SFUND RECORDS CTR

2117872

UNITED STATES ENVIRONMENTAL PROTECTION AGENCYREGION LX LABORATORY

1337 S. 46™ STREET BLDG 201RICHMOND, CA 94804-4698

OCT 1 7 2006 MEMORANDUM

SUBJECT: Field Report, AuClair Waste SamplingLots 12A and 12B, Riverside County, September 26, 2006

FROM: Greg Nagle, Environmental Scientist °^EPA Region 9 Laboratory (MTS-2)

'THROUGH: Brenda Bettencourt, DirectorEPA Region 9 Laboratory (MTS-2)

TO: Kaoru Morimoto - RCRA Enforcement OfficeCaleb Shaffer - RCRA Enforcement OfficeWaste Management Division (WST-3)

Attached please find a Field Report for the sampling performed on September 26th, 2006. Thereport details sample collection activities and observations I made while on the Au Clair propertyin Riverside County, California.

Results of the sample analysis are provided separately. If you have any questions concerningthis report, please contact Greg Nagle at (510) 412-2334.

ATTACHMENT: Field Report

Field Report - Waste Sampling - September 2006

Introduction:In September of 2006, the RCRA Enforcement Office requested sampling and analytical assistance tosupport a Resource Conservation and Recovery Act (RCRA) Compliance Evaluation Inspection (CEI)performed in July of 2006. On September 26th, 2006, I (Greg Nagle) collected waste samples at theAuClair facility for metals analysis. I performed the sampling consistent with the Sampling andAnalysis Plan (SAP) for the AuClair Facility, September 2006 (Attachment A).

Participants:Sean Dusek, Deputy - Riverside County Sheriff OfficeKarou Morimoto, Inspector - EPA RCRA Compliance OfficeGreg Nagle, Environmental Scientist - EPA Region 9 Laboratory, Field, and Biology Team

Sampling Location:Mr. Morimoto chose the five sample locations in the field based on previous global positioning system(GPS) data, and visual observation. Mr. Nagle collected ash and coal samples from the same generallocation, labeled the containers alphabetically, and logged the location with a GPS unit as follows:

LocationAA-CoalBBlCC-CoalDE

DescriptionAshCoalAshDuplicateAshCoalAshAsh

Longitude (Northing)33° 32'46.4"33° 32'46.4"33° 32'46.2"33° 32'46.2"33° 32'46.0"33° 32'46.0"33° 32'46.8"33° 32'47.3"

Latitude (Easting)116° 7'39.8"116° 7'39.8"116° 7 39.3"116° 7'39.3"116° 7'39.6"116° 7'39.6"116° 7'39.4"116° 7'39.1"

Mr. Morimoto photographed each location sampled above (Exhibit A).

Sampling ProceduresI utilized a grab sampling approach to collect sample from the surface to a depth of approximately oneinch. I placed the material directly into the pre-labeled, doubled Ziplock® bags using a disposableplastic scoop, and noted the time of collection on the outside bag.

Transport and DeliveryI transported the samples in a cooler under chain-of-custody (Attachment B) and delivered them to theRegion 9 Laboratory in Richmond, California on the same day without incident. The TransportationSecurity Administration (TSA) inspected the contents of the cooler on the return flight from PalmSprings to San Francisco, California. The custody seal on the samples (i.e., Ziplock® bags) remainedintact.

Request for AnalysisI submitted the samples for the analysis of total, and toxicity characteristic leaching procedure TCLPconcentrations of chromium, arsenic and copper. The EPA Region 9 Laboratory will report both thetotal, and TCLP metals results under Laboratory Project Number 0609057. I also requested anexpedited turnaround time (one to two weeks), and that the lab provide preliminary results as theybecame available.

Photographs

'A" Location (Facing North) 'B" Location (Facing East)

"C" Location (Facing East)

sp •-'•

"D" Location (Facing East)

"E" Location (Facing East)

Chain-of-Custody Record

ENVIRONMENTAL PROTECTION AGENCYOffice of Enforcement CHAIN OF CUSTODY RECORD

REGION 975 Hawthorne Street

San Francisco, California 94105

PROJ. NO PROJECT NAME

SAMPLERS; (Signature)

DATE TIME MATRIXO>

SAMPLE INDENTlFlCATlON

NO.

OF

CON-TAINERS

REMARKS

^/0

XX 3X yX C. X X

(&Z3 X C - XV XX X

tafure,) Date/ Time

f-^bReceived tjy: (Signature) Relinquished by: (Signasuiaj Date / Time Re<»1v6<J by: (Signature)

iqutsroRelinqutsttsd, by; (Signature) Date/ Time Received by' (Signature) Date / Time Received by: (Signature}

Received for Laboratory by: (Signature) Date / Time Tamp. Seals Intact (Y/N) Conditions ^-Remarks j /9s, Cu)

Distribution: Original Accompanies Shipment: Copy to Coordinator Rel<J FitefrLJ nrrs

9- 01811

Sampling and Analysis Plan

SAMPLING AND ANALYSIS PLAN

AuClair Facility

Torres-Martinez Indian ReservationRiverside County, California

Resource Conservation and Recovery ActEnforcement Office

September 2006

Prepared by:U.S. EPA Region 9 Laboratory

Field and Biology Team1337 S. 46th Street, Bldg 201Richmond, California 94804

Table of Contents

1 . Introduction 12 Site Location and Background ' 13 Scope and Objectives 14 Sampling Strategy : 24.1 Number of Samples 25 Field Methods and Procedures 25.1 Sample Collection 25.2 Quality Control Samples 25.3 Methods of Analysis 35.4 Packing and Shipping 36 Data Evaluation 37 Personnel 38 Health and Safety.... 49 Schedule 410 References ..4Figure 1 - AuClair Facility 5Attachment A- Heath and Safety Plan : 1

1 Introduction

The United States Environmental Protection Agency (EPA) Region 9 Laboratory; Field, andBiology (FAB) Team prepared this Sampling and Analysis Plan (SAP) at the request of the EPARegion 9 Resource Conservation and Recovery Act (RCRA) Compliance Office. The purposeof the SAP is to specify the sampling strategy, chemical testing, and number samplesanticipated. This SAP is applicable to the collection of ash samples from chemically preservedvineyard (grape) stakes burned at the AuClair Facility, Riverside County California. This one-time sampling event will occur on September 20, 2006. The EPA will conduct sample analysisat the EPA Region 9 Laboratory in Richmond, California.

2 Site Location and BackgroundThe AuClair facility is located on Torres Martinez tribal property Lots 12A and 12B in Thermal,California (See Figure 1). On June 28, 2006, a Resource Conservation and'Recovery Act(RCRA) Compliance Evaluation Inspection (CEI) was conducted by inspectors from the EPARegion 9 RCRA Compliance Office, accompanied by representatives from the Riverside CountySheriffs Office. During the inspection, EPA noted numerous piles of green waste, brokenfurniture, broken appliances, broken electronics, batteries, tires, clothing, food containers,product containers, broken toys, and a large volume of chemically treated wooden grape stakes.

The purpose of the CEI was to determine the compliance of the AuClair facility with RCRASubtitle C (hazardous waste) and Subtitle D (solid waste) requirements. The chemicals used totreat/preserve the wood to make vineyard stakes contains chromium, arsenic, and copper toresist to decay and damage from pests. The operator periodically burns combustible material toreduce the volume of solid waste and make room for more material. The ash residue maycontain chromium, arsenic, and copper at concentrations in excess of Federal and State SubtitleC disposal limits.

3 Scope and Objectives

The scope of the sampling includes analysis of burned grape stake samples for metals,specifically, chromium, arsenic, and copper. The objective of the split sampling is to determineif the burned material exceeds characteristic toxicity levels for chromium, arsenic, and copperwhen subjected to the Toxicity Characteristic Leaching Procedure (TCLP). The table belowpresents the analytes, reporting limits and toxicity limits for each analytical procedure specifiedabove.

Quantitation Limit Total Value to Necessary Quantitation LimitTotal Analysis to Theoretically Exceed TCLP Analysis TCLP Limit

Analyte (mg/Kg) the TCLP Limit (mg/Kg) (mg/L) (mg/LfChromium (Cr) 2.0 >100 0.01 5.0Arsenic (As) 2.0 >100 0.2 5.0Copper (Cu) 8 >500 0.02 25s

a - 40 CFR Part 261.24 Table 1b - Soluble Threshold Limit Concentration (STLC) Chapter. 11, Article 3, § 66261.24-1

4 Sampling Strategy

4.1 Number of Samples

The field team will use a biased judgmental sampling approach to collect the grape stake ashsamples. The sampling team will choose sample locations in the field based on previous globalpositioning system (GPS) data, and visual observation. The number of samples collected willdepend on the distribution of the ash debris piles encountered, and the availability of the ashmaterial at the surface. EPA does not anticipate that the number of discrete grab samplescollected will exceed ten. EPA will label sample containers alphabetically as follows:

Field ID DescriptionA Material from area 1B Material from area 2C Material from area 3D Material from area 4E Material from area 5F. Material from area 6G Material from area 7H Material from area 8I Material from area 9J Material from area 10X1 Duplicate from one of the areas above

The field team will cross-reference field ID with the GPS reading in a field logbook. EPA willobtain sample of other materials (wood, partially burned wood etc.,) at the discretion of the EPAInspector based on observations made at the time of sample collection.

5 Field Methods and Procedures

5.1 Sample Collection

The EPA will utilize a grab sampling approach collecting sample from the surface to a depth ofapproximately one inch. The sampler will place the material directly into the pre-labeled,doubled-Ziplock® bag using a single-use, disposable plastic scoop, and note the time ofcollection. The EPA will transport samples to the laboratory under chain-of-custody (COC) anddeliver to the laboratory the following day. No chemical or thermal preservation is required.

5.2 Quality Control Samples

Appropriate quality control (QC) samples are additional volume at one location for matrixspike/matrix spike duplicate purposes, and a separate discrete container for a field duplicatecomparison. No trip blank or temperature control sample is required.

5.3 Methods of Analysis

The EPA will analyze the ash samples for chromium, arsenic, and copper using EPA MethodSW6010B, Inductively Coupled Argon Plasma (ICAP) at the Region 9 Laboratory in Richmond,California. Initially, the laboratory will prepare all solid samples for analysis of totalconcentrations in accordance with EPA Method 3050B. The laboratory will perform furtherTCLP testing and analysis in accordance with EPA Method SW1311 as requested by theRegion 9 RCRA Enforcement Office.

The laboratory manually reviews data in accordance with SOPs 846 Internal Laboratory EPAReview of ESAT and EPA Generated Data, and 845 Final Chemistry Review and ReportGeneration.

5.4 Packing and Shipping

The EPA will ship samples in coolers at ambient temperature. Cooling the samples to 4±2°C isunnecessary. The samples will remain in the custody of the EPA representative untilrelinquished for overnight delivery to the laboratory. A COG form will accompany the samplesfrom the point of origin to the designated laboratory in a plastic bag inside of the cooler. Thecooler will have a custody seal affixed across the cooler lid, and on the Ziplock® bag(s)containing the samples prior to shipment.

6 Data Evaluation

The laboratory will report the results of the total analysis on a dry-weight basis and will evaluatethe results of the total analysis as follows:

[A x B] + [C x D]= E

B + [20 (L/kg) x D]

Where:A = Concentration of the analyte in liquid portion of the sample (mg/L)B = Volume of the liquid portion of the sample (L)C = Concentration of the analyte in solid portion of the sample (mg/kg)D = Weight of the solid portion of the sample (kg)E = Maximum theoretical concentration in leachate (mg/L)

If the total result (E) is 20 .times greater than the TCLP value, Method 1311 the waste mayexceed the TCLP. The RCRA Enforcement Office may request that the laboratory perform theTCLP regardless of the results of the total analysis.

7 Personnel

Mr. Kaoru Morimoto of the EPA Region 9 RCRA Enforcement Office and Mr. Greg Nagle of theEPA Region 9 FAB Team will perform the fieldwork. Mr. Morimoto is responsible for

coordinating field activities with Riverside County Sheriffs Office and for identifying the specificsample locations and any photo-documentation. Mr. Nagle is responsible all health and safety,sample collection, chain-of-custody, sample shipment and laboratory coordination relatedactivities.

8 Health and Safety

The EPA prepared a brief Health and Safety Plan (HSP) provided as Attachment A. The EPAwill be review the HSP with all field participants' prior initiation of sampling activities.

9 Schedule

Field sampling activities will occur on September 20, 2006 and should be complete within two tothree hours time. The Region 9 FAB Team will submit a Field Report to the RCRA ComplianceOffice within 21 days of the field audit. The RCRA Compliance Office requested an expeditedlaboratory turn-around times of one week for the total metals analysis and two weeks for anysubsequent TCLP analyses.

The laboratory will report the results of the total analysis within 5 business days of samplereceipt. The EPA Region 9 Laboratory will report the results of the any necessary TCLP testingwithin 10 business days of notice to proceed as directed by the RCRA Enforcement Office. EPAwill complete all sample analysis within six months of sample collection.

10 References

EPA, Test Methods for Evaluating Solid Waste, Volume II: Field Manual, Physical/ChemicalMethods, November 1986, Office of Solid Waste and Emergency Response, SW-846.

EPA, Sampling and Analytical Plan'(SAP) Guidance and Template Version 1, EPA AnalyticalServices Used. R9QA/001.1 (April 2000).

EPA, Test Methods for Evaluating Solid Waste, Volume III: Method 6010B Inductively CoupledPlasma Atomic Emission Spectrometry (Rev 2 December 1996).

EPA, Test Methods for Evaluating Solid Waste, Volume III: Method 3050B Acid Digestion OfSediments, Sludges and Soils (Rev 2. December 1996)

EPA, Test Methods for Evaluating Solid Waste, Volume III: Method 1311 Toxicity CharacteristicLeaching Procedure (Rev 1. July 1992).

EPA, Test Methods for Evaluating Solid. Waste, Volume III: Method 3010A Acid Digestion OfAqueous Sample and Extracts For Total Metals For Analysis By FLAA Or ICP Spectrometry(Rev I.July 1992).

Figure 1 - AuClair Facility

Attachment A - Heath and Safety Plan

UNITED STATES ENVIRONMENTAL PROTECTION AGENCYMANAGEMENT TECHNICAL SERVICES DIVISION

HEALTH AND SAFETY OFFICE

SITE SAFETY AND HEALTH PLAN

I. DESCRIPTION OF FIELD ACTIVITY

Site: AuClair Facility . Site Phone: (510) 912- 2161 Field Phone

Location: Torrez Martinez Indian Reservation, Thermal Lots A&B Riverside County, CA

Date of Proposed Sampling: September. 20 2006

SSHP Prepared By: Greg Naqle

Purpose/Objective: To collect ash samples for the RCRA Compliance Office todetermine whether specific metals (chromium, arsenic, copper) exceed federal landfilldisposal criteria.

Background Review: Complete Preliminary _X_

Background Material Attached: Yes No X

Indicate which of the following information source(S) were consulted: State and/or LocalAgency, State and/or Federal OSHA, NIOSH, EPA files, Site Operator and Local FireDepartment.

Local Fire Department - Oasis Fire Station #42Riverside County Sheriffs Department

Overall Hazard Summary: Low X High Medium Unknown

Route of Exposure: Inhalation X Skin Contact X Ingestion

Map or Sketch Attached: .Yes X No

II SITE CHARACTERISTICS

A. Facility Description: Dump

B. Status: Active X Inactive Unknown

C. History: (Include accidents or injuries on-site, complaints from public, previousreleases and agency reports):EPA RCRA Enforcement Inspectors accompanied by local fire department personnelvisited the site following a recent fire at the dump. During the visit, it was determinedthat wood treated with chromium, arsenic and copper was burned.

D. Is personal protective equipment required by Facility/Site Management?List equipment and specific areas where required:EPA personnel will don modified level D personal protective equipment (i.e., steel toedboots, tyveck pants and booties) while within the perimeter of the dump. EPA staff willalso wear dust masks their necks for easy access and don in the event of dustyconditions.

E. Are employees working at the facility/site monitored for exposure toairborne contaminants? If so, describe situation: Unknown

F. Do employees working at the facility/site participate in an occupationalmedical monitoring program? If so, are special biological tests performed orBiologic Limit Values (BLVs) used?: Unknown

G. Describe medical monitoring procedures for evidence of personnel exposure:Unknown

H. Is there an on-site emergency alarm system? If so, describe alarm: No.

I. Is there an eyewash/safety shower available on site? If not, explainalternate procedures (where applicable): No.

III. HEALTH AND SAFETY CONSIDERATIONS

A. Hazard Assessment (Toxic effects, TLV, odor threshold, reactivity, stability,flammability, and operations hazards with sampling decontamination, etc.)Attach Material Safety Data Sheets for compounds: NA

Areas of Concern Hazard Potential PrecautionsExplosive LOW EPA

staff will work in pairs. No confinedspaces.

Oxygen Deficient(e.g., confined spaces) NA

Particulates

Toxic Gases/Vapors:

Skin/Eye Contact:

Ultraviolet (UV):

Heat Stress:

Falling Objects: NA

LOW EPA staff will also wear dustmasks their necks for easy access anddon in the event of dusty conditions.

LOW Fires are out. If burning isevident, (smoke or smoldering)sampling will not be performed.

LOW Safety glasses, nitrile gloves,Tyvek® pants and will be worn whensampling and will be removed anddisposed on-site. Hands will bethoroughly washed prior to eating ordrinking.

LOW High protection sunscreen andUV rated sunglasses will be worn.

MED Drink lots of fluids. Avoidextended workperiods in direct sun.Use sunscreen and wear hat. Fieldwork will be completed within 1-2 hours.

Uneven ground, construction debris.

Exposure Rate

Falls: pits, ponds, LOWstepping in sediments;elevated work places.

Radioactive Hazard: Hazard?Background NOAlpha Particles NOBeta particles NOGamma particles NO

IV. WORKPLAN INSTRUCTIONS

Hazardous Substance Sampling and Field Investigations

Level of protection: A B C D X

Modifications: Nitrile gloves, steel toed, steel boots, safety glasses, tvvek pants andbooties will be worn during sampling.

Surveillance Equipment and Materials: N/A

Entry procedures:The facility personnel and local law enforcement will be consulted about potentiallyhazardous areas and any special precautions that should be taken.

Field Investigation and Decontamination Procedures: N/A. Only disposableequipment will be used. No decon.

Perimeter Establishment: Zones of Contamination Identified? NAPublic perimeter identified? NAMap/Sketch Attached? NA

EPA Sampling Personnel

Name

Greg Nagle

Field Duties

Sampling

Cert.Level

1

Initial24/40train.

'6/93

Last 8-hrtraining

02/06

Last Resp.fit-test

6/93

Medicalexam

10/05

E. Work Schedule/Limitations: Heat Stress

F. Communications: Cell Phone (707) 373-7801

G. Spill Containment Procedures: (loose particulate absorbent, spill controlpillows, spill pads/blankets): NA

H. Decontamination Procedures: (contaminated protective clothing, instruments,equipment, etc):. NA - Only single use disposable equipment will be used. PPEdisposed of on-site.

Disposal Procedures: (contaminated equipment, supplies, disposal items, wastewater, etc.): All used gloves and miscellaneous garbage will be collected in plasticgarbage bags and disposed on-site.

VII. EMERGENCY PRECAUTIONS:

A. Nearest Hospital Emergency Room. Note: for remote locations, givedirections to hospital and attach map.

Name: Novak Urgent CareAddress: 80545 US Highway 111. Indio. CAPhone: (760)347-9221

B. Emergency Services (Telephone Numbers)

Fire: 911 or (760) 396 2173 (Mecca Station #40)Police: 911Ambulance: 911

C. Health and Safety Office:

Roberto Gutierrez (510)412-2313

JeffWoodlee (415)972-3740

E. Regional Radiation Representative:

Mike Bandrowski (415)947-4194Steve Dean (415)972-3071