United States
Environmental Protection
Agency
Solid Waste And
Emergency Response
(5303W)
520R94004
OSWER Directive 9902.3-2A
May 1994
vvEPA
RCRA Corrective
Action Plan
Final
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United States
Environmental Protection
Agency
Off ice of
Solid Waste and
Emergency Response
EPA
DIRECTIVE NUMBER: 9902.3-2A
TITLE: RCRA Corrective Action Plan
APPROVAL DATE: May 31/ 1994
EFFECTIVE DATE: May 31, 1994
ORIGINATING OFFICE:
OWPE/OSW
0 FINAL
D DRAFT
LEVEL OF DRAFT
fj A — Signed by AA or DAA
fj B — Signed by Office Director
O C — Review & Comment
REFERENCE (other documents): Supercedes interim
Final RCRA Corrective Action Plan (OSWER
Directive #9902.3. The Corrective Action
Glossary (OSWER Directive #9902.3-la) should
be used as a supplement.
OSWER OSWER OSWER
DIRECTIVE DIRECTIVE
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dEPA
United States Environmental Protection Agency
Washington, D.C. 20460
OSWER Directive Initiation Request
1. Directive Number
9902.3-2A
2. Originator Information
Name of Contact Person
Peter Neves
Mail
3. Title
RCRA Corrective Action Plan (Final)
4. Summary of Directive (include brief statement of purpose) The purpose Of the RCRA Corrective
Action Plan (CAP) is to aid Regions and States in determining and
directing the specific work that a Permittee/Respondent must perform,
as part of a complete corrective action program. The CAP provides a
framework for developing site-specific scopes of work.
5. Keywords RCRA, Corrective Action, Permits. Orders, Scope of Work, CAP,
RZI. CMS. CMI. Interim Mpa.gnrpg . Shahi I i 7. a hi nn
6a. Does This Directive Supersede Previous Directive(s)?
b. Does It Supplement Previous Directive(s)?
Yes What directive (number, title) 9902.3
RCRA Corrective Action Pl<
(Interim Einal)
Yes What directive (number, title) 9902.3-
la Corrective Action Glos-
7. Draft Level
A - Signed by AA/DAA
B - Signed by Office Director
C - For Review & Comment
D - In Development
8. Document to be distributed to States by Headquarters?
Yes
No
This Request Meets OSWER Directives System Format Standards
9. Signature of Lead Office Directives Coordinator
r\
1 0. Name and Title of Approving Official
Date
5/5i/T/
Date
EPA Form 1315-17 (Rev. 5-87) Previous editions are obsolete.
OSWER OSWER OSWER OSWER
DIRECTIVE DIRECTIVE DIRECTIVE
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OSWER Directive 9902.3-2A
May 1994
RCRA CORRECTIVE ACTION PLAN
(Final)
Office of Waste Programs Enforcement
Office of Solid Waste
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NOTICE: The policies set out in this document are not final agency action, hut are
intended solely as guidance. They are not intended, nor can they be relied upon, to
create any rights enforceable by any party in litigation with the United States. EPA
officials may decide to follow the guidance provided in this document, or to act at
variance with the guidance, based on an analysis of specific site circumstances. The
agency also reserves the right to change this guidance at any time without public notice.
11
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Table of Contents
Foreword v
Chapter I: Corrective Action Process Update 1
Chapter II: Interim Measures To Achieve Stabilization 11
Chapter III: RCRA Facility Investigation 17
Introduction 17
Release Assessment [optional phase] 18
Section I: Description of Current Conditions 22
Section II: RFI Workplan 26
Section III: Facility Investigation 33
Section IV: Preliminary Evaluation of Corrective Measure
Technologies by Laboratory or Bench-Scale Studies [optional] ... 48
Section V: Investigation Results and Analysis 49
Section VI: Progress Reports 52
Section VIII: Proposed Schedule 53
Chapter IV: Corrective Measures Study 55
Introduction 55
Section I: Corrective Measures Study Workplan 60
Section II: Corrective Measures Study Report 60
Section III: Progress Reports 68
Section IV: Proposed Schedule 69
Chapter V: Corrective Measures Implementation 70
Introduction 70
Section I: Conceptual Design (15% Design Point) 75
Section II: Operation and Maintenance Plan 77
Section III: Intermediate Plans and Specifications (30, 50, 60, 90
and/or 95% Design Point) 80
Section IV: Final Plans and Specifications (100% Design Point) 81
Section V: Construction Workplan 81
Section VI: Construction Completion Report 84
Section VII: Corrective Measure Completion Report 85
Section VIII: Health and Safety Plan 85
Section IX: Public Involvement Plan 87
Section X: Progress Reports 88
Section XI: Proposed Schedule 88
in
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Appendix A - Corrective Action Reference List 90
Appendix B - Chapter One of "Test Methods for Evaluating Solid Waste,
Physical/Chemical Methods", EPA Publication SW-846 [Third Edition as
amended by Update I (July 1992)] 94
Appendix C - Definitions 127
Appendix D - Corrective Action Stabilization Questionnaire 129
Appendix E - Example Scope of Work for Interim/Stabilization Measures 138
Appendix F -Summary of Important Geologic Information 147
Appendix G - Sources of Information on Human Health and Ecological Risk
Assessments 149
IV
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Foreword
This document was issued by Bruce M. Diamond, Director, Office of Waste
Programs Enforcement, and Michael Shapiro, Director, Office of Solid Waste, in
May, 1994 as the RCRA Corrective Action Plan Guidance (Final), OSWER'
Directive Number 9902.3-2A replacing the RCRA Corrective Action Plan Guidance
(Interim Final), OSWER Directive 9902.3, dated June, 1988. The interim final
guidance was updated with the help of a workgroup made up of representatives
from several States and EPA Headquarters and Regions. The updated guidance
reflects the experience the Regions and States have gained and changes that have
occurred in the corrective action program. In addition, new technical information
has been added.
The purpose of the RCRA Corrective Action Plan (CAP) is to aid Regions
and States in determining and directing the specific work that a
Permittee/Respondent must perform, as part of a complete corrective action
program. The CAP will assist the Regions and States in developing corrective
action requirements in permits under §3004(u) and (v) and §3005(c)(3) (omnibus) and
corrective action orders under §3008(h) and §7003.
The CAP provides a framework for developing a site-specific schedule of
compliance to be included in a permit or a corrective action order. It does so by
laying out scopes of work for the four main components of a corrective action
program. These four components and their objectives are as follows:
• Interim/Stabilization Measures (ISMs) - to control or abate threats to
human health and/or the environment from releases and/or to
prevent or minimize the further spread of contamination while
long-term remedies are pursued.
• RCRA Facility Investigation (RFI) - to evaluate thoroughly the
nature and extent of the releases of hazardous waste and hazardous
constituents and to gather necessary data to support the Corrective
Measures Study and/or interim/stabilization measures.
• Corrective Measures Study (CMS) - to develop and evaluate a
corrective measure alternative or alternatives and to recommend the
final corrective measure(s).
• Corrective Measures Implementation (CMI) - to design, construct,
operate, maintain and monitor the performance of the corrective
measure(s) selected.
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A chapter on interim/stabilization measures (Chapter II) has been added in
the final CAP. This optional phase is generally the first phase of corrective action
but may be conducted at any time in the process. The term "interim/stabilization
measures" is being used in this document to encourage the use of interim measures
to achieve stabilization. Interim/stabilization measures are actions to achieve the
goal of stabilization, which is stated above and in Chapter II.
Another optional phase, the Release Assessment or Phase I RFI, could be
performed by the Permittee/Respondent before an RFI (or as a first phase of an
RFI) and after a RCRA Facility Assessment (RFA) to determine whether
interim/stabilization measures are necessary and/or to focus an RFI. A release
assessment should be used to minimize corrective action activities (i.e., by focusing
the RFI) and not to add another step in the process. See section III.D. ("Phasing of
Activities") of Chapter I and the beginning of Chapter III for further discussion and
a model scope of work for release assessments.
The CAP provides an overall model for the corrective action process. The
scopes of work contained in the CAP should not be considered boilerplate; rather,
they should be considered as a menu of possible activities to be required on a site-
specific basis. The model scopes of work in the CAP are intended to foster timely,
concise, and technically adequate submissions by the Permittee/Respondent.
Therefore, when modifying these scopes of work with site-specific information,
only information that is necessary for the subject facility should be required, in
order to minimize the number and length of Permittee/Respondent submissions and
implementing agency review time. The implementing agency decides which
components will be included in the permit or order.
VI
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Chapter I: Corrective Action Process Update
Since the interim final CAP was published in June 1988, several changes have
occurred in the RCRA corrective action program. New philosophies and strategies
were expressed in the July 1990, RCRA Implementation Study (RIS), and new
technical information has become available. The revised CAP reflects these changes,
as well as the experience of the Regions and States in implementing the corrective
action program. Some of the key changes are discussed below following an
introduction to the corrective action program and an explanation of how to use the
CAP.
I. Introduction
The objective of a Corrective Action Program at a hazardous waste
management facility is to evaluate the nature and extent of the releases of hazardous
waste or constituents; to evaluate facility characteristics; and to identify, develop,
and implement an appropriate corrective measure or measures to protect human
health and environment. The following components are necessary to ensure a
complete corrective action program. It should be recognized that the detail required
in each of these steps will vary depending on the facility and its complexity; only
those tasks appropriate for a specific site should be imposed on the
Permittee/Respondent.
1. Locate the source(s) of the release(s) of contaminants (e.g., regulated units,
solid waste management units, and other source areas).
2. Characterize the nature and extent of contamination that is both within the
facility boundary and migrating beyond the facility boundary. This would
include defining the pathways and methods of migration of the hazardous
waste or constituents, including the media affected, the extent, direction and
speed of the contaminants, complicating factors influencing movement,
concentration profiles, etc.
3. Identify areas and populations threatened by releases from the facility.
4. Determine actual and potential threats of releases from the facility to human
health and/or the environment in both the short and long term.
5. Identify and implement an interim/stabilization measure or measures to
abate the further spread of contaminants, control the source of
contamination, or otherwise control the releases themselves.
6. Evaluate the overall integrity of containment structures and activities at the
site intended for long-term containment.
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7. Identify, develop, and implement a corrective measure or measures to
prevent and remediate releases of hazardous waste or constituents from the
facility.
8. Design a program to monitor the maintenance and performance of any
interim or final corrective measure(s) to ensure that human health and the
environment are being protected.
The four main components of a complete corrective action program and their
objectives are as follows:
• Interim/Stabilization Measures (ISMs) - to control or abate threats to
human health and/or the environment from releases and/or to
prevent or minimize the further spread of contamination while
long-term remedies are pursued.
• RCRA Facility Investigation (RFI) - to evaluate thoroughly the
nature and extent of the releases of hazardous waste and hazardous
constituents and to gather necessary data to support the Corrective
Measures Study and/or interim/stabilization measures.
• Corrective Measures Study (CMS) - to develop and evaluate a
corrective measure alternative or alternatives and to recommend the
final corrective measure (s).
• Corrective Measures Implementation (CMI) - to design, construct,
operate maintain and monitor the performance of the corrective
measure(s) selected.
As discussed in section VI of this chapter, all of the components may be streamlined
or phased, and alternatives to the "traditional" corrective action process (i.e., RFI -*
CMS -» CMI) may be appropriate.
A RCRA Facility Assessment (RFA) or equivalent assessment will have been
conducted at the facilities that are to receive permits and for some facilities that are
issued §3008(h) Orders. The results of the RFA should be used as the basis for
focusing the RCRA Facility Investigation (RFI) for individual sites and should
provide the necessary data to complete the "background information" components
of the CAP. In some cases, a Release Assessment (Phase I RFI) may be needed to
further focus the RFI or to determine whether ISMs are necessary.
Exhaustive characterization and studies of a facility during the RFI/CMS, in
the sense of completely eliminating uncertainty, are generally not required to
achieve environmentally protective results. Therefore, it is important for the
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implementing agencies to clearly define scopes of work to be performed that
require the appropriate amount of information to characterize contamination and
identify the cleanup alternative(s) without "going overboard." Reasonable time
frames should be set for activities such as gathering data and conducting studies.
II. How to Use the CAP
Users of the CAP should understand that it is designed to identify actions
that facility Permittees/Respondents may be required to undertake as part of a
corrective action program. It does not identify the steps that are the responsibility
of the implementing agency. However, some guidance language is provided in the
CAP for such agencies and is indicated by brackets ([ ]) and italics. Additional
guidance language is found at the beginning of Chapters II, III, IV, and V, and
before the model scopes of work. Specifying conditions that will be placed in
orders and permits is one key area of responsibility for implementing agencies. The
CAP incorporates certain provisions that are already required by statute or
regulations. If the required information is already present in permits or permit
applications, the implementing agency may allow the Permittee to reference the
appropriate sections of such documents. The remainder of the CAP is guidance,
not a rule, and has not gone through public comment; therefore, use of provisions
in the CAP should be justifiable and tailored to fit site-specific conditions.
Regions and States should incorporate the appropriate provisions of the
corrective action plan in a draft permit. If public comments are received on these
provisions, the implementing agency's response to comments should include a site-
specific justification for the provisions in question, with supporting data as
appropriate. For guidance on public involvement for corrective action under
permits and RCRA §3008 (h) orders, see the RCRA Public Involvement Manual
(EPA530-R-93-006, September 1993).
Limitations exist on the release or discussion of information during the
enforcement process (particularly during negotiations or if a case is referred to the
Department of Justice). However, respondents that are issued RCRA §3008 (h)
administrative orders have the right to request a hearing concerning any material
fact in the order or the terms of the order which may include scopes of work
derived from the CAP. Respondents to §3008 (h) orders may request informal
settlement conferences. Agencies are encouraged to settle such enforcement actions
through informal discussions.
Traditional risk assessment techniques may be a significant factor in
designing RFI, CMS, and ISMs work plans. Risk management decisions should be
used in selecting corrective measures and ISMs, along with current and future land
use scenarios, background levels, health-based and technology-based standards.
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To clarify the interaction between the agency and the facility
Permittee/Respondent, a flow chart of Permittee/Respondent submittals that may
be imposed and the agency actions for the stages of the CAP is represented in
Figure 1 below. It is important to note that this is the "traditional" model and
many variations of the process are possible (see "Alternate Corrective Action
Models" section VI.F. on page nine).
Figure l.RCRA Corrective Action Process
or
Permit
(Modified)
Owner/Operator
Respondent
Agency
Order
^
RFI Workplan
1
r^s
Approval &
Oversight
Corrective
Measure
Study
Public
Participation
5B7-"
RTC*
or
Permit i
Modification *1
«
o
3
W
CO
c
o
1
JO
CO
0)
•»*
c
Design &
Construction
Operation &
Maintenance
Monitoring
Approval &
Oversight
* The Statement of Basis/Response to Comments (SB/RTC) or permit modification
documents the selected corrective measure(s).
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III. Modifications of CAP Scopes of Work
The CAP scopes of work should not be considered boilerplate. The scopes
of work in the CAP are models that should be modified based on site-specific
situations. Information generated from investigations such as RCRA Facility
Assessments (RFAs) should be used to tailor the scope of work to address facility-
specific situations. The following are some examples of situations where
modification to the CAP model scopes of work would be appropriate.
• If the contamination problem at a facility is small or simple (e.g., a
small soil contamination problem), then the implementing agency
may decide to scale down the CAP accordingly. The agency could
require excavation and removal by ISMs or by corrective measures
after approving a streamlined CMS (e.g., with only the one
alternative evaluated).
• If the contamination problem at a facility is complicated, the
Health and Safety Plan and Public Involvement Plans may need to
be comprehensive. However, in less complicated contamination
situations, these plans may be very brief.
• If site-specific conditions require more detail than what has been
scoped out in any particular section of the CAP, then these
requirements should be enhanced accordingly.
• If there is information on air releases at a site which is sufficient to
suggest a remedy which would prevent such an air release, then it
would not be necessary to require the Permittee/Respondent to
perform an air contamination characterization. The air
contamination characterization work under the RFI should be
deleted.
• If interim/stabilization measures are underway, scheduled or
contemplated at a facility, then the interim/stabilization measures
section under the RFI should be modified to specifically reference
such measures.
• If possible, the CAP should focus the Permittee/Respondent on
specific solid waste management units (SWMUs) and other areas of
interest, as well as known waste management activity areas (e.g.,
waste recycling units).
• If only one corrective measure alternative is appropriate for a given
situation, and it would not be necessary to require the
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Permittee/Respondent to further investigate the possibility of other
corrective measure alternatives, then the scopes of work contained
in this document should be modified to reflect this situation.
IV. Available Guidance
The Regions and States are encouraged to make available to the
Permittee/Respondent existing model plans that are relevant to RCRA activities.
For example, the Occupational Safety and Health Guidance Manual for Hazardous
Waste Site Activities Operating Safety Guidelines contains a model that can be used
for the Health and Safety Plan outlined in the CAP. In addition, guidance
documents such as the RCRA Facility Investigation (TRFI) Guidance; Interim Final
(May 15, 1989, document number PB89-200-299, four volumes available from NTIS,
phone number (703) 487-4650) may be referenced. Other corrective action guidance
documents and sources of related information are provided in Appendix A.
V. Tailoring the Work to be Performed for the Site
It is necessary to stress the importance of site-specific technical detail in
developing corrective action orders, permits, and, particularly, scopes of work.
Each facility has unique characteristics and circumstances that need to be considered
and incorporated into any requirements for corrective action. Without this up-front
detail, many Permittees/Respondents will provide deficient submittals that lack the
technical detail necessary to perform a thorough corrective measure program. In
addition to providing a detailed scope of work, the implementing agency should also
establish a site-specific time frame for completing the work. Enforcement of permit
conditions or an order is always easier when specific detail is included. These
documents should contain schedules for submittals such as reports and work plans.
Without a detailed schedule of compliance in a corrective action permit or a
corrective action order, submittals and actions may be delayed or untimely.
VI. New Developments in Corrective Action
A. Streamlining the Corrective Action Process
The introductory remarks in the original CAP (June 1988) stressed the
importance of concise submissions based on site-specific detail and that the scopes of
work contained in the CAP should not be considered boilerplate. The revised CAP
continues to emphasize this policy as well as an overall goal of streamlining the
process in an effort to expedite cleanups. Of course, this goal must be balanced
with the goal of maintaining the technical integrity of the program. Decisions
concerning how and when to streamline the process are to be made at the discretion
of the implementing agency.
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The revised CAP encourages using alternatives to the traditional sequential
approach (e.g., the use of interim measures to achieve stabilization). It presents a
menu of options that are to be tailored to individual sites, taking into account site-
specific conditions. In addition, some steps have been combined or eliminated to
reduce redundancy.
B. Addition of Interim Measures to Achieve Stabilization (Chapter II)
The following chapter, Interim Measures to Achieve Stabilization has been
added to the CAP as an optional phase to be conducted at the discretion of the
implementing agency. The 1990 RIS suggested that the RCRA corrective action
program needed to adjust its longtime program emphasis. While final cleanup
remains the long-term goal of the corrective action program, the RIS recommended
more frequent use, where appropriate, of interim/stabilization measures in the early
stages of corrective action to achieve near term environmental protection at facilities
with the most serious problems. This approach, which may also be appropriate
during later phases of the process, emphasizes controlling sites by stabilizing
identified releases to prevent the further spread of contamination and degradation of
the environment. Note that the term "interim/stabilization measures" is being used
in this document to encourage the use of interim measures to achieve stabilization.
C. Corrective Action Management Units (CAMUs) and Temporary
Units (TUs)
The February 16, 1993, Federal Register (58 FR 8658) finalized provisions for
Corrective Action Management Units (CAMUs) and Temporary Units (TUs) under
subpart S of 40 CFR Part 264. These units function solely to manage remediation
wastes generated at a RCRA facility as a result of required corrective action
activities. EPA recognized that the existing regulatory structure of RCRA Subtitle
C (e.g., permitting, land disposal restrictions), when applied to management of
hazardous wastes for remedial purposes, can often impede the ability to select and
implement effective remedies. CAMUs/TUs were developed to expedite hazardous
waste cleanups by reducing or eliminating certain waste management requirements
of the current RCRA Subtitle C regulations. The use of TUs at a site does not in
any way preclude the need for a final remedy to eventually be implemented at the
site; whereas CAMUs may be included in a final remedy.
The final CAMU/TU provisions are intended to provide flexibility for
decision- makers in implementing protective, reliable, and cost-effective remedies.
The CAMU/TU regulations provide the Regional Administrator (RA) with the
authority to designate and approve such units if the RA determines criteria
specified in 40 CFR § 264.552(c) will be met. If the remediation wastes are managed
in accordance with these provisions, remediation waste (as opposed to process or
"as-generated" waste) will not be subject to the RCRA land disposal restrictions
7
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(LDRs) and the minimum technology requirements (MTRs). The CAMU/TU
regulations apply to corrective action implemented under RCRA permits and
Section 3008(h) orders.
D. Phasing of Activities
A phased approach to corrective action may be appropriate where a variety
of releases (or threats of releases) exist, particularly if some of the releases or threats
can be stabilized. Under this approach, the initial investigation should first focus on
the areas that pose the greatest threats to human health and the environment and
then focus on lower priority areas. Stabilization for the high priority units may be
required before focusing the investigation on the lower priority units. Phasing may
also be appropriate when determining the extent of contamination if it is believed
that substantial migration of contaminants has occurred.
Release Assessments (Phase I RFIs), or other RFI phasing activities are also
intended to streamline the corrective action process. They may be required to
determine whether interim measures/stabilization are necessary and/or to focus an
RFI. A release assessment may be performed between the RFA and RFI and may
be desirable if there is some uncertainty about releases (e.g., due to subsequent
activities) at a facility after the RFA. Note that RFAs are conducted by
implementing agencies and release assessments or Phase I RFIs are conducted by
Permittees/Respondents. The release assessment should be viewed as a way of
focusing an RFI or determining whether interim/stabilization measures are
necessary prior to the RFI.
It is important to note that a release assessment is generally used to minimize
corrective action activities (i.e., by focusing or streamlining the RFI) and not to add
another step in the process. See the beginning of Chapter III for further discussion
and a model scope of work for release assessments.
The CMS may be phased as discussed in the CMS section of the document;
however, all elements of the facility that are of concern eventually should be
addressed in a CMS. Eventually, the CMS will most likely result in a
comprehensive evaluation of corrective measures to be implemented at the entire
site, even if the study is most logically conducted in phases.
E. Quality Assurance Project Plans and Data Quality Objectives
A fundamental requirement of the RCRA corrective action program is the
collection of environmental data that can be documented and are of adequate quality
to support decision making. To meet this requirement, data quality objectives
(DQOs) should be established through the quality assurance project planning
process. A July 7, 1993, memorandum transmitted to the EPA Regions from Sylvia
8
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Lowrance, OSW Director, and H. Matthew Bills, Office of Modeling, Monitoring
Systems and Quality Assurance Director within the Office of Research and
Development, discusses the application of the DQO process to the ground-water
monitoring and corrective action program. As a follow-up to the memorandum,
the two offices are developing examples of Quality Assurance Project Plans
(QAPjPs). These examples are intended to demonstrate that QAPjPs can be of
varying complexity depending upon their associated DQOs and that review and
approval of QAPjPs designed to achieve less complex DQOs can be expedited in
certain cases.
As stated in the July 7, 1993, memorandum, "The overall level of uncertainty
that a decision maker is willing to accept in this decision making process is known
as a DQO." The memorandum also explains that QAPjPs are used as a
management control to ensure that DQOs are defined and documented. QAPjPs
may vary in complexity (e.g., in certain cases, sampling and analysis plans may
substitute for and be the equivalent of QAPjPs), but the minimum elements of a
quality assurance program for all data collection activities in RCRA are outlined in
Chapter One (Quality Assurance) of "Test Methods for Evaluating Solid Waste,
Physical/Chemical Methods" (EPA SW-846 Third Edition as amended by Update
One, July 1992). For this reason, Chapter One of SW-846 is included as an
appendix (Appendix B) to the CAP. References to this appendix also are made in
Chapter Three (RFI) and Chapter Five (CMI).
F. Alternate Corrective Action Models
The following sample alternatives to the traditional corrective action model
(i.e., RFI -» CMS -» CMI) are provided as examples. Note that an RFA would
precede these activities. Except for use in the term "Interim/Stabilization
Measures," the slashes indicate that activities may be conducted concurrently. In
addition, more than one scenario may be taking place at a site at one time.
1) Release Assessment -* No further action
2) Release Assessment -» Streamlined RFI -* No further action
3) Release Assessment -» Streamlined RFI -* CMS -» CMI
4) Interim/Stabilization Measures -» RFI -* CMS -> CMI
5) Interim/Stabilization Measures -* RFI -* Interim/Stabilization Measures -*
CMS -> CMI
6) RFI -» Interim/Stabilization Measures -» CMS -» CMI
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7) RFI/CMS^-CMI
8) RFI/CMS/Interim/Stabilization Measures -» CMI
9) RFI -> Streamlined CMS -» CMI
10) Phased RFI/CMS -> CMI
11) Phased RFI/CMS/Interim/Stabilization Measures -» CMI
12) Phased RFI/CMS/CMI
This is not intended to be an exhaustive list but rather examples of some
possible scenarios. The following chapter provides more guidance on phasing
interim measures to achieve stabilization.
G. Reimbursement of Oversight Costs
EPA is examining various options for recovering oversight costs in the
RCRA program. The Agency may issue guidance on this issue in the future.
H. Definitions
To facilitate use of the CAP, a Definitions Section has been added as an
appendix (Appendix C). For additional guidance on technical terms used in the
Corrective Action Program, the U.S. EPA issued the "Corrective Action Glossary"
(OSWER Directive Number 9902.3-la) in July, 1992. The Glossary is available
through NTIS, phone number (703) 487-4650.
10
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Chapter II: Interim Measures To Achieve Stabilization
Introduction
The RIS recommended using interim actions to achieve near-term
environmental results at facilities with the most serious problems. The overall goal
of this process, termed "stabilization," is to control or abate threats to human health
and/or the environment from releases and/or to prevent or minimize the further
spread of contamination while long-term remedies are pursued. Since 1992, the U.S.
EPA and the States have been implementing a major initiative to achieve this goal.
Interim/stabilization measures (ISMs) are the actions used to achieve the goal of
stabilization.
The stabilization effort builds on work that has already been initiated at
many corrective action sites. Many of the ISMs implemented at numerous RCRA
facilities across the country were undertaken to address actual or imminent threats
to human health or the environment. Guidance on implementing ISMs was
provided in the original CAP, the RCRA Corrective Action Interim Measures
Guidance (OSWER Directive 9902.4, June 1988), the proposed subpart S rule (55 FR
30880, July 27, 1990), and more recently in the RCRA Stabilization Strategy
transmitted to the EPA Regions in a memorandum from Sylvia Lowrance, OSW
Director, and Bruce Diamond, OWPE Director (October 25, 1991). The subpart S
proposal generally constitutes EPA's most authoritative policy statement on
corrective action. As discussed in these guidance documents, a release or threat of a
release, need only be potential (i.e., it does not have to be actual or imminent) to
require the Permittee/Respondent to implement ISMs.
Although intended to be implemented more quickly than traditional
remedial measures, ISMs may be short-term or long-term. Examples of ISMs
include: providing bottled water, erecting a fence around heavily contaminated soil,
hydraulic containment of a contaminated ground-water plume, and excavating and
removing heavily contaminated soil.
To a large extent, the stabilization effort builds on work that has been
ongoing in the Regions and States. These agencies historically have required facility
Permittee/Respondents to undertake interim measures to address obvious
environmental problems, particularly where actual or imminent exposure of human
or environmental populations has been identified. However, these actions have
often been pursued in conjunction with the final, comprehensive remedy for a
facility.
The stabilization initiative focuses limited agency resources on near-term
activities to control or abate threats and/or to prevent or minimize the further
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spread of contamination across many facilities rather than following the traditional
process of pursuing final, comprehensive remedies at a few facilities. By imposing
such expeditious actions, the extent and incidence of continued environmental
degradation from existing releases should be significantly reduced. In addition, the
environmental benefit gained by taking this early action should enable greater
efficiency in final remedies undertaken.
Timing of Stabilization Activities
Interim/stabilization measures are used to achieve the goal of stabilization
and allow the implementing agency to redirect its resources or defer some corrective
action activities to address the worst sites (or parts of sites) first.
In many cases, it will be possible to identify early in the corrective action
process the need for interim measures. The implementing agency may identify such
a need through the combination of the RFA, the facility's rank (using the National
Corrective Action Prioritization System (NCAPS)), and stabilization evaluation.
Individual solid waste management units (SWMUs) with the worst releases and
presenting the most imminent threats can also be identified by using these tools. A
phased approach may be taken during the initial RFI information gathering stage to
focus the investigation on collecting data to design, implement, and monitor interim
measures at high priority SWMUs. The facility-wide RFI (and CMS) can be done
concurrently or be put on a slower track while interim measures are implemented at
the worst SWMUs first. Although the CMS will generally not be completed when
deciding on interim measures, potential final remedies should be under consideration
because the interim measures taken to achieve stabilization should be consistent
with the final remedy. In cases where they will deviate due to the interim nature of
the actions, the interim measures should at a minimum not conflict with the final
remedy.
Conditions Appropriate for Stabilization
Several conditions should exist at a facility (or part of a facility) for
stabilization to be appropriate. Generally, interim measures are most effective when
a specific aspect of the overall contamination at the facility can be isolated. As
discussed earlier, exposure threats to humans or ecosystems should be present. If
these receptors could be exposed to contaminants within five to 10 years or interim
measures could reduce the present or near-term (e.g., less than two years) risks, then
this criterion has been met. Addressing releases expeditiously through interim
measures may prevent further significant contamination of environmental media. If
contaminants are migrating off site, stabilization may be appropriate to stop or slow
the migration. Also, if previously implemented interim measures have been
unsuccessful in preventing the further spread of contamination, new or modified
measures may be needed. Sufficient information about the contaminants and the
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facility's environmental setting (e.g., site hydrogeology) must be known for
stabilization to be a viable option. Finally, a decision to proceed with stabilization
activities should be made only if appropriate technologies are available to deal with
the known contaminants.
Examples of Interim Measures to Achieve Stabilization
Stabilization can be achieved through a variety of interim measures that are
based on site-specific conditions. Stabilization can include source control,
contaminated media cleanup, and/or limiting exposure to contamination. As an
ecological example of interim measures to limit exposure, migrating waterfowl could
be prevented from using open surface impoundments, ponds, etc., with
contaminants of ecological concern by placing a temporary cap over the surface
impoundments or removing the hot spot contamination from such units.
As another example of a facility that has implemented interim measures to
achieve stabilization, consider the following: The initial screening at a chemical
manufacturing plant identified dioxin contamination in superficial soils and
trichlorobenzene non-aqueous phase liquid (NAPL) in the bedding of the facility's
sewer system. Both of the contaminated areas were located near the facility
boundary and posed a threat to a nearby residential area. Interim measures included
installing a fence to prevent access, capping the dioxin-contaminated soil and
installing a grout wall for hydraulic isolation, and initiating a free-product removal
program to eliminate the source and prevent continued NAPL migration along the
sewer system.
As a third example, investigations at a wood treating facility identified past
releases from unlined impoundments, which resulted in considerable quantities of
creosote being present in the ground water as a dense NAPL or DNAPL. Dissolved
hazardous waste constituents were present both on and off site in the underlying
Karst aquifer. The facility installed a downgradient ground-water extraction trench
with extraction sumps to remove free product and contaminated ground water. The
extraction system was expanded throughout the stages of corrective action. Early
action to remove product and contaminants and to limit the plume's extent was
particularly important at this facility because of the uncertain flow patterns
associated with many Karst aquifer systems.
The U.S. EPA has developed guidance documents to facilitate
implementation of the stabilization initiative. One such document, Stabilization
Technologies for RCRA Corrective Actions (EPA/625/6-91/026, August 1991) is a
handbook which provides guidance on identifying the types of environmental
settings that are amenable to stabilization, various technical approaches to accelerate
data gathering, and phasing the RFI. This guidance document also includes a
Corrective Action Stabilization Questionnaire (see Appendix D) that can be used
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immediately after an NCAPS ranking as a first step to gather stabilization-related
information. The questionnaire examines individual solid waste management units
(SWMUs). In addition, stabilization fact sheets are under final review by the U.S.
EPA and should be released in the near future.
The following table provides examples of interim measures that may be
implemented for specific media. Note that these may also be used for final
remedies.
Example Interim Measures
Ground Water
• Interceptor Trench/Sump/Subsurface Drain
• Pump and Treat System (Source Removal and Containment)
• Physical Barriers (Covers/Slurry Walls)
Soils
• Run-off/Run-on Control (Diversion or Collection Devices)
• Cap/Cover
• Source Removal (Excavation)
Surface Water Release (Point and Non-Point)
• Overflow/Underflow Dams
• Filter Fences
• Run-off/Run-on Control (Diversion or Collection Devices)
• Regrading/Revegetation
Gas Migration Control
• Barriers/Collection (e.g., vapor extraction)/Treatment/Monitoring
• Evacuation (Buildings;)
Paniculate Emissions
• Truck Wash (Decontamination Unit)
• Revegetation
• Application of Dust Suppressant
• Cover/Cap
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Interim Measures for Stabilization Scope of Work Outline
The following scope of work outline may be used as a model for the items that
could be included to address stabilization activities at a facility. An example of a
detailed scope of work for implementing ISMs is provided in Appendix E.
INTERIM MEASURES FOR STABILIZATION SCOPE OF WORK
I. Introduction/Executive Summary - A brief description of any
interim/stabilization measures that are being recommended in Section 3
below to achieve stabilization.
II. Current Conditions - A brief description of the current conditions at the
site including a review of any interim measures that are underway at the
site.
III. Interim Measures for Stabilization (implementing agency will choose
applicable requirements)
A. Interim Measures Objectives
B. Description of Interim Measures and Conceptual Design (may
include performance-based design)
C. Construction/Implementation (may be phased)
D. Operation and Maintenance
E. Waste Management (e.g., CAMU/TU)
IV. Sampling and Analysis (if applicable)
A. Purpose/Data Quality Objectives (may not be as stringent as for
RFI)
B. Summary of Sampling Activities
C. Field Methods and Sample Analysis
1. Sample Locations and Depths
2. Sample Location Maps
3. Summary Tables including sampling methods, holding times,
analytical methods, preservation methods, sample depths, etc.
4. Field Quality Control
D. Quality Assurance/Quality Control
V. Project Management
A. Project Organization
1. Personnel/Organizational Chart
B. Project Schedule
C. Reporting Requirements (e.g., Report of Findings)
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VI. Other Submittals
A. Health & Safety Plan
B. Public Involvement Plan (optional at implementing agency's
discretion)
C. Final Report on the Success of the ISMs in meeting stated goal of
stabilization.
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Chapter III: RCRA Facility Investigation
Introduction
As stated in Chapter I, the objective of the RFI is to evaluate thoroughly the
nature and extent of the releases of hazardous waste and hazardous constituents and
to gather necessary data to support the CMS and/or interim/stabilization measures
(ISMs). The RFI may be focused specifically on ISMs data needs. Alternatively,
environmental threats may be discovered or other situations may arise that warrant
the implementation of ISMs during the RFI.
The RFI model scopes of work (SOWs) are intended to provide guidance for
determining the specific work to be performed by the Permittee/Respondent and to
foster timely, concise, and technically adequate submissions by
Permittees/Respondents. The model scopes of work are also intended to assist in
streamlining the corrective action process. To achieve these goals, it is important
when using the model scopes of work to consider facility-specific conditions.
Based on facility-specific circumstances some data collection steps may not be
necessary. The implementing agency should endeavor to minimize unnecessary and
unproductive investigations, and to focus resources on characterizing actual
environmental problems at facilities. For example, for inactive units that do not
contain substantial volumes of volatile organic compounds, RFIs will rarely need to
address air releases. In addition, RFIs may be phased to avoid unnecessary
investigations where a concern can be quickly eliminated. These determinations
will be made at the discretion of the implementing agencies.
The information collected during the RFI will be used to either determine
the need for the next step in the corrective action process - the CMS and/or ISMs -
or alternatively, used to support the recommendation for no further action. If, as a
result of the RFI, a CMS (or ISMs) is determined to be necessary, data collected
during the RFI (and release assessment, if performed), should be used to support the
decision-making process for identifying potential technologies to be considered
during the CMS (or ISMs). Appendix F presents typical geologic data needs for
standard technologies, which may be considered during the CMS or ISMs. These
scopes of work should be modified as necessary at the discretion of the
implementing agency to require only that information necessary to complete the
RFI.
The RFI stage of the corrective action process requires ongoing interaction
between the Permittee/Respondent and the implementing agency. At various times
during the RFI, there are requirements to submit reports to the implementing
agency. At the end of the following sections, where appropriate, the required
report submissions are noted in detail. At the end of this chapter, a proposed
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schedule is presented, which would indicate where in the RFI process each required
report would need to be submitted to the implementing agency.
Release Assessment [optional phase]
A release assessment may be performed as the first phase of an RFI. This
step would,take place between the RFA and RFI. The release assessment (or Phase
I RFI) may serve as an update to the RFA if there is some uncertainty about
releases after the RFA. Some examples of when the release assessment might be
appropriate include when the implementing agency believes confirmatory sampling
is needed or when new waste management activities have begun at a facility. In
addition, it may help determine if there has been a release to ecological/living
resources.
The release assessment may help determine if the RFI should focus on one
area before another and/or if interim/stabilization measures are necessary.
Therefore, the release assessment should be viewed as an optional step to
minimize corrective action activities (i.e., by focusing or streamlining the RFI)
and not as an added step in the process.
The following scope of work may be used as a model for a release
assessment. Note that it serves as an outline, and additional detail may be obtained
from the appropriate section of the RFI Scope of Work that follows it.
Release Assessment Scope of Work
1. Release Assessment Investigation
1.1 Objectives
-Release Assessment Investigation Objectives
-Rationale for this Release Assessment Investigation
1.2 Description of Current Conditions
-Facility Background (include findings from RFA-address, at a
minimum, each SWMU and AOC identified in the RFA)
-Summary of previous field conditions/investigations (if any)
1.3 Project Description/Workplan
1) Objectives of Workplan
2) Field! Investigation (sample locations map, media to be
sampled, number and location of samples to be taken, etc.)
3) Field Sample Collection Procedures
4) Field Measurements
5) QA/QC Procedures
6) Sample Analysis: Methods, Laboratories
7) Data Management: Data Records, Display Format (Tabular,
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Graphical)
8) Schedule
-Dates to submit Progress Reports (if necessary)
-Dates to submit Findings Report
9) Health and Safety Plan
10) Public Involvement Plan (optional at implementing
agency's discretion)
2. Findings Report
2.1 Overview
-Confirmation of Adherence to Workplan
-Identification and Logging of all Sample Locations
-Summary of findings
2.2 Data Analysis and Determination of Further Action
1) Analysis of all facility assessments and results
2) Assessment of type and known extent of contamination
at each SWMU or area of concern (AOC)
3) Recommendation for further action (implementing
agency makes decisions)
-RFI
-Phase 2 Release Assessment (conducted under rare or
unusual circumstances)
-Interim Measures to achieve stabilization
-CMS
-CMI
-Combinations of the above
-No Further Action
2.3 Provide a Description of the Selected Recommendation
-Rationale/Objectives
-Process/Technology/Actions
3. Schedule for next phase (addressing major step(s))
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[NOTE: With certain exceptions, the provisions set out in Sections I through VII are
intended as guidance, and these provisions should be justifiable and tailored to site-
specific conditions when incorporated into permits or orders. The exceptions are certain
provisions which are based on specific regulatory or statutory requirements applicable to
permitting. Regulatory and statutory requirements are binding and do not require site-
specific justification. Applicable requirements include: public notice requirements
specified in 40 CFR subpart D, requirements in 40 CFR §264.101, and applicable
information requirements in 40 CFR § 270.14, including information requirements for
SWMUs in § 270.14(d).]
Scope of Work for a RCRA Facility Investigation (RFI)
Purpose
The purpose of the RCRA Facility Investigation (RFI) is to determine the
nature and extent of releases of hazardous waste or constituents from regulated
units, solid waste management units, and other source areas at a facility and to
gather all necessary data to support a Corrective Measures Study. The
Permittee/Respondent shall furnish all personnel, materials, and services necessary
for, or incidental to, performing the RFI.
Scope
The RCRA Facility Investigation is one step in the corrective action
program. The RFI consists of the following components, which for clarity have
been designated as sections.
[NOTE: The implementing agency may choose to combine or eliminate some of the
sections below. Some typical examples include combining sections III, IV, and V into
one "RFI Report" and eliminating section IV.]
Section I: Description of Current Conditions
A. Facility Background
B. Preliminary Assessment of Nature and Extent of
Contamination
C. Implementation of Interim/Stabilization Measures
Section II: RFI Workplan
A. Purpose/Objectives
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B. Project Management
C. Data Collection/Quality Assurance
D. Data Management and Reporting
E. Health and Safety Plan
F. Public Involvement Plan
G. Schedule for Facility Investigation
Section III: Facility Investigation
A. Purpose/Objectives
B. Environmental Setting
C. Source Characterization
D. Contamination Characterization
E. Potential Receptor Identification
Section IV: Preliminary Evaluation of Corrective Measure Technologies by
Laboratory or Bench-Scale Studies [optional]
Section V: Investigation Results and Analysis
A. Data Analysis
B. Media Cleanup Standards [where applicable]
C. Analysis of Risk [optional]
Section VI: Progress Reports
Section VII: Proposed Schedule
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Section I: Description of Current Conditions
The Permittee/Respondent shall submit, for implementing agency approval,
a report (as set forth below) providing the background information on the facility,
contamination, and interim measures. The Permittee/Respondent shall indicate in
the applicable section if some of this information is not available. This report shall
contain information that is consistent with the data gathered during the RFA (and
the release assessment, if performed). The current condition report shall be
submitted prior to, or concurrently with, the submission of the RFI to allow the
implementing agency time to review it.
[NOTE: The RFA (and the release assessment, if performed) may be submitted as the
current conditions report, with updates when applicable. The implementing agency also
may allow the Permittee/Respondent to reference the appropriate sections of the RFA or
other such documents (i.e., permit application or permit). For example, if map
information is already present in a permit application, the agency may allow the
Permittee to reference the appropriate provisions of the application.}
A. Facility Background
The Permittee's /Respondent's report shall summarize the regional location,
pertinent boundary features, general facility physiography, hydrogeology, and
historical use of the facility for the treatment, storage, or disposal of solid
and hazardous waste. The Permittee's/Respondent's report shall include:
1. Map(s). For permitted facilities, all maps shall be consistent with the
requirements set forth in 40 CFR §270.14 and be of sufficient detail and
accuracy to locate and report all current and future work performed at the
site. (Aerial photographs should be included with SWMUs and AOCs
superimposed on them.) Maps shall depict the following (to the extent not
already included in map requirements under 40 CFR §270.14 (b)(19) for
permitted facilities):
• General geographic location;
• Propeity lines, with the owners of all adjacent property clearly
indicated;
• Topography and surface drainage (with a contour interval of
[number] feet and a scale of 1 inch = 100 feet) depicting all
waterways, wetlands, flood plains, water features, drainage
patterns, and surface-water containment areas;
• All tanks, buildings, utilities, paved areas, easements, rights-of-
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way, and other features;
All solid or hazardous waste treatment, storage, or disposal
areas active after November 19, 1980;
All known past solid or hazardous waste treatment, storage or
disposal areas regardless of whether they were active on or
after November 19, 1980;
All known past and present product and waste underground
tanks or piping;
Surrounding land uses (residential, commercial, industrial,
agricultural, recreational);
The location of all production and groundwater monitoring
wells on the facility and within a 2-mile radius of the facility
boundary. These wells shall be clearly labeled and ground and
top of casing elevations and construction details included (these
elevations and details may be included as an attachment); and
Wind rose and meteorology.
2. A history and description of ownership and operation, solid and
hazardous waste generation, treatment, storage and disposal activities
at the facility.
3. Approximate dates or periods of past product and waste spills,
identification of the materials spilled, the amount spilled, the location
where spilled, and a description of the response actions conducted
(local, state, or federal response units or private parties), including any
inspection reports or technical reports generated as a result of the
response.
4. A summary of past permits applied for and/or received, any
enforcement actions and their subsequent responses and a list of
documents and studies prepared for the facility. This may include
information from previous owner/operators, if available.
B. Preliminary Assessment of Nature and Extent of Contamination
The Permittee/Respondent shall prepare and submit, for implementing
agency approval, a preliminary report describing the existing information on
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the nature and extent of contamination.
1. The Permittee's/Respondent's report shall summarize all possible
source areas of contamination. This, at a minimum, shall include all
RCRA-regulated units, solid waste management units, spill areas, and
other suspected source areas of contamination. For each area, the
Permittee/Respondent shall identify the following:
• Location of unit/area (to be depicted on facility map provided
in Section I);
• Quantities of solid and hazardous wastes (both managed and
spilled or released);
• Type of Hazardous waste or constituents (both causing or
potentially causing contamination), to the extent known;
• Identification of areas where additional information is
necessary; and
• The results of both the RCRA Facility Assessment (RFA) and
a summary of suggested further actions for all SWMUs arid
Areas of Concern (AOCs) and the release assessment (if
performed).
2. The Permittee/Respondent shall prepare a preliminary assessment and
description of the existing degree and extent of contamination. This
shall include:
• For each medium where the permit or order identifies a release
(e.g., soil, ground water, surface water, air, etc.), a description
of the existing extent of contamination. This description must
include all available monitoring data and qualitative
information on the locations and levels of contamination at the
facility (both onsite and offsite). Include biodata (e.g.,
fishkills, distressed vegetation, abnormal individuals of a
species, carcasses, tissue studies, etc.). Include a general
assessment of the data quality, a map showing the location of
all existing sampling points and potential source areas and
contour maps showing any existing ground water plumes at
the facility (if ground water release). Highlight potential
ongoing release areas that would warrant use of interim
corrective measures (see Paragraph C. Implementation of
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Interim/Stabilization Measures).
• A list and brief description of all previous investigations that
have occurred at the facility, who they were conducted for
(i.e., agency) and agency contacts.
3. The Permittee/Respondent shall prepare a preliminary assessment and
description of potential migration pathways. This shall include:
• All potential migration pathways including information on
geology, pedology, hydrogeology, physiography, hydrology,
water quality, foodwebs, meteorology, and air quality;
• Physical properties of contaminants; and
• An assessment of whether off-site migration of contaminants
has occurred; (may include a conceptual model of contaminant
migration).
4. The Permittee/Respondent shall describe the potential impact(s) on
human health and the environment, including demography,
identification of possible sensitive subpopulations (e.g., schools, homes
for the elderly, hospitals and ecosystems), ground water and surface
water use, and land use.
C. Implementation of Interim/Stabilization Measures
[NOTE: See Chapter II for more guidance and a model scope of work}
The Permittee's/Respondent's report shall document past, present, or
proposed interim/stabilization measures at the facility. This shall include:
• Objectives of the interim/stabilization measures: how the
measure is mitigating a potential threat to human health and
the environment and/or is consistent with and integrated into
any long-term solution at the facility;
• Design, construction, operation, and maintenance
requirements;
• Schedules for design, construction and monitoring;
• Schedule for progress reports; and
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Data in support of the potential need for future interim
measures or related to any assessment undertaken to determine
the need for future interim/stabilization measures.
Section II: RFI Workplan
[NOTE: The implementing agency will review the RFI Workplan to determine
its technical accuracy and completeness and to determine its effectiveness toward
conducting a sound, comprehensive investigation of all contamination at the
facility.}
A. Purpose/Objectives
The Permittee/Respondent shall prepare an RFI Workplan. The purpose of
the RFI Workplan is to present to the implementing agency the
Permittee's/Respondent's specific plans to characterize the nature and extent
of contamination. This RFI Workplan shall include the development of
several plans, which shall be prepared concurrently. During the RCRA
Facility Investigation, it may be necessary to revise the RFI Workplan to
increase or decrease the detail of information collected to accommodate
facility-specific situations.
[NOTE: The implementing agency generally will require the
Permittee/Respondent to test media to determine the presence and levels of
hazardous constituents. The implementing agency may use Appendix IX to 40
CFR part 264 - Ground-Water Monitoring List for ground water. For purposes
of establishing a list for other media, the implementing agency may use Appendix
XI - Concentration-Based Exemption Criteria for Media from the Hazardous
Waste Identification Rule (HWIR) proposed rule ft7 FR 21450, May 20, 1992).
This appendix lists constituents for which analytical methods are available. To
streamline the list of constituents requiring analysis, the implementing agency
may use other information (e.g., lists of chemicals used at a facility) as
appropriate.}
B. Project Management
The Permittee/Respondent shall prepare a Project Management Plan, which
will include a discussion of the technical approach, schedules, (including
submittal of the CMS Workplan, if required), budget, and personnel. The
Project Management Plan will also include a description of qualifications of
personnel performing or directing the RFI, including contractor personnel.
This plan shall also document the overall management approach to the RFI.
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C. Data Collection/Quality Assurance
To ensure that all information, data and resulting decisions are technically
sound, statistically valid, and properly documented, the
Permittee/Respondent shall prepare a Quality Assurance Project Plan
(QAPjP) to document all monitoring procedures, sampling, field
measurements and sample analyses performed during the investigation to
characterize the environmental setting, source, and contamination. The
Permittee/Respondent shall use quality assurance, quality control, and chain-
of-custody procedures approved by the implementing agency.
These procedures are described in the soon to be released EPA Requirements
for Quality Assurance Project Plans for Environmental Data Operations
(EPA QA/R-5), which will replace Interim Guidelines and Specifications for
Preparing Quality Assurance Project Plans. (QAMS-005/80, December 29,
1980). The minimum elements of a quality assurance program for data
collection activities are in Chapter One of SW-846 [see Appendix B] and are
outlined below.
1.0 INTRODUCTION
2.0 QA PROJECT PLAN
2.1 Data Quality Objectives
2.2 Project Objectives
2.3 Sample Collection
2.4 Analysis and Testing
2.5 Quality Control
2.6 Project Documentation
2.7 Organization Performing Field or Laboratory Operations
2.7.1 Performance Evaluation
2.7.2 Internal Assessment by QA Function
2.7.3 External Assessment
2.7.4 On-Site Evaluation
2.7.4.1 Field Activities
2.7.4.2 Laboratory Activities
2.7.5 QA Reports
3.0 FIELD OPERATIONS
3.1 Field Logistics
3.2 Equipment/Instrumentation
3.3 Operating Procedures
3.3.1 Sample Management
3.3.2 Reagent/Standard Preparation
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3.3.3 Decontamination
3.3.4 Sample Collection
3.3.5 Field Measurements
3.3.6 Equipment Calibration and Maintenance
3.3.7 Corrective Action
3.3.8 Data Reduction and Validation
3.3.9 Reporting
3.3.10 Records Management
3.3.11 Waste Disposal
3.4 FIELD QA AND QC REQUIREMENTS
3.4.1 Control Samples
3.4.2 Acceptance Criteria
3.4.3 Deviations
3.4.4 Corrective Action
3.4.5 Data Handling
3.5 QUALITY ASSURANCE REVIEW
3.6 FIELD RECORDS
4.0 LABORATORY OPERATIONS
4.1 FACILITIES
4.2 EQUIPMENT/INSTRUMENTATION
4.3 OPERATING PROCEDURES
4.3.1 Sample Management
4.3.2 Reagent/Standard Preparation
4.3.3 General Laboratory Techniques
4.3.4 Test Methods
4.3.5 Equipment Calibration and Maintenance
4.3.6 QC
4.3.7 Corrective Action
4.3.8 Data Reduction and Validation
4.3.9 Reporting
4.3.10 Records Management
4.3.11 Waste Disposal
4.4 LABORATORY QA AND QC PROCEDURES
4.4.1 Method Proficiency
4.4.2 Control Limits
4.4.3 Laboratory Control Procedures
4.4.4 Deviations
4.4.5 Corrective Action
4.4.6 Data Handling
4.5 QUALITY ASSURANCE REVIEW
4.6 LABORATORY RECORDS
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D. Data Management and Reporting
The Permittee/Respondent shall develop and initiate a Data Management
Plan to document and track investigation data and results. This plan shall
identify and establish data documentation materials and procedures, project
file requirements, and project-related progress reporting procedures and
documents. The plan shall also provide the format to be used to present the
raw data and conclusions of the investigation.
1. Data Record
The data record shall include the following:
• Unique sample or field measurement code;
• Sampling or field measurement location and sample or
measurement type;
• Sampling or field measurement raw data;
• Laboratory analysis ID number;
• Property or component measured; and
• Result of analysis (e.g., concentration).
2. Tabular Displays
The following data shall be presented in tabular displays:
• Unsorted (raw) data;
• Results for each medium or for each constituent monitored;
• Data reduction for statistical analysis;
• Sorting of data by potential stratification factors (e.g., location,
soil layer, topography); and
• Summary data.
3. Graphical Displays
The following data shall be presented in graphical formats (e.g., bar graphs,
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line graphs, area or plan maps, isopleth plots, cross-sectional plots or
transects, three dimensional graphs, etc.):
• Sampling location and sampling grid;
• Boundaries of sampling area, and areas where additional data
are required;
• Levels of contamination at each sampling location;
• Geographical extent of contamination;
• Contamination levels, averages, and maxima;
• Changes in concentration in relation to distance from the
source, time, depth or other parameters;
• Features affecting intramedia transport; and
• Potential receptors.
E. Health and Safety Plan
The Permittee/Respondent shall submit a Health and Safety Plan for all field
activity, although it does not require review and approval by the
implementing agency. The Health and Safety Plan shall be developed as; a
stand alone document but may be submitted with the RFI Workplan.
1. Major elements of the Health and Safety Plan shall include:
• Facility description including availability of resources such as
roads, water supply, electricity, and telephone service;
• Description of the known hazards and evaluation of the risks
associated d with each activity conducted;
• A list of key personnel and alternates responsible for site
safety, response operations, and protection of public health;
• Delineation of work area;
• Description of protective clothing or other protective items to
be worn by personnel in work area;
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• Procedures to control site access;
• Description of decontamination procedures for personnel and
equipment;
• Site emergency procedures;
• Emergency medical care needed for injuries and toxicological
problems;
• Description of requirements for an environmental surveillance
program;
• Routine and special training required for response personnel;
and
• Procedures for protecting workers from weather-related
problems.
2. The Facility Health and Safety Plan shall be consistent with:
• NIOSH Occupational Safety and Health Guidance Manual for
Hazardous Waste Site Activities (1985);
• EPA Order 1440.1 - Respiratory Protection;
• EPA Order 1440.3 - Health and Safety Requirements for
Employees engaged in Field Activities;
• Facility Contingency Plan;
• EPA Standard Operating Safety Guide (1984);
• OSHA regulations particularly in 29 CFR 1910 and 1926;
• State and local regulations; and
• Other applicable EPA guidance as provided.
F. Public Involvement Plan
[NOTE: It is strongly recommended that the implementing agency oversee
Permittee's /Respondent's public involvement activities. Public involvement is
an important pan ofRCRA corrective action. The public must be notified of
significant changes to permits and orders regarding corrective action. In some
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cases, they also must be provided with the opportunity to review and comment
on the changes. Notice requirements for permits are set out at 40 CFR Part 270
subpart D. Further guidance on this process is in the CMS, and in the document
entitled RCRA Public Involvement Manual (EPA/530-R-93-006. September,
1993).]
All Public Involvement Plans prepared by the Permittee/Respondent shall be
submitted to the implementing agency for comment and approval prior to
use. Permittees/Respondents must never appear to represent or speak for the
implementing agency before the public, other government officials, or the
media.
Public Involvement activities that may be required of the
Permittee/Respondent include the following:
1. Conducting an open house or informal meeting (i.e.,
availability session) in a public location where people can talk
to agency officials and Permittee/Respondent on a one-to-one
basis;
2. Preparing fact sheets summarizing current or proposed
corrective action activities (all fact sheets should be reviewed
by the implementing agency prior to public distribution);
3. Communicating effectively with people who have vested
interest in the corrective action activities, (e.g., providing
written or verbal information in the foreign language of a
predominantly non-English-speaking community); and
4. Maintaining an easily accessible repository (such as a town hall
or public library or the facility itself, in some limited
circumstances) of information on the facility-specific corrective
action program, including the order or permit, approved
workplans, and/or other reports.
A schedule for community relations activities shall be included in the Public
Involvement Plan.
G. Schedule for Facility Investigation
[NOTE: Schedules should be as detailed as possible, but can be represented as a
series of contingent activities (e.g., sampling beginning within 30 days ofRFI
Workplan approval). This schedule may be required or revised during the next
section entitled "Facility Investigation".]
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1. Sampling
2. Analysis
3. Reports
4. Public Involvement Activities
5. Laboratory or Bench-Scale Studies
Section III: Facility Investigation
A. Purpose/Objectives
The Facility Investigation phase of an RFI is the first step of the
implementation process. Prior to this implementation phase, all
documentation and reports for the Description of Current Conditions and
RFI Workplan are drafted and submitted to the implementing agency for
review and approval. The Permittee/Respondent must have approval prior
to implementing the procedures outlined in the RFI Workplan. Throughout
the RFI implementation phase, it is critical that the Permittee/Respondent
comply with report submission requirements. The Permittee/Respondent
shall submit both progress reports and a draft RFI Report, which must be
submitted to the implementing agency for review. At the direction of the
implementing agency, the Permittee/Respondent shall develop in final format
the RFI Report, which will incorporate any comments received on the draft
report.
The Permittee/Respondent shall conduct those investigations (including
sampling) as approved in the RFI Workplan with all modifications to:
characterize the facility (Environmental Setting); define the source (Source
Characterization); define the degree and three dimensional extent of
contamination (Contamination Characterization); and identify actual or
potential receptors.
The investigations should result in data of adequate technical quality to
support the development and evaluation of the corrective measure
alternative(s) during the Corrective Measures Study (CMS) and/or ISMs.
[NOTE: As discussed in the 40 CFR part 264 subpart S proposed rule (55 FR
30875-30876, July 27, 1990), the implementing agency may require the
Permittee/Respondent to conduct a CMS whenever concentrations of hazardous
constituents in an aquifer, surface water, soils, or air exceed action levels for any
environmental medium. Action levels are health- and environmental-based
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levels determined by the agency to be indicators for protection of human health
and the environment. EPA's recommended action levels are set out in the
subpart S proposed rule. EPA currently is working on revisions to the
recommended levels and will provide notice of any changes to the subpart S
recommendations. ]
The site investigation activities (including sampling) shall follow the plans set
forth in the RFI Workplan.
[NOTE: The implementing agency may require the investigation to be phased
(e.g., by media or SWMU/Area of Contamination), the amount of information
collected to be limited, and/or the level of detail to be reduced.}
B. Environmental Setting
The Permittee/Respondent shall collect information to supplement and
verify existing information on the environmental setting at the facility (when
information already submitted to the implementing agency is not sufficient).
The implementing agency may request additional information not included
on the following lists. The Permittee/Respondent shall characterize the
following areas (the implementing agency should require characterization of
some or all of the following areas depending on the specifics of the site):
1. Hydrogeology
The Permittee/Respondent shall conduct a program to evaluate
hydrogeologic: conditions at the facility. This program shall provide
the following information:
• A description of the regional and facility-specific geologic and
hydrogeologic characteristics affecting ground-water flow
beneath the facility, including:
Regional and facility-specific stratigraphy including:
description of strata including strike and dip, and
identification of stratigraphic contacts;
Structural geology including: description of local and
regional structural features (e.g., folding, faulting, tilting,
jointing, etc.);
Depositional history;
Areas and amounts of recharge and discharge;
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Influence of tidal actions on groundwater flow regimes
near coastal areas or large rivers;
Regional and facility-specific ground-water flow
patterns; and
Seasonal variations in the ground-water flow regime.
An analysis of any topographic features that might influence
the ground-water flow system. (Note: Stereographic analysis of
aerial photographs may aid in this analysis.)
A representative and accurate classification and description of
the hydrogeologic units based on field data, tests, and cores
that may be part of the migration pathways at the facility (i.e.,
the aquifers and any intervening saturated and unsaturated
zones), including, but not limited to:
Hydraulic conductivity, intrinsic permeability
(particularly when non-aqueous phase liquids (NAPLs)
are present), and porosity (total and effective);
Lithology, grain size, sorting, degree of cementation;
An interpretation of hydraulic interconnections
between saturated zones; and
The attenuation capacity and mechanisms of the natural
earth materials (e.g., ion exchange capacity, organic
carbon content, mineral content, etc.).
Based on field studies and cores, structural geology and
hydrogeologic cross sections showing the extent (depth,
thickness, lateral extent) of hydrogeologic units that may be
part of the migration pathways identifying:
Sand and gravel in unconsolidated deposits;
Zones of fracturing or channeling in consolidated and
unconsolidated deposits;
Zones of higher permeability or low permeability that
might direct and restrict the flow of contaminants;
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The uppermost aquifer: geologic formation, group of
formations, or part of a formation capable of yielding a
significant amount of ground water to wells or springs;
Water-bearing zones above the first confining layer that
may serve as a pathway for contaminant migration,
including perched zones of saturation; and
All other geologic formations, or parts thereof, yielding
a significant amount of ground water.
Based on data obtained from ground-water monitoring wells
and piezometers installed upgradient and downgradient of the
potential contaminant source, a representative description of
water level or fluid pressure monitoring including:
Water level contour and/or potentiometric maps;
Hydrologic cross sections showing vertical flow
gradients;
The flow system, including the vertical and horizontal
components of flow; and
Any temporal changes in hydraulic gradients, (due to
tidal or seasonal influences, etc.)
A description of man-made influences that may affect the
hydrogeology of the site, identifying:
Active and inactive local water-supply and production
wells with an approximate schedule of pumping; arid
Man-made hydraulic structures (pipelines, french drains,
ditches, unlined ponds, septic tanks, NPDES outfalls,
retention areas, etc.).
2. Soils
[NOTE: Soil characterization includes the chemical, physical, and
mineralogical analysis of soils. The implementing agency may vary the
required level of characterization based on data needs for the CMS/ISMs,
Where removal of contaminated soil is the logical remedial action,
limited physical information may be required. Where in-situ soil
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treatment may be the remedial action, a full characterization may be
appropriate. Where an estimation of contaminant transport is necessary,
some type of intermediate level characterization may be required.]
The Permittee/Respondent shall conduct a program to characterize
the soil and rock units potentially affected by contaminant release(s).
Such characterization shall include, but not be limited to, the
following information:
• Where remediation by removal of soils is the only corrective
measure option, provide map(s) and perpendicular cross
sections showing:
The extent of contamination;
Depth of groundwater; and
The consistency and distribution of soils (using the
Unified Soil Classification System (USCS) (ASTM D
2487));
[NOTE: The above information is important for stability of cuts. If such factors
are not considered when excavating, piling, or sloping material, the stability of
surrounding walls and piles of material may be compromised.]
• Where remediation by removal is the likely option, and it is
necessary to determine the extent of migration (e.g., to assess
the mobility of wastes from an unlined surface impoundment
or landfill), provide the following in addition to the
requirements immediately above:
Depth to bedrock and the characteristics of the bedrock
including discontinuities such as faults, fissures, joints,
fractures, sinkholes, etc.;
A detailed soil survey conducted according to USDA
Soil Conservation Service (SCS) procedures including:
USDA Textural Soil Classification and soil
profiles showing stratifications or zones which
may affect or direct the subsurface flow;
- Hydraulic conductivity and the SCS hydrologic
group classification of A, B, C or D;
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- Relative permeability (only if the waste may
have changed the soil's hydraulic conductivity,
such as concentrated organics);
Storage capacity (if excavated soil will be stored);
Shrink-swell potential (where extreme dry
weather could lead to the formation of cracks);
- Potential for contaminant transport via erosion,
using the Universal Soil Loss Equation;
Soil sorptive capacity;
Cation exchange capacity;
- Soil organic content; and
Soil pH.
The following contaminant characteristics must be
included:
- Physical state;
- Viscosity;
pH;
pKa;
Density;
- Water solubility;
- Henry's Law Constant;
Biodegradability; and
Rates of hydrolysis, photolysis and oxidation.
Where in-situ soil treatment will likely be the remediation, the
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above information and the following additional information
must be provided:
Bulk density;
Porosity;
Grain size distribution;
Mineral content;
Soil moisture profile;
Unsaturated hydraulic conductivity;
Effect of stratification on unsaturated flow; and
Infiltration and evapotranspiration.
3. Surface Water and Sediment
The Permittee/Respondent shall conduct a program to characterize the
surface water bodies likely to be affected by releases from the facility. Such
characterization shall include the following activities and information:
• Description of the temporal and permanent surface water bodies
including:
For lakes and estuaries: location, elevation, surface area, inflow,
outflow, depth, temperature stratification, and volume;
For impoundments: location, elevation, surface area, depth,
volume, freeboard, and purpose of impoundment;
For streams, ditches, drains, swamps and channels: location,
elevation, flow, velocity, depth, width, seasonal fluctuations,
and flooding tendencies (i.e., 100-year event);
For wetlands obtain any available delineation;
Containment measures in place (e.g., levees, concrete lining,
etc.)
Drainage patterns; and
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Evapotranspiration rates.
• Description of the chemistry of the natural surface water and
sediments. This includes determining:
pH;
total dissolved solids;
total suspended solids;
biological oxygen demand;
alkalinity;
conductivity;
dissolved oxygen profiles;
nutrients (NH3, N03 /N02, PO^3);
chemical oxygen demand;
total organic carbon; and
specific contaminant concentrations.
• Description of sediment characteristics including:
Deposition area;
Thickness profile; and
Physical and chemical parameters (e.g., grain size, density,
organic carbon content, ion exchange capacity, pH, etc.).
4. Air
The Permittee/Respondent shall provide information characterizing the
climate in the vicinity of the facility. Such information shall include:
• A description of the following parameters:
Annual and monthly rainfall averages;
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Monthly temperature averages and extremes;
Wind speed and direction;
Relative humidity/dew point;
Atmospheric pressure;
Evaporation data;
Development of inversions; and
Climate extremes that have been known to occur in the
vicinity of the facility, including frequency of occurrence.
• A description of topographic and man-made features that affect air
flow and emission patterns, including:
Ridges, hills, or mountain areas;
Canyons or valleys;
Surface water bodies (e.g., rivers, lakes, bays, etc.);
Wind breaks and forests; and
Buildings.
[NOTE: The above descriptions should be updated to include any air modeling
that is performed.]
C. Source Characterization
[NOTE: The implementing agency may focus source characterization on the
specific units, disposal areas, or other areas (e.g., exposure pathways) that have
been identified by the agency to be of concern.]
The Permittee/Respondent shall collect analytical data to characterize the
wastes and the areas where wastes have been placed, collected or removed
including: type; quantity; physical form; disposition (containment or nature
of disposal); and any facility characteristics that may affea or have affected a
release (e.g., facility security, engineered barriers). This shall include
quantification of the following specific characteristics, at each source area:
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1. Unit/Disposal Area/Area of Concern Characteristics:
• Location of unit/disposal area;
• Type of unit/disposal area;
• Design features;
• Operating practices (past and present) including the history of releases;
• Period of operation;
• Age of unit/disposal area;
• General physical conditions; and
• Method used to close the unit/disposal area.
2. Waste Characteristics:
• Type of waste placed in the unit;
Hazardous classification (e.g., flammable, reactive, corrosive,
oxidizing or reducing agent);
Quantity; and
Chemical composition.
• Physical and chemical characteristics;
Physical form (solid, liquid, gas);
Physical description (e.g., powder, oily sludge);
Temperature;
pH;
General chemical class (e.g., acid, base, solvent);
Molecular weight;
Density;
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Boiling point;
Viscosity;
Solubility in water;
Cohesiveness of the waste;
Vapor pressure; and
Flash point.
• Migration and dispersal characteristics of the waste;
Sorption;
Biodegradability, bioconcentration, biotransformation;
Photodegradation rates;
Hydrolysis rates; and
Chemical transformations.
The Permittee/Respondent shall document the procedures used in making
the above determinations.
D. Contamination Characterization
The Permittee/Respondent shall collect analytical data on ground water,
soils, surface water, sediment, air, and subsurface gas likely to be affected by
releases from the facility. This data shall be sufficient to define the extent,
origin, direction, and rate of movement of contaminant plumes. Data shall
include:
• time and location of sampling;
• media sampled;
• concentrations found;
• conditions during sampling; and
• the identity of the individuals performing the sampling and analysis.
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The Permittee/Respondent shall address the following types of
contamination at the facility:
1. Groundwater Contamination
The Permittee/Respondent shall conduct a groundwater investigation to
characterize any plumes of contamination at the facility. This investigation
shall, provide the following information:
• A description of the horizontal and vertical extent of any immiscible
or dissolved plume(s) originating from the facility;
• The horizontal and vertical direction of contaminant movement;
• The velocity of contaminant movement;
• The horizontal and vertical concentration profiles of Appendix IX
constituents in the plume(s);
• An evaluation of factors influencing the plume movement; and
• An extrapolation of future contaminant movement over the time
period specified by the implementing agency.
The Permittee/Respondent shall document the procedures used in making
the above determinations (e.g., well design, well construction, geophysics,
modeling, etc.).
[NOTE: It may be helpful for the Permittee/Respondent to refer to applicable
guidance documents such as "RCRA Ground-water Monitoring Technical
Enforcement Guidance Document (TEGD)," OSWER Directive 9950.1,
September 1986,]
2. Soil Contamination
The Permittee/Respondent shall conduct an investigation to characterize the
contamination of the soil and rock units above the water table in the vicinity
of the contaminant release. The investigation shall include the following
information:
• A description of the vertical and horizontal extent of contamination;
• A description of contaminant and soil chemical properties within the
contaminant source area and plume. This includes contaminant
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solubility, speciation, adsorption, leachability, exchange capacity,
biodegradability, hydrolysis, photolysis, oxidation and other factors
that might affect contaminant migration and transformation;
• Specific contaminant concentrations;
• Velocity and direction of contaminant movement; and
• An extrapolation of future contaminant movement over the time
period specified by the implementing agency.
The Permittee/Respondent shall document the procedures used in making
the above determinations.
[NOTE: Analytical data collected under Section III.C. "Source Characterization",
Number 2. "Waste Characteristics" may be relevant to this section. This data
may be used to supplement this section or elements of the two sections regarding
waste characteristics may be combined.]
3. Surface Water and Sediment Contamination
The Permittee/Respondent shall conduct a surface water investigation to
characterize contamination in surface water bodies resulting from
contaminant releases at the facility. The Permittee/Respondent may also be
required to characterize contamination from storm water runoff.
The investigation shall include the following information:
• A description of the horizontal and vertical extent of any immiscible
or dissolved plume(s) originating from the facility, and the extent of
contamination in underlying sediments;
• The horizontal and vertical direction of contaminant movement;
• The contaminant velocity;
• An evaluation of the physical, biological, and chemical factors
influencing contaminant movement;
• An extrapolation of future contaminant movement over the time
period specified by the implementing agency; and
• A description of the chemical and physical properties of the
contaminated surface waters and sediments. This includes
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determining the pH, total dissolved solids, specific contaminant
concentrations, etc.
The Permittee/Respondent shall document the procedures used in making
the above determinations.
4. Air Contamination
The Permittee/Respondent shall conduct an investigation to characterize the
particulate and gaseous contaminants released into the atmosphere. This
investigation shall provide the following information:
• A description of the horizontal and vertical direction and velocity of
contaminant movement;
• The rate and amount of the release; and
• The chemical and physical composition of the contaminants(s)
released, including horizontal and vertical concentration profiles.
The Permittee/Respondent shall document the procedures used in making
the above determinations.
5. Subsurface Gas Contamination
The Permittee/Respondent shall conduct an investigation to characterize
subsurface gases emitted from buried hazardous waste and hazardous
constituents in the ground water. This investigation shall include the
following information:
• A description of the horizontal and vertical extent of subsurface gas
migration;
• The chemical composition of the gases being emitted;
• The rate, amount, and density of the gases being emitted; and
• Horizontal and vertical concentration profiles of the subsurface gases
emitted.
The Permittee/Respondent shall document the procedures used in making
the above determinations.
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E. Potential Receptor Identification
The Permittee/Respondent shall collect data describing the human
populations and environmental systems that currently or potentially are at
risk of contaminant exposure from the facility. Chemical analysis of
biological samples may be needed. Data on observable effects in ecosystems
may also be required by the implementing agency. The following
characteristics shall be identified:
1. Local uses and possible future uses of ground water:
• Type of use (e.g., drinking water source: municipal or
residential, agricultural, domestic/non-potable, and industrial)
and
• Location of ground water users including wells and discharge
areas.
2. Local uses and possible future uses of surface waters characterized in
the "Environmental Setting" or "Contamination Characterization"
Sections above:
• Domestic and municipal (e.g., potable and lawn/gardening
watering);
• Recreational (e.g., swimming, fishing);
• Agricultural;
• Industrial; and
• Environmental (e.g., fish and wildlife propagation).
3. Authorized or unauthorized human use of or access to the facility and
adjacent lands, including but not limited to:
• Recreation;
• Hunting;
• Residential;
• Commercial;
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• Zoning; and
• Relationship between population locations and prevailing wind
direction.
4. A demographic profile of the people who use or have access
(authorized or unauthorized) to the facility and adjacent land,
including, but not limited to: age; sex; sensitive subgroups; and
environmental justice concerns.
5. A description of the ecology of the facility and adjacent areas,
including habitat and species present and expected to be present.
6. A description of the biota in surface water bodies on, adjacent to, or
affected by the facility.
7. A description of any state and federal endangered or threatened
species (both proposed and listed) near the facility.
Section IV: Preliminary Evaluation of Corrective Measure Technologies by
Laboratory or Bench-Scale Studies [optional]
The Permittee/Respondent may conduct laboratory and/or bench scale
studies to determine the applicability of a corrective measure technology or
technologies to facility conditions. These studies may be conducted at any
time during the RFI; the intent is to collect information that will be useful
in evaluating potential technologies and to conduct additional studies when
sufficient data is available and useful. The Permittee/Respondent shall
analyze the technologies, based on literature review, vendor contracts, and
past experience to determine the testing requirements.
[NOTE: Appendix F presents standard geologic data requirements for
consideration in the technology decision process, and Appendix A provides
references for technical assistance (e.g., "Guidance for Conducting Remedial
Investigations and Feasibility Studies Under CERCLA" - Chapter 5).]
The Permittee/Respondent shall develop a testing plan identifying the type(s)
and goal(s) of the study or studies, the level of effort needed, and the
procedures to be used for data management and interpretation.
Upon completion of the testing, the Permittee/Respondent shall evaluate the
testing results to assess the technology or technologies with respect to the
site-specific questions identified in the test plan.
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The Permittee/Respondent shall prepare a report summarizing the testing
program and its results (if studies are performed), both positive and negative.
Section V: Investigation Results and Analysis
The Permittee/Respondent shall prepare an analysis and summary of all
facility investigations and their results. The investigation data should be
sufficient in quality (e.g., quality assurance procedures have been followed)
and quantity to describe the nature and extent of contamination, potential
threat to human health and/or the environment, and to support the
Corrective Measures Study and/or ISMs.
A. Data Analysis
The Permittee/Respondent shall analyze all facility investigation data
outlined in Section III and prepare a report on the type and extent of
contamination at the facility including sources and migration pathways. The
report shall describe the extent of contamination (qualitative/quantitative) in
relation to background levels indicative for the area.
B. Media Cleanup Standards
The Permittee/Respondent shall provide information as required by the
implementing agency to support the agency's selection/development for
media cleanup standards of any releases that may have adverse effects on
human health and the environment due to migration of waste constituents.
Media cleanup standards are to contain such terms and provisions as
necessary to protect human health and the environment, including, the
provisions stated below.
[NOTE: Implementing agencies should determine which of the following items
under 1 through 4 below are necessary on a site-specific basis.]
1. Ground-water Cleanup Standards
The Permittee/Respondent shall provide information to support the
implementing agency's selection/development of ground-water cleanup
standards for all of the Appendix IX constituents found in the ground water
during the Facility Investigation (Section III). The implementing agency
may require the following information:
• For any constituents for which an MCL has been promulgated
under the Safe Drinking Water Act, the MCL value;
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Background concentration of the constituent in the ground
water; or
An alternate standard (e.g., an alternate concentration limit
(ACL) for a regulated unit) to be approved by the
implementing agency.
2. Soil Cleanup Standards
The Permittee/Respondent shall provide information to support the
implementing agency's selection/development of soil cleanup standards.
The implementing agency may require the following information:
• The volume and physical and chemical characteristics of the
wastes in the unit;
• The effectiveness and reliability of containing, confining, and
collecting systems and structures in preventing contaminant
migration;
• The hydrologic characteristics of the unit and the surrounding
area, including the topography of the land around the unit;
• The patterns of precipitation in the region;
• The existing quality of surface soils, including other sources of
contamination and their cumulative impacts on surface soils;
• The potential for contaminant migration and impact to the
underlying groundwater;
• The patterns of land use in the region;
• The potential for health risks caused by human exposure to
waste constituents; and
• The potential for damage to domestic animals, wildlife, food
chains, crops, vegetation, and physical structures caused by
exposure to waste constituents.
3. Surface Water and Sediment Cleanup Standards
The Permittee/Respondent shall provide information to support the
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implementing agency's selection/development of surface water and sediment
cleanup standards. The implementing agency may require the following
information:
• The volume and physical and chemical characteristics of the
wastes in the unit;
• The effectiveness and reliability of containing, confining, and
collecting systems and structures in preventing contaminant
migration;
• The hydrologic characteristics of the unit and the surrounding
area, including the topography of the land around the unit;
• The patterns of precipitation in the region;
• The quantity, quality, and direction of ground-water flow;
• The proximity of the unit to surface waters;
• The current and potential uses of nearby surface waters and
any water quality standards established for those surface
waters;
• The existing quality of surface waters, including other sources
of contamination and their cumulative impacts on surface
waters;
• The potential for damage to domestic animals, wildlife, food
chains, crops, vegetation and physical structures caused by
exposure to waste constituents;
• The patterns of land use in the region; and
• The potential for health risks caused by human exposure to
waste constituents.
4. Air Cleanup Standards
The Permittee/Respondent shall provide information to support the
implementing agency's selection/development of air cleanup standards. The
implementing agency may require the following information:
• The volume and physical and chemical characteristics of the
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wastes in the unit, including its potential for the emission and
dispersal of gases, aerosols and particulates;
• The effectiveness and reliability of systems and structures to
reduce or prevent emissions of hazardous constituents to the
air;
• The operating characteristics of the unit:
• The atmospheric, meteorological, and topographic
characteristics of the unit and the surrounding area;
• The existing quality of the air, including other sources of
contamination and their cumulative impact on the air;
• The potential for health risks caused by human exposure to
waste constituents; and
• The potential for damage to domestic animals, wildlife, crops,
vegetation, and physical structures caused by exposure to waste
constituents.
5. Other Relevant Cleanup Standards
The Permittee/Respondent shall identify all relevant and applicable standards
for the protection of human health and the environment (e.g., National
Ambient Air Quality Standards, Federally approved state water quality
standards, etc.).
C. Analysis of Risk [optional]
The implementing agency may require the Permittee/Respondent to prepare
an analysis of risk at the facility. This analysis may include ecological as well
as human health risk. Generally a baseline risk assessment would be
conducted during the RFI stage with further analysis occurring during the
CMS stage.
[NOTE: While some implementing agencies may require the
Permittee/Respondent to conduct a risk assessment, the policy on conducting risk
assessments in the corrective action program is evolving. Currently, their use is
optional at the discretion of the implementing agency and should be based on
site-specific conditions. Appendix G presents a list of available guidance for
conducting risk assessments.]
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Section VI: Progress Reports
The Permittee/Respondent will, at a minimum, provide the implementing
agency with signed [monthly, bimonthly, or quarterly] progress reports.
These reports may be required to contain the following information, but
agency requirements are not limited to this list:
1. A description and estimate of the percentage of the RFI completed;
2. Summaries of all findings in the reporting period, including results of
any sampling and analysis;
3. Summaries of all changes made in the RFI during the reporting
period;
4. Summaries of all contacts with representative of the local community,
public interest groups or State government during the reporting
period;
5. Summaries of all contacts made regarding access to off-site property;
6. Summaries of all problems encountered during the reporting period;
7. Actions being taken to rectify problems;
8. Changes in relevant personnel during the reporting period;
9. Projected work for the next reporting period; and
10. Copies of daily reports, inspection reports, laboratory/monitoring
data, etc.
Section VIII: Proposed Schedule
The Permittee/Respondent will provide the implementing
agency with RFI reports according to the following schedule:
Facility Submission Due Date
Description of Current [ DATE ]
Conditions
(Section I)
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RFI Workplan [ DATE ]
(Section II)
Draft RFI Report [NUMBER ] days after
(Sections III and V) RFI Workplan Approval
Final RFI Report [ NUMBER ] days after
(Sections III and V) the implementing agency
comments on Draft RFI Report, (date
of approval may be tied to this
submittal of the CMS Workplan, if
required,)
Laboratory and Bench- Concurrent with Final RFI
Scale Studies Report
(Section IV)
Progress Reports on [ MONTHLY, BI-
Sections I through V MONTHLY, other ]
[see Section VI above for guidance on progress reports.]
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Chapter IV: Corrective Measures Study
Introduction
The purpose of the Corrective Measures Study (CMS) portion of the RCRA
corrective action process is to identify and evaluate potential remedial alternatives
for the releases that have been identified at a facility. The scope and requirements
of the CMS, however, need to be balanced with the expeditious initiation of
remedies and rapid restoration of contaminated media, both major goals of the
RCRA corrective action program. In keeping with these goals, the implementing
agency may allow a streamlined approach to remedy selection, enabling a facility to
move from facility investigation to corrective measures implementation more
rapidly. Information gathered during the implementation of ISMs should be used to
augment the CMS and avoid duplicative efforts. Aspects of the implemented ISMs
may be viewed as an early and focused CMS. In some cases, the ISMs may
substitute for the final CMS/CMI after review and approval by the implementing
agency. The Permittee/Respondent shall furnish all personnel, materials, and
services necessary for, or incidental to, performing the CMS.
It is anticipated that Permittees/Respondents of larger sites with complex
environmental problems may need to evaluate several alternative remedial
approaches in determining the most appropriate remedy for the facility. For other
RCRA facilities, however, it may be appropriate for the implementing agency to
allow the Permittee/Respondent to evaluate only one alternative.
Studies needed for developing sound, environmentally protective remedies may
be relatively straightforward at some RCRA facilities, and may not require extensive
evaluation of a number of remedial alternatives. Such "streamlined" CMS's can be
tailored to fit the complexity and scope of the remedial situation presented by the
facility. For example, if the environmental problems at a facility were limited to a
small area of soils with low-level contamination, the CMS might be limited to a
single treatment approach that is known to be effective for such types of
contamination. In a different situation, such as with a large municipal-type landfill,
it may be obvious that the source control element of the CMS should be focused on
containment options, while contaminated media remediation may require more
extensive study. It is anticipated that a streamlined or highly focused CMS may be
appropriate in the following types of situations:
1. "Low risk" facilities. Facilities where environmental problems are
relatively small, and where releases present minimal exposure concerns.
Such facilities might have limited on-site soil contamination.
2. High quality remedies proposed by the Permittee/Respondent. The
Permittee/Respondent may propose a remedy which is highly protective
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(such as an action which would remediate to non-detectable levels) and
which is consistent with all other remedial objectives.
3. Facilities with straightforward remedial solutions. For some
contamination problems, standard engineering solutions can be applied
that have proven effective in similar situations. An example might be
cleanup of soils contaminated with PCBs by excavation, removal and
treatment, then disposal.
4. Phased remedies. At some facilities the nature of the environmental
problem will dictate development of the remedy in phases, which would
focus on one aspect (such as groundwater remediation) of the remedy, or
one area of the facility that requires immediate measures to control
further environmental and human exposure problems. In these
situations, the CMS could be focused on that specific element of the
overall remedy, with follow-up studies as appropriate to deal with the
remaining remedial needs at the facility. Such studies should be
documented in later CMS phases. For particularly large facilities, several
phases should be designated.
It is also recognized that, in contrast to the above situations, some facilities with
very extensive or highly complex environmental problems will likely require an
assessment of a number of alternative remedial technologies or approaches. The
following are examples of situations which would likely need relatively extensive
studies to be done to support sound remedy selection decisions:
1. "High risk" facilities with complex remedial solutions. Such facilities
might have large volumes of both concentrated wastes and contaminated
soils, for which several treatment technologies could be applied to achieve
varying degrees of effectiveness (such as reduction of toxicity or volume),
in conjunction with different types of containment systems for residuals.
2. Contaminant problems for which several different approaches are
practicable. There may be several, quite distinct technical approaches for
remediating a problem at a facility, each of which offers varying degrees
of long-term reliability, and could be implemented over different time
frames. In such cases, remedy selection decisions will necessarily involve
a difficult balancing of competing goals and interests. Such decisions
must be supported with adequate information.
3. Facilities for which innovative treatment technologies may be viable.
In addition to the above examples of situations calling for either a limited, or
relatively complex CMS, other studies will fall in the middle of that range. Given
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the wide range of possibilities for structuring the CMS, this guidance encourages the
implementing agency to focus the evaluation on appropriate remedies, tailoring the
scope and substance of the study to fit the complexity of the situation. It will also
be the responsibility of the implementing agency to determine what level of
evaluation and documentation is necessary in order to support the ultimate remedy
selection for the facility.
The implementing agency has the discretion to not require sections of the plan
and/or report that are specified in this guidance, in those site-specific situations
where all the requirements may not be appropriate. The implementing agency also
may require the Permittee/Respondent to conduct additional studies beyond what is
discussed in the scope of work in order to support the CMS. The
Permittee/Respondent will furnish all personnel, materials and services necessary to
conduct the additional tasks.
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[NOTE: With certain exceptions, the provisions set out in sections I through IV are
intended as guidance, and these provisions should be justifiable and tailored to site-
specific conditions when incorporated into permits or orders. The exceptions are certain
provisions which are based on specific regulatory or statutory requirements applicable to
permitting. Regulatory and statutory requirements are binding and do not require site-
specific justification. Applicable requirements include: public notice requirements
specified in 40 CFR subpart D and requirements in 40 CFR §264.101. The following
Scope of Work (SOW) for the Corrective Measures Study is intended to be a flexible
document capable of addressing both simple and complex site situations.}
Scope of Work for a Corrective Measures Study (CMS)
Purpose
The purpose of the Corrective Measures Study (CMS) portion of the RCRA
corrective action process is to identify and evaluate potential remedial alternatives
for the releases that have been identified at a facility.
Scope
A Corrective Measures Study Workplan and Corrective Measures Study Report
are, unless otherwise specified by the implementing agency, required elements of the
CMS. The CMS consists of the following components:
Section I: Corrective Measures Study Workplan
Section II: Corrective Measures Study Report
A. Introduction /Purpose
B. Description of Current Conditions
C. Corrective Action Objectives
D. Identification, Screening and Development of Corrective Measure
Alternatives
E. Evaluation of A Final Corrective Measure Alternative
F. Recommendation by a Permittee/Respondent for a Final
Corrective Measure Alternative
G. Public Involvement Plan
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Section III: Progress Reports
Section IV: Proposed Schedule
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Section I: Corrective Measures Study Workplan
The Corrective Measures Study (CMS) Workplan may be required by the
implementing agency. If required, it shall include the following elements:
1. A site-specific description of the overall purpose of the Corrective
Measure Study;
2. A description of the corrective measure objectives, including proposed
target media cleanup standards (e.g., promulgated federal and state
standards, risk derived standards) and points of compliance or a
description of how a risk assessment will be performed (e.g., guidance
documents);
3. A description of the specific corrective measure technologies and/or
corrective measure alternatives which will be studied;
4. A description of the general approach to investigating and evaluating
potential corrective measures;
5. A detailed description of any proposed pilot, laboratory and/or bench
scale studies;
[NOTE: Appendix A provides references for technical assistance (e.g.,
"Guidance for Conducting Remedial Investigations and Feasibility Studies
Under CERCLA" • Chapter 5.J]
6. A proposed outline for the CMS Report including a description of how
information will be presented; and
7. A description of overall project management including overall approach,
levels of authority (include organization chart), lines of communication,
project schedules, budget and personnel. Include a description of
qualifications for personnel directing or performing the work.
Section II: Corrective Measures Study Report
The Corrective Measures Study (CMS) Report shall include the following elements:
A. Introduction/Purpose
The Permittee/Respondent shall describe the purpose of the document
and provide a summary description of the project.
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B. Description of Current Conditions
The Permittee/Respondent shall include a brief summary/discussion of
any new information that has been discovered since the RFI current
conditions report was finalized. This discussion should concentrate on
those issues which could significantly affect the evaluation and selection
of the corrective measures alternative(s).
[NOTE: The implementing agency may allow the Permittee/Respondent to
reference the RFI current conditions report in lieu of additional discussion in
this section.]
C. Media Cleanup Standards
The Permittee/Respondent may propose media cleanup standards. The
standards must be based on promulgated federal and state standards, risk derived
standards, all data and information gathered during the corrective action process
(e.g., from interim measures, RCRA Facility Investigation, etc.), and/or other
applicable guidance documents. If no other guidance exists for a given
contaminant and media, the Permittee/Respondent shall propose and justify a
media cleanup standard.
[NOTE: The implementing agency may set cleanup standards before the CMS stage.
The information to support the agency's decision may be submitted by the
Permittee/Respondent as pan of the investigation analysis (see Section V of the RFI
scope of work). The Permittee/Respondent may propose to modify the media cleanup
standards during the CMS. As a result of this or other new information, the
implementing agency may modify the cleanup standards. Final media cleanup
standards are determined by the implementing agency when the remedy is selected
and are documented in the Statement of Basis/Response to Comments (SB/RTC) or
permit modification.]
D. Identification, Screening, and Development of Corrective Measure
Alternatives
1. Identification: List and briefly describe potentially applicable
technologies for each affected media that may be used to achieve
the corrective action objectives. The Permittee/Respondent
should consider including a table that summarizes the available
technologies. Depending on the site-specific situation, the
implementing agency may require the Permittee/Respondent to
consider additional technologies.
The Permittee/Respondent should consider innovative treatment
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technologies, especially in situations where there are a limited
number of applicable corrective measure technologies. Innovative
technologies are defined as those technologies utilized for
remediation, other than incineration, solidification/stabilization,
and pumping with conventional treatment for contaminated
groundwater [see Appendix CJ. Innovative treatment :echnologies
may require extra effort to gather information, to analyze
options, and to adapt the technology to the site-specific situation.
Treatability studies and on-site pilot scale studies may be
necessary for evaluating innovative treatment technologies.
2. Screening [optional]: When the Permittee/Respondent is required
to, or chooses to, evaluate a number of corrective measures
technologies, the Permittee/Respondent will evaluate the
technology limitations to show why certain corrective measures
technologies may prove unfeasible to implement given existing
waste and site-specific conditions.
Likewise, if only one corrective measure alternative is being
analyzed, the Permittee/Respondent must indicate any
technological limitations given waste and site-specific conditions at
the facility for which it is being considered. The Permittee/
Respondent should consider including a table that summarizes
these findings.
3. Corrective Measure Development [optional]: As required by the
implementing agency, the Permittee/Respondent shall assemble
the technologies that pass the screening step into specific
alternatives that have potential to meet the corrective action
objectives for each media. Options for addressing less complex
sites could be relatively straight-forward and may only require
evaluation of a single or limited number of alternatives.
Each alternative may consist of an individual technology or a
combination of technologies used in sequence (i.e., treatment
train). Depending on the site specific situation, different
alternatives may be considered for separate areas of the facility.
List and briefly describe each corrective measure alternative.
E. Evaluation of a Final Corrective Measure Alternative
For each remedy which warrants a more detailed evaluation, including
those situations when only one remedy is being proposed, the
Permittee/Respondent shall provide detailed documentation of how the
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potential remedy will comply with each of the standards listed below.
These standards reflect the major technical components of remedies
including cleanup of releases, source control and management of wastes
that are generated by remedial activities. The specific standards are
provided below.
1. Protect human health and the environment.
2. Attain media cleanup standards set by the implementing agency.
3. Control the source of releases so as to reduce or eliminate, to the
extent practicable, further releases that may pose a threat to
human health and the environment.
4. Comply with any applicable standards for management of wastes.
5. Other Factors.
In evaluating the selected alternative or alternatives the
Permittee/Respondent shall prepare and submit information that
documents that the specific remedy will meet the standards listed above.
The following guidance should be used in completing this evaluation.
This guidance provides examples of the types of information that would
be supportive; the implementing agency may require additional
information.
1. Protect Human Health and the Environment
Corrective action remedies must be protective of human health and the
environment. Remedies may include those measures that are needed to
be protective, but are not directly related to media cleanup, source
control, or management of wastes. An example would be a requirement
to provide alternative drinking water supplies in order to prevent
exposures to releases from an aquifer used for drinking water purposes.
Another example would be a requirement for the construction of barriers
or for other controls to prevent harm arising from direct contact with
waste management units. Therefore, the Permittee/Respondent shall
include a discussion on what types of short term remedies are appropriate
for the particular facility in order to meet this standard. This
information should be provided in addition to a discussion of how the
other corrective measure alternatives meet this standard.
2. Attain Media Cleanup Standards Set by the Implementing Agency
Remedies will be required to attain media cleanup standards set by the
implementing agency which may be derived from existing state or federal
regulations (e.g. groundwater standards) or other standards. The media
cleanup standards for a remedy will often play a large role in determining
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the extent of and technical approaches to the remedy. In some cases,
certain technical aspects of the remedy, such as the practical capabilities
of remedial technologies, may influence to some degree the media cleanup
standards that are established.
As part of the necessary information for satisfying this requirement, the
Permittee/Respondent shall address whether the potential remedy will
achieve the preliminary remediation objective as identified by the
implementing agency as well as other, alternative remediation objectives
that may be proposed by the Permittee/Respondent. The
Permittee/Respondent shall also include an estimate of the time frame
necessary for each alternative to meet these standards.
3. Control the Sources of Releases
A critical objective of any remedy must be to stop further environmental
degradation by controlling or eliminating further releases that may pose a
threat to human health and the environment. Unless source control
measures are taken, efforts to clean up releases may be ineffective or, at
best, will essentially involve a perpetual cleanup. Therefore, an effective
source control program is essential to ensure the long-term effectiveness
and protectiveness of the corrective action program.
The source control standard is not intended to mandate a specific remedy
or class of remedies. Instead, the Permittee/Respondent is encouraged to
examine a wide range of options. This standard should not be
interpreted to preclude the equal consideration of using other protective
remedies to control the source, such as partial waste removal, capping,
slurry walls, in-situ treatment/stabilization and consolidation.
[NOTE: When evaluating potential alternatives, further releases from sources
of contamination are to be controlled to the extent practicable. This qualifier
is intended to account for the technical limitations that may in some cases be
encountered in achieving effective source control. For some very large
landfills, or large areas of widespread soil contamination, engineering
solutions such as treatment or capping to prevent further leaching may not be
technically practicable, to eliminate further releases above health-based
contamination levels. In such cases, source controls may need to be combined
with other measures, such as plume management or exposure controls, to
ensure an effective and protective remedy.]
As part of the CMS Report, the Permittee/Respondent shall address the
issue of whether source control measures are necessary, and if so, the
type of actions that would be appropriate. Any source control measure
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proposed should include a discussion on how well the method is
anticipated to work given the particular situation at the facility and the
known track record of the specific technology.
4. Comply With Any Applicable Standards for Management of Wastes.
The Permittee/Respondent shall include a discussion of how the specific
waste management activities will be conducted in compliance with all
applicable state or federal regulations (e.g., closure requirements, land
disposal restrictions).
5. Other Factors
There are five general factors that will be considered as appropriate by
the implementing agency in selecting/approving a remedy that meets the
four standards listed above. These factors represent a combination of
technical measures and management controls for addressing the
environmental problems at the facility. The five general decision factors
include:
a. Long-term reliability and effectiveness;
b. Reduction in the toxicity, mobility or volume of wastes;
c. Short-term effectiveness;
d. Implementability; and
e. Cost.
The implementing agency may request the Permittee/Respondent to
provide additional information to support the use of these factors in the
evaluation of viable remedial alternatives. Examples of the types of
information that may be requested are provided below:
a. Long-term Reliability and Effectiveness
Demonstrated and expected reliability is a way of assessing the
risk and effect of failure. The Permittee/Respondent may
consider whether the technology or a combination of technologies
have been used effectively under analogous site conditions,
whether failure of any one technology in the alternative would
have an immediate impact on receptors, and whether the
alternative would have the flexibility to deal with uncontrollable
changes at the site (e.g., heavy rain storms, earthquakes, etc.).
Most corrective measure technologies, with the exception of
destruction, deteriorate with time. Often, deterioration can be
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slowed through proper system operation and maintenance, but
the technology eventually may require replacement. Each
corrective measure alternative should be evaluated in terms of the
projected useful life of the overall alternative and of its
component technologies. Useful life is defined as the length of
time the level of effectiveness can be maintained.
b. Reduction in the Toxicity, Mobility or Volume of Wastes
As a general goal, remedies will be preferred that employ
techniques, such as treatment technologies, that are capable of
eliminating or substantially reducing the inherent potential for the
wastes in SWMUs (and/or contaminated media at the facility) to
cause future environmental releases or other risks to human
health and the environment. There may be some situations
where achieving substantial reductions in toxicity, mobility or
volume may not be practical or even desirable. Examples might
include large, municipal-type landfills, or wastes such as
unexploded munitions that would be extremely dangerous to
handle, and for which the short-term risks of treatment outweigh
potential long-term benefits.
Estimates of how much the corrective measures alternatives will
reduce the waste toxicity, volume, and/or mobility may be
helpful in applying this factor. This may be done through a
comparison of initial site conditions to expected post-corrective
measure conditions.
c. Short-term Effectiveness
Short-term effectiveness may be particularly relevant when
remedial activities will be conducted in densely populated areas,
or where waste characteristics are such that risks to workers or to
the environment are high and special protective measures are
needed. Possible factors to consider include fire, explosion,
exposure to hazardous substances and potential threats associated
with treatment, excavation, transportation, and redisposal or
containment of waste material.
d. Implementability
Implement ability will often be a determining variable in shaping
remedies. Some technologies will require state or local approvals
prior to construction, which may increase the time necessary to
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implement the remedy. In some cases, state or local restrictions
or concerns may necessitate eliminating or deferring certain
technologies or remedial approaches from consideration in remedy
selection. Information to consider when assessing
implementability may include:
1. The administrative activities needed to implement the
corrective measure alternative (e.g., permits, rights of way,
off-site approvals, etc.) and the length of time these
activities will take;
2. The constructibility, time for implementation, and time for
beneficial results;
3. The availability of adequate off-site treatment, storage
capacity, disposal services, needed technical services and
materials; and
4. The availability of prospective technologies for each
corrective measure alternative.
e. Cost
The relative cost of a remedy may be an appropriate
consideration, especially in those situations where several
different technical alternatives to remediation will offer
equivalent protection of human health and the
environment, but may vary widely in cost. However, in
those situations where only one remedy is being proposed,
the issue of cost would not need to be considered. Cost
estimates could include costs for: engineering, site
preparation, construction, materials, labor,
sampling/analysis, waste management/disposal, permitting,
health and safety measures, training, operation and
maintenance, etc.
F. Recommendation by Permittee/Respondent for a Final Corrective
Measure Alternative
In the CMS Report, the Permittee/Respondent may recommend a
preferred remedial alternative for consideration by the implementing
agency. Such a recommendation should include a description and
supporting rationale for the proposed remedy, consistent with the
remedial standards and the decision factors discussed above. Such a
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recommendation is not required and the implementing agency still retains
the role of remedy selection.
G. Public Involvement Plan
After the CMS has been performed by the Permittee/Respondent and the
implementing agency has selected a preferred alternative for proposal in
the Statement of Basis, it is the agency's policy to request public
comment on the Administrative Record and the proposed corrective
measure(s). Changes to the proposed corrective measure(s) may be made
after consideration of public comment. The implementing agency may
also require that the Permittee/Respondent perform additional corrective
measures studies. If the public is interested, a public meeting may be
held. After consideration of the public's comments on the proposed
corrective measure, the agency develops the Final Decision and Response
to Comments (RTC) to document the selected corrective measure, the
agency's justification for such selection, and the response to the public's
comment. Additional public involvement activities may be necessary,
based on facility specific circumstances.
[NOTE: Notice requirements for permits are set out at 40 CFR Part 270
subpart D. See RCRA Public Involvement Manual [EPA/530-R-93-006,
September 1993 for further guidance.}
Section III: Progress Reports
The Permittee/Respondent will, at a minimum, provide the implementing
agency with signed [monthly, bimonthly, or quarterly] progress reports. These
reports may be required to contain the following information, but agency
requirements are not limited to this list:
1. A description and estimate of the percentage of the CMS completed;
2. Summaries of all findings in the reporting period, including results of any
pilot studies;
3. Summaries of all changes made in the CMS during the reporting period;
4. Summaries of all contacts with representative of the local community,
public interest groups or State government during the reporting period;
5. Summaries of all contacts made regarding access to off-site property;
6. Summaries of all problems encountered during the reporting period;
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7. Actions being taken to rectify problems;
8. Changes in relevant personnel during the reporting period;
9. Projected work for the next reporting period; and
10. Copies of daily reports, inspection reports, laboratory/monitoring data,
etc.
Section IV: Proposed Schedule
The Permittee/Respondent will provide the implementing agency with CMS reports
according to the following schedule:
Facility Submission Due Date
CMS Workplan [ DATE ]
(Section I)
Draft CMS Report [ NUMBER ] days after
(Section II) CMS Workplan Approval
Final CMS Report [ NUMBER ] days after
(Sections II) the implementing agency
comments on Draft CMS Report
Progress Reports on [ MONTHLY, BI-
Sections I and II MONTHLY, other ]
[see Section III above for guidance on progress reports.]
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Chapter V: Corrective Measures Implementation
Introduction
The purpose of the Corrective Measures Implementation (CMI) portion of the
RCRA corrective action process is to design, construct, operate, maintain and
monitor the performance of the corrective measure(s) selected by the implementing
agency. Thus far in the corrective action program, the CMI process generally
entailed a conceptual design phase for the selected remedy, a detailed review of
intermediate plans and specifications by the implementing agency, and the
development of final plans and specifications.
The new CAP encourages implementing agencies to make the process more
flexible and streamlined. Intermediate design plans may or may not be required at
specific design points (30, 50, 60, 90, and/or 95% are given as examples). Other
sections may be combined or eliminated.
For example, a CMI Workplan may be submitted to the implementing agency
rather than the Conceptual Design (Section I), Intermediate Plans and Specifications
(Section III), and Construction Workplan (Section V). The implementing agency
may approve (or conditionally approve with comments) the CMI Workplan and not
require submittal of Final Plans and Specifications (Section IV) and Construction
Workplan (Section V). A Health and Safety Plan (Section VIII) and Public
Involvement Plan (Section IX) also may be included in a CMI Workplan.
Implementing agencies may consider other approaches to expedite the process and
initiate implementation of corrective measure(s) more quickly.
As discussed in Chapter II, one such approach involves initiating ISMs prior to
the CMI. Plans submitted for ISMs (e.g., health and safety plans, public
involvement plans) may be used or updated during the CMI, particularly since ISMs
should be compatible with final corrective measures. In most cases this will be true,
with the only changes being an expansion/adjustment of the ISMs to constitute a
final remedy.
Another approach to expedite the CMI process involves setting final remedial
(or stabilization) media cleanup standards but not specifying the process by which
the standards would be attained. This performance-based approach should lower
oversight by the implementing agency and promote faster cleanup. The
implementing agency should give special consideration to the types of progress
reports (see Section X) it will require from the Permittee/Respondent so that it can
monitor progress toward achieving the media cleanup standards if this approach is
taken.
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[NOTE: With certain exceptions, the provisions set out in sections I through XI are
intended as guidance, and these provisions should be justifiable and tailored to site-
specific conditions when incorporated into permits or orders. The exceptions are certain
provisions which are based on specific regulatory or statutory requirements applicable to
permitting. Regulatory and statutory requirements are binding and do not require site-
specific justification. Applicable requirements include: financial responsibility
requirements in RCRA sections 3004(u) and 3004(v) and 40 CFR § 264.101.]
Scope of Work for Corrective Measures Implementation
Purpose
The purpose of the Corrective Measures Implementation (CMI) program is to
design, construct, operate, maintain and monitor the performance of the corrective
measure or measures selected by the implementing agency. Corrective measures are
intended to protect human health and/or the environment from releases from the
facility. The Permittee/Respondent will furnish all personnel, materials and services
necessary to implement the corrective measures program.
Scope
The documents required for Corrective Measures Implementation are, unless the
implementing agency specifies otherwise, a Conceptual Design, Operation and
Maintenance Plan, Intermediate Plans and Specifications, Final Plans and
Specifications, Construction Workplan, Construction Completion Report,
Corrective Measure Completion Report, Health and Safety Plan, Public
Involvement Plan, and Progress Reports. The scope of work (SOW) for each
document is specified below. The SOW's are intended to be flexible documents
capable of addressing both simple and complex site situations. If the
Permittee/Respondent can justify, to the satisfaction of the implementing agency,
that a plan and/or report or portions thereof are not needed in the given site-
specific situation, then the implementing agency may waive that requirement.
The implementing agency may require the Permittee/Respondent to conduct
additional studies beyond what is discussed in the SOW's in order to support the
CMI program. The Permittee/ Respondent will furnish all personnel, materials and
services necessary to conduct the additional tasks.
[NOTE: See introduction for discussion on streamlining sections of the CMI Scope of
Work.]
The CMI consists of the following components, which for clarity are designated
as sections in this Scope of Work.
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Section I: Conceptual Design (15% Design Point)
A. Introduction/Purpose
B. Corrective Measures Objectives
C. Conceptual Model of Contaminant Migration
D. Description of Corrective Measures
E. Project Management
F. Project Schedule
G. Design Criteria
H. Design Basis
I. Waste Management Practices
J. Required Permits
K. Long-lead Procurement Considerations
L. Appendices
Section II: Operation and Maintenance Plan
A. Introduction/Purpose
B. Project Management
C. System Description
D. Personnel Training
E. Start-up Procedures
F. Operation and Maintenance Procedures
G. Replacement Schedule for Equipment and Installed Components
H. Waste Management Practices
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I. Sampling and Analysis
J. Corrective Measure Completion Criteria
K. Operation and Maintenance Contingency Procedures
L. Data Management and Documentation Requirements
Section III: Intermediate Plans and Specifications (30, 50, 60, 90 and/or 95%
Design Point)
Section IV: Final Plans and Specifications (100% Design Point)
Section V: Construction Workplan
A. Introduction/Purpose
B. Project Management
C. Project Schedule
D. Construction Quality Assurance/Quality Control
Programs
E. Waste Management Procedures
F. Sampling and Analysis
G. Construction Contingency Procedures
H. Construction Safety Procedures
I. Documentation Requirements
J. Cost Estimate/Financial Assurance
Section VI: Construction Completion Report
Section VII: Corrective Measure Completion Report
Section VIII: Health and Safety Plan
Section IX: Public Involvement Plan
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Section X: Progress Reports
Section XI: Proposed Schedule
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Section I: Conceptual Design (15% Design Point)
The Permittee/Respondent shall prepare a Conceptual Design (CD) that clearly
describes the size, shape, form, and content of the proposed corrective measure;
the key components or elements that are needed; the designer's vision of the
corrective measure in the form of conceptual drawings and schematics; and the
procedures and schedules for implementing the corrective measure(s). It should
be noted that more that one conceptual design may be needed in situations
where there is a complex site with multiple technologies being employed at
different locations. The implementing agency may require approval of the CD
prior to implementation. The CD must, at a minimum, include the following
elements:
A. Introduction/Purpose: Describe the purpose of the document and
provide a summary description of the project.
B. Corrective Measures Objectives: Discuss the corrective measure
objectives including applicable media cleanup standards.
C. Conceptual Model of Contaminant Migration: Present a conceptual
model of the site and contaminant migration. The conceptual model
consists of a working hypothesis of how the contaminants may move
from the release source to the receptor population. The conceptual
model is developed by looking at the applicable physical parameters (e.g.,
water solubility, density, Henry's Law Constant, etc.) for each
contaminant and assessing how the contaminant may migrate given the
existing site conditions (geologic features, depth to groundwater, etc.).
Describe the phase (water, soil, gas, non-aqueous) and location where
contaminants are likely to be found. This analysis may have already
been done as part of earlier work (e.g., Current Conditions Report). If
this is the case, then provide a summary of the conceptual model with a
reference to the earlier document.
D. Description of Corrective Measures: Considering the conceptual model
of contaminant migration, qualitatively describe what the corrective
measure is supposed to do and how it will function at the facility.
Discuss the feasibility of the corrective measure and its ability to meet
the corrective measure objectives.
1. Data Sufficiency: Review existing data needed to support the
design effort and establish whether or not there is sufficient
accurate data available for this purpose. The
Permittee/Respondent must summarize the assessment findings
and specify any additional data needed to complete the corrective
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measure design. The implementing agency may require or the
Permittee/Respondent may propose that sampling and analysis
plans and/or treatability study workplans be developed to obtain
the additional data. Submittal times for any new sampling and
analysis plans and/or treatability study workplans will be
determined by the implementing agency and will be included in
the project schedule.
E. Project Management: Describe the management approach including levels
of authority and responsibility (include organization chart), lines of
communication and the qualifications of key personnel who will direct
the corrective measure design and the implementation effort (including
contractor personnel).
F. Project Schedule: The project schedule must specify all significant steps
in the process and when all CMI deliverables (e.g., Operation and
Maintenance Plan, Corrective Measure Construction Workplan, etc.) are
to be submitted to the implementing agency.
G. Design Criteria: Specify performance requirements for the overall
corrective measure and for each major component. The
Permittee/Respondent must select equipment that meets the performance
requirements.
H. Design Basis: Discuss the process and methods for designing all major
components of the corrective measure. Discuss the significant
assumptions made and possible sources of error. Provide justification for
the assumptions.
1. Conceptual Process/Schematic Diagrams.
2. Site plan showing preliminary plant layout and/or treatment area.
3. Tables listing number and type of major components with
approximate dimensions.
4. Tables giving preliminary mass balances.
5. Site safety and security provisions (e.g., fences, fire control, etc.).
I. Waste Management Practices: Describe the wastes generated by the
construction of the corrective measure and how they will be managed.
Also discuss drainage and indicate how rainwater runoff will be managed.
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J. Required Permits: List and describe the permits needed to construct and
operate the corrective measure. Indicate on the project schedule when
the permit applications will be submitted to the applicable agencies and
an estimate of the permit issuance date.
K. Long-Lead Procurement Considerations: The Permittee/Respondent shall
prepare a list of any elements or components of the corrective measure
that will require custom fabrication or for some other reason must be
considered as long-lead procurement items. The list must include the
reason why the items are considered long-lead items, the length of time
necessary for procurement, and the recognized sources of such
procurement.
L. Appendices including:
1. Design Data - Tabulations of significant data used in the design
effort;
2. Equations - List and describe the source of major equations used
in the design process;
3. Sample Calculations - Present and explain one example calculation
for significant or unique design calculations; and
4. Laboratory or Field Test Results.
Section II: Operation and Maintenance Plan
The Permittee/Respondent shall prepare an Operation and Maintenance (O&M)
Plan that outlines procedures for performing operations, long term maintenance,
and monitoring of the corrective measure. A draft Operation and Maintenance
Plan shall be submitted to the implementing agency simultaneously with the
draft Plans and Specifications (see Section III). A final Operation and
Maintenance Plan shall be submitted to the implementing agency simultaneously
with the final Plans and Specifications. The O&M plan shall, at a minimum,
include the following elements:
A. Introduction/Purpose: Describe the purpose of the document and
provide a summary description of the project.
B. Project Management: Describe the management approach including levels
of authority and responsibility (include organization chart), lines of
communication and the qualifications of key personnel who will operate
and maintain the corrective measures (including contractor personnel).
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C. System Description: Describe the corrective measure and identify
significant equipment.
D. Personnel Training: Describe the training process for O&M personnel.
The Permittee/Respondent shall prepare, and include in the technical
specifications governing treatment systems, the contractor requirements
for providing: appropriate service visits by experienced personnel to
supervise the installation, adjustment, start up and operation of the
treatment systems, and training covering appropriate operational
procedures once the start-up has been successfully accomplished.
E. Start-Up Procedures: Describe system start-up procedures including any
operational testing.
F. Operation and Maintenance Procedures: Describe normal operation and
maintenance procedures including:
1. Description of tasks for operation;
2. Description of tasks for maintenance;
3. Description of prescribed treatment or operation conditions; and
4. Schedule showing frequency of each O&M task.
G. Replacement Schedule for Equipment and Installed Components.
H. Waste Management Practices: Describe the wastes generated by operation
of the corrective measure and how they will be managed. Also discuss
drainage and indicate how rainwater runoff will be managed.
I. Sampling and Analysis: Sampling and monitoring activities may be
needed for effective operation and maintenance of the corrective measure.
To ensure that all information, data and resulting decisions are
technically sound, statistically valid, and properly documented, the
Permittee/Respondent shall prepare a Quality Assurance Project Plan
(QAPjP) to document all monitoring procedures, sampling, field
measurements and sample analyses performed during these activities. The
Permittee/Respondent shall use quality assurance, quality control, and
chain-of-custody procedures approved by the implementing agency.
These procedures are described in the soon to be released EPA
Requirements for Quality Assurance Project Plans for Environmental
Data Operations (EPA QA/R-5), which will replace Interim Guidelines
and Specifications for Preparing Quality Assurance Project Plans. QAMS-
005/80, December 29, 1980.
J. Corrective Measure Completion Criteria: Describe the process and
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criteria (e.g., groundwater cleanup goal met at all compliance points for 1
year) for determining when corrective measures have achieved media
cleanup goals. Also describe the process and criteria for determining
when maintenance and monitoring may cease. Criteria for corrective
measures such as a landfill cap must reflect the need for long-term
monitoring and maintenance. Satisfaction of the completion criteria will
trigger preparation and submittal of the Corrective Measures Completion
Report.
K. O&M Contingency Procedures:
1. Procedures to address system breakdowns and operational
problems including a list of redundant and emergency back-up
equipment and procedures;
2. Alternate procedures to be implemented if the corrective measure
suffers complete failure. The alternate procedures must be able to
prevent release or threatened releases of hazardous wastes or
constituents which may endanger human health and/or the
environment or exceed media cleanup standards;
3. The O&M Plan must specify that, in the event of a major
breakdown and/or complete failure of the corrective measure
(includes emergency situations), the Permittee/Respondent will
orally notify the implementing agency within 24 hours of the
event and will notify the implementing agency in writing within
72 hours of the event. Written notification must, at a minimum,
specify what happened, what response action is being taken
and/or is planned, and any potential impacts on human health
and/or the environment; and
4. Procedures to be implemented in the event that the corrective
measure is experiencing major operational problems, is not
performing to design specifications and/or will not achieve the
cleanup goals in the expected time frame. For example, in certain
circumstances both a primary and secondary corrective measure
may be selected for the Facility. If the primary corrective
measure were to fail, then the secondary would be implemented.
This section would thus specify that if the primary corrective
measure failed, then design plans would be developed for the
secondary measure.
L. Data Management and Documentation Requirements: The O&M Plan
shall specify that the Permittee/Respondent collect and maintain the
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following information:
1. Progress Report Information
2. Monitoring and laboratory data;
3. Records of operating costs; and
4. Personnel, maintenance and inspection records.
This data and information should be used to prepare Progress Reports and the
Corrective Measure Completion Report.
[NOTE: See Section X for guidance on what kind of information may be required
in progress reports.]
Section III: Intermediate Plans and Specifications (30, 50, 60, 90 and/or 95% E>esign
Point)
[NOTE: The Permittee/Respondent may propose or the implementing agency may
require the submittal of several intermediate plans and specifications (e.g., at the 60%
Design Point) or none at all.]
The Permittee/Respondent shall prepare draft Plans and Specifications that are
based on the Conceptual Design but include additional design detail. A draft
Operation and Maintenance Plan and Construction Workplan shall be submitted
to the implementing agency simultaneously with the draft Plans and
Specifications. The draft design package must include drawings and
specifications needed to construct the corrective measure. Depending on the
nature of the corrective measure,.many different types of drawings and
specifications may be needed. Some of the elements that may be required are:
General Site Plans
Process Flow Diagrams
Mechanical Drawings
Electrical Drawings
Structural Drawings
Piping and Instrumentation Diagrams
Excavation and Earthwork Drawings
Equipment Lists
Site Preparation and Field Work Standards
Preliminaiy Specifications for Equipment and Material
General correlation between drawings and technical specifications is a basic
requirement of any set of working construction plans and specifications. Before
submitting the project specifications to the implementing agency, the
Permittee/Respondent shall:
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• Proofread the specifications for accuracy and consistency with the
conceptual design and
• Coordinate and cross-check the specifications and drawings.
Section IV: Final Plans and Specifications (100% Design Point)
The Permittee/Respondent shall prepare Final Plans and Specifications that are
sufficient to be included in a contract document and be advertised for bid. A
final Operation and Maintenance Plan and Construction Workplan shall be
submitted to the implementing agency simultaneously with the final Plans and
Specifications. The final design package must consist of the detailed drawings
and specifications needed to construct the corrective measure. Depending on the
nature of the corrective measure, many different types of drawings and
specifications may be needed. Some of the elements that may be required are:
General Site Plans
Process Flow Diagrams
Mechanical Drawings
Electrical Drawings
Piping and Instrumentation Diagrams
Structural Drawings
Excavation and Earthwork Drawings
Site Preparation and Field Work Standards
Construction Drawings
Installation Drawings
Equipment Lists
Detailed Specifications for Equipment and Material
General correlation between drawings and technical specifications is a basic
requirement of any set of working construction plans and specifications. Before
submitting the final project specifications to the implementing agency, the
Permittee/Respondent shall proofread the specifications for accuracy and
consistency with the preliminary design; and coordinate and cross-check the
specifications and drawings.
Section V: Construction Workplan
The Permittee/Respondent shall prepare a Construction Workplan which
documents the overall management strategy, construction quality assurance
procedures and schedule for constructing the corrective measure. A draft
Construction Workplan shall be submitted to the implementing agency
simultaneously with the draft Plans and Specifications and draft Operation and
Maintenance Plan. A final Construction Workplan shall be submitted to the
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implementing agency simultaneously with the final Plans and Specifications and
final Operation and Maintenance Plan. Upon receipt of written approval from
the implementing agency, the Permittee/Respondent shall commence the
construction process and implement the Construction Workplan in accordance
with the schedule and provisions contained therein. The Construction
Workplan must be approved by the implementing agency prior to the start of
corrective measure construction. The Construction Workplan must, at a
minimum, include the following elements:
A. Introduction/Purpose: Describe the purpose of the document and
provide a summary description of the project.
B. Project Management: Describe the construction management approach
including levels of authority and responsibility (include organization
chart), lines of communication and the qualifications of key personnel
who will direct the corrective measure construction effort and provide
construction quality assurance/quality control (including contractor
personnel).
C. Project Schedule: The project schedule must include timing for key
elements of the bidding process, timing for initiation and completion of
all major corrective measure construction tasks as specified in the Final
Plans and Specifications, and specify when the Construction Completion
Report is to be submitted to the implementing agency.
D. Construction Quality Assurance/Quality Control Programs: The
purpose of construction quality assurance is to ensure, with a reasonable
degree of certainty, that a completed corrective measure will meet or
exceed all design criteria, plans, and specifications. The Construction
Workplan must include a complete Construction Quality Assurance
Program to be implemented by the Permittee/Respondent.
E. Waste Management Procedures: Describe the wastes generated by
construction of the corrective measure and how they will be managed.
F. Sampling and Analysis: Sampling and monitoring activities may be
needed for construction quality assurance/quality control and/or other
construction related purposes. To ensure that all information, data and
resulting decisions are technically sound, statistically valid, and properly
documented, the Permittee/Respondent shall prepare a Quality Assurance
Project Plan (QAPjP) to document all monitoring procedures, sampling,
field measurements and sample analysis performed during these activities.
The Permittee/Respondent shall use quality assurance, quality control,
and chain-of-custody procedures approved by the implementing agency.
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These procedures are described in the soon to be released EPA
Requirements for Quality Assurance Project Plans for Environmental
Data Operations (EPA QA/R-5), which replaces Interim Guidelines and
Specifications for Preparing Quality Assurance Project Plans. QAMS-
005/80, December 29, 1980.
G. Construction Contingency Procedures:
1. Changes to the design and/or specifications may be needed during
construction to address unforeseen problems encountered in the
field. Procedures to address such circumstances, including
notification of the implementing agency, must be included in the
Construction Workplan;
2. The Construction Workplan must specify that, in the event of a
construction emergency (e.g. fire, earthwork failure, etc.), the
Permittee/Respondent will orally notify the implementing agency
within 24 hours of the event and will notify the implementing
agency in writing within 72 hours of the event. The written
notification must, at a minimum, specify what happened, what
response action is being taken and/or is planned, and any
potential impacts on human health and/or the environment; and
3. Procedures to be implemented if unforeseen events prevent
corrective measure construction. For example, in certain
circumstances both a primary and secondary corrective measure
may be selected for the Facility. If the primary corrective
measure could not be constructed, then the secondary would be
implemented. This section would thus specify that if the primary
corrective measure could not be constructed, then design plans
would be developed for the secondary measure.
H. Construction Safety Procedures: Construction safety procedures should
be specified in a separate Health and Safety Plan. [See Section VIII]
I. Documentation Requirements
The Permittee/Respondent shall describe how analytical data and results
will be evaluated, documented, and managed.
[See Appendix B]
]. Cost Estimate/Financial Assurance
[NOTE: See 40 CFR § 264.101]
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Financial assurance for corrective measure construction and operation
may be required by an enforcement order, facility permit, or permit
modification. The Construction Workplan must include a cost estimate
and specify which financial mechanism will be used and when the
mechanism will be established. The cost estimate shall include both
construction and operation and maintenance costs. An initial cost
estimate shall be included in the draft Construction Workplan and a final
cost estimate shall be included in the final Construction Workplan. The
financial assurance mechanism may include a performance or surety
bond, a trust fund, a letter of credit, financial test and corporate
guarantee equivalent to that in 40 CFR. § 265.143 or any other
mechanism acceptable to the implementing agency.
Financial assurance mechanisms are used to assure the implementing
agency that the Permittee/Respondent has adequate financial resources to
construct and operate the corrective measure.
Section VI: Construction Completion Report
The Permittee/Respondent shall prepare a Construction Completion (CC) Report
which documents how the completed project is consistent with the Final Plans and
Specifications. A CC Report shall be submitted to the implementing agency when
the construction and any operational tests have been completed. The CC Report
shall, at a minimum, include the following elements:
1. Purpose;
2. Synopsis of the corrective measure, design criteria, and certification that
the corrective measure was constructed in accordance with the Final
Plans and Specifications;
3. Explanation and description of any modifications to the Final Plans and
Specifications and why these were necessary for the project;
4. Results of any operational testing and/or monitoring, indicating how
initial operation of the corrective measure compares to the design criteria;
5. Summary of significant activities that occurred during construction.
Include a discussion of problems encountered and how they were
addressed;
6. Summary of any inspection findings (include copies of key inspection
documents in appendices);
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7. As built drawings or photographs; and
8. Schedule indicating when any treatment systems will begin full scale
operations.
Section VII: Corrective Measure Completion Report
The Permittee/Respondent shall prepare a Corrective Measure Completion (CMC)
Report when the Permittee/Respondent believes that the corrective measure
completion criteria have been satisfied. The purpose of the CMC Report is to fully
document how the corrective measure completion criteria have been satisfied and to
justify why the corrective measure and/or monitoring may cease. The CMC
Report shall, at a minimum, include the following elements:
1. Purpose;
2. Synopsis of the corrective measure;
3. Corrective Measure Completion Criteria: Describe the process and
criteria for determining when corrective measures, maintenance and
monitoring may cease. Corrective measure completion criteria were
given in the final Operation and Maintenance (O&M) Plan;
4. Demonstration that the completion criteria have been met. Include
results of testing and/or monitoring, indicating how operation of the
corrective measure compares to the completion criteria;
5. Summary of work accomplishments (e.g., performance levels achieved,
total hours of treatment operation, total treated and/or excavated
volumes, nature and volume of wastes generated, etc.);
6. Summary of significant activities that occurred during operations.
Include a discussion of problems encountered and how they were
addressed;
7. Summary of inspection findings (include copies of key inspection
documents in appendices); and
8. Summary of total operation and maintenance costs.
Section VIII: Health and Safety Plan
The Permittee/Respondent shall submit a Health and Safety Plan for all field
activity, although it does not require review and approval by the implementing
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agency. The Health and Safety Plan shall be developed as a stand alone
document but may be submitted with the CMI Workplan. The Health and
Safety Plan must, at a minimum, include the following elements:
1. Objectives: Describe the goals and objectives of the health and
safety program (must apply to on-site personnel and visitors).
The health and safety plan must be consistent with the Facility
Contingency Plan, OSHA Regulations, NIOSH Occupational
Safety and Health Guidance Manual for Hazardous Waste Site
Activities (1985), all state and local regulations and other
implementing agency guidance as provided.
2. Hazard Assessment: List and describe the potentially hazardous
substances that could be encountered by field personnel during
construction and/or operation and maintenance activities. Discuss
the following:
Inhalation Hazards
Dermal Exposure
Ingestion Hazards
Physical Hazards
Overall Hazard Rating
Include a table that, at a minimum, lists: known contaminants,
highest observed concentration, media, symptoms/effects of acute
exposure.
3. Personal Protection/Monitoring Equipment
• Describe personal protection levels and identify all
monitoring equipment for each operational task.
• Describe any action levels and corresponding response
actions (i.e., when will levels of safety be upgraded).
• Describe decontamination procedures and areas.
4. Site Organization and Emergency Contacts
List and identify all contacts (include phone numbers). Identify
the nearest hospital and provide a regional map showing the
shortest route from the facility to the hospital. Describe site
emergency procedures and any site safety organizations. Include
evacuation procedures for neighbors (where applicable).
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Include a facility map showing emergency station locations (first
aid, eye wash areas, etc.).
Section IX: Public Involvement Plan
[NOTE: It is strongly recommended that the implementing agency oversee the
Permittee's/Respondent's public involvement activities. Public involvement is an
important part ofRCRA corrective action. The public must be notified of
significant changes to permits and orders regarding corrective action. In some cases,
they also must be provided with the opportunity to review and comment on the
changes. Further guidance on this process is in the document entitled RCRA Public
Involvement Manual (EPA/530-R-93-006, September 1993).]
All Public Involvement Plans prepared by the Permittee/Respondent shall be
submitted to the implementing agency for comment and approval prior to use.
Permittees/Respondents must never appear to represent or speak for the
implementing agency before the public, other government officials, or the media.
Public Involvement activities that may be required of the Permittee/Respondent
include, the following:
1. Conducting an open house or informal meeting (i.e., availability
session) in a public location where people can talk to agency
officials and Permittee/Respondent on a one-to-one basis;
2. Preparing fact sheets summarizing current or proposed corrective
action activities (all fact sheets should be reviewed by the
implementing agency prior to public distribution);
3. Communicating effectively with people who have vested interest
in the corrective action activities, (e.g., providing written or
verbal information in the foreign language of a predominantly
non-English-speaking community); and
4. Maintaining an easily accessible repository (such as a town hall or
public library or the facility itself, in some limited circumstances)
of information on the facility-specific corrective action program,
including the order or permit, approved workplans, and/or other
reports.
A schedule for community relations activities shall be included in the
Public Involvement Plan.
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Section X: Progress Reports
The Permittee/Respondent will, at a minimum, provide the implementing
agency with signed [monthly, bimonthly, or quarterly] progress reports during
corrective measure design, construction, operation and maintenance. The
implementing agency may adjust the frequency of progress reporting to address site-
specific needs. For example, more frequent progress reports may be needed to track
critical activities such as corrective measure construction and start-up. Progress
reports must, at a minimum, include the following elements:
1. A description of significant activities (e.g., sampling events, inspections,
etc.) and work completed/work accomplishments (e.g., performance
levels achieved, hours of treatment operation, treated and/or excavated
volumes, concentration of contaminants in treated and/or excavated
volumes, nature and volume of wastes generated, etc.) during the
reporting period;
2. Summary of system effectiveness. Provide a comparison of system
operation to predicted performance levels (applicable only during
operation of the corrective measure);
3. Summaries of all findings (including any inspection results);
4. Summaries of all contacts with representatives of the local community,
public interest groups or State government during the reporting period;
5. Summaries of all problems or potential problems encountered during the
reporting period;
6. Actions being taken and/or planned to rectify problems;
7. Changes in personnel during the reporting period;
8. Projected work for the next reporting period; and
9. If requested by the implementing agency, the results of any sampling tests
and/or other data generated during the reporting period.
Section XI: Proposed Schedule
The Permittee/Respondent will provide the implementing agency with CMI
reports according to the following schedule:
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Facility Submission
Due Date
Conceptual Design
(Section I)
[DATE]
Operation and Maintenance [ DATE ]
Plan (Section II)
Intermediate Plans and
Specifications
(Section III)
Final Plans and
Specifications
(Sections IV)
Construction Workplan
(Section V)
[NUMBER ] days after
Conceptual Design Approval
[ NUMBER ] days after
the implementing agency
comments on Intermediate Plans and Specifications
(date of approval may be tied to submittal of the
CMI Workplan, if required)
Concurrent with Final Plans and Specifications
(or approval thereof)
Construction Completion [ DATE ]
Report (Section VI)
Corrective Measure
Completion Report
(Section VII)
Health and Safety Plan
(Section VIII)
Public Involvement Plan
(Section IX)
Progress Reports on
Sections I through IX
[DATE]
(based on when completion criteria are believed to
have been satisfied)
[DATE]
[DATE]
[ MONTHLY, BI-
MONTHLY, other ]
[see Section X above for guidance on progress reports.]
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Appendix A
Corrective Action Reference List
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REFERENCE LIST
The following list comprises guidance documents and other information sources which may be useful in
implementing corrective action. Contacts for additional information are included at the end of this list.
"Handbook: Stabilization Technologies for RCRA Corrective Actions," EPA/625/6-91/026, August 1991.
"Interim Final RCRA Facility Investigation (RFI) Guidance," Volumes I-IV, EPA/530/SW-89-031, May
1989.
" Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA," Interim Final
EPA/540/G-89/004, OSWER Directive 9355.3-01, October 1988.
"RCRA Ground-water Monitoring Technical Enforcement Guidance Document (TEGD)," OSWER
Directive 9950.1, September 1986.
"Handbook: Ground Water," Volumes I and II, EPA/625/6-90/016 (a&b), September 1990 and July
1991.
"Ground-Water Modeling: An Overview and Status Report," EPA/600/2-89/028, December 1988.
" Statistical Analysis of Ground-Water Monitoring Data at RCRA Facilities," Interim Final, EPA/530/SW-
89/026, April 1989.
"Data Quality Objectives for Remedial Response Activities," EPA/540/G-87/003 & 004, OSWER
Directive 9335.0-7B, March 1987.
"Human Health Evaluation Manual, Supplemental Guidance: Standard Default Exposure Factors,"
OSWER Directive 9285.6-03, March 25, 1991.
"Risk Assessment Guidance for Superfund, Volume I: Human Health Evaluation Manual (Part A),"
Interim Final, EPA/540/1-89/002, December 1989
"Risk Assessment Guidance for Superfund, Volume II: Environmental Evaluation Manual," Interim Final,
EPA/540/1-89/001, March 1989.
"Final Guidance for Data Useability in Risk Assessment," (Parts A & B), OSWER Directive 9285.7-09A,
April 1992.
"Ecological Assessment of Hazardous Waste Sites: A Field and Laboratory Reference Document," EPA
600/3-89/013, March 1989.
"A Compendium of Superfund Field Operations Methods," Two Volumes, EPA/540/P-87/001a&b,
OSWER Directive 9355.0-14, August 1987.
"Technical Guidance Document: Construction Quality Assurance for Hazardous Waste Land Disposal
Facilities," EPA 530/SW-86/031, OSWER Directive 9472.003, October 1986.
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"Corrective Measures for Releases to Ground Water from SWMUs," Draft Final, EPA/530-SW-88-020,
March 1985.
"Basics of Pump-and-Treat Groundwater Remediation Technology," EPA/600/8-90/003, March 1990.
"Technical Guidance for Corrective Measures-Determining Appropriate Technology and Response for
Air Releases," Draft Final, EPA/530-SW-88-021, March 1985.
"Air/Superfund National Technical Guidance Study Series," Volumes I-IV, EPA 450/1-89-
001,002,003,004 (1989 and 1990).
"Corrective Measures for Releases to Soil from SWMUs," Draft F EPA/530-SW-88-022, March 1985.
"Technical Guidance for Corrective Measures - Subsurface Gas," EPA/530-SW-88-023, March 1985.
"Guide for Conducting Treatability Studies under CERCLA," Interim Final, EPA/540/2-89/058.
" Guide for Conducting Treatability Studies under CERCLA: Aerobic Biodegradation Remedy Screening",
EPA/540/2-91/013B, July 1991.
"Guide for Conducting Treatability Studies under CERCLA: Chemical Dehalogenation", EPA/540/R-
92/013B.
"Guidefor Conducting Treatability Studies under CERCLA: Soil Vapor Extraction", EPA/540/2-91/019B,
September 1991.
"Guide for Conducting Treatability Studies under CERCLA: Soil Washing," EPA/540/2-91/020B,
September 1991.
"Selected Alternative and Innovative Treatment Technologies for Corrective Action and Site Remediation,"
EPA/540/8-91/092, 1991.
"Synopses of Federal Demonstrations of Innovative Site Remediation Technologies," EPA/540/8-91/009,
May 1991.
"Bibliography of Federal Reports and Publications Describing Alternative and Innovative Treatment
Technologies for Corrective Action and Site Remediation," EPA/540/8-91/007, May 1991.
"Technical Guidance Document: Final Covers on Hazardous Waste Landfills and Surface
Impoundments," EPA/530/SW-89/047, July 1989.
"Handbook on In-Situ Treatment of Hazardous Waste-Contaminated Soils," EPA/540/2-90/002, 1990.
"Stabilization/Solidification for CERCLA andRCRA Wastes," EPA/625/6-89/022, May 1989.
"Technology Screening Guide for Treatment of CERCLA Soils and Sludges," EPA/540/2-88/004,
September 1988.
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"Health and Safety Requirements of Employees Employed in Field Activities," EPA Order 1440.2, July
12, 1981.
"Handbook of RCRA Ground-Water Monitoring Constituents: Chemical and Physical Properties,"
EPA/530/R-92/022, September 1992.
"RCRA Ground-Water Monitoring: Draft Technical Guidance," EPA/530/R-93/001, November 1992.
"Statistical Training Course for Ground-Water Monitoring Data Analysis," EPA/530/R-93/003, 1992.
"Literature Survey of Innovative Technologies for Hazardous Waste Site Remediation: 1987 - 1991,"
EPA/542/B-92/004, July 1992.
"Characterizing Heterogeneous Wastes: Methods and Recommendations," EPA/600/R-92/033, Feb. 1992.
"Handbook of Suggested Practices for the Design and Installation of Ground-Water Monitoring Wells,"
EPA/600/4-89/034, April 1989.
Quality Assurance
"Interim Guidelines and Specifications for Preparing Quality Assurance Project Plans," QAMS-005/80,
December 29, 1980.
GENERAL INFORMATION:
"OSWER Directives - System Catalog," OSWER Directive 9013.15-3D, March 1992. (Provides a list
of OSWER Directives published through March 1991.)
" Technical Support Services for Superfund Site Remediation and RCRA Corrective Action," (third edition),
EPA/540/8-91/091, March 1992.
"Accessing Federal Data Bases for Contaminated Site Clean-Up Technologies," EPA/540/8-91/008, May
1991.
"Memorandum on the Use of Supplemental Environmental Projects, Amendment to GM 22," James M.
Strock, February 12, 1991.
"Catalog of Office of Waste Programs Enforcement Publications," EPA/540/8-90/016, November 1990.
"A Catalogue of Hazardous and Solid Waste Publications," EPA 530-SW-91-013, May 1991.
USEFUL TELEPHONE NUMBERS:
RCRA/CERCLA/UST Hotline: (800) 424-9346
ORD Publications Office, Center for Environmental Research Information (CERI): (513) 569-7562
National Technical Information Service (NTIS): (703) 487-4650
93
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Appendix B
Chapter One of SW-846,
"Test Methods for Evaluating Solid Waste, Physical/Chemical Methods"
[Third Edition as amended by Update I (July 1992)]
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CHAPTER ONE
TABLE OF CONTENTS
Section
1.0
2.0
3.0
INTRODUCTION
QA PROJECT PLAN
2.1 DATA QUALITY OBJECTIVES
2.2 PROJECT OBJECTIVES
2.3 SAMPLE COLLECTION
2.4 ANALYSIS AND TESTING
2.5 QUALITY CONTROL
2.6 PROJECT DOCUMENTATION
2.7 ORGANIZATION PERFORMING FIELD OR LABORATORY
OPERATIONS
2.7.1 Performance Evaluation
2.7.2 Internal Assessment by QA Function
2.7.3 External Assessment
2.7.4 On-Site Evaluation .
2.7.4.1 Field Activities
2.7.4.2 Laboratory Activities
2.7.5 QA Reports
FIELD OPERATIONS
3.1 FIELD LOGISTICS
3.2 EQUIPMENT/INSTRUMENTATION
3.3 OPERATING PROCEDURES
3.3.1 Sample Management
3.3.2 Reagent/Standard Preparation
3.3.3 Decontamination
3.3.4 Sample Collection
3.3.5 Field Measurements
3.3.6 Equipment Calibration And Maintenance . . .
3.3.7 Corrective Action
3.3.8 Data Reduction and Validation
3.3.9 Reporting
3.3.10 Records Management
3.3.11 Waste Disposal
3.4 FIELD QA AND QC REQUIREMENTS
3.4.1 Control Samples
3.4.2 Acceptance Criteria
3.4.3 Deviations
3.4.4 Corrective Action
3.4.5 Data Handling
3.5 QUALITY ASSURANCE REVIEW
3.6 FIELD RECORDS .
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TABLE OF CONTENTS
(continued)
Section
4.0
5.0
6.0 ,
INDEX
LABORATORY OPERATIONS
4.1 FACILITIES
4.2 EQUIPMENT/INSTRUMENTATION
4.3 OPERATING PROCEDURES
4.3.1 Sample Management
4.3.2 Reagent/Standard Preparation
4.3.3 General Laboratory Techniques
4.3.4 Test Methods
4.3.5 Equipment Calibration and Maintenance . . .
4.3.6 QC
4.3.7 Corrective Action
4.3.8 Data Reduction and Validation
4.3.9 Reporting
4.3.10 Records Management ....
4.3.11 Waste Disposal . . .
4.4 LABORATORY QA AND QC PROCEDURES
4.4.1 Method Proficiency
4.4.2 Control Limits
4.4.3 Laboratory Control Procedures
4.4.4 Deviations
4.4.5 Corrective Action
4.4.6 Data Handling
4.5 QUALITY ASSURANCE REVIEW
4.6 LABORATORY RECORDS
DEFINITIONS
REFERENCES
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CHAPTER ONE
QUALITY CONTROL
1.0 INTRODUCTION
It is the goal of the U.S. Environmental Protection Agency's (EPA's)
quality assurance (QA) program to ensure that all data be scientifically valid,
defensible, and of known precision and accuracy. The data should be of
sufficient known quality to withstand scientific and legal challenge relative to
the use for which the data are obtained. The QA program is management's tool for
achieving this goal.
For RCRA analyses, the recommended minimum requirements for a QA program
and the associated quality control (QC) procedures are provided in this chapter.
The data acquired from QC procedures are used to estimate the quality of
analytical data, to determine the need for corrective action in response to
identified deficiencies, and to interpret results after corrective action
procedures are implemented. Method-specific QC procedures are incorporated in
the individual methods since they are not applied universally.
A total program to generate data of acceptable quality should include both
a QA component, which encompasses the management procedures and controls, as well
as an operational day-to-day QC component. This chapter defines fundamental
elements of such a data collection program. Data collection efforts involve:
1. design of a project plan to achieve the data quality objectives
(DQOs);
2. implementation of the project plan; and
3. assessment of the data to determine if the DQOs are met.
The project plan may be a sampling and analysis plan or a waste analysis plan if
it covers the QA/QC goals of the Chapter, or it may be a Quality Assurance
Project Plan as described later in this chapter.
This chapter identifies the minimal QC components that should be-used in
the performance of sampling and analyses, including the QC information which
should be documented. Guidance is provided to construct QA programs for field
and laboratory work conducted in support of the RCRA program.
2.0 QA PROJECT PLAN
It is recommended that all projects which generate environment-related data
in support of RCRA have a QA Project Plan (QAPjP) or equivalent. In some
instances, a sampling and analysis plan or a waste analysis plan may be
equivalent if it covers all of the QA/QC goals outlined in this chapter. In
addition, a separate QAPjP need not be prepared for routine analyses or
activities where the procedures to be followed are described in a Standard
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Operating Procedures manual or similar document and include the elements of a
QAPjP. These documents should be available and referenced in the documentation
and/or records for the analysis activities. The term "QAPjP" in this chapter
refers to any of these QA/QC documents.
The QAPjP should detail the QA/QC goals and protocols for a specific data
collection activity. The QAPjP sets forth a plan for sampling and analysis
activities that will generate data of a quality commensurate with their intended
use. QAPjP elements should include a description of the project and its
objectives; a statement of the DQOs of the project; identification of those in-
volved in the data collection and their responsibilities and authorities;
referehce to (or inclusion of) the specific sample collection and analysis
procedures that will be followed for all aspects of the project; enumeration of
QC procedures to be followed; and descriptions of all project documentation.
Additional elements should be included in the QAPjP if needed to address all
quality related aspects of the data collection project. Elements should be
omitted only when they are inappropriate for the project or when absence of those
elements will not affect the quality of data obtained for the project (see
reference 1).
The role and importance of OQOs and project documentation are discussed
below in Sections 2.1 through 2.6. Management and organization play a critical
role in determining the effectiveness of a QA/QC program and ensuring that all
required procedures are followed. Section 2.7 discusses the elements of an
organization's QA program that have been found to ensure an effective program.
Field operations and laboratory operations (along with applicable QC procedures)
are discussed in Sections 3 and 4, respectively.
2.1 DATA QUALITY OBJECTIVES
Data quality objectives (DQOs) for the data collection activity describe
the overall level of uncertainty that a decision-maker is willing to accept in
results derived from environmental data. This uncertainty is used to specify the
quality of the measurement data required, usually in terms of objectives for
precision, bias, representativeness, comparability and completeness. The DQOs
should be defined prior to the initiation of the field and laboratory work. The
field and laboratory organizations performing the work should be aware-of the
DQOs so that their personnel may make informed decisions during the course of the
project to attain those DQOs. More detailed information on DQOs is available
from the U.S. EPA Quality Assurance Management Staff (QAMS) (see references 2 and
4).
2.2 PROJECT OBJECTIVES
A statement of the project objectives and how the objectives are to be
attained should be concisely stated and sufficiently detailed to permit clear
understanding by all parties involved in the data collection effort. This
includes a statement of what problem is to be solved and the information required
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in the process. It also includes appropriate statements of the DQOs (i.e., the
acceptable level of uncertainty in the information).
2.3 SAMPLE COLLECTION
Sampling procedures, locations, equipment, and sample preservation and
handling requirements should be specified in the QAPjP. Further details on
quality assurance procedures for field operations are described in Section 3 of
this chapter. The OSW is developing policies and procedures for sampling in a
planned revision of Chapter Nine of this manual. Specific procedures for
groundwater sampling are provided in Chapter Eleven of this manual.
2.4 ANALYSIS AND TESTING
Analytes and properties of concern, analytical and testing procedures to
be employed, required detection limits, and requirements for precision and bias
should be specified. All applicable regulatory requirements and the project DQOs
should be considered when developing the specifications. Further details on the
procedures for analytical operations are described in Section 4 of this chapter.
2.5 QUALITY CONTROL
The quality assurance program should address both field and laboratory
activities. Quality control procedures should be specified for estimating the
precision and bias of the data. Recommended minimum requirements for QC samples
have been established by EPA and should be met in order to satisfy recommended
minimum criteria for acceptable data quality. Further details on procedures for
field and laboratory operations are described in Sections 3 and 4, respectively,
of this chapter.
2.6 PROJECT DOCUMENTATION
Documents should be prepared and maintained in conjunction with the data
collection effort. Project documentation should be sufficient to allow review
of all aspects of the work being performed. The QAPjP discussed in Sections 3
and 4 is one important document that should be maintained.
The length of storage time for project records should comply with
regulatory requirements, organizational policy, or project requirements,
whichever is more stringent. It is recommended that documentation be stored for
three years from submission of the project final report.
Documentation should be secured in a facility that adequately
addresses/minimizes its deterioration for the length of time that it is to be
retained. A system allowing for the expedient retrieval of information should
exist.
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Access to archived information should be controlled to maintain the
integrity of the data. Procedures should be developed to identify those
individuals with access to the data.
2.7 ORGANIZATION PERFORMING FIELD OR LABORATORY OPERATIONS
Proper design and structure of the organization facilitates effective and
efficient transfer of information and helps to prevent important procedures from
being overlooked.
The organizational structure, functional responsibilities, levels of
authority, job descriptions, and lines of communication for all project
activities should be established and documented. One person may cover more than
one organizational function. Each project participant should have a clear
understanding of his or her duties and responsibilities and the relationship of
those responsibilities to the overall data collection effort.
The management of each organization participating in a project involving
data collection activities should establish that organization's operational and
QA policies. This information should be documented in the QAPjP. The management
should ensure that (1) the appropriate methodologies are followed as documented-
in the QAPjPs; (2) personnel clearly understand their duties and
responsibilities; (3) each staff member has access to appropriate project
documents; (4) any deviations from the QAPjP are communicated to the project
management; and documented; and (5) communication occurs between the field,
laboratory, and project management, as specified in the QAPjP. In addition, each
organization should ensure that their activities do not increase the risk to
humans or the environment at or about the project location. Certain projects may
require specific policies or a Health and Safety Plan to provide this assurance.
The management of the participating field or laboratory organization should
establish personnel qualifications and training requirements for the project.
Each person participating in the project should have the education, training,
technical knowledge, and experience, or a combination thereof, to enable that
individual to perform assigned functions. Training should be provided for each
staff member as necessary to perform their functions properly. Personnel
qualifications should be documented in terms of education, experience, and
training, and periodically reviewed to ensure adequacy to current
responsibilities.
Each participating field organization or laboratory organization should
have a designated QA function (i.e., a team or individual trained in QA) to
monitor operations to ensure that the equipment, personnel, activities,
procedures, and documentation conform with the QAPjP. To the extent possible,
the QA monitoring function should be entirely separate from, and independent of,
personnel engaged in the work being monitored. The QA function should be
responsible for the QA review.
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2.7.1 Performance Evaluation
Performance evaluation studies are used to measure the performance of the
laboratory on unknown samples. Performance evaluation samples are typically
submitted to the laboratory as blind samples by an independent outside source.
The results are compared to predetermined acceptance limits. Performance
evaluation samples can also be submitted to the laboratory as part of the QA
function during internal assessment of laboratory performance. Records of all
performance evaluation studies should be maintained by the laboratory. Problems
identified through participation in performance evaluation studies should be
immediately investigated and corrected.
2.7.2 Internal Assessment by QA Function
Personnel performing field and laboratory activities are responsible for
continually monitoring individual compliance with the QAPjP. The QA function
should review procedures, results and calculations to determine compliance with
the QAPjP. The results of this internal assessment should be reported to
management with requirements for a plan to correct observed deficiencies.
2.7.3 External Assessment
The field and laboratory activities may be reviewed by personnel external
to the organization. Such an assessment is an extremely valuable method for
identifying overlooked problems. The results of the external assessment should
be submitted to management with requirements for a plan to correct observed
deficiencies.
2.7.4 On-Site Evaluation
On-site evaluations may be conducted as part of both internal and external
assessments. The focus of an on-site evaluation is to evaluate the degree of
conformance of project activities with the applicable QAPjP. On-site evaluations
may include, but are not limited to, a complete review of facilities, staff,
training, instrumentation, procedures, methods, sample collection, analyses, QA
policies and procedures related to the generation of environmental data. Records
of each evaluation should include the date of the evaluation, location, the areas
reviewed, the person performing the evaluation, findings and problems, and
actions recommended and taken to resolve problems. Any problems identified that
are likely to affect data integrity should be brought immediately to the
attention of management.
2.7.4.1 Field Activities
The review of field activities should be conducted by one or more persons
knowledgeable in the activities being reviewed and include evaluating, at a
minimum, the following subjects:
Completeness of Field Reports -- This review determines whether all
requirements for field activities in the QAPjP have been fulfilled, that
complete records exist for each field activity, and that the procedures
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specified in the QAPjP have been implemented. Emphasis on field
documentation will help assure sample integrity and sufficient technical
information to recreate each field event. The results of this
completeness check should be documented, and environmental data affected
by incomplete records should be identified.
Identification of Valid Samples -- This review involves interpretation and
evaluation of the field records to detect problems affecting the repre-
sentativeness of environmental samples. Examples of items that might
indicate potentially invalid samples include improper well development,
improperly screened wells, instability of pH or conductivity, and collec-
tion of volatiles near internal combustion engines. The field records
should be evaluated against the QAPjP and SOPs. The reviewer should docu-
ment the sample validity and identify the environmental data associated
with any poor or incorrect field work.
Correlation of Field Test Data -- This review involves comparing any
available results of field measurements obtained by more than one method.
For example, surface geophysical methods should correlate with direct
methods of site geologic characterization such as lithologic logs
constructed during drilling operations.
Identification of Anomalous Field Test Data -- This review identifies any
anomalous field test data. For example, a water temperature for one well
that is 5 degrees higher than any other well temperature in the same
aquifer should be noted. The reviewer should evaluate the impact of
anomalous field measurement results on the associated environmental data.
Validation of Field Analyses -- This review validates and documents all
data from field analysis that are generated in situ or from a mobile
laboratory as specified in Section 2.7.4.2. The reviewer should document
whether the QC checks meet the acceptance criteria, and whether corrective
actions were taken for any analysis performed when acceptance criteria
were exceeded.
2.7.4.2 Laboratory Activities
The review of laboratory data should be conducted by one or more -persons
knowledgeable in laboratory activities and include evaluating, at a minimum, the
following subjects:
Completeness of Laboratory Records -- This review determines whether: (1)
all samples and analyses required by the QAPjP have been processed, (2)
complete records exist for each analysis and the associated QC samples,
and that (3) the procedures specified in the QAPjP have been Implemented.
The results of the completeness check should be documented, and
environmental data affected by incomplete records should be Identified.
Evaluation of Data with Respect to Detection and Quantitation Limits --
This review compares analytical results to required quantitation limits.
Reviewers should document instances where detection or quantitation limits
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exceed regulatory limits, action levels, or target concentrations
specified in the QAPjP.
Evaluation of Data with Respect to Control Limits -- This review compares
the results of QC and calibration check samples to control criteria.
Corrective action should be implemented for data not within control
limits. The reviewer should check that corrective action reports, and the
results of reanalysis, are available. The review should determine
whether samples associated with out-of-control QC data are identified in
a written record of the data review, and whether an assessment of the
utility of such analytical results is recorded.
Review of Holding Time Data -- This review compares sample holding times
to those required by the QAPjP, and notes all deviations.
Review of Performance Evaluation (PE) Results -- PE study results can be
helpful in evaluating the impact of out-of-control conditions. This review
documents any recurring trends or problems evident in PE studies and
evaluates their effect on environmental data.
Correlation of Laboratory Data -- This review determines whether the
results of data obtained from related laboratory tests, e.g., Purgeable
Organic Hal ides (POX) and Volatile Organics, are documented, and whether
the significance of any differences is discussed in the reports.
2.7.5 QA Reports
There should be periodic reporting of pertinent QA/QC information to the
project management to allow assessment of the overall effectiveness of the QA
program. There are three major types of QA reports to project management:
Periodic Report on Key QA Activities -- Provides summary of key QA activi-
ties during the period, stressing measures that are being taken to improve
data quality; describes significant quality problems observed and
corrective actions taken; reports information regarding any changes in
certification/accreditation status; describes involvement in resolution of
quality issues with clients or agencies; reports any QA organizational
changes; and provides notice of the distribution of revised documents
controlled by the QA organization (i.e., procedures).
Report on Measurement Quality Indicators -- Includes the assessment of QC
data gathered over the period, the frequency of analyses repeated due to
unacceptable QC performance, and, if possible, the reason for the unac-
ceptable performance and corrective action taken.
Reports on QA Assessments -- Includes the results of the assessments and
the plan for correcting identified deficiencies; submitted immediately
following any internal or external on-site evaluation or upon receipt of
the results of any performance evaluation studies.
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3.0 FIELD OPERATIONS
The field operations should be conducted in such a way as to provide
reliable information that meets the DQOs. To achieve this, certain minimal
policies and procedures should be implemented. The OSW is considering revisions
of Chapter Nine and Eleven of this manual. Supplemental information and guidance
is available in the RCRA Ground-Water Monitoring Technical Enforcement Guidance
Document (TEGD) (Reference 3). The project documentation should contain the
information specified below.
3.1 FIELD LOGISTICS
The QAPjP should describe the type(s) of field operations to be performed
and the appropriate area(s) in which to perform the work. The QAPjP should
address ventilation, protection from extreme weather and temperatures, access to
stable power, and provision for water and gases of required purity.
Whenever practical, the sampling site facilities should be examined prior
to the start of work to ensure that all required items are available. The actual
area of sampling should be examined to ensure that trucks, drilling equipment,
and personnel have adequate access to the site.
The determination as to whether sample shipping is necessary should be made
during planning for the project. This need is established by evaluating the
analyses to be performed, sample holding times, and location of the site and the
laboratory. Shipping or transporting of samples to a laboratory should be done
within a timeframe such that recommended holding times are met.
Samples should be packaged, labelled, preserved (e.g., preservative added,
iced, etc.), and documented in an area which is free of contamination and
provides for secure storage. The level of custody and whether sample storage is
needed should be addressed in the QAPjP.
Storage areas for solvents, reagents, standards, and reference materials
should be adequate to preserve their identity, concentration, purity, and
stability prior to use.
Decontamination of sampling equipment may be performed at the location
where sampling occurs, prior to going to the sampling site, or in designated
areas near the sampling site. Project documentation should specify where and how
this work is accomplished. If decontamination is to be done at the site, water
and solvents of appropriate purity should be available. The method of
accomplishing decontamination, including the required materials, solvents, and
water purity should be specified.
During the sampling process and during on-site or in situ analyses, waste
materials are sometimes generated. The method for storage and disposal of these
waste materials that complies with applicable local, state and Federal
regulations should be specified. Adequate facilities should be provided for the
collection and storage of all wastes, and these facilities should be operated so
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as to minimize environmental contamination. Waste storage and disposal
facilities should comply with applicable federal, state, and local regulations.
The location of long-term and short-term storage for field records, and the
measures to ensure the integrity of the data should be specified.
3.2 EQUIPMENT/INSTRUMENTATION
The equipment, instrumentation, and supplies at the sampling site should
be specified and should be appropriate to accomplish the activities planned. The
equipment and instrumentation should meet the requirements of specifications,
methods, and procedures as specified in the QAPjP.
3.3 OPERATING PROCEDURES
The QAPjP should describe or make reference to all field activities that
may affect data quality. For routinely performed activities, standard operating
procedures (SOPs) are often prepared to ensure consistency and to save time and
effort in preparing QAPjPs. Any deviation from an established procedure during
a data collection activity should be documented. The procedures should be
available for the indicated activities, and should include, at a minimum, the
information described below.
3.3.1 Sample Management
The numbering and labeling system, chain-of-custody procedures, and how the
samples are to be tracked from collection to shipment or receipt by the
laboratory should be specified. Sample management procedures should also specify
the holding times, volumes of sample required by the laboratory, required
preservatives, and shipping requirements.
3.3.2 Reagent/Standard Preparation
The procedures describing how to prepare standards and reagents should be
specified. Information concerning specific grades of materials used in reagent
and standard preparation, appropriate glassware and containers for preparation
and storage, and labeling and record keeping for stocks and dilutions should be
included.
3.3.3 Decontamination
The procedures describing decontamination of field equipment before and
during the sample collection process should be specified. These procedures
should include cleaning materials used, the order of washing and rinsing with the
cleaning materials, requirements for protecting or covering cleaned equipment,
and procedures for disposing of cleaning materials.
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3.3.4 Sample Collection
The procedures describing how the sampling operations are actually
performed in the field should be specified. A simple reference to standard
methods is not sufficient, unless a procedure is performed exactly as described
in the published method. Methods from source documents published by the EPA,
American Society for Testing and Materials, U.S. Department of the Interior,
National Water Well Association, American Petroleum Institute, or other
recognized organizations with appropriate expertise should be used, if possible.
The procedures for sample collection should Include at least the following:
• Applicability of the procedure,
• Equipment required,
• Detailed description of procedures to be followed in collecting the
samples,
• Common problems encountered and corrective actions to be followed, and
• Precautions to be taken.
3.3.5 Field Measurements
The procedures describing all methods used in the field to determine a
chemical or physical parameter should be described in detail. The procedures
should address criteria from Section 4, as appropriate.
3.3.6 Equipment Calibration And Maintenance
The procedures describing how to ensure that field equipment and
instrumentation are in working order should be specified. These describe
calibration procedures and schedules, maintenance procedures and schedules,
maintenance logs, and service arrangements for equipment. Calibration and
maintenance of field equipment and instrumentation should be in accordance with
manufacturers' specifications or applicable test specifications and should be
documented.
3.3.7 Corrective Action
The procedures describing how to identify and correct deficiencies in the
sample collection process should be specified. These should Include specific
steps to take In correcting deficiencies such as performing additional
decontamination of equipment, resampling, or additional training of field
personnel. The procedures should specify that each corrective action should be
documented with a description of the deficiency and the corrective action taken,
and should include the person(s) responsible for implementing the corrective
action.
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3.3.8 Data Reduction and Validation
The procedures describing how to compute results from field measurements
and to review and validate these data should be specified. They should include
all formulas used to calculate results and procedures used to independently
verify that field measurement results are correct.
3.3.9 Reporting
The procedures describing the process for reporting the results of field
activities should be specified.
3.3.10 Records Management
The procedures describing the means for generating, controlling, and
archiving project-specific records and field operations records should be
specified. These procedures should detail record generation and control and the
requirements for record retention, including type, time, security, and retrieval
and disposal authorities.
Project-specific records relate to field work performed for a project.
These records may include correspondence, chain-of-custody records, field
notes, all reports issued as a result of the work, and procedures used.
Field operations records document overall field operations and may include
equipment performance and maintenance logs, personnel files, general field
procedures, and corrective action reports.
3.3.11 Waste Disposal
The procedures describing the methods for disposal of waste materials
resulting from field operations should be specified.
3.4 FIELD QA AND QC REQUIREMENTS
The QAPjP should describe how the following elements of the field QC
program will be implemented.
3.4.1 Control Samples
Control samples are QC samples that are introduced into a process to
monitor the performance of the system. Control samples, which may include blanks
(e.g., trip, equipment, and laboratory), duplicates, spikes, analytical
standards, and reference materials, can be used in different phases of the data
collection process beginning with sampling and continuing through transportation,
storage, and analysis.
Each day of sampling, at least one field duplicate and one equipment
rinsate should be collected for each matrix sampled. If this frequency is not
appropriate for the sampling equipment and method, then the appropriate changes
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should be clearly identified in the QAPjP. When samples are collected for
volatile organic analysis, a trip blank is also recommended for each day that
samples are collected. In addition, for each sampling batch (20 samples of one
matrix type), enough volume should be collected for at least one sample so as to
allow the laboratory to prepare one matrix spike and either one matrix duplicate
or one matrix spike duplicate for each analytical method employed. This means
that the following control samples, are recommended:
•Field duplicate (one per day per matrix type)
•Equipment rinsate (one per day per matrix type)
•Trip blank (one per day, volatile organics only)
•Matrix spike (one per batch [20 samples of each matrix type])
•Matrix duplicate or matrix spike duplicate (one per batch)
Additional control samples may be necessary in order to assure data quality to
meet the project-specific DQOs.
3.4.2 Acceptance Criteria
Procedures should be in place for establishing acceptance criteria for
field activities described in the QAPjP. Acceptance criteria may be qualitative
or quantitative. Field events or data that fall outside of established
acceptance criteria may indicate a problem with the sampling process that should
be investigated.
3.4.3 Deviations
All deviations from plan should be documented as to the extent of, and
reason for, the deviation. Any activity not performed in accordance with
procedures or QAPjPs is considered a deviation from plan. Deviations from plan
may or may not affect data quality.
3.4.4 Corrective Action
Errors, deficiencies, deviations, certain field events, or data that fall
outside established acceptance criteria should be investigated. In some in-
stances, corrective action may be needed to resolve the problem and restore
proper functioning to the system. The investigation of the problem -and any
subsequent corrective action taken should be documented.
3.4.5 Data Handling
All field measurement data should be reduced according to protocols
described or referenced in the QAPjP. Computer programs used for data reduction
should be validated before use and verified on a regular basis. All information
used in the calculations should be recorded to enable reconstruction of the final
result at a later date.
Data should be reported in accordance with the requirements of the end-user
as described in the QAPjP.
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3.5 QUALITY ASSURANCE REVIEW
The QA Review consists of internal and external assessments to ensure that
QA/QC procedures are in use and to ensure that field staff conform to these
procedures. QA review should be conducted as deemed appropriate and necessary.
3.6 FIELD RECORDS
Records provide the direct evidence and support for the necessary technical
interpretations, judgments, and discussions concerning project activities. These
records, particularly those that are anticipated to be used as evidentiary data,
should directly support current or ongoing technical studies and activities and
should provide the historical evidence needed for later reviews and analyses.
Records should be legible, identifiable, and retrievable and protected against
damage, deterioration, or loss. The discussion in this section (3.6) outlines
recommended procedures for record keeping. Organizations which conduct field
sampling should develop appropriate record keeping procedures which satisfy
relevant technical and legal requirements.
Field records generally consist of bound field notebooks with prenumbered
pages, sample collection forms, personnel qualification and training forms,
sample location maps, equipment maintenance and calibration forms, chain-of-
custody forms, sample analysis request forms, and field change request forms.
All records should be written in indelible ink.
Procedures for reviewing, approving, and revising field records should be
clearly defined, with the lines of authority included. It is recommended that
all documentation errors should be corrected by drawing a single line through the
error so it remains legible and should be initialed by the responsible
individual, along with the date of change. The correction should be written
adjacent to the error.
Records should include (but are not limited to) the following:
Calibration Records & Traceability of Standards/Reagents -- Calibration is
a reproducible reference point to which all sample measurements can be
correlated. A sound calibration program should include provisions for
documentation of frequency, conditions, standards, and records reflecting
the calibration history of a measurement system. The accuracy of the
calibration standards is important because all data will be in reference
to the standards used. A program for verifying and documenting the
accuracy of all working standards against primary grade standards should
be routinely followed.
Sample Collection -- To ensure maximum utility of the sampling effort and
resulting data, documentation of the sampling protocol, as performed in
the field, is essential. It is recommended that sample collection records
contain, at a minimum, the names of persons conducting the activity,
sample number, sample location, equipment used, climatic conditions,
documentation of adherence to protocol, and unusual observations. The
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actual sample collection record is usually one of the following: a bound
field notebook with prenumbered pages, a pre-printed form, or digitized
information on a computer tape or disc.
Chairi-of-Custody Records -- The chain-of-custody involving the possession
of samples from the time they are obtained until they are disposed or
shipped off-site should be documented as specified in the QAPjP and should
include the following information: (1) the project name; (2) signatures
of samplers; (3) the sample number, date and time of collection, and grab
or composite sample designation; (4) signatures of individuals involved in
sample transfer; and (5) if applicable, the air bill or other shipping
number.
Maps and Drawings -- Project planning documents and reports often contain
maps. The maps are used to document the location of sample collection
points and monitoring wells and as a means of presenting environmental
data. Information used to prepare maps and drawings is normally obtained
through field surveys, property surveys, surveys of monitoring wells,
aerial photography or photogrammetric mapping. The final, approved maps
and/or drawings should have a revision number and date and should be sub-
ject to the same controls as other project records.
QC Samples -- Documentation for generation of QC samples, such as trip and
equipment rinsate blanks, duplicate samples, and any field spikes should
be maintained.
Deviations -- All deviations from procedural documents and the QAPjP
should be recorded in the site logbook.
Reports -- A copy of any report issued and any supporting documentation
should be retained.
4.0 LABORATORY OPERATIONS
The laboratory should conduct its operations in such a way as to provide
reliable information. To achieve this, certain minimal policies and procedures
should be implemented.
4.1 FACILITIES
The QAPjP should address all facility-related issues that may impact
project data quality. Each laboratory should be of suitable size and
construction to facilitate the proper conduct of the analyses. Adequate bench
space or working area per analyst should be provided. The space requirement per
analyst depends on the equipment or apparatus that is being utilized, the number
of samples that the analyst is expected to handle at any one time, and the number
of operations that are to be performed concurrently by a single analyst. Other
issues to be considered include, but are not limited to, ventilation, lighting,
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control of dust and drafts, protection from extreme temperatures, and access to
a source of stable power.
Laboratories should be designed so that there is adequate separation of
functions to ensure that no laboratory activity has an adverse effect on the
analyses. The laboratory may require specialized facilities such as a perchloric
acid hood or glovebox.
Separate space for laboratory operations and appropriate ancillary support
should be provided, as needed, for the performance of rdutine and specialized
procedures.
As necessary to ensure secure storage and prevent contamination or
misidentification, there should be adequate facilities for receipt and storage
of samples. The level of custody required and any special requirements for
storage such as refrigeration should be described in planning documents.
Storage areas for reagents, solvents, standards, and reference materials
should be adequate to preserve their identity, concentration, purity, and
stability.
Adequate facilities should be provided for the collection and storage of
all wastes, and these facilities should be operated so as to minimize environ-
mental contamination. Waste storage and disposal facilities should comply with
applicable federal, state, and local regulations.
The location of long-term and short-term storage of laboratory records and
the measures to ensure the integrity of the data should be specified.
4.2 EQUIPMENT/INSTRUMENTATION
Equipment and instrumentation should meet the requirements and specifica-
tions of the specific test methods and other procedures as specified in the
QAPjP. The laboratory should maintain an equipment/instrument description list
that includes the manufacturer, model number, year of purchase, accessories, and
any modifications, updates, or upgrades that have been made.
4.3 OPERATING PROCEDURES
The QAPjP should describe or make reference to all laboratory activities
that may affect data quality. For routinely performed activities, SOPs are often
prepared to ensure consistency and to save time and effort in preparing QAPjPs.
Any deviation from an established procedure during a data collection activity
should be documented. It is recommended that procedures be available for the
indicated activities, and include, at a minimum, the information described
below.
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4.3.1 Sample Management
The procedures describing the receipt, handling, scheduling, and storage
of samples should be specified.
Sample Receipt and Handling -- These procedures describe the precautions
to be used in opening sample shipment containers and how to verify that
chain-of-custody has; been maintained, examine samples for damage, cfieck
for proper preservatives and temperature, and log samples into the
laboratory sample streams.
Sample Scheduling -- These procedures describe the sample scheduling in
the laboratory and includes procedures used to ensure that holding time
requirements are met.
Sample Storage -- These procedures describe the storage conditions for all
samples, verification and documentation of daily storage temperature, and
how to ensure that custody of the samples is maintained while in the
laboratory.
4.3.2 Reagent/Standard Preparation
The procedures describing how to prepare standards and reagents should be
specified. Information concerning specific grades of materials used in reagent
and standard preparation, appropriate glassware and containers for preparation
and storage, and labeling and recordkeeping for stocks and dilutions should be
included.
4.3.3 General Laboratory Technigues
The procedures describing all essentials of laboratory operations that are
not addressed elsewhere should be specified. These techniques should include,
but are not limited to, glassware cleaning procedures, operation of analytical
balances, pipetting techniques, and use of. volumetric glassware.
4.3.4 Test Methods
Procedures for test methods describing how the analyses are actually
performed in the laboratory should be specified. A simple reference to standard
methods is not sufficient, unless the analysis is performed exactly as described
in the published method. Whenever methods from SW-846 are not appropriate,
recognized methods from source documents published by the EPA, American Public
Health Association (APHA), American Society for Testing and Materials (ASTM), the
National Institute for Occupational Safety and Health (NIOSH), or other
recognized organizations with appropriate expertise should be used, if possible.
The documentation of the actual laboratory procedures for analytical methods
should include the following:
Sample Preparation and Analysis Procedures -- These include applicable
holding time, extraction, digestion, or preparation steps as appropriate
to the method; procedures for determining the appropriate dilution to
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analyze; and any other information required to perform the analysis
accurately and consistently.
Instrument Standardization -- This includes concentration(s) and frequency
of analysis of calibration standards, linear range of the method, and
calibration acceptance criteria.
Sample Data -- This includes recording requirements and documentation in-
cluding sample identification number, analyst, data verification, date of
analysis and verification, and computational method(s).
Precision and Bias -- This includes all analytes for which the method is
applicable and the conditions for use of this information.
Detection and Reporting Limits -- This includes all analytes in the
method.
Test-Specific QC -- This describes QC activities applicable to the
specific test and references any applicable QC procedures.
4.3.5 Equipment Calibration and Maintenance
The procedures describing how to ensure that laboratory equipment and
instrumentation are in working order should be specified. These procedures
include calibration procedures and schedules, maintenance procedures and
schedules, maintenance logs, service arrangements for all equipment, and spare
parts available in-house. Calibration and maintenance of laboratory equipment
and instrumentation should be in accordance with manufacturers' specifications
or applicable test specifications and should be documented.
4.3.6 QC
The type, purpose, and frequency of QC samples to be analyzed in the
laboratory and the acceptance criteria should be specified. Information should
include the applicability of the QC sample to the analytical process, the
statistical treatment of the data, and the responsibility of laboratory staff and
management in generating and using the data. Further details on development of
project-specific QC protocols are described in Section 4.4.
4.3.7 Corrective Action
The procedures describing how to identify and correct deficiencies in the
analytical process should be specified. These should include specific steps to
take in correcting the deficiencies such as preparation of new standards and
reagents, recalibration and restandardization of equipment, reanalysis of
samples, or additional training of laboratory personnel in methods and
procedures. The procedures should specify that each corrective action should be
documented with a description of the deficiency and the corrective action taken,
and should include the person(s) responsible for implementing the corrective
action.
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4.3.8 Data Reduction and Validation
The procedures describing how to review and validate the data should be
specified. They should include procedures for computing and interpreting the
results from QC samples, and independent procedures to verify that the analytical
results are reported correctly. In addition, routine procedures used to monitor
precision and bias, including evaluations of reagent, equipment rinsate, and trip
blanks, calibration standards, control samples, duplicate and matrix spike
samples, and surrogate recovery, 'should be detailed in the procedures. More
detailed validation procedures should be performed when required in the contract
or QAPjf.
4.3.9 Reporting
The procedures describing the process for reporting the analytical results
should be specified.
4.3.10 Records Management
The procedures describing the means for generating, controlling, and
archiving laboratory records should be specified. The procedures should detail
record generation and control, and the requirements for record retention, includ-
ing type, time, security, and retrieval and disposal authorities.
Project-specific records may include correspondence, chain-of-custody
records, request for analysis, calibration data records, raw and finished
analytical and QC data, data reports, and procedures used.
Laboratory operations records may include laboratory notebooks, instrument
performance logs and maintenance logs in bound notebooks with prenumbered
pages; laboratory benchsheets; software documentation; control charts;
reference material certification; personnel files; laboratory procedures;
and corrective action reports.
4.3.11 Waste Disposal
The procedures describing the methods for disposal of chemicals including
standard and reagent solutions, process waste, and samples should be specified.
4.4 LABORATORY QA AND QC PROCEDURES
The QAPjP should describe how the following required elements of the
laboratory QC program are to be implemented.
4.4.1 Method Proficiency
Procedures should be in place for demonstrating proficiency with each
analytical method routinely used in the laboratory. These should Include
procedures for demonstrating the precision and bias of the method as performed
by the laboratory and procedures for determining the method detection limit
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(MDL). All terminology, procedures and frequency of determinations associated
with the laboratory's establishment of the MDL and the reporting limit should be
well-defined and well-documented. Documented precision, bias, and MDL
information should be maintained for all methods performed in the laboratory.
4.4.2 Control Limits
Procedures should be in place for establishing and updating control limits
for analysis. Control limits should be established to evaluate laboratory
precision and bias based on the analysis of control samples. Typically, control
limits for bias are based on the historical mean recovery plus or minus three
standard deviation units, and control limits for precision range from zero (no
difference between duplicate control samples) to the historical mean relative
percent difference plus three standard deviation units. Procedures should be in
place for monitoring historical performance and should include graphical (control
charts) and/or tabular presentations of the data.
4.4.3 Laboratory Control Procedures
Procedures should be in place for demonstrating that the laboratory is in
control during each data collection activity. Analytical data generated with
laboratory control samples that fall within prescribed limits are judged to be
generated while the laboratory was in control. Data generated with laboratory
control samples that fall outside the established control limits are judged to
be generated during an "out-of-control" situation. These data are considered
suspect and should be repeated or reported with qualifiers.
Laboratory Control Samples -- Laboratory control samples should be
analyzed for each analytical method when appropriate for the method. A
laboratory control sample consists of either a control matrix spiked with
analytes representative of the target analytes or a certified reference
material.
Laboratory control sample(s) should be analyzed with each batch of samples
processed to verify that the precision and bias of the analytical process
are within control limits. The results of the laboratory control
sample(s) are compared to control limits established for both precision
and bias to determine usability of the data.
Method Blank -- When appropriate for the method, a method blank should be
analyzed with each batch of samples processed to assess contamination
levels in the laboratory. Guidelines should be in place for accepting or
rejecting data based on the level of contamination in the blank.
Procedures should be in place for documenting the effect of the matrix on
method performance. When appropriate for the method, there should be at least
one matrix spike and either one matrix duplicate or one matrix spike duplicate
per analytical batch. Additional control samples may be necessary to assure data
quality to meet the project-specific DQOs.
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Matrix-Specific Bias -- Procedures should be in place for determining the
bias of the method due to the matrix. These procedures should include
preparation and analysis of matrix spikes, selection and use of surrogates
for organic methods, and the method of standard additions for metal and
inorganic methods. When the concentration of the analyte in the sample is
greater than 0.1%, no spike is necessary.
Matrix-Specific Precision -- Procedures should be in place for determining
the precision of the method for a specific matrix. These procedures
should include analysis of matrix duplicates and/or matrix spike
duplicates. The frequency of use of these techniques should be based on
the DQO for the data collection activity.
Matrix-Specific Detection Limit -- Procedures should be in place for
determining the MDL for a specific matrix type (e.g., wastewater treatment
sludge, contaminated soil, etc).
4.4.4 Deviations
Any activity not performed in accordance with laboratory procedures or
QAPjPs is considered a deviation from plan. All deviations from plan should be
documented as to the extent of, and reason for, the deviation.
4.4.5 Corrective Action
Errors, deficiencies, deviations, or laboratory events or data that fall
outside of established acceptance criteria should be investigated. In some
instances, corrective action may be needed to resolve the problem and restore
proper functioning to the analytical system. The investigation of the problem
and any subsequent corrective action taken should be documented.
4.4.6 Data Handling
Data resulting from the analyses of samples should be reduced according to
protocols described in the laboratory procedures. Computer programs used for
data reduction should be validated before use and verified on a regular-basis.
All information used in the calculations (e.g., raw data, calibration files,
tuning records, results of standard additions, interference check resul-ts, and
blank- or background-correction protocols) should be recorded in order to enable
reconstruction of the final result at a later date. Information on the
preparation of the sample (e.g., weight or volume of sample used, percent dry
weight for solids, extract volume, dilution factor used) should also be
maintained in order to enable reconstruction of the final result at a later date.
All data should be reviewed by a second analyst or supervisor according to
laboratory procedures to ensure that calculations are correct and to detect
transcription errors. Spot checks should be performed on computer calculations
to verify program validity. Errors detected in the review process should be
referred to the analyst(s) for corrective action. Data should be reported in
accordance with the requirements of the end-user. It is recommended that the
supporting documentation include at a minimum:
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Laboratory name and address.
Sample information (including unique sample identification, sample
collection date and time, date of sample receipt, and date(s) of sample
preparation and analysis).
Analytical results reported *with an appropriate number of significant
figures.
Detection limits that reflect dilutions, interferences, or correction for
equivalent dry weight.
Method reference.
Appropriate QC results (correlation with sample batch should be traceable
and documented).
Data qualifiers with appropriate references and narrative on the quality
of the results.
4.5 QUALITY ASSURANCE REVIEW
The QA review consists of internal and external assessments to ensure that
QA/QC procedures are in use and to ensure that laboratory staff conform to these
procedures. QA review should be conducted as deemed appropriate and necessary.
4.6 LABORATORY RECORDS
Records provide the direct evidence and support for the necessary technical
interpretations, judgements, and discussions concerning project activities.
These records, particularly those that are anticipated to be used as evidentiary
data, should directly support technical studies and activities, and provide the
historical evidence needed for later reviews and analyses. Records should be
legible, identifiable, and retrievable, and protected against damage,
deterioration, or loss. The discussion in this section (4.6) outlines
recommended procedures for record keeping. Organizations which conduct field
sampling should develop appropriate record keeping procedures which satisfy
relevant technical and legal requirements.
Laboratory records generally consist of bound notebooks with prenumbered
pages, personnel qualification and training forms, equipment maintenance and
calibration forms, chain-of-custody forms, sample analysis request forms, and
analytical change request forms. All records should be written in indelible ink.
Procedures for reviewing, approving, and revising laboratory records should
be clearly defined, with the lines of authority included. Any documentation
errors should be corrected by drawing a single line through the error so that it
remains legible and should be initialed by the responsible individual, along with
the date of change. The correction is written adjacent to the error.
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Strip-chart recorder printouts should be signed by the person who performed
the instrumental analysis. If corrections need to be made in computerized data,
a system parallel to the corrections for handwritten data should be in place.
Records of sample management should be available to permit the re-creation
of an analytical event for review in the case of an audit or investigation of a
dubious result.
Laboratory records should include, at least, the following:
Operating Procedures -- Procedures should be available to those performing
the task outlined. Any revisions to laboratory procedures should be
written, dated, and distributed to all affected individuals to ensure
implementation of changes. Areas covered by operating procedures are
given in Sections 3.3 and 4.3.
Quality Assurance Plans -- The QAPjP should be on file.
Equipment Maintenance Documentation -- A history of the maintenance record
of each system serves as an indication of the adequacy of maintenance
schedules and parts inventory. As appropriate, the maintenance guidelines
of the equipment manufacturer should be followed. When maintenance is
necessary, it should be documented in either standard forms or in
logbooks. Maintenance procedures should be clearly defined and written
for each measurement system and required support equipment.
Proficiency -- Proficiency information on all compounds reported should be
maintained and should include (1) precision; (2) bias; (3) method detec-
tion limits; (4) spike recovery, where applicable; (5) surrogate recovery,
where applicable; (6) checks on reagent purity, where applicable; and
(7) checks on glassware cleanliness, where applicable.
Calibration Records & Traceabilitv of Standards/Reagents -- Calibration is
a reproducible reference point to which all sample measurements can be
correlated. A sound calibration program should include provisions for
documenting frequency, conditions, standards, and records reflecting the
calibration history of a measurement system. The accuracy of the
calibration standards is important because all data will be in reference
to the standards used. A program for verifying and documenting the
accuracy and traceability of all working standards against appropriate
primary grade standards or the highest quality standards available should
be routinely followed.
Sample Management -• All required records pertaining to sample management
should be maintained and updated regularly. These include chain-of-
custody forms, sample receipt forms, and sample disposition records.
Original Data -- The raw data and calculated results for all samples
should be maintained in laboratory notebooks, logs, benchsheets, files or
other sample tracking or data entry forms. Instrumental output should be
stored in a computer file or a hardcopy report.
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QC Data -- The raw data and calculated results for all QC and field
samples and standards should be maintained in the manner described in the
preceding paragraph. Documentation should allow correlation of sample
results with associated QC data. Documentation should also include the
source and lot numbers of standards for traceability. QC samples include,
but are not limited to, control samples, method blanks, matrix spikes, and
matrix spike duplicates.
Correspondence -- Project correspondence can provide evidence supporting
technical interpretations. Correspondence pertinent to the project should
be kept and placed in the project files.
Deviations -- All deviations from procedural and planning documents should
be recorded in laboratory notebooks. Deviations from QAPjPs should be
reviewed and approved by the authorized personnel who performed the
original technical review or by their designees.
Final Report -- A copy of any report issued and any supporting documenta-
tion should be retained.
5.0 DEFINITIONS
The following terms are defined for use in this document:
ACCURACY
BATCH:
BIAS:
The closeness of agreement between an observed value and
an accepted reference value. When applied to a set of
observed values, accuracy will be a combination of a
random component and of a common systematic error (or
bias) component.
A group of samples which behave similarly with respect to
the sampling or the testing procedures being employed and
which are processed as a unit (see Section 3.4.1 for field
samples and Section 4.4.3 for laboratory samples). For QC
purposes, if the number of samples in a group is greater
than 20, then each group of 20 samples or less will all be
handled as a separate batch.
The deviation due to matrix effects of the measured value
(x, - xu) from a known spiked amount. Bias can be assessed
by comparing a measured value to an accepted reference
value in a sample of known concentration or by determining
the recovery of a known amount of contaminant spiked into
a sample (matrix spike). Thus, the bias (B) due to matrix
effects based on a matrix spike is calculated as:
where:
B - (x. - xu ) - K
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BLANK:
CONTROL SAMPLE:
DATA QUALITY
OBJECTIVES (DQOs)
DATA VALIDATION:
DUPLICATE:
EQUIPMENT BLANK:
EQUIPMENT RINSATE:
ESTIMATED
QUANTITATION
LIMIT (EQL):
x. = measured value for spiked sample,
xu = measured value for unspiked sample, and
K * known value of the spike in the sample.
Using the following equation yields the percent recovery
%R « 100 (x. -
xu)/ K
see Equipment Rinsate, Method Blank, Trip Blank.
A QC sample introduced into a process to monitor the
performance of the system.
A statement of the overall level of uncertainty that a
decision-maker is willing to accept in results derived
from environmental data (see reference 2, EPA/QAMS, July
16, 1986). This is qualitatively distinct from quality
measurements such as precision, bias, and detection limit.
The process of evaluating the available data against the
project DQOs to make sure that the objectives are met.
Data validation may be very
depending on project DQOs. The
will include analytical results,
data, and may also include field
rigorous, or cursory,
available data reviewed
field QC data and lab QC
records.
see Matrix Duplicate, Field Duplicate, Matrix Spike
Duplicate.
see Equipment Rinsate.
A sample of analyte-free media which has been used to
rinse the sampling equipment. It is collected after
completion of decontamination and prior to sampling. This
blank is useful in documenting adequate decontamination of
sampling equipment.
The lowest concentration that can be reliably achieved
within specified limits of precision and accuracy during
routine laboratory operating conditions. The EQL is
generally 5 to 10 times the MDL. However, it may be
nominally chosen within these guidelines to simplify data
reporting. For many analytes the EQL analyte
concentration is selected as the lowest non-zero standard
in the calibration curve. Sample EQLs are highly matrix-
dependent. The EQLs in SW-846 are provided for guidance
and may not always be achievable.
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FIELD DUPLICATES:
LABORATORY CONTROL
SAMPLE:
MATRIX:
MATRIX DUPLICATE:
MATRIX SPIKE:
MATRIX SPIKE
DUPLICATES:
METHOD BLANK:
METHOD DETECTION
LIMIT (MDL):
Independent samples which are collected as close as
possible to the same point In space and time. They are
two separate samples taken from the same source, stored In
separate containers, and analyzed Independently. These
duplicates are useful in documenting the precision of the
sampling process.
A known matrix spiked with compound(s) representative of
the target analytes. This is used to document laboratory
performance.
The component or substrate (e.g., surface water, drinking
water) which contains the analyte of interest.
An intralaboratory split sample which is used to document
the precision of a method in a given sample matrix.
An aliquot of sample spiked with a known concentration of
target analyte(s). The spiking occurs prior to sample
preparation and analysis. A matrix spike is used to,
document the bias of a method in a given sample matrix.
Intralaboratory split samples spiked with identical
concentrations of target analyte(s). The spiking occurs
prior to sample preparation and analysis. They are used
to document the precision and bias of a method in a given
sample matrix.
An analyte-free matrix to which all reagents are added in
the same volumes or proportions as used in sample
processing. The method blank should be carried through
the complete sample preparation and analytical procedure.
The method blank is used to document contamination
resulting from the analytical process.
For a method blank to be acceptable for use wtth the
accompanying samples, the concentration in the blank of
any analyte of concern should not be higher than the
highest of either:
(l)The method detection limit, or
(2)F1ve percent of the regulatory limit for that analyte,
or
(3)Five percent of the measured concentration in the
sample.
The minimum concentration of a substance that can be
measured and reported with 99% confidence that the analyte
concentration is greater than zero and is determined from
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analysis of a sample in a given matrix type containing
the analyte.
For operational purposes, when it is necessary to
determine the MDL in the matrix, the MDL should be
determined by multiplying the appropriate one-sided 99% t-
statistic by the standard deviation obtained from a
minimum of three analyses of a matrix spike containing the
analyte of interest at a concentration three to five times
the estimated MDL, where the t-statistic is obtained from
standard references or the table below.
No. of samples; t-statistic
3 6.96
4 4.54
5 3.75
6 3.36
7 3.14
8 3.00
9 2.90
10 2.82
Estimate the MDL as follows:
Obtain the concentration value that corresponds to:
a) an instrument signal/noise ratio within the range of
2.5 to 5.0, or
b) the region of the standard curve where there is a
significant change in sensitivity (i.e., a break in the
slope of the standard curve).
Determine the variance (S2) for each analyte as follows:
n-I
where x{ * the ith measurement of the variable x
and x - the average value of x;
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ORGANIC-FREE
REAGENT WATER:
PRECISION:
Determine the standard deviation (s) for each analyte as
follows:
2x1/2
s - (S?)
Determine the MDL for each analyte as follows:
MDL
u(n-1. a « .99)
(S)
where t(n_,, wx is the one-sided t-statistic appropriate
for the number'of samples used to determine (s), at the 99
percent level.
For volatiles, all references to water in the methods
refer to water in which an interferant is not observed at
the method detection limit of the compounds of interest.
Organic-free reagent water can be generated by passing tap
water through a carbon filter bed containing about 1 pound
of activated carbon. A water purification system may be
used to generate organic-free deionized water.
Organic-free reagent water may also be prepared by boiling
water for 15 minutes and, subsequently, while maintaining
the temperature at 90°C, bubbling a contaminant-free inert
gas through the water for 1 hour.
For semivolatiles and nonvolatiles, all references to
water in the methods refer to water in which an
interferant is not observed at the method detection limit
of the compounds of interest. Organic-free reagent water
can be generated by passing tap water through a carbon
filter bed containing about 1 pound of activated carbon.
A water purification system may be used to generate
organic-free deionized water.
The agreement among a set of replicate measurements
without assumption of knowledge of the true value.
Precision is estimated by means of duplicate/replicate
analyses. These samples should contain concentrations of
analyte above the MDL, and may involve the use of matrix
spikes. The most commonly used estimates of precision are
the relative standard deviation (RSD).or the coefficient
of variation (CV),
RSD - CV - 100 S/x,
ONE - 27
123
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PROJECT:
QUALITY ASSURANCE
PROJECT PLAN
(QAPJP):
RCRA:
REAGENT BLANK:
REAGENT GRADE:
REAGENT WATER:
REFERENCE MATERIAL:
SPLIT SAMPLES:
STANDARD ADDITION:
STANDARD CURVE:
wtiere:
x « the arithmetic mean of the KJ measurements, and S =
variance; and the relative percent difference (RPD) when
only two samples are available.
RPD = 100 [(x, - x2)/((x, + x2)/2}].
Single or multiple data collection activities that are
related through the same planning sequence.
An orderly assemblage of detailed procedures designed to
produce data of sufficient quality to meet the data
quality objectives for a specific data collection
activity.
The Resource Conservation and Recovery Act.
See Method Blank.
Analytical reagent (AR) grade, ACS reagent grade, and
reagent grade are synonymous terms for reagents which
conform to the current specifications of the Committee on
Analytical Reagents of the American Chemical Society.
Water that has been generated by any method which would
achieve the performance specifications for ASTM Type II
water. For organic analyses, see the definition of
organic-free reagent water.
A material containing known quantities of target analytes
in solution or in a homogeneous matrix. It is used to
document the bias of the analytical process.
Aliquots of sample taken from the same container and
analyzed independently. In cases where aliquots of
samples are impossible to obtain, field duplicate samples
should be taken for the matrix duplicate analysis. These
are usually taken after mixing or compositing and are used
to document intra- or inter!aboratory precision.
The practice of adding a known amount of an analyte to a
sample immediately prior to analysis. It is typically
used to evaluate interferences.
A plot of concentrations of known analyte standards versus
the instrument response to the analyte. Calibration
standards are prepared by successively diluting a standard
solution to produce working standards which cover the
working range of the instrument. Standards should be
prepared at the frequency specified in the appropriate
ONE - 28
124
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SURROGATE:
TRIP BLANK:
The calibration standards should be prepared
same type of acid or solvent and at the same
as will result in the samples following
sample preparation. This is applicable to organic and
inorganic chemical analyses.
section.
using the
concentration
An organic compound which is similar to the target
analyte(s) in chemical composition and behavior in the
analytical process, but which is not normally found in
environmental samples.
A sample of analyte-free media taken from the laboratory
to the sampling site and returned to the laboratory
unopened. A trip blank is used to document contamination
attributable to shipping and field handling procedures.
This type of blank is useful in documenting contamination
of volatile organics samples.
6.0 REFERENCES
1. Interim Guidelines and Specifications for Preparing Quality Assurance
Project Plans, QAMS-005/80, December 29, 1980, Office of Monitoring Systems
and Quality Assurance, ORD, U.S. EPA, Washington, DC 20460.
2. Development of Data Quality Objectives, Description of Stages I and II, July
16, 1986, Quality Assurance Management Staff, ORD, U.S. EPA, Washington, DC
20460.
3. RCRA Ground-Water Monitoring Technical Enforcement Guidance Document,
September, 1986, Office of Waste Programs Enforcement. OSWER, U.S. EPA,
Washington, DC, 20460.
4. DQO Training Software, Version 6.5, December, 1988, Quality Assurance
Management Staff, ORD, U.S. EPA, Washington, DC 20460.
5. Preparing Perfect Project Plans, EPA/600/9-89/087, October 1989, Risk
Reduction Engineering Laboratory (Guy Simes), Cincinnati OH.
6. ASTM Method D 1129-77, Specification for Reagent Water. 1991 Annual Book
of ASTM Standards. Volume 11.01 Water and Environmental Technology.
7. Generation of Environmental Data Related to Waste Management Activities
(Draft). February 1989. ASTM.
ONE - 29
125
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NDEX
Accuracy 1, 13, 22, 23', 24
Batch 12, 19, 21, 23"
Bias 2, 3, 17-20, 22, 23'-25, 28
Blank 11, 12, 14, 18-20, 23", 24, 25, 28, 29
Equipment Rinsate 11, 12, 14, 18, 24"
Method Blank 19, 24, 25", 28
Reagent Blank 28"
Trip Blank 12, 18, 24, 29"
Chain-of-Custody 9, 11, 13, 14, 18, 21, 22
Control Chart 18, 19
Control Sample 11, 12, 18, 19, 23, 24"
Data Quality Objectives (DQO) 1-3, 8, 12, 19, 20, 24', 28
Decision-maker 2, 24
Duplicate 11, 12, 14, 18-20, 23, 24", 25, 27, 28
Field Duplicate 11, 12, 24, 25", 28
Matrix Duplicate 12, 19, 20, 24, 25", 28
Matrix Spike Duplicate 12, 19, 20, 23, 24, 25"
Equipment Blank 11, 24"
Equipment Rinsate 11, 12, 14, 18, 24"
Estimated Quantitation Limit (EQL) 24"
Field Duplicate 12, 24, 25*, 28
Laboratory Control Sample 19, 25"
Matrix 11, 12, 18-20, 23-25", 26-28
Matrix Duplicate 12, 19, 20, 24, 25", 28
Matrix Spike 12, 18-20, 23, 25', 26, 27
Matrix Spike Duplicate 12, 19, 20, 23, 24, 25"
Method Blank 19, 24, 25", 28
Method Detection Limit (MDL) 18-20, 22, 24, 25"-27
Organic-Free Reagent Water 27", 28
Precision 1-3, 17-20, 22, 24, 25, 27', 28
Project 1-5, 7, 8, 11-14, 17-19, 21, 23, 24, 28"
Quality Assurance Project Plan (QAPjP) 1-9, 11, 12, 14, 15, 18, 20, 22, 23, 28"
RCRA 1, 8, 28"
Reagent Blank 28]
Reagent Grade 28"
Reagent Water 27, 28"
Reference Material 8, 11, 15, 18, 19, 28"
Split Samples 25, 28"
Standard Addition 20, 28"
Standard Curve 26, 28*
Surrogate 18, 20, 22, 29"
Trip Blank 12, 18, 24, 29"
Definition of term.
ONE - 30 Revision 1
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Appendix C
Definitions
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DEFINITIONS
Alternate Concentration Limits: A concentration limit-in lieu of an MCL~established by the
implementing agency for a hazardous constituent based on a finding that the constituent does not pose
a substantial present or potential hazard to human health or the environment as long as the alternate
concentration limit is not exceeded.
Corrective Action Management Unit (CAMU): An area within a facility that is designated by the
Regional Administrator under part 264 subpart S, for the purpose of implementing corrective action
requirements under §264.101 and RCRA section 3008(h). A CAMU shall only be used for
management of remediation wastes pursuant to implementing such corrective action requirements at
the facility.
Facility: (1) All contiguous land, and structures, other appurtenances, and improvements on the land,
used for treating, storing, or disposing of hazardous waste. A facility may consist of several
treatment, storage, or disposal operational units (e.g., one or more landfills, surface impoundments,
or combinations of them). (2) For the purpose of implementing corrective action under §264.101, all
contiguous property under the control of the owner or operator seeking a permit under RCRA subtitle
C. This definition also applies to facilities implementing corrective action under RCRA § 3008(h).
Innovative Treatment Technologies: Those technologies for treatment of soil, sediment, sludge and
debris other than incineration or solidification/stabilization and those technologies for treatment of
groundwater contamination that are alternatives to pump and treat. Pump and treat in this instance
refers to pumping with conventional treatments like air stripping, UV oxidation.
Maximum Contaminant Level (MCL): Under Section 141 of the Safe Drinking Water Act, as
amended, the maximum permissible level of a contaminant in water delivered to any user of a public
water system. MCLs reflect health factors and the technical and economic feasibility of recovering
contaminants from the water supply.
Permittee/Respondent: Any person owning .or operating a facility or conducting activity subject to
regulation under RCRA and subject to a permit or order requiring corrective action.
Solid Waste Management Unit (SWMU): Any discernible unit at which solid wastes have been placed
at any time, irrespective of whether the unit was intended for the management of solid or hazardous
waste. Such units include any area at a facility at which solid wastes have been routinely and
systematically released.
Stabilization: The goal or philosophy of controlling or abating threats to human health and/or the
environment from releases and/or preventing or minimizing the further spread of contaminants while
long-term remedies are pursued.
Temporary Unit (777): A unit used for the storage or treatment of hazardous wastes that originate
during corrective action activities at a facility.
[NOTE: For additional guidance on technical terms used in the corrective action program, see the
"Corrective Action Glossary" (OSWER Directive Number 9902.3-la, July, 1992)]
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Appendix D
Corrective Action Stabilization Questionnaire
129
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INTRODUCTION TO THE CORRECTIVE ACTION STABILIZATION QUESTIONNAIRE
Decision Strategy
The question of whether to implement stabilization measures at a RCRA facility undergoing
some phase of corrective action should be answered based upon a series of policy and technical
judgments. Many of these individual judgments are difficult to quantify and, therefore, must be based
upon the professional judgment of Federal and State environmental regulators responsible for
implementing the RCRA corrective action program. These judgments, as a group, should form a basis
upon which the relative benefits to be gained through stabilization at a particular facility are weighed.
The types of benefits envisioned through facility stabilization include limited contaminant migration,
reduced volume of contaminated media, and lowered risk to human health and the environment.
The attached questionnaire attempts to prompt the decision making process by asking both
policy and technical questions regarding stabilization of a facility. For each question, a short
discussion of the importance and relevance of the answer is provided below. It may be useful to refer
to these short discussions as the questionnaire is completed.
Background Facility Information
Question 1 Is this checklist being completed for one solid waste management unit
(SWMU), several SWMUs, or the entire facility? Explain.
A strategy for stabilization may be considered or implemented for either an entire facility, a
specific SWMU, or a group of SWMUs. Stabilization activities, while addressing releases from one or
more SWMUs, are likely to concentrate on a specific environmental medium, such as ground water,
surface water, air, or soil. The SWMU(s) and media being considered for stabilization should be
recorded in the spaces provided.
Status of Corrective Action Activities at the Facility
Question 2 What is the current status of HSWA corrective action activities at the facility?
The current status of HSWA corrective action activities is a major factor for consideration when
deciding whether and when to implement a stabilization strategy at a particular facility. Stabilization
should be considered an option at a facility up until the point where it becomes more expedient and
cost-effective to implement the final corrective measures. Generally, the immediate implementation of
final corrective measures, rather than stabilization measures, becomes more efficient after the
Corrective Measures Study (CMS) is completed, because the effort arH resources that might be used
to plan, design, and construct stabilization structures may be more effectively spent on Corrective
Measures Implementation (CMI).
Interim measures may be implemented at any point in the corrective action process, and if
they have been implemented, they should be noted on the questionnaire in addition to the other
activities listed.
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Question 3 If corrective action activities have been initiated, are they being carried out
under a permit or an enforcement order?
Corrective action activities are usually carried out under the authority of either a RCRA
operating or post-closure permit, or under a RCRA §3008(h) administrative order. The authority used
for an ongoing corrective action project at a particular facility will affect the ease with which a
stabilization strategy can be incorporated into an existing compliance schedule. The extra time
needed for public comment, State concurrence, and other administrative requirements associated with
modifying or revising either a permit or an order (to incorporate stabilization) should be taken into
account when considering whether stabilization is appropriate for a given facility because as the time
required to address procedural requirements increases, the benefits potentially derived from
stabilization decrease.
Question 4 Have interim measures, if required or completed [See Question 2], been
successful in preventing the further spread of contamination at the facility?
If interim measures have been implemented at a facility and they have been successful in
preventing the further spread of contamination from all significant releases, stabilization has, in effect,
been accomplished. In this case, additional stabilization measures should not be required.
Conversely, if interim measures have not been carried out, or if they have not been successful in
limiting the spread of contamination, stabilization measures should eventually be considered for this
facility.
EPA is currently evaluating facilities for stabilization based upon the
priority ranking a facility receives under the RCRA National
Corrective Action Prioritization System. At this time, the Agency is
only evaluating those facilities that have been ranked as 'high'
priorities. Therefore, the attached questionnaire need only be
completed when evaluating those facilities ranked as high priorities
and where interim actions are not yet under way or have been
unsuccessful in preventing the further spread of contamination at
the facility.
Facility Releases and Exposure Concerns
Question 5 To what media have contaminant releases from the facility occurred or been
suspected of occurring?
Releases of hazardous materials to any environmental media are a serious concern.
Stabilization measures are generally technically feasible for any of the four environmental media
(ground water, surface water, air, or soils), and stabilization should be considered wherever this type
of action could limit the further spread of contaminant migration.
Question 6 Are contaminant releases migrating off-site?
Off-site migration of contaminants generally indicates the need for some stabilization measure
to limit contaminant movement until final corrective measures can be implemented.
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Questions 7a and 7b Are humans currently being exposed to contaminants released from
the facility?
Is there a potential for human exposure to the contaminants released
from the facility over the next five to 10 years?
The actual occurrence, or the near- to mid-term (i.e., within five to 10 years) potential, of
human exposure to released contaminants is a factor supporting the implementation of stabilization
measures. The type of exposure that has occurred is an important consideration in determining the
type of stabilization measure employed for a facility or SWMU. The stabilization measure considered
should eliminate or significantly reduce the human exposure levels at and near the facility.
The make-up of the exposed population (e.g., facility employees, nearby home owners,
school children, nursing home residents) and the duration of exposure are factors that should be
considered when determining the type of stabilization or corrective measure to be implemented.
Exposure of high-risk populations, such as children, may require the implementation of "real-time"
stabilization measures, perhaps even emergency measures, to immediately reduce the contaminant
levels near that population sooner than may be possible with final corrective measures.
The potential short-term and long-term effects of human exposure to released contaminants
should be considered when determining the need for stabilization measures. Any significant exposure
concern is a factor in favor of implementing stabilization measures.
Questions 8a and 8b Are environmental receptors currently being exposed to contaminants
released from the facility?
Is there a potential that environmental receptors could be exposed to
the contaminants released from the facility over the next five to 10
years?
The existence of potential threats to the environment from the release of hazardous
constituents is to be considered a factor in favor of implementing stabilization measures.
Environmental receptors include terrestrial and aquatic organisms, food chain plants and animals, vital
ecology or potential natural resources, and Class I or other aquifers. The time frame over which these
threats may materialize (i.e., will the threat materialize before final corrective measures can be
implemented) should be used to determine the immediacy of the need for stabilization measures.
Anticipated Final Corrective Measures
Question 9 If already identified or planned, would final corrective measures be able to be
implemented in time to adequately address any existing or short-term threat to
human health and the environment?
Final corrective measures, which sometimes can be identified early in the RFI, should always
be designed to reduce or eliminate, to the degree practicable, both short-term and long-term risks
posed by the release of hazardous constituents. If final corrective measures are currently being
planned or constructed, it is unlikely that any relatively new stabilization measures could be
implemented fast enough to be more effective in reducing short-term threats to human health and the
environment. Therefore, if final corrective measures have reached the planning stages, it should be
considered a factor against the implementation of stabilization measures.
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Questions 10 and 11 Could a stabilization initiative at this facility reduce the present or near-term
(e.g., less than two years) risks to human health and the environment?
If a stabilization activity were not begun, would the threat to human health and
the environment significantly increase before final corrective measures could
be implemented?
If it can be determined that a fast-track,' or quickly implementable, stabilization measure could
significantly reduce the present or near-future risks to human health and the environment, stabilization
measures should be favorably considered. Similarly, if it can be determined that the absence of
stabilization measures would result in a significantly greater risk to human health and the environment,
stabilization measures should be favorably considered.
Technical Ability to Implement Stabilization Activities
Question 12 In what phase does the contaminant exist under ambient site conditions?
The physical phase of a contaminant will affect the technical practicability of stabilization. See
Attachment A for a preliminary analysis of types of waste constituents that may be stabilized by
various remediation technologies.
Question 13 Are one or more of the following major chemical groupings of concern at the
facility?
Some contaminants are more amenable to stabilization techniques than others. See
Attachment A for a preliminary analysis of types of waste constituents that may be stabilized by
various remediation technologies.
Question 14 Are appropriate stabilization technologies available to prevent the further
spread of contamination, based on contaminant characteristics and the
facility's environmental setting? [See Attachment A for a listing of potential
stabilization technologies.]
The implementation of stabilization measures is, of course, dependent upon the availability of
appropriate technologies and techniques. Attachment A lists a series of hazardous waste site
remediation technologies and techniques that have potential applicability for stabilization of certain
wastes under certain conditions. If there are no identified technologies appropriate for stabilizing
contamination at this facility, this evaluation is complete and the rest of this questionnaire need not be
completed.
Question 15 Has the RFI, or another environmental investigation, provided the site
characterization and waste release data needed to design and implement a
stabilization activity? If No, can these data be obtained faster than the data
needed to implement the final corrective measures?
Stabilization measures should not be considered for implementation until adequate site
characterization and waste release data are available. Gathering data specifically for stabilization is
not a worthwhile endeavor if the data for a final corrective measure are more readily available or
quicker to obtain.
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Timing and Other Procedural Issues Associated with Stabilization
Question 16 Can stabilization activities be implemented more quickly than the final
corrective measures?
Generally, stabilization measures should not be implemented unless they can be put in place
more quickly and/or more efficiently, or will be effective significantly sooner than final corrective
measures.
Question 17 Can stabilization activities be incorporated into the final corrective measures at
some point in the future?
Stabilization measures should generally be amenable to incorporation into the final corrective
action project. Measures that cannot be successfully integrated into the overall site remediation
should be able to significantly and predictably reduce threats to human health or the environment, or
produce some other beneficial effects deemed important by the Administrator.
Conclusion
Question 18 Is this facility an appropriate candidate for stabilization activities?
The decision of whether or not to implement stabilization measures at a facility is a
professional judgment that should be based upon a careful weighing of factors such as those
described above. There may also be other site-specific factors that enter into the decision, and these
factors and their consequences should be documented in an appropriate manner.
In most cases, stabilization should only be implemented if it offers some clear advantages (in
terms of protecting human health and the environment) over waiting for the implementation of final
corrective measures. The stabilization measure used at a facility should be at least a part of the final
corrective measure, with changes in timing and short-term goals (limiting contaminant movement
versus contaminant cleanup) being the major points setting it apart from the final measures.
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CORRECTIVE ACTION STABILIZATION QUESTIONNAIRE
Completed by:
Date:
Background Facility Information
Facility Name:
EPA Identification No.:
Location (City, State):
Facility Priority Rank:
Is this checklist being completed for one
solid waste management unit (SWMU),
several SWMUs, or the entire facility?
Explain.
Status of Corrective Action Activities at the
Facility
2. What is the current status of HSWA
corrective action activities at the facility?
( ) No corrective action activities
initiated
( ) RCRA Facility Assessment (RFA)
or equivalent completed
( ) RCRA Facility Investigation (RFI)
completed
( ) Corrective Measures Study (CMS)
completed
Corrective Measures
Implementation (CMI) begun or
completed
Interim Measures begun or
completed
3. If corrective action activities have been
initiated, are they being carried out under
a permit or an enforcement order?
( ) Operating permit
( ) Post-closure permit
( ) Enforcement order
4. Have interim measures, if required or
completed [see Question 2], been
successful in preventing the further
spread of contamination at the facility7
( ) Yes
( ) No
( ) Uncertain; still underway
CONTINUE TO QUESTION 5 ONLY IF THE
FOLLOWING CONDITIONS ARE MET:
• The facility ranks "High" on the National
Corrective Action Prioritization System;
AND
• Interim Measures have not been initiated,
or if initiated, have not been successful in
preventing the further spread of
contamination at the facility.
Facility Releases and Exposure Concerns
5. To what media have contaminant releases
from the facility occurred or been
suspected of occurring?
( ) Ground water
( ) Surface water
( ) Air
( ) Soils
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6. Are contaminant releases migrating off-
site7
( ) Yes; Indicate media,
concentrations, and level of-
certainty.
( ) No
( ) Uncertain
7a. Are humans currently being exposed to
contaminants released from the facility?
( ) Yes
( ) No
( ) Uncertain
7b. Is there a potential for human exposure to
the contaminants released from the facility
over the next five to 10 years?
( ) Yes
( ) No
( ) Uncertain
8a. Are environmental receptors currently
being exposed to contaminants released
from the facility?
( ) Yes
( ) No
( ) Uncertain
8b. Is there a potential that environmental
receptors could be exposed to the
contaminants released from the facility
over the next five to 10 years?
( ) Yes
( ) No
( ) Uncertain
1-6
Anticipated Final Corrective Measures
9. If already identified or planned, would final
corrective measures be able to be
implemented in time to adequately
address any existing or short-term threat
to human health and the environment?
( ) Yes
( ) No
( ) Uncertain
Additional explanatory notes:
10. Could a stabilization initiative at this facility
reduce the present or near-term (e.g., less
than two years) risks to human health and
the environment?
( ) Yes
( ) No
( ) Uncertain
Additional explanatory notes:
11. If a stabilization activity were not begun,
would the threat to human health and the
environment significantly increase before
final corrective measures could be
implemented?
( ) Yes
( ) No
( ) Uncertain
Additional explanatory notes:
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Technical Ability to Implement Stabilization
Activities
12. in what phase does the contaminant exist
under ambient site conditions?
( ) Solid
( ) Light non-aqueous phase liquids
(LNAPLs)
( ) Dense non-aqueous phase liquids
(DNAPLs)
( ) Dissolved in ground water or
surface water
( ) Gaseous
( ) Other
13. Are one or more of the following major
chemical groupings of concern at the
facility?
( ) Volatile organic compounds
(VOCs) and/or semi-volatiles
( ) Polynuclear aromatics; (PAHs)
( ) Pesticides
( ) Polychlorinated biphenyls (PCBs)
and/or dioxins
Other organics
Inorganics and metals;
Explosives
Other
14. Are appropriate stabilization technologies
available to prevent the further spread of
contamination, based on contaminant
characteristics and the facility's
environmental setting? [See Attachment
A for a listing of potential stabilization
technologies.]
( ) Yes; Indicate possible course of
action.
( ) No; Indicate why stabilization
technologies are not appropriate;
then go to Question 19.
15. Has the RFI, or another environmental
investigation, provided the site
characterization and waste release data
needed to design and implement a
stabilization activity?
Yes
No
If No, can these data be obtained faster
than the data needed to implement the
final corrective measures?
( ) Yes
( ) No
Timing and Other Procedural Issues
Associated with Stabilization
16. Can stabilization activities be implemented
more quickly than the final corrective
measures?
( ) Yes
( ) No
( ) Uncertain
Additional explanatory notes:
17. Can stabilization activities be incorporated
into the final corrective measures at some
point in the future?
( ) Yes
( ) No
( ) Uncertain
Additional explanatory notes:
37
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Appendix E
Example Scope of Work for
Interim/Stabilization Measures
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EXAMPLE
SCOPE OF WORK FOR INTERIM MEASURES IMPLEMENTATION
PURPOSE
Interim measures are actions to control and/or eliminate
releases of hazardous waste and/or hazardous constituents from a
facility prior to the implementation of a final corrective
measure. Interim measures must be used whenever possible to
achieve the goal of stabilization which is to control or abate
threats to human health and/or the environment, and to prevent or
minimize the spread of contaminants while long-term corrective
action alternatives are being evaluated.
SCOPE
The documents required for Interim Measures (IM) are, unless
the Implementing Agency specifies otherwise, an IM Workplan, an
Operation and Maintenance Plan and IM Plans and Specifications.
The scope of work (SOW) for each document is specified below.
The SOW's are intended to be flexible documents capable of
addressing both simple and complex site situations. If the
Permittee/Respondent can justify, to the satisfaction of the
Implementing Agency, that a plan or portions thereof are not
needed in the given site specific situation, then the
Implementing Agency may waive that requirement.
The scope and substance of interim measures should be focused
to fit the site specific situation and be balanced against the
need to take quick action.
The Implementing Agency may require the Permittee/Respondent
to conduct additional studies beyond what is discussed in the
SOW's in order to support the IM program. The Permittee/
Respondent will furnish all personnel, materials and services
necessary to conduct the additional tasks.
A. Interim Measures Workplan
The Permittee/Respondent shall prepare an IM Workplan that
evaluates interim measure options and clearly describes the
proposed interim measure, the key components or elements
that are needed, describes the designers vision of the
interim measure in the form of conceptual drawings and
schematics, and includes procedures and schedules for
implementing the interim measure(s). The IM Workplan must
be approved by the Implementing Agency prior to implemen-
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tation. The IM Workplan must, at a minimum, include the
following elements:
1. Introduction/Purpose
Describe the purpose of the document and provide a
summary of the project.
2. Conceptual Model of Contaminant Migration
It is important to know where the contaminants are and
to understand how they are moving before an adequate
interim measure can be developed. To address this
critical question, the Permittee/Respondent must
present a conceptual model of the site and contaminant
migration. The conceptual model consists of a working
hypothesis of how the contaminants may move from the
release source to the receptor population. The
conceptual model is developed by looking at the
applicable physical parameters (e.g., water solubility,
density, Henry's Law Constant, etc.) for each
contaminant and assessing how the contaminant may
migrate given the existing site conditions (geologic
features, depth to groundwater, etc.). Describe the
phase (water, soil, gas, non-aqueous) and location
where contaminants are likely to be found. This
analysis may have already been done as part of earlier
work (e.g., Current Conditions Report). If this is the
case, then provide a summary of the conceptual model
with a reference to the earlier document.
3. Evaluation of Interim Measure Alternatives
List, describe and evaluate interim measure
alternatives that have the potential to stabilize the
facility. Propose interim measures for implementation
and provide rationale for the selection. Document the
reasons for excluding any interim measure alternatives.
4. Description of Interim Measures
Qualitatively describe what the proposed interim
measure is supposed to do and how it will function at
the facility.
5. Data Sufficiency
Review existing data needed to support the design
effort and establish whether or not there is sufficient
accurate data available for this purpose. The
Permittee/Respondent must summarize the assessment
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findings and specify any additional data needed to
complete the interim measure design. The Implementing
Agency may require or the Permittee/Respondent may
propose that sampling and analysis plans and/or
treatability study workplans be developed to obtain the
additional data. Submittal times for any new sampling
and analysis plans and/or treatability study workplans
must be included in the project schedule.
6. Project Management
Describe the levels of authority and responsibility
(include organization chart), lines of communication
and a description of the qualifications of key
personnel who will direct the interim measure design
and implementation effort (including contractor
personnel).
7. Project Schedule
The project schedule must specify all significant steps
in the process, when any key documents (e.g., plans and
specifications, operation and maintenance plan) are to
be submitted to the Implementing Agency and when the
interim measure is to be implemented.
8. Design Basis
Discuss the process and methods used to design all
major components of the interim measure. Discuss the
significant assumptions made and possible sources of
error. Provide justification for the assumptions.
9. Conceptual Process/Schematic Diagrams.
10. Site plan showing preliminary plant layout and/or
treatment area.
11. Tables listing number and type of major components with
approximate dimensions.
12. Tables giving preliminary mass balances.
13. Site safety and security provisions (e.g., fences, fire
control, etc.).
14. Waste Management Practices
Describe the wastes generated by the construction of
the interim measure and how they will be managed. Also
discuss drainage and indicate how rainwater runoff will
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be managed.
15. Required Permits
List and describe the permits needed to construct the
interim measure. Indicate on the project schedule when
the permit applications will be submitted to the
applicable agencies and an estimate of the permit
issuance date.
16. Sampling and monitoring activities may be needed for
design and during construction of the interim measure.
If sampling activities are necessary, the IM Workplan
must include a complete sampling and analysis section
which specifies the following information:
a. Description and purpose of monitoring tasks;
b. Data quality objectives;
c. Analytical test methods and detection limits;
d. Name of analytical laboratory;
e. Laboratory quality control (include laboratory
QA/QC procedures in appendices)
f. Sample collection procedures and equipment;
g. Field quality control procedures:
* duplicates (10% of all field samples)
* blanks (field, equipment, etc.)
* equipment calibration and maintenance
* equipment decontamination
* sample containers
* sample preservation
* sample holding times (must be specified)
* sample packaging and shipment
* sample documentation (field notebooks, sample
labeling, etc) ,•
h. Criteria for data acceptance and rejection; and
i. Schedule of monitoring frequency.
The Permittee/Respondent shall follow all EPA guidance
for sampling and analysis. The Implementing Agency may
request that the sampling and analysis section be a
separate document.
17. Appendices including:
Design Data - Tabulations of significant data used in
the design effort;
Equations - List and describe the source of major
equations used in the design process;
Sample Calculations - Present and explain one example
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calculation for significant calculations; and
Laboratory or Field Test Results.
B. Interim Measures Operation and Maintenance Plan
The Permittee/Respondent shall prepare an Interim Measures
Operation and Maintenance (OovM) Plan that includes a
strategy and procedures for" pe.cfornvmu operations,
maintenance, and monitoring c I the inter..',.!-'.! measure (s). An
Interim Measures Operation and Maintenance Plan shall be
submi''•".'•:<'••' 1
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Describe normal operation and maintenance procedures
including:
a. Description of tasks for operation;
b. Description of tasks for maintenance;
c. Description of prescribed treatment or operation
conditions; and
d. Schedule showing frequency of each O&M task.
7. Replacement schedule for equipment and installed
components.
8. Waste Management Practices
Describe the wastes generated by operation of the
interim measure and how they will be managed. Also
discuss drainage and indicate how rainwater runoff will
be managed.
9. Sampling and monitoring activities may be needed for
effective operation and maintenance of the interim
measure. If sampling activities are necessary, the O&M
plan must include a complete sampling and analysis
section which specifies the following information:
a. Description and purpose of monitoring tasks;
b. Data quality objectives;
c. Analytical test methods and detection limits;
d. Name of analytical laboratory;
e. Laboratory quality control (include laboratory QA/QC
procedures in appendices)
f. Sample collection procedures and equipment;
g. Field quality control procedures:
* duplicates (10% of all field samples)
* blanks (field, equipment, etc.)
* equipment calibration and maintenance
* equipment decontamination
* sample containers
* sample preservation
* sample holding times (must be specified)
* sample packaging and shipment
* sample documentation (field notebooks, sample
labeling, etc);
h. Criteria for data acceptance and rejection; and
i. Schedule of monitoring frequency.
The Permittee/Respondent shall follow all EPA guidance
for sampling and analysis. The Implementing Agency may
request that the sampling and analysis section be a
separate document.
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10. O&M Contingency Procedures:
a. Procedures to address system breakdowns and
operational problems including a list of redundant
and emergency back-up equipment and procedures;
b. Should the interim measure suffer complete
failure, specify alternate procedures to prevent
release or threatened releases of hazardous
substances, pollutants or contaminants which may
endanger public health and/or the environment or
exceed cleanup standards; and
c. The O&M Plan must specify that, in the event of a
major breakdown and/or complete failure of the
interim measure (includes emergency situations),
the Permittee/Respondent will orally notify the
Implementing Agency within 24 hours of the event
and will notify the Implementing Agency in writing
within 72 hours of the event. The written
notification must, at a minimum, specify what
happened, what response action is being taken
and/or is planned, and any potential impacts on
human health and the environment.
11. Data Management and Documentation Requirements
Describe how analytical data and results will be
evaluated, documented and managed, including
development of an analytical database. State the
criteria that will be used by the project team to
review and determine the quality of data.
The O&M Plan shall specify that the Permittee/
Respondent collect and maintain the following
information:
a. Progress Report Information
* Work Accomplishments (e.g., performance levels
achieved, hours of treatment operation, treated
and/or excavated volumes, concentration of
contaminants in treated and/or excavated volumes,
nature and volume of wastes generated, etc.).
* Record of significant activities (e.g., sampling
events, inspections, problems encountered, action
taken to rectify problems, etc.).
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b. Monitoring and laboratory data;
c. Records of operating costs; and
d. Personnel, maintenance and inspection records.
The Implementing Agency may require that the Permittee/
Respondent submit additional reports that evaluate the
effectiveness of the interim measure in meeting the
stabilization goal.
C. IM Plans and Specifications
[Note - The decision to require the submittal of plans and
specifications should be based on the site specific
situation. The requirement for plans and specifications
should be balanced against the need to quickly implement
interim measures at a facility.]
The Permittee/Respondent shall prepare Plans and
Specifications for the interim measure that are based on the
conceptual design but include additional detail. The Plans
and Specifications shall be submitted to the Implementing
Agency simultaneously with the Operation and Maintenance
Plan. The design package must include drawings and
specifications needed to construct the interim measure.
Depending on the nature of the interim measure, many
different types of drawings and specifications may be
needed. Some of the elements that may be required are:
General Site Plans
Process Flow Diagrams
Mechanical Drawings
Electrical Drawings
Structural Drawings
Piping and Instrumentation Diagrams
Excavation and Earthwork Drawings
Equipment Lists
Site Preparation and Field Work Standards
Preliminary Specifications for Equipment and Material
General correlation between drawings and technical
specifications is a basic requirement of any set of working
construction plans and specifications. Before submitting
the project specifications to the Implementing Agency, the
Permittee/Respondent shall:
a. Proofread the specifications for accuracy and
consistency with the conceptual design; and
b. Coordinate and cross-check the specifications and
drawings.
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Appendix F
Summary of Important Geologic Information
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Summary of Important Geologic Information
Appropriate Collection Methods
Information Needed
Structural Features:
Purpose or Rationale
Primary
Secondary
Folds, faults
Joints, fractures.
interconnected voids
Determine natural flow barriers or Existing geologic maps, field
controls surveys
Predict major boundaries, avenues Existing geologic profiles, pump
of groundwatcr flow ' tests
Remote sensing, aerial
photography, geophysical
techniques
Borehole logging and mapping.
geophysical techniques (limited)
Stratigraphic Characteristics:
Thickness, aerial extent,
correlation of units: extent
(horizontal and vertical) of
aquifers and confining units
Mineral composition.
permeability and porosity,
grain-size, distribution, in
situ density, moisture
content
Determine geometry of aquifers
and confining layers, aquifer
recharge and discharge
Determine groundwater quality.
movement, occurrences.
productivity
Existing geologic maps,
observation wells
Laboratory analyses, existing
geologic literature
Borehole logging and mapping,
geophysical techniques (
Groundwater Occurrence:
Aquifer boundaries and
locations
Aquifer ability to transmit
water
Define flow uxnits and degree of
aquifer confinement
Existing literature, water resource Existing literature
Determine potential quantities and Pumping and injection tests of
rales for treatment options monitor wells
Borehole logging, regional water
level measurements
Groundwater Movement:
Direction of flow
Rale of flow
Identify most likely pathways of
contaminant migration
Determine maximum potential
migration rate and dispersion of
contaminates
Existing bydrologic literature
Existing hydrologic literature
Water level measurements in
monitor wells
Hydraulic gradient permeability.
and effective porosity from water
level contours, pump tesi results.
and laboratory analyses
Groundwater
Recharge/Discharge:
Location of
recharge/discharge areas
Rale
Determine interception points for
withdrawal options, areas or
capping
Existing site data, bydrologic
literature site inspection
Comparison of water levels in
observation wells, piezometers.
lakes, and streams
Groundwater Quality:
pH. total dissolved solids. Determine variability of loading to Existing literature
salinity, specific treatment options
contaminant concentrations
Determine exposure via Existing site data
groundwaier. define contaminant
plume for evaluation of
interception methods
Water balance calculations added
by geology and soil data
Analysis of groundwater samples
from observation wells.
geophysics
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Appendix G
Sources of Information on Human Health and Ecological Risk Assessments
149
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SOURCES OF INFORMATION ON HUMAN HEALTH AND ECOLOGICAL RISK
ASSESSMENTS
HUMAN HEALTH
• Integrated Risk Information System (IRIS)
• Resource, Conservation and Recovery Act (RCRA) - Statute - Amended by Hazardous
and Solid Waste Amendments (HSWA) of 1984
• Corrective Action for Solid Waste Management Units at Hazardous Waste
Management Facilities (Subpart S) [NOTE: Proposed Regulation - 55 FR S0798, July
24, 1990]
• RCRA Facility Investigation Guidance [Interim Final], (OSWER Directive 9502.00-
6D (4 vols.))
• Risk Assessment Guidance for Superfund, Volume 1, Human Health Evaluation
Manual (Part A) [Interim Final] (EPA/540/1-89/002, OSWER Publication 9285.7-
01A)
• Risk Assessment Guidance for Superfund, Volume 1, Human Health Evaluation
Manual (Part B) [Interim Final] (OSWER Publication 9285.7-01B)
• Risk Assessment Guidance for Superfund, Volume 1, Human Health Evaluation
Manual (Part C) [Interim Final] (OSWER Publication 9285.7-01C)
• Human Health Evaluation Manual, Supplemental Guidance: Standard Default
Exposure Factors [Interim Final] (OSWER Publication 9285.6-03)
• Superfund Exposure Assessment Manual (EPA/540/1-88/001)
• Exposure Factors Handbook (EPA/600/8-89/043)
• Health Effects Assessment Summary Tables Annual FY 1992 (HEAST) (OSWER
Publication 9200.6-303)
ECOLOGICAL
Resource, Conservation and Recovery Act (RCRA) - Statute - Amended by Hazardous
and Solid Waste Amendments (HSWA) of 1984
Corrective Action for Solid Waste Management Units at Hazardous Waste
Management Facilities (Subpart S) [NOTE: Proposed Regulation -55 FR 30798, July
23, 1990]
RCRA Facility Investigation Guidance [Interim Final], (OSWER Directive 9502.00-
6D (4 vols.))
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Risk Assessment Guidance for Superfund, Volume 2, Environmental Evaluation
Manual [Interim Final] (EPA/540/1-89/001)
Role of Acute Toxicity Bioassays Report in the Remedial Action Process at Hazardous
Waste Sites - Report
Summary of Ecological Risks, Assessment Methods, and Risk Management Decisions
in Superfund and RCRA - Report
Quantifying Effect in Ecological Site Assessments: Biological and Statistical
Considerations (EPA/600/D-90/152)
Ecological Assessment of Hazardous Waste Sites: A Field and Laboratory
Reference - Guidance - (EPA/600/3-89/013)
Summary Report on Issues in Ecological Risk Assessments - Report - (EPA/625/3-
91/018)
ECO Update: Ecological Assessment of Superfund Sites: An Overview, Volume 1,
Number 2 (OSWER Publication 9345.0-051)
ECO Update; The Role of BTAGS in Ecological Assessment, Volume 1, Number 1
(OSWER Publication 9345.0-051)
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United States
Environmental Protection Agency
(5502G)
Washington, DC 20460
Official Business
Penalty for Private Use
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