supply and Pollution Control Division, Hazen Drive, P.O. Box 95,
Concord, New Hampshire 03301, Attention: UST Registration
New Jersey (State Form), Underground Storage Tank Coordinator,
Department of Environmental Protection, Division of Water Resources
(CN–029), Trenton, New Jersey 08625, 609/292–0424
New Mexico (EPA Form), New Mexico Environmental Improvement Division,
Groundwater/Hazardous Waste Bureau, P.O. Box 968, Santa Fe, New Mexico
37504, 505/827–2933
New York (EPA Form), Bulk Storage Section, Division of Water, Department
of Environmental Conservation, 50 Wolf Road, Room 326, Albany, New York
12233–0001, 518/457–4351
North Carolina (EPA Form), Division of Environmental Management,
GroundWater Operations Branch, Department of Natural Resources and
Community Development, P.O. Box 27687, Raleigh, North Carolina 27611,
919/733–3221
B-3
EM 1110-1-4006
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North Dakota (State Form), Division of Hazardous Management and Special
Studies, North Dakota Department of Health, Box 5520, Bismarck, North
Dakota 58502–5520
Northern Mariana Islands (EPA Form), Chief, Division of Environmental
Quality, P.O. Box 1304, Commonwealth of Northern Mariana Islands,
Saipan, CM 96950, Cable Address: Gov. NMI Saipan, Overseas Operator:
6984
Ohio (State Form), State Fire Marshal’s Office, Department of Commerce,
8895 E. Main Street, Reynoldsburg, Ohio 43068, State Hotline:
800/282–1927
Oklahoma (EPA Form), Underground Storage Tank Program, Oklahoma
Corporation Comm., Jim Thorpe Building, Oklahoma City, Oklahoma 73105
Oregon (State Form), Underground Storage Tank Program, Hazardous and
Solid Waste Division, Department of Environmental Quality, 811 S.W.
Sixth Avenue, Portland, Oregon 98204, 503/229–5788
Pennsylvania (EPA Form), PA Department of Environmental Resources,
Bureau of Water Quality Management, Ground Water Unit, 9th Floor Fulton
Building, P.O. Box 2063, Harrisburg, Pennsylvania 17120
Puerto Rico (EPA Form), Director, Water Quality Control Area,
Environmental Quality Board, Commonwealth of Puerto Rico, Santurce,
Puerto Rico, 809/725–0717
Rhode Island (EPA Form), UST Registration, Department of Environmental
Management, 83 Park Street, Providence, Rhode Island 02903, 401/277–2234
South Carolina (State Form), Ground-Water Protection Division, South
Carolina Department of Health and Environmental Control, 2600 Bull
Street, Columbia, South Carolina 29201, 803/758–5213
South Dakota (EPA Form), Office of Water Quality, Department of Water
and Natural Resources, Joe Foss Building, Pierre, South Dakota 57501,
Tennessee (EPA Form), Tennessee Department of Health and Environment,
Division of Superfund Underground Storage Tank Section, 150 Ninth
Avenue, North, Nashville, Tennessee 37219–5404, 615/741–0690
Texas (EPA Form), Underground Storage Tank Program, Texas Water
Commission, P.O. Box 13087, Austin, Texas 78711
Utah (EPA Form), Division of Environmental Health, P.O. Box 45500, Salt
Lake City, Utah 84145–0500
B-4
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Vermont (State Form), Underground Storage Tank Program, Vermont
AEC/Waste Management Division, State Office Building, Montpelier,
Vermont 05602, 802/828–3395
Virginia (State Form), Virginia Department of Environmental Quality, UST
Program, P. O. Box 10009, Richmond, Virginia 23240–0009, 804/698-4269.
Virgin Islands (EPA Form), 205(J) Coordinator, Division of Natural
Resources Management, 14 F Building 111, Watergut Homes, Christianstead,
St. Croix, Virgin Islands 00820
Washington (State Form), Underground Storage Tank Notification, Solid
and Hazardous Waste Program, Department of Ecology, M/S PV–11, Olympia,
Washington 98504–8711, 206/459–6316
West Virginia (EPA Form), Attention: UST Notification, Solid and
Hazardous Waste, Ground Water Branch, West Virginia Department of
Natural Resources, 1201 Greenbriar Street, Charleston, West Virginia
25311
Wisconsin (State Form), Bureau of Petroleum Inspection, P.O. Box 7969,
Madison, Wisconsin 53707, 608/266–7605
Wyoming (EPA Form), Water Quality Division, Department of Environmental
Quality, Herschler Building, 4th Floor West, 122 West 25th Street,
Cheyenne, Wyoming 82002, 307/777–7781.
B-5
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30 SEP 98
APPENDIX C
WELL OPENING PROCEDURES
Volatile organic contaminants (VOCs) tend to accumulate in the vapor space of
well casings. These organics can escape the well stem as a "slug" once the
cap is removed from the wellhead. Field personnel will follow these
procedures for initial opening of all wells in which the water is expected to
contain VOCs in greater than trivial concentrations.
-
A two-party team will initiate well-opening PRIOR to any sampling
activity.
-
Approach the wells from an upwind direction.
-
For initial well-opening, wear a minimum of Level C respiratory
protection, e.g., an Ultratwin with a GMC-H cartridge.
-
Open wells with unvented casings and threaded caps slowly to avoid
sudden release of gases due to over-pressure.
-
When the well is open, test the air in the wellhead for the
contaminants of concern.
-
If the readings indicate a potential health hazard from the
venting process, allow the well to vent for 15 to 30 minutes and
then test again.
-
The field team may perform monitoring or sampling in the level of
protection specified in Chapter 7 for the concentrations found.
-
Take new exposure readings at least four or five times an hour.
-
Many wells can be opened and "sniffed" at one time, which allows
the maximum ventilation time.
If field personnel can demonstrate that volatile organics are not a concern,
the site safety and health officer may allow them to skip the VOA procedure.
Experience with a recent round of groundwater sampling at the same location
would provide enough information to show whether this route of exposure is a
concern.
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APPENDIX D
HEAT/COLD STRESS MONITORING
D-1.
Heat Stress. Heat stress usually is a result of protective clothing
decreasing natural body ventilation, although it may occur at any time
work is being performed at elevated temperatures.
a.
Symptoms. If the body's physiological processes fail to maintain
a normal body temperature because of excessive heat, a number of
physical reactions can occur ranging from mild (such as fatigue,
irritability, anxiety, and decreased concentration, dexterity, or
movement) to fatal. Because heat stress is one of the most common
and potentially serious illnesses at hazardous waste sites,
regular monitoring and other preventative measures are vital.
Site workers must learn to recognize and treat the various forms
of heat stress.
b.
Treatment. The best approach is preventative heat stress
management. In general:
(1)
Urge workers to drink 0.5 liters (16 ounces) of water before
beginning work, such as in the morning or after lunch.
Provide disposable 120-ml (4-ounce) cups and water that is
maintained at 10 degrees to 15 degrees C (50 degrees to 60
degrees F). Urge workers to drink 1 to 2 of these cups of
water every 20 minutes, for a total of 3.5 to 7 liters (1 to
2 gallons) per day. Workers must wash hands and face prior
to drinking. Provide a cool area for rest breaks.
(2)
Acclimate workers to site work conditions by slowly
increasing workloads, i.e., do not begin site work with
extremely demanding activities.
(3)
Provide cooling devices to aid natural body ventilation.
These devices, however, add weight, and their use should be
balanced against worker efficiency. An example of a cooling
aid is long cotton underwear that acts as a wick to help
absorb moisture and protect the skin from direct contact
with heat-absorbing protective clothing.
(4)
Install mobile showers and/or hose-down facilities to reduce
body temperature and to cool protective clothing.
(5)
Conduct field activities in the early morning or evening in
hot weather.
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D-2.
D-3.
(6)
Ensure that adequate shelter is available to protect
personnel against heat, cold, rain, or snow, etc., all of
which can decrease physical efficiency and increase the
probability of both heat and cold stress. If possible, set
up the command post in the shade.
(7)
In hot weather, rotate shifts of workers wearing impervious
clothing.
(8)
Good hygienic standards must be maintained by frequent
changes of clothing and showering. Clothing should be
permitted to dry during rest periods. Persons who notice
skin problems should immediately consult medical personnel
and the site safety and health officer (SSHO).
Heat Stroke. Heat stroke is a medical emergency, with a high mortality
rate. Heat stroke is an acute and dangerous reaction to heat stress
caused by a failure of heat-regulating mechanisms of the body – the
individual's temperature control system that causes sweating stops
working correctly. Body temperature rises so high that brain damage and
death will result if the person is not cooled quickly.
a.
Symptoms: Red, hot, dry skin, although person may have been
sweating earlier; nausea; dizziness; confusion; extremely high
body temperature; rapid respiratory and pulse rates;
unconsciousness; or coma.
b.
Treatment: The most important objective in the treatment of heat
stroke is the lowering of the victim's body temperature as rapidly
as possible. Cool the victim quickly. If the body temperature is
not brought down fast, permanent brain damage or death will
result. Soak the victim in cool but not cold water, sponge the
body with cool water, or pour water on the body to reduce the
temperature to below 102 degrees F. Observe the victim and obtain
medical help. Do not give coffee, tea, or alcoholic beverages.
Heat Exhaustion. Heat exhaustion is a state of very definite weakness
or exhaustion caused by the loss of fluids from the body. This
condition is much less dangerous than heat stroke, but it nonetheless
must be treated.
a.
Symptoms: Pale, clammy, moist skin; profuse perspiration; and
extreme weakness. Body temperature is normal, pulse is weak and
rapid, breathing is shallow. The person may have a headache, may
vomit, and may be dizzy.
b.
Treatment: Remove the person to a cool, air conditioned place;
loosen clothing; place in a head-low position; and provide bed
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rest. Consult physician, especially in severe cases. The normal
thirst mechanism is not sensitive enough to ensure body fluid
replacement. Have patient drink 1 to 2 cups of water immediately,
and every 20 minutes thereafter, until symptoms subside. Total
water consumption should be about 3.5 to 7 liters (1 to 2 gallons)
per day.
D-4.
D-5.
D-6.
Heat Cramps. Heat cramps are caused by perspiration that is not
balanced by adequate fluid intake. Heat cramps are often the first sign
of a condition that can lead to heat stroke.
a.
Symptoms: Acute painful spasms of voluntary muscles (e.g.,
abdomen and extremities).
b.
Treatment: Remove victim
Have patient drink 1 to 2
minutes thereafter, until
consumption should be 3.5
Consult with physician.
to a cool area and loosen clothing.
cups of water immediately, and every 20
symptoms subside. Total water
to 7 liters (1 to 2 gallons) per day.
Heat Rash. Heat rash is caused by continuous exposure to heat and humid
air and aggravated by chafing clothes. The condition decreases ability
to tolerate heat.
a.
Symptoms: Mild red rash, especially in areas of the body in
contact with protective gear.
b.
Treatment: Decrease amount of time in protective gear and provide
powder to help absorb moisture and decrease chafing.
Heat Stress Monitoring and Work Cycle Management. For strenuous field
activities that are part of ongoing site work activities in hot weather,
the following procedures should be used to monitor the body's
physiological response to heat and to manage the work cycle, even if
workers are not wearing impervious clothing. These procedures are to be
instituted when the temperature exceeds 70 degrees F.
a.
Measure Heart Rate (HR). Take a rest period and measure heart rate
by the radial pulse for 30 seconds as early as possible, in the
resting period. The HR at the beginning of the rest period should
not exceed 110 beats/minute. If the HR is higher, shorten the
next work period by 33 percent, while the length of the rest
period stays the same. If the pulse rate still exceeds 110
beats/minute at the beginning of the next rest period, shorten the
following work cycle by another 33 percent. The procedure is
continued until the rate is maintained below 110 beats/minute.
b.
Measure Body Temperature. Body temperature should be measured
orally with a clinical thermometer as early as possible in the
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resting period. Oral temperature (OT) at the beginning of the
rest period should not exceed 99.40 degrees F; if it does, the
worker will be prohibited from continuing work until the OT is
maintained below 99.4 degrees F (37.4 degrees C).
c.
Manage Work/Rest Schedule. Use the following work/rest schedule as
a guideline:
Adjusted
Temperature (EF)
Active Work Time (min/hr)
Using Level B/C Protective Gear
75 or less
50
80
40
85
30
90
20
95
10
100
d.
0
Measure the air temperature with a standard thermometer. Estimate
fraction of sunshine by judging what percent of the sun is out:
-
100-percent sunshine = no cloud cover = 1.0
50-percent sunshine = 50-percent cloud cover = 0.5
0-percent sunshine = full cloud cover = 0.0
Calculate the adjusted temperature:
T (adjusted) =
e.
D-7.
T (actual) + (13 x fraction sunshine)
Reduce or increase the work cycle according to the guidelines
under heart rate and body temperature.
Cold Stress.
a.
Persons working outdoors in low temperatures, especially at or
below freezing are subject to cold stress. Exposure to extreme
cold for a short time causes severe injury to the surface of the
body or results in profound generalized cooling, causing death.
Areas of the body that have high surface area-to-volume ratio such
as fingers, toes, and ears are the most susceptible.
b.
Protective clothing. Personal protective clothing and equipment
are essential in the prevention of cold stress and injury related
to a cold environment. Clothing made of thin cotton fabric is
ideal; it helps evaporate sweat by "picking it up" and bringing it
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to the surface. Loosely fitted clothing also aids sweat
evaporation. Tightly fitted clothing of synthetic fabric
interferes with evaporation. Recommended clothing includes the
following: cotton undershirt, cotton shorts/underpants, cotton
and wool thermal underwear, cotton and wool socks, wool or thermal
trousers (quilted or specially lined), waterproof insulated boots,
wool shirt, wool sweater over cotton shirt, Anorak or arctic
parka, wool knit cap, hard-hat liner, wool mittens, ski mask or
scarf, and windproof and waterproof outer layer.
D-8.
c.
Many factors influence the development of a cold injury: the type
and duration of exposure, the ambient temperature, the humidity,
and the velocity of the wind. Wind chill is used to describe the
chilling effect of moving air in combination with low temperature.
d.
As a general rule, the greatest incremental increase in wind chill
occurs when a wind of 5 mph increases to 10 mph. Additionally,
water conducts heat 240 times faster than air. Thus, the body
cools suddenly when chemical-protective equipment is removed if
the clothing underneath is perspiration soaked.
Frostbite Symptoms. Local injury resulting from cold is included in the
generic term frostbite. Frostbite of the extremities can be categorized
in three ways:
-
Frost nip or incipient frostbite is characterized by sudden
blanching or whitening of skin.
-
Superficial frostbite is characterized by skin with a waxy or
white appearance and is firm to the touch, but tissue beneath is
resilient.
-
Deep frostbite is characterized by tissues that are cold, pale,
and solid.
b.
Treatment.
To administer first aid for frostbite:
(1)
Take the victim indoors and rewarm the areas quickly in
water that is between 39 degrees and 41 degrees C (102
degrees and 105 degrees F).
(2)
Give a warm drink–not coffee, tea, or alcohol.
must not smoke.
(3
Keep the frozen parts in warm water or covered with warm
clothes for 30 minutes, even though the tissue will be very
painful as it thaws.
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c.
D-9.
(4)
Elevate the injured area and protect it from injury.
(5)
Do not allow blisters to be broken.
(6)
Use sterile, soft, dry material to cover the injured areas.
(7)
Keep victim warm and get immediate medical care.
Precautions. After thawing, the victim should try to move the
injured areas a little, but no more than can be done alone,
without help.
(1)
Do not rub the frostbitten part (this may cause gangrene).
(2)
Do not use ice, snow, gasoline, or anything cold on the
frostbitten area.
(3)
Do not use heat lamps or hot water bottles to rewarm the
part.
(4)
Do not place the part near a hot stove.
Hypothermia. Systemic hypothermia is caused by exposure to freezing or
rapidly dropping temperature.
a.
b.
Symptoms.
Its symptoms are usually exhibited in five stages:
(1)
Shivering.
(2)
Apathy, listlessness, sleepiness, and (sometimes) rapid
cooling of the body to less than 95 degrees F.
(3)
Unconsciousness, glassy stare, slow pulse, and slow
respiratory rate.
(4)
Freezing of the extremities.
(5)
Death.
Treatment. As a general rule, field activities must be curtailed
if equivalent chill temperature (degrees F) as defined in Table
D-1 is below zero (0 degrees F).
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TABLE D-1
COOLING POWER ON EXPOSED FLESH EXPRESSED AS AN
EQUIVALENT TEMPERATURE UNDER CALM CONDITIONS*
o
Actual Temperature Reading ( F)
Estimated Wind
50
40
30
20
10
0
-10
-20
-30
-40
-50
-60
o
Speed (in mph)
Equivalent Chill Temperature ( F)
calm
50
40
30
20
10
0
-10
-20
-30
-40
-50
-60
-68
5
48
37
27
16
6
-5
-15
-26
-36
-47
-57
10
40
28
16
4
-9
-24
-33
-46
-58
-70
-83
-95
15
36
22
9
-5
-18
-32
-45
-58
-72
-85
-99
-112
20
32
18
4
-10
-25
-39
-53
-67
-82
-96
-110
-121
25
30
16
0
-15
-29
-44
-59
-74
-88
-104
-118
-133
30
28
13
-2
-18
-33
-48
-63
-79
-94
-109
-125
-140
35
27
11
-4
-20
-35
-51
-67
-82
-98
-113
-129
-145
40
26
10
-6
-21
-37
-53
-69
-85
-100
-116
-132
-148
Wind Speeds
LITTLE DANGER
INCREASING DANGER
greater than
in <hr with dry skin
40 mph have
Maximum danger of false sense
Danger from freezing of
exposed flesh within one
little additional
of security.
(1) minute.
GREAT DANGER
Flesh may freeze within
30 seconds.
effect.
Trenchfoot and immersion foot may occur at any point on this chart.
*Developed by U.S. Army Research Institute of Environmental Medicine, Natick, MA
SOURCE: ACGIH, Threshold Limit Values for Chemical Substances in the Work Environment for 1984-1985.
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APPENDIX E
CONFINED SPACE ENTRY
E-1.
General. These procedures establish minimum requirements for safe entry
into, work in, and exit from confined spaces like tanks, vessels,
manholes, pipelines, water transmission lines, tunnels, stilling wells,
junction structures, valve and metering vaults, dry wells, and wet
wells. These confined spaces are dangerous because gases and vapors
accumulate to form oxygen deficient, toxic, or explosive atmospheres.
E-2.
Confined Space Entry Program. No one will enter a confined space unless
these procedures (or equivalent procedures established by the
subcontractor or client) are followed. The SSHO will determine whether
alternate procedures are equivalent. A confined space entry program
must include at a minimum:
a.
Responsibilities and duties of personnel associated with confined
space entry activities.
b.
Continuing evaluation and identification (posting) of confined
spaces.
c.
Coordination of confined space entry activities.
d.
Specific training for confined space entrants.
e.
Pre-entry review and permit preparation.
f.
Provision of appropriate safety equipment.
g.
Adherence to the buddy system.
h.
Detection of hazardous conditions.
i.
Ventilation of hazardous gases.
j.
Written rescue and emergency services and procedures.
k.
Vessel preparation, isolation, lockout/tagout.
l.
Atmospheric testing, oxygen, toxicity, and flammability.
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m.
E-3.
Communication devices, hand, radio, rope.
Confined Space Entry Personnel.
personnel include:
The roles of confined space entry
-
Confined Space Entry Coordinator. Personnel at the project
trained and authorized in writing by the designated authorities
to sign, issue, and revoke entry permits.
-
Person-in-Charge. An entry team member trained and authorized to
certify that entry permit conditions have been met.
-
Confined Space Entrants. Entry team member trained to perform
actual work in the confined space.
-
Entry Attendant. An individual stationed outside and required to
remain outside the confined space while entrants are in the
confined space, who monitors the authorized entrants and the
confined space activities and, under specified conditions,
authorizes evacuation of the confined space.
-
Rescue Personnel. Personnel who are trained, qualified, and
authorized to respond to emergencies in confined spaces.
a.
The personnel who fill these roles must have completed training in
these procedures and in site-specific confined space hazards
identified by the SSHO.
b.
Entry by personnel into any confined space where liquids or gases
may have been present, or may occur during the entry, requires at
least three persons: one entrant, one attendant, and one rescue
worker. The attendant and rescue worker are to remain outside
confined space. Rescue workers may perform other tasks during an
entry if those tasks will not impede response to an emergency.
c.
Personnel may fill the roles listed above only if they are
qualified. All entrants and rescue teams must be trained in their
entry-procedure responsibilities. A written record of the length
and content of such training must be kept.
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E-4.
E-5.
Confined Space Entry Permits.
a.
Written entry permits are required for any entry into, or work in,
confined spaces. When a work team plans to enter a confined
space, it must complete an entry permit form that contains, at a
minimum, the information in Table E-1. Users are directed to
create local forms meeting their specific needs. Forms should
include the personnel, task, measurements, equipment required, and
the emergency contact.
b.
Entry permits may be issued only by the Confined Space Entry
Coordinator.
Actual entry is authorized when the "Person in
Charge" completes the pre-entry checklist on the entry permit and
signs the form.
c.
Entry permits will address a single work project in a single
confined space, for one work period, not to exceed 8 hours. The
coordinator may issue permits for a task involving a group of
spaces with a common hazard potential. A permit may allow work
over a longer period, if the personnel, the tasks, and the hazards
do not change.
Equipment Required for Confined Space Entry.
a.
USACE personnel may enter a confined space only with the equipment
specified in the entry permit. The safety equipment listed below
would be adequate for most foreseeable conditions.
b.
Personal Protective Equipment (PPE)
(1)
Airline respirator or Self-Contained Breathing Apparatus
(SCBA)
(2)
Steel-toe safety shoes
(3)
Hard hat
(4)
Surgical PVC inner gloves
(5)
Neoprene rubber outer gloves
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TABLE E-1
CONFINED SPACE ENTRY PERMIT MINIMUM REQUIREMENTS
Space to be Entered:
Nature of Task:
Duration of Permit:
Person In Charge:
Authorized Entrants:
_______________________________________________
_______________________________________________
From: _________________ To: ___________________
_______________________________________________
_______________________________________________
_______________________________________________
_______________________________________________
Attendant:
_______________________________________________
Coordinator Signature:
_______________________________________________
Pre-Entry Check List
Needed? In Place? (To Be Initialed By Person in Charge)
_____ _____
Traffic cones or barriers in place
_____ _____
Safety harness with retrieval tripod in place
_____ _____
SCBA ready for emergency use
_____ _____
Valves tagged out (mark N/A if not applicable)
_____ _____
Electrical equipment disconnected & locked out (or N/A)
_____ _____
Protective clothing & equipment donned appropriately
_____ _____
Rescue worker is within easy reach
Personal Protective Equipment
Needed? In Place?
_____ _____
_____ _____
_____ _____
_____ _____
_____ _____
_____ _____
Airline breathing mask
Steel-toe safety shoes
Surgical PVC inner gloves
Chemical safety goggles
PVC rain suit
Forced ventilation blower
Needed? In Place?
_____ _____
_____ _____
_____ _____
_____ _____
_____ _____
_____ _____
SCBA
Hard hat
Rubber outer gloves
Rubber overboots
Duct tape on seams
5-minute escape packs
Atmospheric Testing
Needed? In Place?
_____ _____
_____ _____
_____ _____
_____ _____
_____ _____
_____ _____
Oxygen deficiency (>19.5% and <21.5%)
Flammable gases (<10% LEL)
Toxic gases (< PELs). (Specify: ________________________)
Ventilation blower pushing clean air into space
Gas Detector(s) – on the belts or suits of entrants
Atmospheric Testing – after period of ventilation
ENTRY APPROVED: __________________________________ _________________
Person-in-Charge
Date
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c.
d.
(6)
Chemical safety goggles
(7)
Rubber overboots or hip waders
(8)
PVC rain suit
(9)
Duct tape on the seams
(10)
Forced ventilation blower
(11)
Five-minute escape packs
Rescue Equipment
(1)
Parachute-type safety harness
(2)
Safety lifeline
(3)
Automatic rescue winch
(4)
Rescue & retrieval tripod or derrick
(5)
Two-way radios
(6)
First-aid kit
Routine confined space entries can be performed in regular work
clothes if the entry team has enough information about the
atmosphere inside the space. Some circumstances that would change
the type of equipment needed include the following:
Respiratory protection is not necessary if:
(1)
The monitoring equipment reveals no contaminants in the air
and
(2)
There is no potential source of contaminants and
(3)
The oxygen level is at least 19.5 percent.
e.
If the air and surfaces in the space are free of contaminants,
protective clothing is not needed.
f.
If air contaminants in the space can affect the worker by
absorption through the skin, a Level A suit is required.
g.
A SCBA, in working order, must be ready for use.
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h.
E-6.
E-7.
Only intrinsically-safe equipment may be used in confined spaces.
Temporary lighting, whether electrically or battery operated, must
be low-voltage, double-insulated, and explosion-proof. Tools used
in confined spaces must be of a non-sparking type, unless there is
no potential for flammable vapors or gases in the space.
Preparation for Entry.
a.
Inspect the area near the space for tripping hazards, traffic, and
ignition sources, like lighted cigarettes. Remove them, if you
can. Provide controls if you cannot move them.
b.
Inspect the condition of the entry steps of the confined space.
Do not rely on a permanent ladder if the space is often wet. If
it appears that the steps will not support your weight or if the
confined space contains no steps, then provide a ladder and
approved hoist or another form of ready entry and exit. Only one
person at a time should ascend or descend a ladder. Personnel
must not carry tools or other objects in their hands while
climbing in or out of the confined space.
c.
If materials can flow into the space:
(1)
And valves are motor operated: disconnect them, engage the
lockouts, and attach a lockout tag.
(2)
And valves are manually operated: either station someone at
the valve handle or chain and padlock the handle.
(3)
Install steel blanks in lines with flanged connections.
d.
The potential types of emergency in the spaces vary with the type
of confined space. The rescue equipment, including the SCBA,
should be inspected and tested prior to space entry.
e.
Coworkers must inspect each other's safety equipment before entry
to determine if it is properly adjusted and in the proper
position.
Monitoring.
a.
Combination combustible gas and oxygen indicators must be used to
test the atmosphere of the confined space for the presence of
combustible gases and adequate oxygen levels before entering. The
permit must specify tests for any other dangerous contaminants,
such as hydrogen sulfide, which could be present in the space.
b.
Prior to entry, the Person-in-Charge must test the atmosphere
within the confined space with the meters as specified below.
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E-8.
E-9.
(1)
Start up, check voltage, and field check the meters. Do not
calibrate the detector with the probe in the confined space.
(2)
Insert the probe about 12 inches into the space.
meters.
(3)
Drop the probe to the level that workers in the space will
occupy. Read it again.
(4)
Measure for vapor conditions on the assumption that
stratification of vapors has occurred in the tank. At a
minimum, measure the top, middle, and bottom of the space as
well as any identifiable pockets, corners, etc.
Read the
c.
Gases and vapors tend to stratify in confined spaces. One entrant
must wear or carry the meter throughout the duration of the entry.
d.
If a toxic material is present above its exposure limit, or
flammable gas is above 10 percent of the LEL, or oxygen is below
19.5 percent or above 21.5 percent, the team shall provide forced
ventilation to eliminate these conditions and shall not make entry
until these conditions are eliminated. The LEL must be less than
10 percent and oxygen levels must be between 19.5 percent and 22
percent.
e.
The air monitors must be field tested in accordance with the
instructions contained in the instrument manual. If the detector
fails the prescribed field tests, it must be recalibrated by the
procedures established by the manufacturer. No entry is permitted
unless the required measurements have been collected.
Ventilation.
a.
When monitoring indicates a need for ventilation, it must be
provided until the monitor indicates acceptable air levels.
Blowers should be coupled with a large-diameter, flexible hose
that can direct air into the work area. Blowers used within
confined spaces will be intrinsically safe. Gasoline, diesel, or
gas-operated equipment used near confined spaces must be oriented
so that their exhaust cannot enter the space.
b.
Continuous ventilation is desirable for any confined space entry.
It is required for entry into any space where liquids or gases may
have been present or could enter during the personnel entry.
Responsibilities During Confined Space Entry.
a.
The Person-in-Charge of the entry must:
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EM 1110-1-4006
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(1)
Assure that the pre-entry checklist on the permit is
completed before any employee enters a confined space.
(2)
Evaluate the pre-entry conditions.
(3)
Verify that the rescue worker is available and that the
means for summoning is operable.
(4)
Terminate the entry upon becoming aware of a nonpermitted
condition.
b.
The Person-in-Charge of entry may serve as an entrant or an
attendant in accordance with the sections below.
c.
The Entry Attendant must:
(1)
Remain outside the confined space.
(2)
Leave only when replaced by an equally qualified individual
or to save his/her own life. If the attendant must leave and
there is no replacement, order the entrants to exit the
confined space.
(3)
Stay continuously aware of the location and condition of all
authorized entrants within the confined space by voice,
radio, telephone, visual observation, or other equally
effective means.
(4)
Stay continuously aware of conditions in the space.
(5)
Order entrants to exit the confined space at the first
indication of hazardous condition (such as instrument alarms,
visible releases, or unusual behavior by the entrants).
(6)
Summon immediate emergency assistance, if needed.
(7)
Warn unauthorized persons not to enter or to exit immediately
if they have entered. Advise the authorized entrants and
management of entry by unauthorized persons.
(8)
Assemble and inspect the equipment that the rescue worker
would need to enter the space.
(9)
Keep objects away from the access hole where they can be
accidentally knocked, pushed, or dragged into the confined
space. Lower tools or supplies to workers inside by a hand
line.
E-8
EM 1110-1-4006
30 SEP 98
(10)
d.
If safety harnesses are worn into the space, secure the
safety line to a nearby well-anchored object, never to
movable equipment or a vehicle. Monitor the safety line at
all times, taking up extra slack as needed. Keep the safety
line away from traffic and equipment with moving parts.
Confined space entrants must:
(1)
Remove all jewelry before entering the space.
(2)
Inspect their own and each other's personal safety gear
before entering the confined space.
(3)
Comply with these procedures and the conditions of the
permit.
(4)
Follow the directions of the Person-in-Charge and the
Attendant.
(5)
Leave the space and report to the Attendant immediately upon
feeling the effects of a chemical exposure.
(6)
While working, avoid looking up.
E-10. Rescue Procedures.
a.
b.
Upon detecting an emergency condition, the personnel in the
confined space must:
(1)
Move an incapacitated coworker in close proximity toward the
exit. However, do not move towards the hazard, even to save
a coworker.
(2)
Exit the space.
(3)
Immediately inform the Attendant of the nature of the
hazard.
Upon detecting an emergency, the Attendant must:
(1)
Remain outside the confined space to lower necessary rescue
equipment into the space and render other necessary
assistance.
(2)
Start to withdraw the worker(s) with the safety line.
(3)
Notify the rescue worker(s).
E-9
EM 1110-1-4006
30 SEP 98
c.
d.
e.
(4)
Send someone to notify the emergency service providers
specified in the permit. Give the location and any other
pertinent information.
(5)
Remain available to lower necessary rescue equipment into
the space, render any other necessary assistance, and guide
emergency units to the scene.
Upon detecting an emergency, rescue workers must:
(1)
Report to the confined space as quickly as possible.
(2)
If appropriate, don a SCBA.
(3)
Enter to offer assistance and correct the problem.
Protection of employee life and health is the first priority of
the rescue worker. No employee may enter the confined space
without a SCBA until all causes of the incapacitation have been
eliminated.
The rescue team must be trained in:
(1)
The requirements for entrants.
(2)
The rescue functions assigned to them using the retrieval
and rescue equipment furnished.
(3)
Basic first aid and cardiopulmonary resuscitation.
E-10
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