Reclamation Manual

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Reclamation Manual LND 12-01
Reclamation Manual

Directives and Standards

(247)
06/23/2006

NEW RELEASE AND SUPERSEDES (51-ENV 02-04) 09/06/1996

(Minor revision approved 08/11/2006)

Page 1
Subject:
Identification and Reporting of Potential Hazardous Substances on
Reclamation Acquired or Withdrawn Lands (Reclamation lands)

Purpose:
Establishes the requirements and responsibilities for identifying and
reporting potential hazardous substance release sites on Reclamation
lands. The benefit of this Directive and Standard (D&S) is an increased
employee awareness of potential hazardous substances and contamination
on Reclamation lands that will result in a more efficient reporting
process. In addition, this D&S will further quantify Reclamations
environmental liability.

Authority:
Occupational Safety and Health Act (Public Law 91-596 as amended;
29 U.S.C. 651 et seq.; 29 CFR 1910); Federal Water Pollution Control
Act (Clean Water Act) (Public Law 92-500 as amended; 33 U.S.C. 1251
et seq.); Toxic Substances Control Act (TSCA) (Public Law 94-469 as
amended; 15 U.S.C. 2601 et seq.); Resource Conservation and Recovery
Act of 1976 (RCRA) (Public Law 94-580 as amended by Public
Law 95-609 and Public Law 98-616; 42 U.S.C. 6901 et seq.);
Comprehensive Environmental Response, Compensation, and Liability
Act (CERCLA/Superfund) (Public Law 96-510 as amended;
42 U.S.C. 9601 et seq.); National Oil and Hazardous Substances Pollution
Contingency Plan, (National Contingency Plan) (Required by Public
Law 96-510; 42 U.S.C. 9605; 40 CFR 300); Emergency Planning and
Community Right to Know Act of 1986 (Title III of the Superfund
Amendments and Reauthorization Act of 1986 (SARA)) (Title III of
Public Law 99-499; 42 U.S.C. 11001 et seq.); Reclamation Manual
Directive and Standard, Required Training and Medical Surveillance for
Hazardous Waste Operations and Emergency Response, ENV 02-06; and
applicable Executive Orders.

Approving Official: Director, Office of Program and Policy Services

Contact:
Office of Program and Policy Services, Lands Resources Office, 84-53000

1.

Purpose. The intent of this D&S is to facilitate efficiency in identifying and reporting
potential hazardous substance release sites by having all staff involved in any periodic or
planned land review and inspection also being aware of both: (a) the possible presence of
potential hazardous material and site contamination on Reclamation lands and (b) the
required procedures to be employed when any such conditions are encountered.

2.

Activities. Employees engaged in all types of field work must be cognizant of any potential
hazardous substances or site contamination they may encounter. They must also be
knowledgeable of the process required to report any such discoveries to the appropriate
Hazardous Material (HazMat) official. (See Paragraph 3.B. Report.) Reporting the
discovery of potentially contaminated sites is required in conjunction with field work LND 12-01
Reclamation Manual

Directives and Standards

(247)
06/23/2006

NEW RELEASE AND SUPERSEDES (51-ENV 02-04) 09/06/1996

(Minor revision approved 08/11/2006)

Page 2
associated with any land reviews being implemented, such as the periodic review of
unneeded acquired lands or withdrawal reviews as well as all other field work being
performed such as cultural resource surveys, land surveys and land-use reviews, recreation
reviews, engineering and biological surveys, Environmental Management Systems audits,
and the inspection and monitoring of permitted facilities and other authorized land uses
taking place on Reclamation lands. This D&S defines the identification and reporting
process. Compliance with this D&S does not in any way constitute compliance with Phase I
Environmental Site Assessment as defined in American Society for Testing and Materials
(ASTM) Standard No. E1527-05.

A.

Training. Pursuant to the requirements of ENV 02-06, awareness training shall be
required for all Lands, Realty, Recreation and other appropriate personnel prior to
engaging in field activities where they may encounter potential hazardous substances
and hazardous waste. Paragraph 1.A. of
ENV 02-06
states, All appropriate personnel
shall receive training on recognition, safety, and appropriate response for hazardous
wastes in the field, including wastes discovered incidentally in the performance of
other duties.

B.

Use Caution. With all sites that are potentially contaminated with hazardous
substances, use caution when approaching. Employees must remain outside of the
apparent perimeter of any contaminated site and, when possible, only approach any
such site from an up-wind direction, paying close attention to any signs of danger.
Drums and tanks must not be moved or disturbed. Unlabeled drums or containers must
have their contents determined by proper sampling and testing methods. Do not sniff,
inhale, touch, or make contact with any unknown substance. Under no circumstances
should the employee try to move a drum or tank, or kick a container to determine the
amount of contents. If a strong or unusual odor is detected, leave the area immediately
in an up-wind direction.

3.

Employee Responsibilities. Employees who encounter any observed indicators of
hazardous substance releases (including those noted in Paragraph 4. Indicators and Actions)
while conducting their normal field work are required to document and report such findings
to the appropriate person as identified below. Observation and documentation will only be
performed at a safe distance. Under no circumstances should field personnel closely
approach potentially hazardous substances or contaminated sites unless specifically trained
to do so.

A.

Document. Employees conducting field work must document any observed indicators
of potentially contaminated sites. Documentation must include the name of the
person(s) performing the field work, the time and date of the field work, identification
of the field work site, a brief description of the indicator as noted in Paragraph 4.
Indicators and Actions, and the location of the indicator down to at least the nearest
section. Map the access to the location of the potentially contaminated site LND 12-01
Reclamation Manual

Directives and Standards

(247)
06/23/2006

NEW RELEASE AND SUPERSEDES (51-ENV 02-04) 09/06/1996

(Minor revision approved 08/11/2006)

Page 3
(preferably on a U.S. Geological Survey (USGS) topographic map) providing
approximate distances and landmarks. Whenever possible, the employee will take
photographs of their findings.

B.

Report. Employees conducting field work must report any observed indicators of
potentially hazardous substances or contaminated sites to both their supervisor and
Facility or Area Office HazMat Coordinator or Regional HazMat Coordinator, as
appropriate. Follow established reporting procedures and report hazardous substance
incidents as soon as possible.

C.

Do Not Contaminate. It is important that the employee takes precautions not to
contaminate others. If an employee has been exposed to potentially hazardous
substances, proper decontamination procedures must be followed. If a vehicle must be
used to return from the field, take reasonable precautions and minimize additional
exposure. Vehicles and equipment may require decontamination prior to use by others.
Do not enter buildings or facilities without taking appropriate precautions or first
following decontamination procedures.

4.

Indicators and Actions. Common indicators of lands contaminated by hazardous
substances, and actions to take, include:

A.

Abandoned Cans, Drums or Large Tanks. Note signs of leaking (stained soil) and
condition (rusted, dented, bulging). Look for labels, but do not handle, any such cans,
drums, or tanks. Note if labels are missing or note the contents if label is present. If
the contents are visible, note the color and whether they are solids or liquid. Also note
any stressed vegetation or dead animals near the spill.

B.

Abandoned Vehicle Batteries. Note whether or not battery cases are intact and
estimate the size of the area of any associated stains.

C.

Abandoned Vehicles or Construction Equipment. Note the condition of the vehicles
or equipment and the make and/or model, if possible. If a Vehicle Identification
Number or license number can be located without risking exposure to hazardous
substances, report that as well.

D.

Abandoned Storage Sheds. Look for stains around the foundation. Do not open if
strong or unusual odors are present.

E.

Suspicious Grouping of Trash Bags or Cans. This can possibly indicate or be the
remains of illegal drug manufacture especially if strong or unusual odors are present. If
strong or unusual odors are detected, do not approach.

F.

Stained Soil. Stained soil is a possible indication of a spill. The extent of the stain is a
potential indicator of the amount spilled. Estimate the size of the stained area and no