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&EPA
United States
Environmental Protection
Agency
Off ice of Air Quality
Planning and Standards
Research Triangle ParK NC 27711
EPA -450/1 -90-001
January 1990
Air/Supertund
AIR/SUPERFUND
NATIONAL TECHNICAL
GUIDANCE STUDY SERIES
Superfund Air Pathway Analyses
Review Criteria Checklists
Final
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DCN 90-203-080-61-02
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• by
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SUPERFUND AIR PATHWAY ANALYSES
REVIEW CRITERIA CHECKLISTS
FINAL REPORT
John E. Letkeman
Radian Corporation
8501 Mo-Pac Boulevard
Austin, Texas 78720
Contract No. 68-02-4392
Work Assignment No. 61
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Grace M. Musumeci, Project Officer
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION II, AIR PROGRAMS BRANCH
26 FEDERAL PLAZA
NEW YORK, NEW YORK 10278
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17 January 1990
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DISCLAIMER
This report was prepared for the U.S. Environmental Protection Agency by
Radian Corporation, Austin, Texas, under Contract No. 68-02-4392, Work
Assignment No. 61. Mention of trade names or commercial products does not
constitute endorsement or recommendation for use by the Air Management
Division, U.S. Environmental Protection Agency.
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CONTENTS
Acknowledgment ........................... i-v
1. Introduction ....................... 1
2 . Background ........................ 3
• 3. Purpose and Use of the Checklists ............. 4
A. Content and Format of the Checklists
References
M. Appendices
™ A. Review Criteria Checklist for the Workplan of the
Superfund Remediation Process
• B. Review Criteria Checklist for the Remedial Investigation
Phase of the Superfund Remediation Process
• C. Review Criteria Checklist for the Feasibility Study Phase
of the Superfund Remediation Process
ID. Review Criteria Checklist for the Remedial Design Phase
of the Superfund Remediation Process
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ACKNOWLEDGMENT
This document was prepared for the U.S. Environmental Protection Agency
(EPA) by Radian Corporation. The project was managed by Ms. Grace M. Musumeci
EPA Region II, Air Programs Branch. The principal author was Mr. John
Letkeman of Radian with assistance from Mr. Kirk Hummel. The author would
like to thank Mr. Thomas Morahan, Mr. Bart Eklund, Mr. Michael Kienbusch, and
Ms. Sandra Smith of Radian for their guidance and assistance.
iv
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SECTION 1
INTRODUCTION
This report documents the development of checklists for the review of
Superfund Air Pathway Analyses (APAs). Under the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA) and the recent Superfund
Amendments and Reauthorization Act (SARA), EPA has the responsibility for
assessment and cleanup of Superfund sites. Because air emissions pose a
potential human health risk at these sites, the EPA developed a four-volume
set of procedures for evaluating these risks entitled Procedures for Conduct-
ing Air Pathway Analyses for Superfund Applications (hereafter referred to as
the NTGS volumes).
The task of ensuring that all aspects of determining the effects of
airborne pollutants from hazardous waste sites is very complex and therefore a
systematic approach is necessary. The Checklists presented here are designed
to assist reviewers of EPA documents in systematically applying the proced-
ures. The checklists contain questions on all important aspects of the APA
process to ensure that all significant risks are evaluated.
Four separate checklists were drafted sequentially and revised according
to EPA comments. Each checklist coincides with one of the major deliverables
of the Superfund Remedial Action process. Air pathway assessment techniques
were applied to the Superfund remedial action process to develop the set of
questions which make up each checklist. Information for the content of the
checklists was drawn from Superfund documents, the NTGS series, other check-
lists, and Radian's experience in the field.
This report presents Radian's work under EPA Contract 68-02-4392, Work
Assignment 61. The report discusses the background, summarizes related
documents, discusses the use of the checklists, summarizes the contents of
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each checklist and provides the final versions of the checklists in the
V appendix. A reproducible master set of checklists is provided separately.
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SECTION 2
BACKGROUND
Although the methods of air pathway analyses of environmental air
pollutants are reasonably well understood, the application of these methods to
hazardous waste sites is fairly new. In addition the problems of estimating
the emissions from the hazardous waste sites are complex because the source
contamination level is rarely known with great precision. The APA problems
encountered at hazardous waste cleanup sites require techniques specifically
designed for hazardous waste sites. The NTGS volumes were therefore completed
in 1989 to provide the required techniques.
The NTGS volumes contain four volumes of detailed procedures for the
following:
• An overview and general APA procedures;
• Emission estimates from uncontrolled Superfund sites with an
emphasis on landfills and lagoons;
• Emission estimates from remedial activities such as material moving
and sources such as incinerators and strippers; and
• Dispersion modeling and air monitoring methods.
Technical resources are provided for the design of measurement programs,
dispersion estimates, emission controls, and impact assessments. The series
is designed to be used by EPA remedial project managers, enforcement project
managers, air experts, and contractors involved in Superfund remediation
activities.
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SECTION 3
PURPOSE AND USE OF THE CHECKLISTS
The checklists are intended for use by EPA air reviewers when they are
performing the tasks of reviewing the APAs submitted with Superfund remedial
action documents. The format of the APAs has been known to vary significantly
from one project to the next. The organization and presentation of informa-
tion dealing with air pathway analyses can vary. In some cases, the reviewer
must review large volumes of data to find the required information. In
consideration of the above variations and difficulties, the checklists are
designed to organize the process of review and to ensure that all necessary
components of the APA are evaluated.
The APA procedures provide a systematic approach which involves applica-
tion of modeling and monitoring methods to estimate emission rates and
concentrations of air contaminants. The procedures are designed to be
flexible, allowing professional judgment to vary the performance of the APA.
The checklists reflect the flexibility of the procedures while providing a
systematic format of review. The checklists are not intended to prescribe the
content and format of the APAs. They are designed to be applied to many
different styles of Air Pathway Analyses. It should be possible to apply the
checklist to all Superfund projects, although some projects will not require
application of all the sections of the checklists.
With a few exceptions, the checklists do not provide reference data
because the volume of data required would be too great. Reference data may be
found in the NTGS volumes, in Applicable or Relevant and Appropriate Require-
ments (ARARs), and other engineering and scientific manuals.
It is expected that the checklists will be reviewed and revised as
regulations and procedures vary and as experience in the use of the checklists
becomes instructive.
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The diversity in Superfund remedial activities require versatility in the
procedures while at the same time the pathway of all known toxins must be
evaluated as accurately as is possible. The nature of the air pathway
analyses which must be reviewed by the EPA therefore vary significantly from
one project to another. Therefore a concise but versatile review guidance is
required to help the reviewer determine whether all necessary factors are
evaluated. This guidance is provided as a set of questions contained in the
checklists which the reviewer can apply to the submitted Superfund documents.
The EPA has developed a checklist for the review of PSD applications.
The PSD checklist asks specific questions regarding measurements of air
quality parameters. The four Superfund APA checklists differ from the PSD
checklist in that they are more general in nature. This generality is
necessary because these checklists must deal with the high variability in
Superfund projects and criteria and non-criteria pollutants while the PSD
checklist deal with criteria pollutants.
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SECTION 4
CONTENT AND FORMAT OF THE CHECKLISTS
The four checklists developed for the review of Superfund documents are
directed towards the deliverable documented results of Superfund projects.
The individual checklists contain an identification section, an instruction
section, some brief information, and sectionalized sets of questions related
to specific portions or the required Superfund process. The four separate
checklists are titled as follows:
• Review Criteria Checklist for the Workplan of the Superfund Remedia-
tion Process (WP Checklist);
• Review Criteria Checklist for the Remedial Investigation Phase of
the Superfund Remediation Process (RI Checklist);
• Review Criteria Checklist for the Feasibility Study Phase of the
Superfund Remediation Process (FS Checklist); and
• Review Criteria Checklist for the Remedial Design Phase of the
Superfund Remediation Process (RD Checklist).
The WP checklist prompts the air reviewer to ensure that all the neces-
sary aspects of the remedial investigation and the feasibility study are
contained in the workplan. Questions concerning existing data on site
conditions, preliminary site measurements, safety, planned analyses, and
scheduling are included in the checklist.
The RI Checklist presents questions which prompt the reviewer to evaluate
the completeness of the data presented to characterize the baseline conditions
of the site. Sections on the physical characteristics of the site, the
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characterization of the contamination, emission estimates, dispersion esti-
mates, and ambient monitoring results, and exposure assessments are included.
The FS checklist includes questions on the physical site characteristics,
site characterization, data quality, and a table for evaluation of each
remedial alternative in respect to the above questions as well as ARARs,
emission controls, waste disposal, emission monitoring, long-term effective-
ness, storage and handling, and overall protection of the environment.
The RD Checklist contains questions on physical site characteristics,
contaminant characterization, emissions, modeling, monitoring, and a table for
results of questions on particular aspects of the APA for each contaminant
being remediated. An additional table providing sources of potential ARARs is
provided as a resource.
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REFERENCES
1. U.S. Environmental Protection Agency. Volume I - National Technical
Guidance Series - Application of Air Pathway Analyses for Superfund
Activities. EPA-450/1-89-001, NTIS PB90 113374/AS.
2. U.S. Environmental Protection Agency. Volume II - National Technical
Guidance Series - Estimation of Baseline Air Emissions at Superfund
Sites. EPA-450/1-89-002, NTIS PB89 180053/AS.
3. U.S. Environmental Protection Agency. Volume III - National Technical
Guidance Series - Estimation of Air Emissions From Clean-up Activities at
Superfund Sites. EPA-450/1-89-003, NTIS PB89 180061/AS.
4. U.S. Environmental Protection Agency. Volume IV - National Technical
Guidance Series - Procedures for Dispersion Modeling and Air Monitoring
for Superfund Air Pathway Analyses. EPA-450/1-89-004, NTIS PB90
113382/AS.
5. U.S. Environmental Protection Agency. PSD Permit Applications Review
Checklist. Internal Publication.
6. U.S. Environmental Protection Agency. Guidance for Conducting Remedial
Investigations and Feasibility Studies Under CERCLA. EPA/540/G-89/004.
Washington, D.C., October 1988.
7. U.S. Environmental Protection Agency. Guidelines on Air Quality Models
(Revised). EPA-405/2-78-027R. NTIS PB86 245248. Office of Air Quality
Planning and Standards. July 1986.
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APPENDIX A
REVIEW CRITERIA CHECKLIST
FOR THE WORKPLAN PHASE
OF THE SUPERFUND REMEDIATION PROCESS
(WP CHECKLIST)
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REVIEW CRITERIA CHECKLIST FOR THE WORKPLAN OF THE SUPERFUND REMEDIATION PROCESS
(WP CHECKLIST)
SITE IDENTIFICATION
Site Name: Account No.j
Operable Unit: County/State:
Proj ect Manager: Branch: Phone:
Air Reviewer: Branch: Phone:.
Date Document Received: Date Review Completed:
INSTRUCTIONS TO THE REVIEWER: This checklist is formatted along the lines of
the Air Pathway Analysis process. Each work plan section contains a number of
questions indicating what air-related information to look for. Each question
should be marked according to the quality of the information presented in the
work plan submission. We recommend a scale of one to four for the quality
rank (1 - Very Thorough, 2 - Acceptable, 3 - Needs Revision, 4 - Missing).
The deficiencies may then be compiled and summarized by the reviewer in a
format of his/her choice. Tables 1 and 2 are attached to assist the reviewer
in checking off requirements for multiple contaminants.
Section I relates to the presentation of the site conditions affecting the
level of contamination and the air pathway.
Section II asks questions related to preliminary site measurements which may
have been made in order to adequately characterize the contamination at the
site for the purpose of scoping and planning. These preliminary measurements
may or may not have actually been performed.
Section III contains questions on the characterization of the contamination
with air pathway potential. Amounts, concentrations, risk analyses, and
emission descriptions are examined. This section examines the quality of the
information that the RPM is using as a basis for the RI.
Section IV includes questions which will help determine whether or not the
planned measurements and analyses will provide sufficiently accurate and
complete information to assess the risks to the environment due to the
baseline site conditions and the remedial activities.
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WP CHECKLIST (Continued)
I. SITE DESCRIPTIONS
1. Physical Setting Description:
a. Contour and land use maps of waste area and
surroundings ?
b. Schematic diagrams of facilities?
c. Climatology: wind velocity rose, temperature
means and extremes?
d. Descriptions of major geographical features
affecting dispersion?
R N/A Page
NOTES:
2. Are the distance and direction from the emission
hazards to the susceptible receptors clearly
identified? (See #3 below for examples of sus-
ceptible receptors)
NOTES:
Air contaminant receptor descriptions for the following?
a. Population centers, sensitive receptors such as
schools, hospitals
b. Farming, food train entries, transportation routes
c. Flora, fauna, endangered species?
NOTES:
4. Are previous biological testing results discussed as
related to acute and chronic toxicity or bioaccumulation
in the food chain?
NOTES:
5. History of site use: Disposal, closure, cleanup, other
activities:
a. What was disposed during which time periods?
b. Previous cleanup attempts?
c. Is the time and method of site closure described?
d. Other previous activities at the site described?
NOTES:
6. Previous Air Quality enforcement actions or complaints?
NOTES:
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WP CHECKLIST (Continued)
II. SITE ANALYSES PRIOR TO THE REMEDIAL INVESTIGATION
R N/A Page
1. List the contaminants known to be present at the site prior to the
preliminary site analyses:
Are concentrations and quantity known for pollutants
in liquid or solid phases with related potential to
emit air pollutants?
Are data classified according to physical and
chemical characteristics (e.g., volatiles, semi-
volatiles, metals, particulates)?
NOTES:
2. Are site specific and regional atmospheric data
related to air pathways listed?
NOTES:
Existing air quality data summary:
a. Results of any previous sampling events: Air
quality data related to the identified potential
air contaminants?
b. Is evidence of air contamination impacts documented?
c. Is information on the data precision and
accuracy included?
NOTES:
4. Interim work plan:
a. Was an interim Health and Safety Plan (HSP)
submitted?
b. Are potential air contaminants addressed in HSP?
c. Were measurements of potentially hazardous air
contaminants taken and used as input to the HSP?
d. Were data quality objectives defined for the
interim work plan?
e. Is a detailed description of the preliminary site
analyses provided?
f. List the contaminants and concentrations which
were measured in the preliminary site work:
NOTES:
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Are reasons included for the decisions on whether to make
additional site measurements for each of the following?
a. Air Monitoring
b. Site mapping
c. Limited sampling to determine the need for waste
treatability studies
d. Preliminary ecological reconnaissance?
NOTES:
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• WP CHECKLIST (Continued)
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WP CHECKLIST (Continued)
III. CONTAMINANT IDENTIFICATION AND CHARACTERIZATION
R N/A Page
Waste characteristics:
a. Distribution and volumes of types of waste described?
b. Contaminants in the waste identified and
characterized?
NOTES:
Is a schematic model showing potential routes of
exposure provided?
a. Primary, Secondary air releases shown?
b. Known and potential air emission sources shown?
c. Known and potential air pathways shown?
d. Known and potential receptors shown?
NOTES:
3. a. Was a preliminary air contaminant hazard ranking
performed?
b. Results of hazard ranking summarized?
NOTES:
4. Was a preliminary assessment of human health and
environmental impacts (a risk assessment for each
pollutant identified) performed?
NOTES:
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WP CHECKLIST (Continued)
IV. PLANNED ANALYSES DURING REMEDIAL INVESTIGATION
Preliminary identification (list) of air ARARs and TBC
a. For potential emission sources resulting from
possible remedial actions?
b. For existing sources and contaminants?
R N/A Page
NOTES:
If a preliminary air pathway assessment is
required for planning purposes, does it include
the following?
a. Remedial action objectives listed?
b. Identification of potential remedial alternatives?
c. Potential technologies identified?
d. Literature sources documenting technology
effectiveness?
NOTES:
Is the level of sophistication given for each of
the parameters to be measured?
a. Ambient air quality measurements
b. Emission measurements
c. Meteorological measurements
d. Emission estimates
e. Dispersion model estimates
NOTES:
4. Has the work plan indicated whether modeling or
monitoring methods will be used to estimate the air
quality impact for each contaminant?
NOTES:
5. Is the approach supported with a justification?
NOTES:
6. Does the reviewer feel that the appropriate analysis
methods are planned (Table 21, Volume IV, APA
procedures)?
NOTES:
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• WP CHECKLIST (Continued)
R N/A Page
• 7. Will the APA schedule and approach provide adequate
measurement data and still meet the project schedule?
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NOTES:
• 8. Are the planned duration and frequency of monitoring
sufficient (Table 20, Volume IV, APA procedures)?
NOTES:
I 9. Have the data uses been identified and prioritized?
NOTES:
10. Are the DQOs or level of sophistication appropriate
• to the data uses?
NOTES:
11. Will the testing plan fill the data gaps identified
during the initial evaluation?
NOTES:
• 12. Are the qualifications and training of the monitoring,
modeling, and QA/QC staff described and adequate?
NOTES:
13. Do the planned emission measurements meet State
regulations?
NOTES:
• 14. Do the planned screening approaches meet the guidelines
as shown in Table 6 of Volume IV, APA procedures?
NOTES:
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• WP CHECKLIST (Continued)
_ R N/A Page
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15. Does the dispersion modeling plan follow the guidelines
in Table 8, Volume IV, APA procedures?
NOTES:
NOTES:
|| 16. Is the planned meteorological database sufficient for
modeling and monitoring APA activities?
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TABLE 1. TABLE OF CONTAMINANT IDENTIFICATION AND CHARACTERIZATION
List of Contaminants Identified or Expected
#2
#7
#8
#10
#12 #13
#14
#15
vo
Contaminant Name (or Formula)
Information Required
Concentration data meet DQOs?
QA/QC sufficient?
Media Described?
Hazard index known?
Amount of contaminant defined?
QA/QC sufficient?
Media Described?
Hazard index known?
Emission points defined?
Volumetric rates for point sources?
Dimensions of sources defined?
Concentration at source?
Mass emission rates: average long-term
Mass emission rates: short-term
Density relative to air?
Particle size distribution?
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WP CHECKLIST (Continued)
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APPENDIX B
REVIEW CRITERIA CHECKLIST
FOR THE REMEDIAL INVESTIGATION PHASE
OF THE SUPERFUND REMEDIATION PROCESS
(RI CHECKLIST)
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REVIEW CRITERIA CHECKLIST FOR THE REMEDIAL INVESTIGATION
PHASE OF THE SUPERFUND REMEDIATION PROCESS
(RI CHECKLIST)
SITE IDENTIFICATION
Site Name: Account No.j_
Operable Unit: County/State:
Project Manager: Branch: Phone:
Air Reviewer: Branch: Phone: _
Date Document Received: Date Review Completed:
INSTRUCTIONS TO THE REVIEWER: This checklist is formatted along the lines of
the Air Pathway Analysis process. Each work plan section contains a number of
questions indicating what air-related information to look for. Each question
should be marked according to the quality of the information presented in the
work plan submission. We recommend a scale of one to four for the quality
rank (1 - Very Thorough, 2 - Acceptable, 3 - Needs Revision, 4 - Missing).
The deficiencies may then be compiled and summarized by the reviewer in a
format of his/her choice.
Tables 1, 2, and 3 are provided to aid the reviewer in tracking the
performance of the RI for each contaminant. If the potential air contaminant
is identified in the work plan it should be tracked in the RI report through
the stages of the APA. The reviewer may want to assign an identification
number to each contaminant of interest and use the same identification in each
table. The reviewer may enter a 'Y' on 'N' in appropriate cells to indicate
sufficiency of the submission, or she/he may choose to enter values for easy
access later in the review process.
Part A contains the baseline risk assessment review under the following
sections:
I PHYSICAL CHARACTERISTICS OF THE SITE
II NATURE AND EXTENT OF CONTAMINATION
III EMISSION ESTIMATES
IV ATMOSPHERIC DISPERSION ESTIMATES
V AMBIENT AIR MONITORING RESULTS
VI EXPOSURE ASSESSMENT
Part B contains a question on the estimates of disturbed site emissions.
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RI CHECKLIST (Continued)
PART A BASELINE RISK ASSESSMENT
SECTION I - REMEDIAL INVESTIGATION: Physical Characteristics of the Site
R N/A Page
1. Are topographic features and water bodies at the site
and vicinity discussed and graphically displayed?
NOTES:
2. Are the soil and vegetation characteristics of the site
and vicinity described?
NOTES:
3. Are the distance and direction from the emission hazards
to the susceptible receptors clearly identified?
NOTES:
4. Does the site investigation provide survey data on the
human population (especially off-site) that may have
been exposed to contaminated air from the site?
NOTES:
5. Does the site investigation include information on:
a. Possible health effects?
b. Health complaints?
NOTES:
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RI CHECKLIST (Continued)
SECTION II - REMEDIAL INVESTIGATION: Nature and Extent of Contamination
R N/A Page
1. [Note: Question 1 is of critical importance.] Have
the level and extent of contamination of surface-water,
sediment, soil, and ground-water been determined?
Has the uncertainty of estimates been sufficiently
defined?
NOTES:
Does the analysis sufficiently characterize volatiles
or hazardous inorganics with air release potential?
A contaminant characterization matrix is attached
which will aid the reviewer in checking that all
required data on each contaminant is addressed.
NOTES:
3. Has the source of the waste been identified? (Sources
may include petroleum refining, pesticide production,
petrochemical or chemical manufacturing, etc.)
NOTES:
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RI CHECKLIST (Continued)
SECTION III - REMEDIAL INVESTIGATION: Baseline Emission Estimates
R N/A Page
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1. Were screening level emission source sampling studies
performed?
NOTES:
• 2. Are results from screening level studies presented?
NOTES:
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3. Were all units of a combined site studied?
NOTES:
4. Was a QA/QC program to assess data quality sufficient?
NOTES:
5. Was it determined that the screening study was
adequate to characterize the air contamination
• migration pathway?
NOTES:
6. If a detailed baseline emissions estimate was then
_ deemed necessary, were in-depth survey technologies
• then implemented?
NOTES:
7. If the screening study was deemed to sufficiently
•characterize the air pathway, does the reviewer concur
(i.e., decision to terminate the APA due to lack
of impact)?
NOTES:
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RI CHECKLIST (Continued)
R N/A Page
8. Does the emission model fully describe the waste
characteristics:
a. Volatiles - vapor pressure, Henry's Law constant,
water solubility, temperature?
b. Particulates - rainfall, wind speed, physical
state of waste, porosity and density of soil,
moisture content of soil?
NOTES:
How were the indicator chemicals selected (also
called "target compounds")? Did the contractor follow
the methodology for selecting these compounds for
assessing human health risks as described in the
"Superfund Public Health Evaluation Manual"
(U.S.EPA, Oct. 1986)?
NOTES:
10. Does the report relate the selection of indicator species
to the ideal indicator as described in Volume II, NTGS
APA manual (p. 36)?
NOTES:
11. After selection of the indicator chemicals, is there
discussion of a final check to be made during remedy
selection to ensure that the proposed strategy will
address risks posed by the full range of contaminants
at the site?
NOTES:
12. Do the emissions rates correlate with information
available on the types of waste contained at the site
(i.e., presence of waste solvents resulting in
volatile emissions, presence of asbestos waste
resulting in particulate emissions)?
NOTES:
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RI CHECKLIST (Continued)
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Potential Routes of Migration
13. Did the report consider all soil/waste characteristics
which would affect migration (i.e., adsorption or
absorption properties of the soil, solubility in
water, microbial action of soil, moisture content
of soil)?
NOTES:
14. Were other site characteristics included (i.e.,
temperature, pressure, wind speed, presence of
berms or wind breaks, and waste geometry)?
NOTES:
15. Based on meteorological data above and waste location,
could soil particulates (i.e., entrained dust) be a
potential source of emissions?
NOTES:
16. Was soil sampling extensive enough to determine that
potential "hot spots" are located?
NOTES:
Air Emissions from Surface Wastes
17. Are all potential forms of air emissions from surface
wastes considered:
a. Gas phase mechanisms include: volatilization,
biodegradation, photodecomposition, hydrolysis,
and combustion.
b. Particulate mechanisms include: wind erosion,
mechanical disturbance, combustion, and
absorption.
NOTES:
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RI CHECKLIST (Continued)
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18. Did the report include air emissions from gas migration
controls (if present)?
NOTES:
19. Did the report include air emissions from volatilization
of dissolved contaminants from contaminated ground
water?
NOTES:
Air Emissions from Subsurface Wastes
20. Are all potential forms of air emissions from
subsurface wastes considered (includes emissions
at the surface soil/atmosphere interface caused by
contaminated soil gas)?
NOTES:
21. Were emissions (predictive) models used to compare or
validate other emissions estimates?
NOTES:
22. Were QA/QC checks performed to evaluate the model?
NOTES:
23. Is the emissions model appropriate for the source
(i.e., has the model been validated)?
Validated models for various emission sources include:
a. AP-42 Dust Emission from Vehicles
b. Covered Landfill Models
c. Open Dump Models
d. Lagoon Models
NOTES:
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J RI CHECKLIST (Continued)
• R N/A Page
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mation given?
I a. Are the models referenced?
b. Are accuracy and limitations discussed?
c. Is the version or date given?
NOTES:
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RI CHECKLIST (Continued)
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• SECTION IV - REMEDIAL INVESTIGATION: Atmospheric Dispersion Estimates - If
™ modeling is required, the following questions apply:
I
1. Are model inputs documented in a form similar to
m Table 3, Volume IV, of the APA procedures?
NOTES:
• 2. Is the emission inventory defined according to
guidelines (Section 2.4.4, Volume IV, APA procedures)?
NOTES:
• 3. Are the screening technique used appropriate (list of
* techniques and applications shown in Table 6, Volume IV,
APA procedures?
NOTES:
• 4. Are the refined techniques used listed in Table 7,
Volume IV, APA procedures?
NOTES:
15. Is the receptor grid adequately designed to include
sufficient detail for all receptors, with higher
resolution for sensitive receptors?
• NOTES:
16. If any other modeling technique (other than those
listed in volume IV) is used, is an adequate
justification provided?
NOTES:
(Table 5, Volume IV)?
NOTES:
• 7. Does the meteorological data set meet program DQOs
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RI CHECKLIST (Continued)
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8. If off-site meteorological data are used, are the data
B representative of the site?
NOTES:
9. Is the length of the meteorological data set sufficient?
I NOTES:
10. Was a benchmark test case run on the model?
NOTES:
t
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• NOTES:
12. Was the model uncertainty addressed in the analysis
of results?
NOTES:
13. Was a supplemental analysis performed if necessary?
NOTES : _ _ _
• 14. Is the modeling report complete (the recommended
™ outline is found on page 2-76 of Volume IV,
APA procedure)?
NOTES:
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SECTION V - REMEDIAL INVESTIGATION: Ambient Air Monitoring Results
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1. Were the indicator chemicals (also called "target
compounds") selected according to the guidelines
(Section 3.4.2, Volume IV, APA procedures)?
NOTES:
2. Was the choice of screening methods appropriate?
NOTES:
3. Does the reviewer agree with the conclusions drawn from
the screening studies? The attached Air Monitoring
Results table can be of assistance in tracking and
evaluating the completeness and quality of the
screening studies for each contaminant of concern.
The results can be related to the application of the
sampling techniques as summarized in Table 14, Volume
IV, APA procedures.
NOTES:
4. Was the Quality Assurance/ Quality Control sufficient
(Tables 35 & 36, Volume IV, APA procedure)?
NOTES:
5. Are Monitoring result Summaries sufficient
(use attached Table 2)?
NOTES:
Meteorological Investigations (Guidelines are found in Section 3.4.3,
Volume IV, APA procedures)
6. Does the meteorological program meet the requirements
of the APA procedures for the following categories?
a. Screening studies
b. Refined studies
c. Data quality objectives (Tables 16 & 17
Volume IV)
d. Monitor network design survey (if applicable)
NOTES:
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RI CHECKLIST (Continued)
SECTION VI - REMEDIAL INVESTIGATION: Exposure Assessment
An EXPOSURE ASSESSMENT table which relates each air contaminant
identified to the requirements below is attached to assist the reviewer in
tracking performance of the APA.
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1. Are all existing human receptors identified (including
sensitive subpopulations such as pregnant women and
infants)?
NOTES:
2. Are both acute and chronic exposure addressed?
NOTES:
3. Does the site investigation adequately assess plant and
animal life that may have been exposed to identified
air contaminants from the site?
NOTES:
NOTES:
5. Were any endangered species and their habitats
identified?
NOTES:
6. Is the surrounding area home to any species which are
consumed by humans or found in human food chains?
NOTES:
7. Are future possible changes in receptors discussed
(i.e., what are implications for long-term)?
NOTES:
12
4. Were any sensitive environments identified (examples
include wetlands, flood plains, wildlife breeding
areas, wildlife refuges, and other specially designated
areas such as parks and scenic areas)?
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RI CHECKLIST (Continued)
8. Have exposure estimates from modeling results and from
monitoring studies been adequately applied to
applicable state and federal ARARS?
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NOTES:
9. Have modeling and monitoring results been compared
V and the differences discussed?
NOTES:
10. Is the level of contamination of plant and animal
_ life known? (Potential impact on food chain?)
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RI CHECKLIST (Continued)
PART B ASSESSMENT OF DISTURBED SITE CONDITION
I. If any preliminary removal action is performed or planned, does the
report include any estimates of air emission rates from the source in its
disturbed state resulting from possible remediation activities such as
the following?
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fl. Excavation (e.g., possibility of breaching buried tanks
or drums, or additional exposure of volatile waste when
removing overburden)
NOTES:
2. Transport (e.g., additional particulates caused by
increased vehicular traffic)
NOTES:
3. Dumping
NOTES:
4. Storage
NOTES:
3. Grading
NOTES:
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TABLE 1. CONTAMINANT CHARACTERIZATION MATRIX
Contaminant
#1 #2 #3 #4 #5 #6 #7 #8 #9 #10 #11 #12 #13 #14 #15
Parameter
1. Volume
2. Physical Dimensions
3. Concentration
4. Media
5. Media Properties
6. Exposure
7. Containment
8. Physical Location
9. Volatility
10. Biodegradability
11. Particle Size Distribution
12. Wind Erodibility
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TABLE 2. AMBIENT AIR MONITORING RESULTS
Contaminant
Parameter
#1
#2
#3
#4
#5
#6
#7
#8
#9
#
10
*
11
#
12
#
13
4
1*
«
15
1. Level of Sophistication
2. Existing Data
3. Detection Limits
it. Upwind Concentrations
5. Sample Periods Reported
6. Number of Samples
7. Mean Concentrations
8. Minimum Concentrations
9. Maximum Concentrations
10. Number of Excursions
ARARS
H & S Criteria
Odor Thresholds
11. Data Recovery Rates
12. Plots of Results
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TABLE 3. EXPOSURE ASSESSMENT
Contaminant
Exposure Data
#1
#2
#3
#4
#5
#6
#7
#8
#9
4
10
#
11
#
12
#
13
4
14
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15
1. Acute Exposure
2. Chronic Exposure
3. Gas Phase
4. Particulate
5. Aerosol
6. Continuous
7. Intermittent
8. Variability
9. Locations
10. Exceeds ARARS?
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APPENDIX C
REVIEW CRITERIA CHECKLIST
FOR THE FEASIBILITY STUDY PHASE
OF THE SUPERFUND REMEDIATION PROCESS
• (FS CHECKLIST)
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REVIEW CRITERIA CHECKLIST FOR THE FEASIBILITY STUDY
PHASE OF THE SUPERFUND REMEDIATION PROCESS
(FS CHECKLIST)
SITE IDENTIFICATION
Site Name: Account No.-
Operable Unit: County/State:
Project Manager: Branch: Phone:
Air Reviewer: Branch: Phone:_
Date Document Received: Date Review Completed:
INSTRUCTIONS TO THE REVIEWER: Each question should be marked according to
the quality of the information presented in the Feasibility Study submission.
We recommend a scale of one to four for the quality rank (1-Very Thorough,
2-Acceptable, 3-Needs Revision, 4-Missing, with N/A-Not Applicable). A space
is provided for the page number in the document where the relevant information
is found. The deficiencies may then be compiled and summarized by the
reviewer in a format of his/her choice.
Section IV of this checklist is the detailed evaluation of alternatives.
TABLE 1 should be completed for this portion.
I. PHYSICAL SITE CHARACTERISTICS
The features of the site and vicinity should be described in sufficient detail
to enable a thorough Air Pathway Analysis for each of the remedial alterna-
tives evaluated. The reviewer should ensure that the following features are
described:
N/A Page t R
1. Contour and land use maps of waste area and
surroundings.
2. Schematic diagrams of facilities.
3. Distance and direction to susceptible receptors
(eg. population centers, especially schools, hospitals,
and farms, transportation routes, endangered species)
from potential emission sources.
4. Meteorological and climatological factors.
Comments:
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FS CHECKLIST (Continued)
II. SITE CHARACTERIZATION
The nature and extent of the contamination at the site should be defined in
sufficient detail for calculation of the rates and duration of remedial
operations for each of the alternatives evaluated. Table I of the RI Check-
list may be of assistance in evaluating the submission in more detail.
Following are the key items:
N/A Page I R
1. Distribution, volumes, and concentrations
of contaminants.
2. Physical, chemical, and toxic properties
of contaminants.
3. Media descriptions and properties.
4. Physical location and containment.
Comments:
III. DATA QUALITY
The confidence of estimates should be maximized by the use of the highest
quality data available. The following guidelines apply:
N/A Page 4 R
1. Are site-specific measurements used whenever
possible?
2. If models are used, are site-specific measurements
used for inputs whenever available?
3. Are tabulated default values (used only when
measured data are not available) supported by
literature?
4. Is the data quality sufficient for the feasi-
bility study?
Comments:
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FS CHECKLIST (Continued)
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IV. EVALUATION OF ALTERNATIVES
Table I should be completed to examine in detail the individual remedial
action alternatives evaluated.
REVISIONS OR ADDENDUMS REQUIRED
review should be listed along with the reasons for their requirement. The
contaminants involved should be specified. The following table is provided for
listing the requirements:
Requirement Reasons Contaminants
1:
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TABLE 1. REMEDIAL ACTION ALTERNATIVE EVALUATION
Alternative Descriptions
#4 #5 #6 #7
#10
Criteria
1. Site characterization sufficient?
2. Alternative description sufficient?
3. Alternative causes air impacts?
4. ARARs identified?
5. Use of highest quality data available?
6. Are all the potential air contaminants
identified in the RI evaluated?
7. Appropriate emission control methods
evaluated?
8. New products resulting from remedial
action evaluated?
9. Ash or waste disposal addressed?
10. Emissions during storage and handling
assessed?
11. Short-term and long-term effects
evaluated?
12. Worst-case conditions evaluated?
13. Methods of monitoring emissions?
14. Overall protection of health and
environment?
15. Long-term effectiveness and permanence
of alternative evaluated?
3
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Revised evaluation required?
Contaminants not sufficiently evaluated: 1.
2.
3.
4.
5.
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APPENDIX D
REVIEW CRITERIA CHECKLIST
FOR THE REMEDIAL DESIGN PHASE
OF THE SUPERFUND REMEDIATION PROCESS
• (RD CHECKLIST)
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REVIEW CRITERIA CHECKLIST FOR THE REMEDIAL DESIGN PHASE
OF THE SUPERFUND REMEDIATION PROCES
(RD CHECKLIST)
SITE IDENTIFICATION
Site Name: __Account No.j
Operable Unit: County/State:
Project Manager: Branch: Phone:
Air Reviewer: Branch: Phone: _
Date Document Received: Date Review Completed:
INSTRUCTIONS TO THE REVIEWER: The controls required to protect health and
environment should be determined and any deficiencies in the RD should be
identified. The extent of the modeling and monitoring (process and ambient)
must be evaluated to determine the adequacy of environmental protection
defined in the RD. We recommend a scale of one to four for the quality rank
(1- Very Thorough, 2- Acceptable, 3- Needs Revision, 4- Missing). A space is
provided for the page number in the document where the relevant information is
found and N/A-Not Applicable. The deficiencies may then be compiled and
summarized by the reviewer in a format of his/her choice.
A table is provided to track the completeness of the remedial design APA
(Table 1).
A table of sources of potential Superfund ARARS is attached (Table 2).
The checklist contains the following sections.
I. Physical Site Characteristics
II. Characterization of Contamination
III. Emissions
IV. General
V. Modeling
VI. Monitoring
VII. Revisions or Addendums Required
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RD CHECKLIST (Continued)
I. PHYSICAL SITE CHARACTERISTICS
The features of the site and vicinity should be described in sufficient detail
to enable a thorough Air Pathway Analysis (evaluation of modeling, monitor-
ing, and risk assessment if necessary) for the remedial design. The features
which should be described are:
N/A Page# R
1. Contour and land use maps of waste area and
surroundings?
2. Schematic diagrams of facilities and other
data relevant to emissions (location, height,
temperature, velocity of emissions, and
structural measurements?
3. Distance and direction to susceptible receptors
(as determined from modeling results) (eg.
nearest residences and population centers,
especially schools, hospitals, retirement homes,
and farms, transportation routes, endangered
species) from potential emission sources?
4. Meteorological and climatological factors.
(Seasonal wind roses, precipitation temperature,
and description of severe weather and topographic
effects.)
Comments: —
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RD CHECKLIST (Continued)
II. CHARACTERIZATION OF CONTAMINATION:
The nature and extent of the contamination at the site should be defined in
sufficient detail for calculation of the rates and duration of remedial
operations. The physical and chemical characteristics of the waste and the
contaminated media should also be described and grouped to ensure proper
assessment techniques are applied. The descriptions should be directly
related to the risks that the contamination poses to exposure via the air
pathway.
N/A PageV/ R
1. Are the physical characteristics of the
contaminated media described (e.g., soil &
geology, surface water, size and distribution
of contaminated or potentially contaminated
media, possible routes of migration to the
atmosphere)?
2. Are the contaminants described in sufficient
detail to determine the best method of
measurement and estimation (e.g., separation
of contaminants into volatile, semi-volatile,
liquid and particulate groups)?
3. Is the description consistent with site history?
4. Are other contaminants expected even though
they have not yet been identified?
5. Are contaminants prioritized according to
relative risk potential?
Comments:
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RD CHECKLIST (Continued)
III. EMISSIONS N/A Page#
1. Are all the potential remedial action emission
sources (routine and fugitive) assessed
(removal, treatment, incineration, containment)?
2. Are all uncontrolled sources defined and
quantified sufficiently?
3. Are the control methods and control efficiencies
defined?
4. Engineering Design Criteria:
• Are air emission-related parameters
sufficiently defined for each control
technology (maximum and average design
emission rates, stack dimensions, exit
velocity, design load, operating
conditions)?
• Has sufficient information been included
to check the quality of the designs
(P&ID, PFD, operational descriptions)?
• Will sufficient operational monitoring
data be collected?
• Are acceptance testing and trial runs
with sufficient testing planned?
Comments:
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RD CHECKLIST (Continued)
IV. GENERAL N/A
1. Have all the air related local, state, and
federal ARARS (emission and ambient) been
researched and addressed? The attached
table will assist in checking the ARARS
for each contaminant.
Comments:
2. Are risk assessments conducted if no ARARS or
TBC's exist for a particular contaminant.
Comments:
3. Based on the site characterizations, and risk
assessments, does the reviewer agree with the
LIST OF CONTAMINANTS for which APA is required?
Comments:
4. Are the DATA QUALITY OBJECTIVES defined and
based on data usage?
Comments:
Is the APA INPUT DATA quality maximized (site
specific data whenever available, if not,
modeled data using site specific inputs, or,
last, tabulated defaults)?
Comments:
6. Is the SCHEDULE of activities sufficient for
information feedback from air contaminant
laboratory analysis and modeling activities,
etc (e.g., laboratory analysis results may
take one month)?
Comments:
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IN/A Page# _R_
7. Are BASELINE emission estimates included in
the emission inventory?
g| Comments: .
• 8. Does the choice of TARGET COMPOUNDS (indicator
chemicals) follow the NTG (VOL II)?
• Comments: _^_
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RD CHECKLIST (Continued)
MODELING N/A
Do the SCREENING MODEL techniques follow the
Superfund APA procedures?
Comments:
2. Are the estimated BACKGROUND CONCENTRATIONS
appropriate?
Comments:
3. Are WORST-CASE scenarios assessed using appro-
priate worst-case meteorological conditions?
Comments:
4. Does the METEOROLOGICAL data quality meet the
EPA requirements?
Comments:
5. Are the RECEPTOR GRID selections consistent
with Superfund APA procedures?
Comments:
6. Does the refined modeling include BENCHMARK
tests?
Comments:
7. Are the modeling UNCERTAINTIES defined and the
APA implications discussed?
Comments:
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RD CHECKLIST (Continued)
8. Are TOPOGRAPHIC. WATER BODY, and BUILDING
features addressed in models?
Comments:
N/A Page#
9. Are FUGITIVE emissions modeled (including
B fugitive dusts from remedial activities)?
Comments:
10. Are the SOURCE types and dimensions correctly
defined?
Comments:
11. Are the emission control effects on source
parameters included in the modeling input?
Comments:
12. If the ISC model is not used, is the model
choice appropriate?
Comments: .
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RD CHECKLIST (Continued)
I VI. MONITORING N/A Page#
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1. Is the OAPP sufficient?
Comments:
2. Is the ambient MONITORING PLAN based on the
following considerations?
•Dispersion model predictions
Environmental characteristics
Receptor characteristics
•Source characteristics
Siting constraints
Duration of program
Comments:
3. Are MONITOR AND PROBE siting in compliance
with EPA criteria ?
Comments:
• 4. Are the following sufficiently defined in the
monitoring plan?
I Meteorological monitoring
Sampling schedule
Staffing
•Instrumentation
Data quality
Comments:
15. Has monitoring been correctly performed for
Health & Safety Plan input?
Comments:
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RD CHECKLIST (Continued)
VII. REVISIONS OR ADDENDUMS REQUIRED
Any recommended revisions or requests for more information study resulting
from the review should be listed along with the reasons for their requirement.
The contaminants involved should be specified. The following table is provided
for listing the requirements:
• Requirement Reasons Contaminants
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RD CHECKLIST (Continued)
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• RD CHECKLIST (Continued)
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TABLE 2. (Continued)
3004U
Subpart 0
OSHA
TSCA
FlrUA
AEA
IMTRCA
STATE
Air Toxics
Program:
SIP:
Odor/Fugitive
Dust Nuisances:
HUD - Air
Emissions:
Pre-Remedlat ion Sources
landfills
X
Lagoons
X
Containers
Contaminated
Soil
X
(Above-
ground)
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Remediation Sources
Soil
Handling
X
X
X
X
X
X
X
X
Air In-SItu
Strippers Incinerators Venting
X
XXX
X
X
XXX
XXX
XXX
XXX
Solidification/
Stablliatlon
X
X
X
X
X
X
X
Post Remediation Sou re
Landfills
X
Lagoons
X
Soil
Surfaces
X
e?
Container
(above
ground)
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
en
H
n
o
P
rt
I
n>
ex
Key:
PH-IO - Part leu late matter less than 10 Microns.
SO. - Sulfur dioxide
HA - don-attainment
CO - Carbon monoxide
0-| - Ozone
NO, - Nitrogen dioxide
VOC - Volatile Organic Compounds
TSCA - Toxic Substances Control Act
BACT - Best Available Control Technology
LAER - Lowest Achievable Emission Rate
NAAQS - National Ambient Air Quality Standards
NESHAP - National Emission Standards for Hazardous Air Pollutants
FIFRA - Federal Insecticide. Fungicide, and Rodenticide Act
NSPS - New Source Performance Standards
PSD - Prevention of Significant Deterioration
RCRA - Resource Conservation and Recovery Act
RCRA 40CFR264 - Fugitive Particulate Emissions
RCRA 3004° - No Migration
RCRA 3004° - Location Standards
RCRA 3004° - Air Emissions Monitoring/Control
RCRA 3004" - Corrective Action
RCRA Subpart 0 - Hazardous Waste Incinerators
AEA - Atonic Energy Act
SIP - Site Implementation Plan for Clean Air Act
OSHA - Occupational Safety and Health Act
UNTRCA - Uranium Hill Tailings Radiation Control Act
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
EPA-450/1-90-001
4. TITLE AND SUBTITLE
Air/Superfund National Technical Guidance Series
Superfund Air Pathway Analyses Review Criteria
Checklists
John E. .Letkeman
i. PERFORMING ORGANIZATION NAME AND ADDRESS
Radian Corporation
8501 Mo-Pac Blvd.
Austin, TX 78720
12. SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Research Triangle Park, NC 27711
3. RECIPIENT'S ACCESSION NO.
5. REPORT DATE
January 17, 1990
6. PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT NO.
DCN 90-203-080-61-02
10. PROGRAM ELEMENT NO.
61
11. CONTRACT/GRANT NO.
68-02-4392
13. TYPE OF REPORT AND PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
The EPA has responsibility for assessment and cleanup of superfund sites. Because
air emissions pose a potential human health risk at these sites, the EPA has developed
a set of procedures for evaluating these risks. The four checklists presented in
this report provide a systematic approach for air reviewers to apply the air pathway
assessment procedures. The background, prupose, and application of the checklists
are discussed.
KEY WORDS AND DOCUMENT ANALYSIS
b.lDENTIFIERS/OPEN ENDED TERMS
c. COSATI Field/Group
Air Pathway Assessment
Air Pollution
Superfund
Exposure Assessment
Air Pathway Analysis
Air Pollution Assessment
18. DISTRIBUTION STATEMENT
19. SECURITY CLASS (This Report)
21. NO. OF PAGES
20. SECURITY CLASS (This page I
I
EPA Form 2220-1 (R.v. 4-77) PMEVIOUS COITION is OBSOLETE
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