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SAMPLING AND ANALYSIS PLAN -2- ,OF POTENTIAL TOXIC PIT CLEANUP ACT (TPCA) SURFACE IMPOUNDMENTS the sludge column appears to be homogenous, the sample may be vertically composited. Samples from different borings may not be composited. Sampling Liquid Wastes Liquid wastes in the surface impoundment need to be sampled in addition to the sludges. The same elements of sample representativeness and waste heterogeneity should be considered before sampling the liquid wastes. The time variable element may be more important when. sampling the liquid wastes. A number of samples should be collected from the same site at different times to define this variability. Chemical Analysis The waste liquid and sludges should be chemically analyzed to demonstrate the hazardous vs non -hazardous nature of the waste. Chapter 30, Division 4 of Title 22 of the California Administrative Code should be referenced in making the determination. At a minimum, analysis should include any hazardous materials handled at the facility and any other hazardous compounds that could be created from those compounds during manufacturing and/or waste treatment processes. If any constituents identified during chemical analysis of the waste is found in the list of Hazardous Waste and Hazardous Materials in Article 9, then the potential hazardous property indicated in the Article 9 list must be evaluated pursuant to the criteria setforth in Article 11. A demonstration of the appropriateness of the number of samples used to evaluate the waste should be included i n the data analysis. The program designed to analyze the wastes should be specific to the industry. If the analysis program is not performed as requested above, rationale and supporting documentation is required to justify the proposed program. Reporting A sampling and analysis report shall be submitted by a qualified professional knowledgable in sampling and laboratory protocol. The report shall describe, in detail, the sampling and analysis program performed to determine if the surface impoundments contain hazardous wastes and are subject to TPCA. This report shall specifically discuss: Surface Impoundment Characteristics (size, depth, holding capacity, waste type, inflow, outflow, pond type (evaporation, treatment, storage, etc.), sludge thickness and variability, etc.) ° Sampling Plan (number of samples, sample location, sampling equipment methodology, sample preparation, equipment decontamination procedures, etc.j Analysis Plan (analytical procedures, methodology, field and lab QA/QC, etc.) o Also, maps, cross-sections and appropriate drawings should accompany the tabulated data in the report.