EPA documented drums exposed in the creek bank and lying on the ground surface.  The drums contents were colorful and resembled paint.  The drums were in poor condition and leaking their contents. EPA collected three samples from leaking drums and surface soil for total and Toxicity Characteristic Leachate Procedure (TCLP) metals analysis.  Analytical results were compared to regional screening levels (RSL) for industrial soil and regulatory limits for toxicity established in the Resource Conservation and Recovery Act (RCRA), 40 Code of Federal Regulations (CFR) § 261.24.  Drum and surface soil sample results indicated: 

• Two drum samples exceeded the industrial RSL for arsenic of 1.6 milligrams per kilogram (mg/kg) at a maximum concentration of 57.9 mg/kg; 
• One drum sample and the surface soil sample exceeded the industrial RSL for lead of 800 mg/kg at a maximum concentration of 16,100 mg/kg;  and
• The surface soil sample exceeded the lead TCLP limit for lead of 5 milligrams per liter (mg/L) at a concentration of 8.35 mg/L.

Seven subsurface soil samples were collected to determine if material leaking from the drums had migrated.  Samples were analyzed for total and TCLP metals, semi-volatile organic compounds (SVOC), total and TCLP volatile organic compounds (VOC), and PCBs.  Results were compared to industrial RSLs and regulatory limits for toxicity.  Subsurface soil sample results indicated:

• Arsenic was above the industrial RSL of 1.6 mg/kg in 6 of 7 samples with a maximum concentration of 39.8 mg/kg at a depth from 6 to 8 feet;
• Lead exceeded the RSL of 800 mg/kg in 3 of 7 samples at a maximum concentration of 1,500 mg/kg at a depth from 6 to 8 feet; and
• In two samples collected at depths of 3 to 4 feet, PCBs exceeded the industrial RSL of 740 ug/kg in two samples at maximum concentrations of 5,200 and 1,500 micrograms per kilogram (ug/kg), for Aroclor-1248 and Aroclor-1254 respectively, at a depth of 3 to 4 feet.

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• Developing and implementing site plans including a site-specific Health and Safety Plan (HASP), a Quality Assurance Project Plan (QAPP), a Site Emergency Contingency Plan, and a Work Plan;
• Establishing site security;
• Determining the extent of buried drums and contamination in soil;
• Developing and implementing a plan to control, contain, and/or remove drums and highly contaminated soil;
• Performing sampling and analysis to determine disposal options;
• Providing EPA with notice of sampling events five (5) business days in advance of the sampling so that EPA can conduct oversight and split samples; and 
• Consolidating and packaging hazardous substances, pollutants and contaminants for transportation and off-site disposal in accordance with the EPA Off-Site Rule, 40 CFR § 300.440.