% UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
September 22, 2004
S EPA Headquarters Library
" Man cuae 3404T
i200 Pennsylvania Avenue NW
Washington, DC 20460 EMERGENCY
202-566-0550 RESPONSE
OFFICE OP
SOLID HASTE AND
EMERGENCY
OSWER 9200.3-31
MEMORANDUM
SUBJECT: Superfimd Environmental Indicators Guidance Manual
FROM: Michael B. Cook, Director /s/
Office of Superfund Remediation and Technology Innovation
TO: Superfund National Policy Managers, Regions I - X
Purpose
This memorandum transmits to regional and headquarters staff guidance on making
determinations for Superfund Environmental Indicators (Els). Environmental Indicators are data
measures that help document progress in protecting human health and the environment as a result
of Superfund cleanup activities.
Background
Historically, the Superfund program has focused on the completion of construction at
National Priorities List sites as a primary measure of cleanup progress. Doing so does not
recognize the incremental progress made toward safeguarding human health and the environment
that occurs during site clean up. The Office of Superfund Remediation and Technology
Innovation, which manages the Superfund Program, developed a way to more accurately
document and communicate environmental accomplishments at Superfund sites. This guidance
provides an overview of the Superfund Els, presents relevant definitions and data requirements,
and describes how Superfund El data are used to communicate cleanup progress. It also explains
the process of entering, extracting, and using Superfund El data from EPA's WasteLAN
database.
-------
Implementation
This document is intended primarily to assist those who are responsible for making
Superfund Environmental Indicator determinations. Depending on the region, this group
includes regional managers, data entry personnel, and/or site managers. Regions are required to
update El data in WasteLAN, at a minimum, once each fiscal year (no later than October 15th).
The Human Exposure, and Migration of Contaminated Ground Water Indicators should be
updated as site conditions change. The guidance presents detailed instructions on keeping El
data accurate, consistent, and up to date.
Please refer questions about the implementation of this guidance to Rich Norris at
norris.rich@epa.gov, (703) 603-9053. The guidance may also be found at:
http://www.epa.gov/superfund/accomp/ei/guidance.htm
Attachment
cc: OSRTI Managers
OSWER Office Directors
Susan Bromm, OSRE
Dave Kling, FFEO
Earl Salo, OGC
John Michaud, OGC
Eric Steinhaus, Superfund Lead Region Coordinator, USEPA Region 8
NARPM Co-Chairs
Joanna Gibson, OSRTI Documents Coordinator
-------
SUPERFUND ENVIRONMENTAL
INDICATORS
GUIDANCE MANUAL
OFFICE OF SLPERFUND REMEDIATION AND TECHNOLOGY INNOVATION
U.S. ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
SEPTEMBER 2004
-------
CONTENTS OF THE GUIDANCE
1.0 INTRODUCTION 1
2.0 ENVIRONMENTAL INDICATORS OVERVIEW 1
2.1 Background 1
2.2 Updating El Information 3
2.3 Coordination with the Resource Conservation and Recovery Act (RCRA) Program 3
2.4 Relationship of Interim Els to Final Remedies 4
2.5 Site-Specific Data and Environmental Indicators 4
2.6 Environmental Indicator Reports 7
3.0 POPULATIONS PROTECTED El 8
3.1 Data Reporting 8
3.2 Action Types 8
3.3 Populations Affected (Number of People Protected) 9
4.0 CLEANUP VOLUMES El 9
4.1 Data Reporting 9
4.2 Media Types 10
4.3 Cleanup Volumes 11
5.0 HUMAN EXPOSURE UNDER CONTROL El 11
5.1 Making the Human Exposure Determination 12
Superfund Human Exposures Controlled Worksheet 13
Summary Exposure Pathway Evaluation Table 16
5.2 Information Update and Reporting Requirements 17
5.3 Frequently Asked Questions - Human Exposure Under Control 19
6.0 MIGRATION OF CONTAMINATED GROUND WATER UNDER CONTROL El 26
6.1 Making the Migration of Contaminated Ground Water Under
Control Determination 26
Superrund Migration of Contaminated Ground Water Under Control Worksheet .... 27
6.2 Considering Monitored Natural Attenuation Remedies 31
6.3 Information Update and Reporting Requirements 31
6.4 Frequently Asked Questions - Migration of Contaminated Ground Water Under Control . 33
APPENDICES
Appendix A - El Data Entry/Viewing 1
Appendix B - Environmental Indicator Reports 14
-------
1.0 INTRODUCTION
This document is primarily intended to provide guidance regarding Superfund Environmental
Indicators (Els) for U.S. Environmental Protection Agency's (EPA's) Superfund personnel,
including Regional Superfund Managers and Remedial Project Managers. This document may
also be a useful resource for those interested in how Superfund El data are collected and how to
interpret Superfund El reporting. This guidance document provides an overview of the
Superfund Els, including definitions, data requirements, and descriptions of how Superfund El
data are used to communicate the progress of cleanups at Superfund sites. The Appendices to
this manual explain the process of entering, extracting, and using Superfund El data from
WasteLAN to monitor the results of cleanup actions and to communicate incremental progress to
the public.
In 1980, Congress passed the Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA), to clean up abandoned or uncontrolled hazardous waste sites.
CERCLA was amended in 1986 by the Superfund Amendments and Reauthorization Act
(SARA). EPA's primary response authority is found in Section 104 of CERCLA gives EPA the
authority to respond to the release or threat of release of a hazardous substance, pollutant, or
contaminant which may present a substantial risk to human health or the environment. EPA
began developing Els for the Superfund Program in the early 1990s to measure progress in
protecting human health and the environment.
2.0 ENVIRONMENTAL INDICATORS OVERVIEW
2.1 BACKGROUND
Past criticism of the Superfund program has focused on the relatively few sites that have been
deleted from the National Priorities List (NPL) following remediation. Since a site is not deleted
until all cleanup goals are achieved, this has provided a perception that little progress has been
made toward the cleanup of the Nation's hazardous waste sites since the Superfund program was
first authorized. Measuring the success of the Superfund program by the number of sites
removed from the NPL neglects the incremental progress made toward safeguarding public
health and the environment that occurs during site clean up. EPA developed three initial
program-based indicators to address this mispcrccption and to document and communicate
environmental progress towards cleaning up Superfund sites.
The three original Superfund El's were: Populations Protected; Progress Towards Permanent
Cleanup; and Cleanup Technologies Applied. Currently, two of these three program-based
indicators, Populations Protected and Cleanup Volumes (Formerly Cleanup Technologies
Applied), are being implemented. Progress Toward Permanent Cleanup was functionally
-1-
-------
replaced by the development of the construction completion category. Since the inception of the
Superfund El initiative, two additional indicators, Human Exposure Under Control (HE) and
Migration of Contaminated Ground Water Under Control (GM), have been developed to measure
the interim progress in meeting the Superfund goal to protect human health and the expectation
to return usable ground waters to their beneficial use. These Superfund Els are discussed more
fully in Sections 3.0 through 6.0 of this document. Additional indicators are under development
to measure progress in controlling long-term human exposures, protecting ecological resources,
and returning contaminated land to productive use.
All of Superfund's Environmental Indicators are designed to communicate the tangible progress
made in protecting human health and the environment through site cleanup activities. In the past,
OSRTI has used Superfund El data in Congressional testimony for Superfund reauthorization,
Government Performance and Results Act (GPRA) reporting, and budget requests to the Chief
Financial Officer. The Agency consistently requests Superfund El data from the Regions
because it is effective in reporting:
The number of people protected from immediate and long-term threats through the
provision of alternate water supplies, relocation of the affected population, and the
implementation of site security and institutional controls;
• The amount of contaminated media that has been treated, stabilized, or removed through
the use of treatment or containment technologies;
* The number of sites at which human exposure to contamination under current conditions
is under control; and
• The number of sites where the migration of contaminated ground water has been
contained within the existing area of contamination.
Subsections 2.2 - 2.7 below provide an overview of El reporting policies, definitions, and
indicator relational diagrams. Sections 3.0 - 7.0 provide indicator-specific guidance including
data requirements, instructions for data reporting, and guidelines used to make El determinations.
This guidance is intended to provide Superfund personnel with the information necessary to
capture the most current, complete El data available.
-2-
-------
2.2 UPDATING El INFORMATION
Beginning in FY 92, EPA Regions have been responsible for recording environmental progress
information directly in WasteLAN to make data collection more efficient and timely and to
standardize future reporting cycles. In FY 95 determinations for the three program-based Els
were first required to be reported. Detenninations for the new HE and GM Superfund Els were
first required to be reported in FY 2001. Please refer to Section 2.7 for a summary of
Environmental Indicator Reports in WasteLAN.
Many Environmental Indicator data points have been incorporated into the Superfund
Comprehensive Accomplishment Plan (SCAP). For further information, see Reporting
Requirements for Environmental Indicators in Appendix B of the Superfund /Oil Program
Implementation Manual Fiscal Year 2003/2004 (Publication 9200.3-14-1G-Q, April 7, 2003).
At a minimum, Regional personnel are required to update Environmental Indicator data in
WasteLAN once each fiscal year (by October 15th of each year). The HE and GM Indicators
should be updated as site conditions change.
2.3 COORDINATION WITH THE RESOURCE CONSERVATION AND RECOVERY ACT (RCRA)
PROGRAM
Following OSRTI's development of the initial three indicators, EPA's Office of Solid Waste
developed two indicators to measure interim progress in reducing current risks and controlling
migration of contaminated ground water at RCRA sites. The Senate Appropriations Committee
felt OSRTI would benefit from the development of Superfund Els "as in the RCRA corrective
action program."(Evaluation of Superfund Environmental Indicators, Report No. 2002-P-3,
December 27, 2001) Recognizing the benefits of comparability among indicators for similar
cleanup programs. OSRTI developed the HE and GM Superfimd indicators to be as consistent
with the RCRA indicators as possible, while incorporating the specific requirements of the
Superfund program and taking advantage of data sources unique to the Superfund program.
Where both RCRA and CERCLA authorities are being used to address different areas of the
same site, it is very important for the CERCLA and RCRA program managers to work together
to make a consistent determination for the site, since both of these indicators are site-wide
determinations. If both programs cannot make the determination that conditions meet the HE
indicator, then the site, as a whole, does not meet the criteria. Similarly, a single response for the
GM El should be reported by both programs. To facilitate this policy, when both programs are
evaluating Els at a site, the record of El determination should be signed by both program
managers in order to provide verification and greater credibility for the Els.
-3-
-------
2.4 RELATIONSHIP OF INTERIM EIS TO FINAL REMEDIES
While the HE and GM Superfund Els document interim progress in reaching final cleanup goals
at NPL sites, the fundamental goal of the program has not changed. The goal of Superfund
remedies is still to protect human health and the environment, maintain protection over time, and
to minimize untreated waste (NCP, Section 300.430(a)(l)(i)). The CERCLA program realizes
this goal at NPL sites by implementing final remedies to achieve cleanup goals specified in
Records of Decision. Progress in implementing these remedies and achieving cleanup goals is
measured by other program indicators (i.e. construction completions and site deletions). The
focus of these new indicators on interim progress in no way changes the goal of the remedial
process to provide remedies that are protective of human health, maintain protection over time,
and minimize untreated waste. Achieving the HE and GM Superfund Els will not substitute for
meeting final remedy requirements, expectations associated with sources of contamination, and
the need to restore, wherever practicable, contaminated ground water to beneficial use.
2.5 SITE-SPECIFIC DATA FOR ENVIRONMENTAL INDICATORS
The different Superfund El categories are described below.
The Site is the basic reporting unit for environmental progress.
Human Exposure Under Control indicates whether contamination levels at a site fall within the
levels specified by EPA as safe, or if they do not, whether adequate controls are in place to
prevent unacceptable human exposure to contamination.
Migration of Contaminated Ground Water Under Control indicates whether contamination
levels fall within the levels specified as safe by EPA, or if they do not, whether the migration of
contaminated ground water is stabilized, and mere is no currently unacceptable ground water
discharge to surface water.
Actions are the primary level of data below the site where media and subsequent Populations
Protected and Cleanup Volumes data reside. Actions for which El data are required include:
Removal (RV), PRP Removal (BB), FF Removal (LV), Remedial Action (RA), PRP RA (BF),
FF RA (LY), PRP Emergency Removal (PJ), and Initial Remedial Measure (IP).
The Media information category documents the contaminated materials addressed.
Population Protected indicates the number and type of people protected from risks to human
health through the provision of alternate water sources, or through temporary or permanent
relocation, or where site security measures have been implemented during both long and short-
term response actions.
Cleanup Volumes documents the amount of contaminated media that has been treated, stabilized,
contained, or removed through the use of risk management technologies, engineering techniques,
or institutional controls.
-4-
-------
The HE and GM indicators are site-wide determinations. The Populations Protected indicator is
reported at the action level, while the Cleanup Volumes indicator is reported on an action and
medium-specific basis.
-5-
-------
Exhibit 1 below shows how Regional data reported in WasteLAN support the action-level based
indicators. Detailed descriptions regarding the analysis and reporting of specific data elements
supporting each indicator appear in the sections following this introduction.
Exhibit 1: Crosswalk of Environmental Indicators to Reported Progress Information
Sites with Removal or Remedial Actions1
Populations Protected
Cleanup Volumes
Removal and Remedial actions that require El reporting include: Removals (RV); PRP Removals (BB); FF
Removals (LV); PRP Emergency Removals (PJ); Remedial Actions (RA); PRP RAs (BF); Federal Facility RAs
(LY); and Initial Remedial Measures (IP).
-6-
-------
2.6 ENVIRONMENTAL INDICATOR REPORTS
Environmental Indicator Reports were developed to assist the Regions with data entry to
facilitate National and site-specific report viewing. OSRTI refines the El reporting system by
noting any defects and enhancements that appear in the WasteLAN User Request System, as well
as through contact with EPA HQ and Regional personnel. The following tools are currently
available in WasteLAN to facilitate data entry and viewing:
PGMT-08 Environmental Indicators Audit Report
The audit report displays sites where there are incomplete or missing Environmental
Indicators data. It displays discrepancies in El data at the national, regional, state, or site-
specific levels. For example, an error code and description will be generated in the report
if a Populations Protected-specific action has been selected, but is not accompanied by
the number of people affected by that particular action. Please note: El legacy sites2 are
excluded from PGMT-08 reporting.
PGMT-09 Data Compilation Report
The Data Compilation Report is a summary of site data that can be used in conjunction
with the PGMT-08 report to ensure that all data for a site are entered completely and
accurately. This report displays the most recent information entered into WasteLAN and
is useful for the review of start and completion dates,
PGMT-10 Site Turnaround Report
The Site Turnaround Report lists key progress information for a specific site or for all
sites managed by a selected site manager. Progress information that populates this report
is obtained from pollution reports, contractor progress reports, sampling reports, field
logs, telephone logs, closeout reports, and other site reporting documents. The report is
intended to serve as a simple data entry guide for site managers, and as an effective
quality assurance record for confirming that El data are entered accurately into the
system.
PGMT-11 Environmental Indicators HE/GM Report
To prevent the PGMT-08 HI Audit Report from continually identifying volumetric data errors for sites
where cleanup activities are no longer occurring, a universe of El Legacy sites has been identified and excluded from
PGMT-08 audit reporting. El Legacy sites are defined as sites listed prior to 1995 that have no ongoing or planned
pipeline actions (action codes: RV, BB, PJ, LV, Rl , NA, NH , FS, NK., Ni, CO, BD, LW, RO, RD, BE, LX, RA,
BF, LY). Please note that the PGMT-08 El Audit Report identifies errors related to the Populations Protected and
Cleanup Volumes El data only. Missing data for these Legacy Sites arc reported in the PGMT-12 Environmenta!
Indicators HE/GM Error Report for the HE or GM Superfund Els.
-7-
-------
3.0
The El HE/GM report is a site-wide summary detail and Regional summary count of HE
and GM determinations and last Regional and Headquarters review dates. This report is
intended to be a quick reference guide for use by both Headquarters and the Regions.
PGMT-12 Environmental Indicators HE/GM Error Report
The HE/GM Error report displays a site summary of data gaps and potential reporting
errors for the HE and GM El's. Errors are reported for sites missing an HE or GM
determination or for sites with an HE or GM determination that differs from the approved
Headquarters determination.
PGMT-13 Environmental Indicators Summary Report
The PMGT-13 is a quick reference cumulative summary of all El data. This report
includes NPL and non-NPL totals of solid waste (hazardous soil, solid waste and
sediment) and liquid waste (hazardous liquid waste, ground water, and surface water), the
number of people provided alternative drinking water, and the number of people either
temporarily or permanently relocated and the number of people returned, to addition, the
report provides totals of HE and GM totals by determination type.
POPULATIONS PROTECTED El
The Populations Protected Superfund El was developed to measure the progress made in
protecting individuals living at or near Superfund sites from immediate threats of exposure to
contaminated media. Specifically, this El measures the number individuals protected through the
provision of alternate drinking water supplies or relocation in response to contamination.
3.1 DATA REPORTING
Certain removal and remedial actions trigger the need to enter Populations Protected El data.
The Populations Protected El provides a means for describing the types of actions used to protect
people living at or near Superfund sites.
3.2 ACTION TYPES
In general, Populations Protected El data should be reported by the Regions when a removal or
remedial action at an NPL or non-NPL site provides for:
• Alternate sources of drinking water, either temporarily or permanently;
Reinstatement of drinking water supply following provision of temporary supply;
* Relocation, either permanently or temporarily; or
* Return of population following temporary relocation.
-8-
-------
When a removal or remedial action is conducted, the action and the following details describing
the action should be reported:
• The date the population was either relocated or provided alternative drinking water;
• The level at which the population was relocated or provided alternative drinking water
(temporarily, permanently, or returned/reinstated); and
The number of people relocated or provided alternative drinking water.
To obtain the most accurate description of site activity, designate as many actions as necessary to
characterize how people were protected from immediate and long-term threats posed by site
contamination. Data related to this indicator can typically be found by reviewing RODs, Action
Memoranda, pollution reports (POLREPS), Remedial Action Reports, and Close Out Reports.
3.3 POPULATIONS AFFECTED (NUMBER OF PEOPLE PROTECTED)
Report the number of people who were provided alternate water supply or were relocated either
temporarily or permanently, hi addition, the population whose water supply has been reinstated
or a population who has been returned from relocation should also be recorded. If the population
in the site records is listed as number of homes or residences and not the actual number of people
relocated, use Census statistics (http://www.census.goy/) for county-level data on average
number of people per household and multiply by the number of households to obtain a good
estimate of the number of people protected. For a quick estimate, the Year 2000 US Census
estimates that there were an average of 2.69 people per owner-occupied household and 2.40
people per renter-occupied household. Finally, round the estimate to the nearest whole number,
as there are no fractions of people.
See Appendix B for detailed data entry instructions.
4.0 CLEANUP VOLUMES El
The CleanupVolumes Indicator was developed to measure the amount of contaminated media
that has been treated, stabilized, contained, or removed through the use of risk management
technologies, engineering techniques, or institutional controls.
4.1 DATA REPORTING
For this indicator, report the following information for NPL and non-NPL sites:
Date that the quantity of contaminated media were addressed;
Media addressed by a removal or remedial action.
• Quantity of contaminated media addressed by each removal or remedial action reported in
WasteLAN.
-9-
-------
Often, a single medium may be addressed by multiple actions. If that is the case, multiple entries
may exist for a single medium. To assist in data entry and reporting, media associated with
different actions can be named accordingly in the SCAP or Remedy Selection screens (e.g. Soil
01 and Soil 02). Data associated with this indicator can be found in RODs, Action Memoranda,
POLREPS, Interim RA Reports, Final RA Reports, and Close Out Reports.
4.2 MEDIA TYPES
Media types are carried over to the Add/Edit El screen from other areas in WasteLAN, such as
the Remedy Selection or SCAP-Selected Remedy Screens. If a medium is not present for a
volume to be entered, it will be necessary to add that medium on the Add/Edit Media screen via
the SCAP or Remedy selection screens as mentioned in Section 4.1. Once the medium has been
entered, it will be available on the Cleanup Volume tab in the Add/Edit El module for entry
along with its corresponding volume. Use the following descriptions as a guide to assist in
reporting the types of contaminated media that have been addressed:
Air: Gases from processes such as landfilling or thermal treatment.
• Debris: Large solid waste, such as machinery, buildings, and tanks.
• Ground water: Water in the ground, both shallow and deep aquifers.
• Leachate: Rainwater, surface water, or ground water filtered through a landfill.
* Liquid waste: Waste such as acid contained in tanks, drums, lagoons, or ponds.
• Residuals: Waste remaining after treatment, such as incinerator ash.
• Sediment: Solids settled out of surface water or dredged material.
• Sludge: Solids settled out of a liquid, for example following wastewater treatment.
• Soil: Soil not distinguished as surface or subsurface.
• Solid waste: Discarded material such as garbage, refuse, tars, and contained gaseous
materials but excluding for WasteLAN purposes debris, liquid waste, and sludge.
• Subsurface soil: Generally, soil below surface soil and at a depth of 2 feet and below.
• Surface soil: Generally, the top 2 feet of soil, but may be deeper depending on site-
specific conditions and exposures.
• Surface water: Water open to the air, such as wetlands, lakes, streams, ponds, and
overland surface flow.
43 CLEAN UP VOLUMES
Record in WasteLAN the volumes of contaminated media that have been addressed. The current
Add/Edit El screen, allows for the entry of incremental volumetric data. It is important to add a
-10-
-------
new cleanup date and corresponding volume each time a new volume of waste has been
addressed. For example, if 200 cubic yards (cu yd) of solid waste were reported as previously
treated, and an additional 100 cu yd are currently being treated, a new separate entry of 100 cu yd
of solid waste should be created along with the cleanup date. Cumulative totals by media can be
viewed on the Add/Edit El Summary tab.
Cleanup volumes can be entered for non-standard units available in the drop-down list (cubic
feet, drums, liters, tons, pounds cubic meters, tanks, cylinders, and battery casings). Once
selected, these non-standard units will convert to standard units of gallons for liquid-based waste
and cubic yards for solid-based waste. Appendix B provides detailed data entry instructions for
Cleanup Volumes.
5.0 HUMAN EXPOSURE UNDER CONTROL El
The HE Indicator documents whether contamination is below protective, risk-based levels or, if
not, whether adequate controls are in place to prevent human exposure to contamination based on
current land and ground water use conditions at NPL sites. A positive determination of "human
exposure under control" indicates that all information on known contaminants to soil, ground
water, surface water, sediments, and air have been reviewed and the following conditions are met
at the site:
• No ground water, soil, surface water, sediment or air media are known or suspected to be
contaminated above appropriately protective levels; or
• If one or more media is know or suspected to be "contaminated" above protective levels,
actual or potential human exposure is not expected or is within acceptable limits under
current land and ground water use conditions.
The data for this El can first be reported when the site is proposed to be listed on the NPL.
-11-
-------
5.1 MAKING THE HUMAN EXPOSURE UNDER CONTROL DETERMINATION
The following guidelines should be observed when making the HE determination:
• The determination is made on a site-wide basis looking at all media across the entire site.
• The determination must be made with "reasonable certainty" (i.e., based on the most
current data for the site). Documents such as risk assessments, RODs, Action
Memoranda, POLREPS, Five-year Reviews, and Close Out Reports are good sources of
data and often provide the information necessary for making a determination with
reasonable certainty. The determination can be revised as new information becomes
available.
• The determination is intended to be a realistic, risk-based evaluation based on actual
current land and ground water use. The determination should not consider hypothetical
human exposures, but rather exposure that would be expected under current use.
Similarly, current land and ground water use should be considered, but exposures that
would occur under reasonably anticipated future land or ground water use are not
considered for this indicator.
Use the step-by-step process and worksheet on the following pages to make a determination of
"Yes", "No", or "Insufficient Data" for the HE EL The worksheet was developed in cooperation
with representatives from all ten Regions, and was designed to assist project managers in making
the most accurate El determination possible.
-12-
-------
Superfimd Human Exposure Under Control Worksheet
ay ancBCpfrlflBlmKiiBi gcpmtin! icate cirigt IroA. KIM! Kipuncvcutw- IBP tonctifanit ndy. Tint gnad
«•!*:'» »«i5(»«n'*;
mnauitton" m£ lumaa iwvptoo roch tttat a^cmm
1- nod tn»Ddirator-aK) ocnditraa?
-—
1 .irt Kttt fl«frntiM! DtwuraruL-
jy«
Slq)4. A»ltopctOTt>rfraTOTurc»ft Make Ddenntlutkn
NO. Sins Dow N« Mw. Deflttitlon
-13-
-------
Detailed instructions for completing the worksheet and determining the appropriate response to
enter into WasteLAN are as follows.
• (Step 1) Based on the most current data for the site, have all available
relevant/significant information on known contaminants to soil, ground water, surface
water/sediments, and air at the NPL site been considered in this El determination?
If no, re-evaluate existing data.
If data are unavailable or are insufficient to make this determination, select
"Insufficient Data" in WasteLAN.
If yes, proceed to Step 2.
Tips for completing rationale:
"Current data for the site " are those that describe conditions that are known or
suspected at the time the El determination is made.
Review and consider only that information that is pertinent to the evaluation of
human exposure. Consider all available sources, even if you decide to base the
indicator determination on one source or a subset of sources.
Note: For additional guidance, please see Section 5.3 for a compilation of frequently
asked questions that may assist in making the HE determination.
• (Step 2) Are ground water, soil, surface water, sediments, or air media known or
reasonably suspected to be "contaminated" above appropriately protective risk-based
"levels" (applicable promulgated standards, as well as other appropriate standards,
guidelines, guidance, or criteria) from known contaminants?
If no, site meets definition of HE. Select "No" in WasteLAN.
If yes, proceed to Step 3.
If insufficient data are available to make this determination, select "Insufficient
Data" in WasteLAN.
Tips for completing rationale:
"Contaminated" refers to concentrations of contaminants that exceed
appropriately protective risk-based levels such as chemical-specific Applicable or
Relevant and Appropriate Requirements (ARARs) or health-based levels
developed in a risk assessment or Record of Decision.
-14-
-------
Contaminated media include indoor air contaminated via vapor intrusion from a
source of volatile contaminants beneath the structure. Contaminated media also
include contaminated fish, shellfish, and other edible plants and animals
associated with the site.
If a medium contains no contaminants at concentrations above risk-based levels,
do not consider the medium in Steps 3 and 4.
(Step 3) Are there complete pathways between "contamination" and human receptors
such that exposures can be reasonably expected under the current (land- and ground
water-use) conditions?
If no, site meets definition of HE. Select "No" in WasteLAN.
If yes, proceed to Step 4.
If insufficient data are available to make this determination, select "Insufficient
Data" in WasteLAN.
Tips for completing rationale:
Use the table below and modify as needed to identify potential exposure
pathways. Consider indirect and direct exposure pathways, including indoor air
contaminated via vapor intrusion and exposure to contaminated food (e.g., fish,
shellfish, dairy, edible plants).
Consider the exposure scenarios being evaluated for risk management decisions
for the site. Note that some exposure pathways evaluated in the baseline risk
assessment may be identified as "incomplete " in this El determination if the
pathway was eliminated using institutional or engineering controls.
Consider not only the presence of controls intended to eliminate exposure
potential but also their effectiveness. Answer "yes " only where controls are
known to be effective.
The ground water exposure pathway is considered complete if an uncontained
contaminated ground water plume is migrating toward a drinking water supply
and contaminant concentrations are expected to reach unacceptable levels within
a year in the absence of response actions.
If a potential pathway is not complete, do not consider the pathway in Step 4.
-15-
-------
Summary Exposure Pathway Evaluation Table:
Potential Human Receptors (Under Current Commons)
Contaminated Media Residents Workers Day Care Construction Trespassers Recreation Food
Air (indoors)
Soil (surface
a 9 , < 2 It)
Sediment
Soil (substrtace
Note: In order to focus the evaluation on the most probable combinations, some potential
"Contaminated" Media - Human Receptor combinations (Pathways) do not have spaces
for check marks. While these combinations are not likely in most situations, they may be
appropriate in some settings and should be added as necessary.
-16-
-------
• (Step 4) Are the potential exposures from Step 3 within acceptable limits under current
(land and ground water use) conditions (e.g., within the cancer risk range or HI less than
or equal to 1)?
If no, site does not meet definition of HE. Select "No" in WasteLAN.
If yes, site meets definition of HE. Select "Yes" in WasteLAN.
If insufficient data are available to make this determination, select "Insufficient
Data" in WasteLAN.
Tips for completing rationale:
Refer to the summary of site risks section in the ROD if available. Note that if the
exposures driving the remedy are based on future land or ground water use only,
and future use conditions are different than current, it may be necessary to review
the RI to obtain data on current risks.
The definition of "acceptable limits," risk (e.g., cumulative or single substance),
exposure assumptions, etc. should be the same as those being used to make risk
management decisions for the site. Examples of "acceptable limits " are the
cancer risk range and HI< I.
Refer to Close-Out Report, if available, for documentation of whether the
remedial action (RA) achieved the cleanup goals to reduce risks from the site.
5.2 Information Update and Reporting Requirements
Complete the HE El worksheet in WasteLAN after a site is listed as Final on the NPL (data can
first be entered when the site is Proposed), and update the HE El as soon as a change in the
determination is warranted. At a minimum, data updates are required by October 15 of each
year, or as required in the current year SPIM, to reflect the status at each site as of the end of the
prior fiscal year.
Changes in El Status
A new worksheet is required whenever the El status changes. It is recommended that a copy of
the worksheet also be kept with official site files. Submit the new worksheet to OSRTI, and
update WasteLAN within 30 days of knowing that the El status has changed.
No Change in El Status
If there is no change in the status of the HE El, update the "Last Review Date" in WasteLAN for
the appropriate indicator on the Site Characterization Screen.
-17-
-------
New Listings on the NPL
For sites that are placed on the NPL after FY 2002, complete and submit a worksheet to OSRTI
and update WasteLAN within one year of NPL site listing as Final.
Detailed data entry instructions for assigning a site determination in WasteLAN are discussed in
Appendix B.
-18-
-------
5.3 FREQUENTLY ASKED QUESTIONS - HUMAN EXPOSURE UNDER CONTROL
Step I : Based on the most current data for the site, has all available information on media contamination been
considered in this El determination?
Question
1-1
1-2
1-3
1-4
1-5
1-6
1-7
What are the best sources of information for
me to consider for this El determination?
There may be several different sources of
information (e.g., State, EPA, PRP). Do I
need to review all of this information to
answer "yes." to this question'.'
Volumes of data may be available for a site.
I've got other priorities. Do 1 need to review
all of this information to answer "yes" to this
question?
What if a PRP has drawn different
conclusions than EPA regarding the status of
the HE? Do 1 need to consider the PRP's
data?
What if 1 am aware of information that
another Agency or a PRP has collected but
cannot obtain a copy of it? Should 1 answer
"no?"
We have yet to start the Rl, and there is little
information available regarding exposure
pathways. How should 1 answer this
question?
How is a "no" answer for Step 1 recorded in
WastcLAN?
Answer
Documents such as RI/FS reports, RODs. Action
Memoranda, POLREPS, Close Out Reports, Five-Year
Reviews, etc. are good sources of information.
You need to review and consider only that information
that is: 1) pertinent to evaluation of human exposure;
and 2) available to you. If the information from other
sources is both relevant and available to you, it should
be reviewed and considered when making this
determination.
You need to review and consider only that information
that is pertinent to evaluation of human exposure.
Focus your lime on existing data or reports that address
human health risk. This indicator does not require that
you perform any new analyses but, rather, that you
reflect analyses that have already been done.
Yes. To answer "yes" under Step 1 , you need to
consider the PRP data that is available to you. When
answering the questions in Steps 2 through 4, you can
decide what weight to place on the PRP's conclusions.
No. This step assures that you have considered that
information that is available to you. If the information
is riot avail able for your review and consideration, you
can still answer "yes" to this question.
If data are unavailable or insufficient to make the Hfi
El determination, answer "data incomplete" and select
"Insufficient Data" in WasteLAN.
You must answer either "yes" or "data unavailable" in
Step 1. If you answer "no," re-evaluate the available
data to make a determination for this El.
-19-
-------
Step 2: Are ground water, soil, surface water, sediments, or air media known or reasonably suspected to be
"contaminated" above appropriately protective risk-based "levels" (applicable promulgated standards, as well as
other appropriate standards, guidelines, guidance, or criteria) from known contaminants?
Question
Answer
2-1
Where can 1 find the information to answer
this question?
Documents such as Rl/FS reports, RODs, Action
Memoranda, POLREPS, Close Out Reports, Five-Year
Reviews, etc. are good sources of information.
2-2
Actions have reduced contamination in the
contaminated medium of greatest concern
(e.g., ground water) to below risk-based
levels. Should 1 answer "no" to this question
(i.e., media is not contaminated above risk-
based levels)?
Only if this medium (e.g., ground water) was the only
contaminated medium. The indicator reflects a site-
wide determination, so contamination in all media must
be below appropriately protective risk-based levels to
answer "no" in Step 2.
2-3
Activities to date have focused on the most
significantly contaminated medium (e.g., soil)
and have reduced contamination to below
risk-based levels. There is a possibility that
another medium (e.g., sediment) is
contaminated but we have yet to assess this.
Should we count this as "reasonably
suspected?"
In the absence of sampling and analytical data, you will
need to use your best judgment. If the conceptual site
model indicates that there is a reasonable possibility of
contamination in the medium yet to be investigated
(e.g., sediment), you should answer either "yes" or
"insufficient data." The El requires that you make your
determination with "reasonable certainty."
2-4
How do 1 answer this question if some
contaminant levels are below their respective
risk-based levels and others are above?
If the concentration of any contaminant in a medium of
concern exceeds its appropriately protective risk-based
level, answer "yes" "to this question.
2-5
Does a single "hit" of contamination mean
that 1 should answer "yes" to this question or
should 1 use average, UCL on the mean, or
another type of concentration when answering
this question?
Base your determination on the information and
approach being used for risk-based decisions at the
site. If you are in the early stages of the investigation,
with limited data, a single hit may be enough to make a
"yes" determination if multiple lines of evidence
corroborate this conclusion. If you are at a later stage
and the UCL is being used as the exposure point
concentration, use this to answer this question.
2-6
Concentrations of all of the contaminants in
the medium of concern for which 1 have risk-
based levels are below those levels. For the
remaining contaminants, 1 do not have risk-
based levels and plan to develop them at a
later date. How do 1 answer this question?
In the interest of providing as accurate a program
measure as passible, please skip this Step (i.e., answer
"yes") and base your determination on Steps 3 and 4.
Alternatively, you could answer "insufficient data."
2-7
Should 1 always use MCLs as basis for
answering this question for ground water?
Only if the aquifer is currently being used as a drinking
water supply and: 1) contaminated wells are being
used; or 2) the plume is not contained and is likely to
reach drinking water wells within a year unless actions
are taken.
-20-
-------
Step 2: Arc ground water, soil, surface water, sediments, or air media known or reasonably suspected to be
"contaminated" above appropriately protective risk-based "levels" (applicable promulgated standards, as well as
other appropriate standards, guidelines, guidance, or criteria) from known contaminants?
Question
2-8
2-9
2-10
2-11
How should I answer this question if the
contaminant levels are above PRGs but below
final cleanup levels?
What should I use as the "risk-based levels" if
all of the final cleanup levels in the ROD are
based on future land or ground water use
conditions that are different than current use
conditions?
What should 1 do if the risk-based levels that 1
used to answer this question change as we
learn mure about the site?
What should 1 do if the COCs in a medium
change or contaminant concentrations arc re-
evaluated as we learn more about the site?
Answer
Use the risk-based levels that are consistent with the
most recent stage of the response action. In this case,
assuming that they are appropriate for current
exposures, use the final cleanup levels.
If the cleanup levels were developed during the FS for
both current and future conditions, use the levels that
would apply under current use conditions. In the
absence of this, use other risk-based levels (e.g., PRGs,
SSl.s) that are appropriate based on current conditions.
If none of these are available or appropriate, please
skip this Step (i.e., answer "yes") and base your
determination on Steps 3 and 4 (preferred) or answer
"insufficient data." The El requires that you make your
determination with "reasonable certainty."
If risk-based levels change, consider whether the
change would effect the HE El determination for the
site. If so, update the El determination to reflect the
new information.
If COCs in the medium change or contaminant
concentrations are re-evaluated based on new data,
consider whether the change would effect the HE El
delermination for the site. If so, update the El
determination to reflect the new information.
-21-
-------
Step 3: Are there complete pathways between "contamination" and human receptors such that exposures can be
reasonably expected under the current (land- and ground water-use) conditions?
Question
Answer
3-1
Where can 1 find the information to answer
this question?
Documents such as Rl/FS reports, RODs, Action
Memoranda, POLREPS, Close Out Reports, Five-Year
Reviews, etc. are good sources of information.
3-2
How do 1 answer this question if the only
complete exposure pathways exist for media
in which none of the contaminants exist above
appropriately protective risk-based levels?
Answer "no." The questions in Steps 2 and 3 (and 4)
are related by medium. Only those media identified as
"contaminated" above appropriately protective risk-
based levels under Step 2 should be considered in
Step 3.
3-3
Actions have been taken to eliminate exposure
to the contaminated medium of primary
concern (e.g., ground water) based on current
conditions. Should I answer "no" to this
question (i.e., human exposures are not
reasonably expected under current
conditions)?
If this is the only medium in which contaminants exist
above appropriately protective risk-based levels,
answer "no." This El reflects a site-wide
determination. If complete exposure pathways exist for
other media that are contaminated above risk-based
levels, answer "yes."
3-4
Activities to date have focused on the most
significantly contaminated medium (e.g., soil)
and have eliminated all exposure pathways
associated with this medium based on current
conditions. There is a possibility that another
contaminated medium (e.g., sediment) poses a
risk. Should 1 include this in the
determination?
In the absence of a complete exposure assessment, you
will need to use your best judgment. If the conceptual
site model indicates that there is a reasonable
expectation of exposure to a medium for which an
exposure assessment has yet to be completed (e.g.,
sediment), you should answer either "yes" or
"insufficient data." The El requires that you make your
determination with "reasonable certainty."
3-5
Should 1 consider the indoor air inhalation
pathway (associated with vapor intrusion) and
food chain exposure pathway when answering
this question?
Consider all exposure pathways of concern identified
in the baseline risk assessment. If these pathways are
pathways of concern, they should be considered in your
answer. If an exposure assessment has yet to be
completed, use your best judgment and make your
determination with reasonable certainty.
3-6
If the only complete exposure pathway for the
entire site (all media) is for the "trespasser"
scenario, should 1 still answer "yes" to this
question?
If exposure to a contaminated medium (i.e., medium
contaminated above risk-based levels) can be
reasonably expected under any current exposure
scenario, answer "yes" under Step 3.
3-7
At present, no drinking water wells have been
impacted by contaminated ground water, but
the wells could be impacted in the near
future? Should we answer "no" now and
change our response to "yes" if and when the
plume reaches the wells?
If the plume is not contained and is migrating such that
it is likely to reach drinking water wells within a year
unless actions are taken, answer "yes."
-22-
-------
Step 3: Are there complete pathways between "contamination" and human receptors such that exposures can be
reasonably expected under the current (land- and ground water-use) conditions?
Question
3-8
3-9
3-10
The exposure scenarios driving the remedy, as
presented in the ROD, are based on future
land or ground water use conditions that are
different than current use conditions. Should 1
base this El determination on current use
scenarios that arc not driving the remedy.
A fishing advisory is in place to eliminate
exposure to contaminated fish. Should 1
answer "no" to this question if this was the
only remaining complete pathway prior to this
action?
What should 1 do if new complete exposure
pathways are identified or complete exposure
pathways are eliminated due to response
actions or a better understanding of the site?
Answer
Yes. Use the exposure scenarios that consider current
use, as developed in the baseline risk assessment, to
make this determination.
Only if you are reasonably certain that the fishing
advisory is effective. This determination requires that
you consider not only the presence of controls intended
to eliminate exposure potential, but also their
effectiveness. If evidence suggests that some people
are catching and eating fish despite the advisory, this
remains a complete pathway, and you should answer
"yes."
If exposure pathway information changes based on new
data, consider whether the change would effect the HE
l£l determination for the site. If so, update the El
determination to reflect the new information.
-23-
-------
Step 4: Are the potential exposures from Step 3 within the acceptable limits under current (land and ground water
use) conditions (e.g., within the cancer risk range or HI-1)?
Question
Answer
4-1
Where can 1 find the information to answer
this question?
Documents such as Rl/FS reports, RODs, Action
Memoranda, POLREPS, Close Out Reports, Five-Year
Reviews, etc. are good sources of information.
4-2
Actions have been taken to reduce potential
exposures to the contaminated medium of
primary concern (e.g., ground water) to within
acceptable limits under current conditions.
Should 1 answer "yes" to this question (i.e.,
potential exposures are within acceptable
limits)?
Only if this was the only medium for which exposures
above acceptable limits exist. The indicator reflects a
site-wide determination, so exposures via all media
must be within acceptable limits to answer "yes" in
Step 4.
4-3
Activities to date have focused on the most
significantly contaminated medium (e.g., soil)
and have reduced potential exposures
assoc iated w ith this medium to within
acceptable limits based on current conditions.
There is a possibility that another
contaminated medium (e.g., sediment) poses a
risk. Should I include this in the
determination?
In the absence of a completed risk assessment, you will
need to use your best judgment. If the conceptual site
model indicates that potential exposures to a
contaminated medium for which risk has yet to be
characterized (sediment) could represent an
unacceptable risk, you should answer either "yes" or
"insufficient data." The El requires that you make your
determination with "reasonable certainty."
4-4
We have yet to complete a baseline risk
assessment for the site; however, some
contaminant concentrations exceed
appropriately protective risk-based levels in
media for which complete pathways are
reasonably expected under current conditions.
Can 1 answer this question without a risk
assessment?
In the absence of a completed risk assessment, base
your determination on the best available information.
If the medium is contaminated above the risk-based
levels that have been identified at this stage of the
assessment and complete exposure pathways are
reasonably expected, you could answer "yes"or
"insufficient data," based on your knowledge of the site
and best judgment.
4-5
What risk "limits" should be used to make this
determination? Should we use 10"6 or
10"* excess lifetime cancer risk?
Base your determination on the risk limits being used
for risk-based decisions at the site. For sites with a
ROD, use the risk value used to establish cleanup
levels. If a ROD has not been signed, use the protocol
typically applied in the Region forpre-ROD sites (e.g.,
use state ARARs, NCP risk range, etc.). If the
appropriate risk limit is uncertain, answer "insufficient
information."
4-6
How do 1 answer this question if the risks
from exposure to some contaminants are
above acceptable limits and others are within
acceptable limits?
If the potential exposures to any contaminant represent
an unacceptable risk, answer "no" to this question.
-24-
-------
Step 4: Are the potential exposures from Step 3 within the acceptable limits under current (land and ground water
use) conditions (e.g., within the cancer risk range or Hl = l)?
Question
Answer
4-7
The potential exposures to individual
contaminants are within acceptable limits
under current conditions; however, cumulative
risks under current conditions are above
acceptable limits. Should 1 use single
contaminant or cumulative risk as the basis for
this determination?
Base your determination on the approach being used
for risk-based decisions at the site. For example, if
remedial actions to address current exposures are being
driven by an assessment of cumulative risk, base your
determination on the cumulative effects of exposure to
multiple strcssors.
4-8
The risks resulting from potential exposures
vary depending on the exposure assumptions
and the approach used to estimate the
exposure point concentrations. What
approach should be used to assess the risk
from potential exposures to make this El
determination?
Base your determination on the approach being used
for risk-based decisions al the site. Use the same
exposure assumptions and approach to determining
exposure point concentrations as are used in the risk
assessment for the site - do not create any new
information in order to answer this question. Note that
the exposure scenarios considered in this step may be
different than those considered in the baseline risk
assessment, for example, if a pathway was eliminated
in Step 3 due to the presence of effective ICs (which
are not considered in the baseline risk assessment).
4-9
If the only unacceptable potential exposures
for the entire site (all media) are associated
with the "trespasser" scenario, should I still
answer "no" to this question?
Yes. If potential exposures are not within acceptable
limits for any scenario, based on current conditions,
answer "no" under Step 4.
4-10
At present, contamination in drinking water
wells does not present an unacceptable risk,
but contaminant concentrations could be
rising. Should 1 answer "yes" now and
change the response to "no" if and when the
contaminant concentrations reach a level such
that exposure would represent an
unacceptable risk'.1
If the plume is not contained and is migrating such that
contaminant concentrations are expected to reach
unacceptable levels within a year unless actions are
taken, answer "no."
4-11
The exposure scenarios driving the remedy, as
presented in the ROD, are based on future
land or ground water use conditions that are
different than current use conditions. Should 1
base this El determination on current use
scenarios that are not driving the remedy?
Yes. Use the exposure scenarios that consider current
use, as developed in the baseline risk assessment, to
make this determination.
4-12
What should 1 do if the degree of risk from
potential exposures based on current
conditions is re-evaluated as we gain a belter
understanding of the site?
If the degree of risk is re-evaluated based on new data,
consider whether the change would effect the HE El
determination for the site. If so, update the El
determination to reflect the new information.
-25-
-------
6.0 MIGRATION OF CONTAMINATED GROUND WATER UNDER CONTROL El
The GM El documents whether contamination is below protective, risk-based levels or, if not,
whether the migration of contaminated ground water is stabilized and there is no unacceptable
discharge to surface water and monitoring will be conducted to confirm that affected ground
water remains in the original area of contamination. This indicator is limited to NPL sites with
known or reasonably suspected ground water contamination above appropriately protective risk-
based levels.
A positive determination of "migration of contaminated ground water under control" indicates
that all information on known and reasonably expected ground water contamination has been
reviewed and the above conditions are met.
6.1 MAKING THE MIGRATION OF CONTAMINATED GROUND WATER UNDER CONTROL
DETERMINATION
Observe the following guidelines when making the GM determination:
• This determination needs to be made only for those sites with past or present ground
water contamination. It is necessary to capture data for sites where ground water was
previously contaminated but has been cleaned up to ensure that the indicator accurately
records program progress.
This determination is made on a site-wide basis, looking at distinct plumes across the
entire site.
The determination must be made with "reasonable certainty" (i.e., based on the most
current data for the site). Documents such as RODs, Action Memoranda, POLREPS,
Five-year Reviews, periodic ground water and surface water monitoring reports, and
Close Out Reports are good sources of data and often provide the information necessary
in making a determination with reasonable certainty. As new data become available, the
determination can be revised.
• The determination is based on the existing plume boundary (not property boundary or
projected exposure point).
• Ongoing monitoring is required to document both stabilization of migration and the status
of impacts to surface water by contamination.
Limited migration is permissible if it is part of a formal natural attenuation remedy.
Use the step-by-step process and worksheet on the following pages to make a determination of
"Yes", "No", or "Insufficient Data" for the GM El.
-26-
-------
Superfund Migration of Contaminated
Ground Water Under Control Worksheet
UftMOaiK
Heyac:
„ nm»
JMt
XEEflUiniACfl^
Qda
D4ffl
EiuuOkflCd
D«t
Step 1 . fiascd on 'he TOW wire* ietB on *c sra, hn »n awlnblc n^v«niml{iiWair.t biftira«*w on
fcwwB wd nuonibiy su^»c«ed nin« to Q» sround witot bflttt coos&Bcd in th!« H i«*icain»aoaJ
List Site RcfeKOKDonmcnl;
JW*K*« riak-taawi -lfp)lD»fck> psoaipual ttmdndi, u wdJuofbKappi^iiitoKiiailiitd),
fi^cioct, oraiiEriB)« • KMdt oftnbae torn *>c«te?
LutSissRefewiwIto.
j^:
Step 3.
1» ojsrtid to Rouin wtlfain "nbttag «:«• ofoootrndnstod grouad wiuO " (fcBned hytasmeotodag
deaJgnatol st lie lime ttf Jil» itetacffltastoK?
Explain Ultimate:_
yfcs
*x»ptoi>ls" a Jls»«a, or eotuwtetm
Lot Sit. Retain* DocnajnK
« waetw?) he coaeessd ia flus (Watt 6> rooty iSttJ orattninzto
'ofo
riut remwoed witbto
Lnt Site Refensecc DocaaMnl;
Ko
.Definition
No
Jit)
Nb
n*sirsnciE*ri>ArA,
+
YES.S.W Dow MwdMBiiikn
NO,SteEWMSot
-27-
-------
Detailed instructions for completing the worksheet and determining the appropriate response to
enter into WasteLAN are as follows:
• (Step 1) Based on the most current site data, has all available relevant/significant
information on known and reasonably suspected releases to the ground water been
considered in this El determination?
If no, re-evaluate existing data.
If data are unavailable or are insufficient to make this determination, select
"Insufficient Data" in WasteLAN.
If yes, proceed to Step 2.
Tips for completing rationale:
"Current data for the site " are those that describe conditions that are known or
suspected at the time the El determination is made.
Review and consider only that information that is pertinent to the evaluation of
contaminated ground water migration. Consider all available sources, even if
you decide to base the indicator determination on one source or a subset of
sources.
• (Step 2) Is ground water known or reasonably suspected to be "contaminated" above
appropriately protective risk-based "levels" (applicable promulgated standards, as well as
other appropriate standards, guidelines, or criteria)?
If no, site meets definition of GM. Select "No" in WasteLAN.
If yes, proceed to Step 3.
If insufficient data are available, select "Insufficient Data" in WasteLAN.
Tips for completing rationale:
"Contaminated" refers to concentrations of contaminants that exceed
appropriately protective risk-based levels such as chemical-specific Applicable or
Relevant and Appropriate Requirements (ARARs) or health-based levels
developed in a risk assessment or Record of Decision.
All contaminants of potential concern present at the site above risk-based
screening levels must be considered for sites without a ROD. For sites with a
ROD, consider contaminants of concern identified in the Risk Assessment.
• (Step 3) Is the migration of contaminated ground water stabilized (such that
contaminated ground water is expected to remain within "existing area of contaminated
-28-
-------
ground water") as defined by the monitoring locations designated at the time of this
determination?
If no, site does not meet definition of GM. Select "No" in WasteLAN.
If yes, proceed to Step 4.
If insufficient data are available, select "Insufficient Data" in WasteLAN.
Tips for completing rationale:
The "existing area of contamination " is an area (with horizontal and vertical
dimensions) that has been venfiably demonstrated to contain all relevant ground
water contamination associated with this determination, and is defined by
designated locations proximate to the outer perimeter of "contamination " that
can and will be monitored in the future to physically verify that all
"contaminated"ground water remains within this area.
Determination of plume stability is based on expectations that the plume will
remain in the "existing area of contaminated ground water " and should consider
all available data. For P&T remedies, the determination should be based on
multiple lines of evidence for ground water capture (see Elements for Effective
Management of Operating Pump and Treat Systems/
If monitored natural attenuation (MNA) is the selected remedy for the site, a
positive determination oj GM can be made if post-selection monitoring results are
consistent with the assumptions used to support the MNA remedy selection (see
Section 6.2).
(Step 4) Does "contaminated" ground water discharge into surface water bodies?
If no, proceed to Step 6.
If yes, proceed to Step 5.
If insufficient data are available, select "Insufficient Data" in WasteLAN.
Tips for completing rationale:
"Surface water bodies " include lakes, rivers, estuaries, etc. and related sediment
and ecosystems.
Base answer for this step on hydraulic information, considering contaminant
information only to the extent that it demonstrates with reasonable certainty (hat
there is no hydraulic connection between the contaminated ground water and
surface water.
-29-
-------
Consider both constant and intermittent (e.g., seasonal) discharges - any
expected discharge, constant or intermittent, would result in a "yes"
determination.
(Step 5) Can the discharge of "contaminated" ground water into surface water be shown
to be "currently acceptable" (i.e., not cause unacceptable impacts to surface water,
sediments, or ecosystems that should not be allowed to continue until a final remedy
decision can be made and implemented)?
If no, site does not meet definition of GM. Select "No" in WasteLAN.
If yes, proceed to Step 6.
If insufficient data are available, select "Insufficient Data" in WasteLAN.
Tips for completing rationale:
Consider surface water, sediments, and ecosystems to determine whether
unacceptable impacts exist at the site.
Assessment and measurement endpoints should be the same as those being used to
make risk management decisions for the site.
Aquifer contaminant levels identified or developed specifically for the protection
of surface water can be used to make this determination.
(Step 6) Will ground water monitoring/measurement data (and surface
water/sediment/ecological data, as necessary) be collected in the future to verify that
contaminated ground water has remained within the horizontal (or vertical, as necessary)
dimensions of the "existing area of contaminated ground water"?
If no, site does not meet definition of GM. Select "No" in WasteLAN.
If yes, site meets definition of GM. Select "Yes" in WasteLAN.
If insufficient data are available, select "Insufficient Data" in WasteLAN.
Tips for completing rationale:
Review ground water and surface water monitoring reports on a regular basis
(i.e., at the same frequency as monitoring - e.g., quarterly, annually, etc.) and
compare to historical data to evaluate the status of the El determination.
To make a positive determination for this indicator, monitoring will be required
to verify that the ground water contamination remains within the "existing area
of contaminated ground water" and ensure that surface water impacts remain
acceptable, if applicable.
-30-
-------
This question is focused on the future. Consider whether there are plans, for
monitoring, not whether monitoring has been completed in the past. "Plans for
monitoring" will usually be documented in the remedy decision (e.g., ROD),
remedial design, Interim RA, PCOR, or similar document.
Data entry instructions for assigning a site determination in WasteLAN are discussed in
Appendk B.
6.2 CONSIDERING MONITORED NATURAL ATTENUATION REMEDIES
A positive determination for the GM El can be made if Monitored Natural Attenuation (MNA) is
the selected remedy for the contaminated ground water at the site. Decisions to employ MNA as
the sole remedy or a component of the remedy should be thoroughly and adequately supported
with site-specific characterization and analysis. MNA should not be used when it would result in
plume migration or unacceptable impacts to environmental resources.
EPA recognizes that a plume boundary is more realistically defined by a zone rather than a line.
Fluctuations within this zone arc likely to occur due to a number of factors (e.g., analytical,
spatial, or seasonal variability), which may or may not be indicative of a trend in plume
migration. Limited plume migration can be acceptable as part of the MNA remedy and, if it is
determined that such migration does not indicate a trend, a positive determination of GM can be
achieved as long as all other conditions for this determination are met. However, if post-
selection monitoring results suggest that the contamination is not attenuating as expected, the
remedy decision will need to be reviewed, and a positive determination of GM should not be
made.
6.3 INFORMATION UPDATE AND REPORTING REQUIREMENTS
Complete the GM El worksheet in WasteLAN after a site is first listed as Final on the NPL (data
can first be entered when the site is Proposed), and update the GM El as soon as a change in the
determination is warranted. Data updates are required by October 15 of each year or as required
by the current year SPIM, to reflect the status at each site as of the end of the prior fiscal year.
-31-
-------
Changes in El Status
A new worksheet is required whenever the El status changes (a copy of the worksheet is
contained in Appendix E). It is recommended that a copy of the worksheet also be and kept with
official site files. Submit the new worksheet to OSRTI, and update WasteLAN within 30 days of
knowing that the El status has changed.
No Change in El Status
If there is no change in the status of the GM El, update "Last Review Date" in WasteLAN for
appropriate indicator on the Site Characterization Screen.
New Listings on the NPL
For sites that are placed on the NPL after FY 2002, complete and submit a worksheet to OSRTI,
and update WasteLAN within one year of NPL site listing as Final.
-32-
-------
6.4 FREQUENTLY ASKED QUESTIONS - MIGRATION OF CONTAMINATED GROUND WATER UNDER
CONTROL
Step 1: Based on the most current data for the site, has all available information on media contamination been
considered in this HI determination'.'
Question
Answer
1-1
What are the best sources of information for
me to consider for this El determination?
Documents such as RI/FS reports, RODs, Action
Memoranda, POLREPS, Close Out Reports, annual or
periodic ground water and surface water monitoring
reports, Five-Year Reviews, etc. are good sources of
information.
1-2
No known ground water contamination exists
at the site. Do 1 need to make a determination
for this El?
Do not consider this El if no known or suspected
ground water contamination exists or has existed in the
past at the site. If ground water contamination is
known or suspected or if contamination once was
present but has since been cleaned up, you should
complete all appropriate steps in making this
determination
1-3
There may be several different sources of
information (e.g., State, EPA, PRP). Do 1
need to review all of this information to
answer "yes" to this question?
You need to review and consider only that information
that is: 1) pertinent to evaluation of migration of
contaminated ground water; and 2) available to you. If
the information from other sources is both relevant and
available to you, it should be reviewed and considered
when making this determination.
1-4
Volumes of data may be available for a site.
I've got other priorities. Do I need to review
all of this information to answer "yes" to this
question?
You need to review and consider only that information
that is pertinent to evaluation of ground water
migration. Focus your time on existing data or reports
thai address ground water contamination. This
indicator does not require that you perform any new
analyses but, rather, that you reflect analyses that have
already been done.
1-5
What if a PRP has drawn different
conclusions than EPA regarding the status of
contaminated ground water migration? Do I
need to consider the PRP's data?
Yes. To answer "yes" under Step 1, you need to
consider the PRP data that is available to you. When
answering the questions in Steps 2 through 5, you can
decide what weight to place on the PRP's conclusions.
1-6
What if 1 am aware of information that
another Agency or a PRP has collected but
cannot obtain a copy of it? Should 1 answer
"no?"
No. This step assures that you have considered that
information that is available to you. If the information
is not available for your review and consideration, you
can still answer "yes" to this question.
1-7
The pump and treat remedy has been
operating for only a short time, and it is
unknown whether the plume has been
captured. How should 1 answer this question'.'
If data are unavailable or insufficient to make the HE
El determination, answer "data incomplete" and select
"Insufficient Data" in WasteLAN.
-33-
-------
Step 1: Based on the most current data for the site, has all available information on media contamination been
considered in this El determination?
Question
1-8
1-9
The site investigation is in the early stages and
it is unknown whether the plume is naturally
attenuating (i.e., contained). How should I
answer this question'.'
How is a "no" answer for Step 1 recorded in
WasteLAN?
Answer
If data are unavailable or insufficient to make the HE
El determination, answer "data incomplete" and select
"Insufficient Data" in WasteLAN.
You must answer either "yes" or "data unavailable" in
Step 1. If you answer "no," re-evaluate the available
data to make a determination for this El.
-34-
-------
Step 2: Is ground water known or reasonably suspected to be "contaminaicd" above appropriately protective risk-
based levels as a result of a release from the site?
Question
Answer
2-1
Where can I find the information to answer
this question?
Documents such as Rl/FS reports, RODs. Action
Memoranda, POLREPS, Close Out Reports, annual or
periodic ground water and surface water monitoring
reports, Five-Year Reviews, etc. are good sources of
information.
2-2
What risk-levels should 1 use in this step?
Use risk levels that are consistent with the most recent
stage of the response action. Risk-based levels such as
chemical-specific Applicable or Relevant and
Appropriate Requirements (ARARs) or health-based
levels developed in a risk assessment or Record of
Decision are appropriate.
2-3
How should 1 interpret whether ground water
is "reasonably suspected" to be contaminated
if my sampling data are limited?
In the absence of extensive sampling and analytical
data, you will need to use your best judgment. If
evidence-even limited evidence-indicates that there is
a reasonable possibility of ground water contamination,
you should answer either "yes" or "insufficient data."
The El requires that you make your determination with
"reasonable certainty."
2-4
How do 1 answer this question if some ground
water contaminant levels are below their
respective risk-based levels and others are
above?
If the concentration of any contaminant in ground
water exceeds its appropriately protective risk-based
level, answer "yes" "to this question.
2-5
Does a single "hit" of contamination mean
that 1 should answer "yes" to this question?
Base your determination on the information and
approach being used for risk-based decisions at the
site. If you are in the early stages of the investigation,
with limited data, a single hit may be enough to make a
"yes" determination if multiple lines of evidence
corroborate this conclusion. Use professional
judgement to make a determination with reasonable
certainty. If data do not allow you to make a
judgement with reasonable certainty, answer
"insufficient data" to this question.
2-fi
Should I use average, UCL on the mean, or
another type of concentration when answering
this question?
Base your determination on the information and
approach being used for risk-based decisions at the
site. If you arc at a later stage in the cleanup process
and the UCL is being used as the exposure point
concentration, use this to answer this question.
-35-
-------
Step 2: Is ground water known or reasonably suspected to be "contaminated" above appropriately protective risk-
based levels as a result of a release from the site?
Question
Answer
2-7
How should 1 answer this question if the
contaminant levels are above PRGs but below
final cleanup levels?
Use the risk-based levels that are consistent with the
most recent stage of the response action if they are
appropriate for current exposures. If final cleanup
levels are the most recent risk-based numbers, base
your answer on comparison of current conditions to
final cleanup levels. If PRGs are the most recent risk-
based levels, base your answer on comparison of
current conditions to PRGs.
2-8
If more than one distinct contaminated plume
exists at a site, should I make the
determination based on only one plume or
multiple plumes?
If more than one distinct plume exists at a site and only
one plume contains contaminants above risk-based
levels, answer "yes" to this question and continue with
step 3. Ultimately, if you determine migration of
contaminated ground water plume is under control for
one plume but not another, the site does not meet the
definition for this El. Answer "no" in WasteLAN if
any plume does not meet the definition as defined in
steps 2-6.
2-9
If multiple distinct plumes exist at the site, do
1 consider each plume separately?
Evaluate each plume separately, to the extent that the
plumes can be separately identified. If you answer
"yes" for a ground water plume in this step, answer
step 3 (and subsequent steps, if applicable) for that
plume. If you answer "no" for a plume in this step, this
plume can be dropped from further consideration under
this El. Ultimately, if you determine migration of
contaminated ground water plume is under control for
one plume but not another, the site does not meet the
definition for this El.
2-10
What should I do if the risk-based levels that 1
used to answer this question change as we
learn more about the site?
If risk-based levels change, consider whether the
change would effect the contaminated ground water
migration under control El determination for the site.
If so, update the El determination to reflect the new
information.
2-11
What should 1 do if the COCs in ground water
change or contaminant concentrations are re-
evaluated as we learn more about the site?
If COCs in ground water change or contaminant
concentrations are re-evaluated based on new data,
consider whether the change would effect the El
determination for the site. If so, update the El
determination to reflect the new information.
-36-
-------
Step 3: Is the migration of contaminated ground water stabilized as defined by the monitoring locations
designated at the time of determination?
Question
Answer
Where should 1 find information to answer
this question?
Documents such as RI/FS reports, RODs. Action
Memoranda, POLRBPS, Close Out Reports, annual or
periodic ground water and surface water monitoring
reports, Five-Year Reviews, etc. are good sources of
information.
3-2
If monitored natural attenuation has been
selected as the remedy for a site, can 1 answer
"yes" to this question?
Monitored natural attenuation does not preclude you
from answering "yes" to this question. If the selected
remedy is monitored natural attenuation and the plume
meets conditions set forth in steps 1-3, you can answer
"yes" to this question and proceed to step 4.
3-3
If one monitoring location shows a single
"hit" of a contaminant of concern, should 1
answer "no" to this question?
Generally, the determination that migration has
stabilized will require consideration of site
characteristics and multiple rounds of sampling to
assess any trends. A single "hit" should be considered
in the context of this other data. Jf the data are
limited, use your best professional judgement to answer
the question with reasonable certainty. If uncertainty
persists, answer "insufficient data."
3-4
How is the "existing area of contamination"
determined?
The existing area of contamination is defined by
designated locations proximate to the outer perimeter
of contamination that can and will be monitored in the
future to physically verify that all contamination
remains in this area. Note that monitoring wells used
to make this determination can be located inside the
area of contamination (they do not have to be "clean"
wells). You do not need to continue to monitor wells
that show consistently low levels of contamination
solely for the purposes of this El. Use that data that
you would normally collect to monitor site conditions
when making this HI determination.
3-5
I have very limited data on which to make
judge stability of the plume. Can I answer
"insufficient data" to this question? What is
"sufficient?"
Yes, you can answer "insufficient data" in such an
instance, liach site is unique, so there is no common
definition of "sufficiency." Use your best professional
judgement and determine your answers based on
"reasonable certainty.".
3-6
Evidence indicates contamination beyond the
existing area, but the contamination is below
risk-based levels. How would this question be
answered for this scenario?
Contamination levels outside of the area of
contamination need not exceed risk-based levels to
show migration of the plume. If contamination has
been identified outside of the existing area of
contamination, consider all of the information
available, including capture zone analyses (for P&T
remedies) and use your best judgment to assess
whether migration of the plume is stabilized.
-37-
-------
Step 3: Is the migration of contaminated ground water stabilized as defined by the monitoring locations
designated at the time of determination?
Question
Answer
3-7
Only some contaminants (COPCs or non-
COPCs) associated with a site were detected
outside the area of existing contamination.
Should I consider the plume not stable?
Any contaminant-COPC or non-COPC- associated
with the ground water plume that has migrated beyond
the area of existing contamination, could be an
indication that the plume is not stabilized. Consider all
available analytical and hydraulic information and use
your best judgment to assess whether migration of the
plume is stabilized.
3-8
Multiple plumes exist at a site. At least one is
stabilized. How do 1 record this for this El
step?
The El determination is made on a site-wide basis. If
any plume for which you answered "yes" in step 2 is
not stable, the site does not meet the definition of
contaminated ground water migration under control.
Answer "no" to this question.
3-9
What should 1 do if the COCs in ground water
change or contaminant concentrations are re-
evaluated as we learn more about the site?
If COCs in ground water change or contaminant
concentrations are re-evaluated based on new data,
consider whether the change would effect the El
determination for the site. If so, update the El
determination to reflect the new information.
3-10
What if monitoring locations change in the
future?
If monitoring locations for the existing area of
contamination change, you need not update this El
unless contamination is found outside of the area of
contamination as determined by those monitoring
locations. If so, update the El determination to reflect
the new information.
-38-
-------
Step 4: Does contaminated ground water discharge into surface water bodies'?
Question
Answer
4-1
Where can I find the information to answer
this question?
Documents such as RI/FS reports, RODs, Action
Memoranda, POLREPS, Close Out Reports, annual or
periodic ground water and surface water monitoring
reports, Five-Year Reviews, etc. are good sources of
information.
4-2
If surface water data are limited (f.g-, no
surface water samples have been collected),
how should 1 make this determination?
In the absence of a complete characterization of the
ground water to surface water pathway, you wiH need
to use your best judgment. Ground water and
hydrologkal investigations collected during the RI may
provide enough information to make your
determination with "reasonable certainty." You could
also consult the CSM to determine whether it would be
reasonable to assume groundwater discharge. If no
information is available, you should answer either "no"
or "insufficient data."
4-3
Ground water to surface water discharge is not
constant or is very sporadic. Should I answer
"yes" to this question?
If ground water has been documented to discharge to
surface water at any time, answer "yes" to this
question.
4-4
Ground water to surface water discharge has
been documented; however, sampling did not
show contamination in the surface water at the
discharge point. Therefore, I cannot assume
"contaminated" ground water is discharging at
this point. Should 1 answer "no" to this
question?
You should base your answer on "reasonable
certainty." If you are reasonably certain no
contaminated ground water is discharging to surface
water, answer "no" to this question. However, if you
are unsure or your professional judgment leads you to
think contaminated ground water is discharging to
surface water (e.g., contamination exists at the ground
water table just upgradient of Ihe surface water body) ,
answer "insufficient data" or "yes" based on your level
of certainty.
4-5
Multiple plumes exist at the site. Only one
plume discharges contamination into a surface
water body. How do 1 answer this question?
The El determination is made on a site-wide basis. If
contaminated ground water associated with a plume for
which you answered "yes" in slcp 3 discharges into
surface water, answer "yes" to this question and answer
question 5 for this plume.
4-6
Should future/past discharges be considered
when making this determination?
Because ground water levels and discharge to surface
water can fluctuate throughout the year, future or past
discharges should be considered when answering this
question. If there is evidence of past discharges, or
likelihood of future discharges, answer "yes" to this
question regardless of current conditions. If conditions
change, preventing future discharge answer "no" to this
question. (See question 4-7).
-39-
-------
Step 4: Does contaminated ground water discharge into surface water bodies?
Question
4-7
What if conditions change and a remedy
prevents future discharges?
Answer
Reevaluate the answer to this question if conditions
change. If a remedy addresses contaminated ground
water discharge into surface water so that surface water
is unlikely to receive future ground water discharge,
answer "no" to this question.
-40-
-------
Step 5: Can the discharge of contaminated ground water into surface water be shown to be currently acceptable as
defined (i.e., not cause unacceptable impacts lo surface water, sediments, or ecosystems that should not be
allowed to continue until a final remedy decision can be made and implemented)?
Question
Answer
5-1
Where can 1 find the information to answer
this question?
Documents such as Rl/FS reports, RODs, Action
Memoranda, POLREPS, Close Out Reports, annual or
periodic ground water and surface water monitoring
reports, Five-Year Reviews, etc. are good sources of
information.
5-2
Should 1 use ground water contaminant levels
(identified in step 2) to determine if discharge
of contaminated ground water to surface water
is within currently acceptable limits?
No. Base your decision on contaminant levels
identified or developed specifically for the protection
of surface water (e.g., AWQC). Use those surface
water standards or other contaminant levels being used
for risk-based decisions for the site.
5-3
What if surface water contaminant levels are
above one standard, but below another? How
should 1 answer this question?
Based your answer on the standards being used for risk
based decisions for the site. If contaminant levels are
above a standard that has been deemed the
"acceptable" level for a site, answer "no" to this
question.
5-4
Water quality standards (e.g., TMDLs,
AWQC) have not been developed for any
contaminants at the site. How should 1 make
this determination?
In the absence of water quality standards, base your
determination on the best available information. If
evidence suggests that ground water discharge has
resulted in unacceptable impacts on surface water (e.g.
if remedial actions are planned for the surface water
pathway), answer "no" to this question.
5-5
At present, discharge of contaminated ground
water to surface water is acceptable. Should 1
answer "yes" now and change the response to
"no" if and when the surface water
contaminant concentrations reach a level such
that the surface water, sediment, or
ecosystems are negatively impacted?
Use your professional judgment or consult the risk
assessment for aid in making this decision with
reasonably certainty. Answer "no" only if future
impacts lo surface water are imminent (i.e., are
expected to occur before remedial actions can be
implemented).
5-6
The only contaminants detected in the surface
water are not present in the ground water
plume. If these contaminants are above
acceptable levels, but might not be related to
the ground water plume, should 1 answer
"yes?"
Use your professional judgment and consider all
aspects of the site, including the extent of sampling
conducted at the time of determination, in order to
determine (he answer. If the contaminants are clearly
not related to ground water, answer "yes" to this
question and continue with the worksheet.
5-7
Some contaminants in surface water are at
acceptable levels, others are not. How should
I answer this question?
If any contaminant associated with the discharge of
ground water is found in surface water above
acceptable limits, answer "no" to this question.
-41-
-------
Step 5: Can the discharge of contaminated ground water into surface water be shown to be currently acceptable as
defined (i.e., not cause unacceptable impacts to surface water, sediments, or ecosystems that should not be
allowed to continue until a final remedy decision can be made and implemented)?
Question
5-8
5-9
Contaminants associated with ground water
discharge were found in sediment samples at
unacceptable levels, but not in surface water
samples. Is it appropriate to answer "no" to
this question if only sediment contamination is
found?
How do 1 answer this question if contaminant
levels in surface water/ sediment/ecosystems
have decreased to acceptable limits?
Answer
Yes. Sediments are to be considered when making this
determination. Past releases can be "trapped" in
sediments after surface water contamination has been
cleared. Because of this, sediment contaminant levels
may not correlate directly with surface water
contaminant levels. It is conceivable that sediment
contamination may be measured even if surface water
contamination is not detected. Therefore, assuming the
contamination can be associated with present or past
ground water discharge (see questions 4-6 and 4-7),
answer "no" to this question.
If ground water discharge continues, yet surface water
contaminant levels are within currently acceptable
limits, answer "yes" to this question and continue to
step 6.
-42-
-------
Step 6: Will ground walcr monitoring/measurement data (and surface water/sediment/ecological data, as
necessary) be collected in the future to verify that contaminated ground water has remained within the horizontal
(or vertical, as necessary) dimensions of the existing area of contaminated ground water?
Question
6-1
6-2
6-3
6-4
6-5
6-6
6-7
Where can 1 find the information to answer
this question?
How should the existing area of contaminated
ground water be determined?
What if future monitoring shows migration of
the ground water plume?
Contaminated ground water discharges to
surface water at the site. However, adverse
surface water impacts have not been shown
from discharging contaminated ground water.
No future monitoring is planned. Should 1
answer "no" to this question, even if future
impacts to surface water are possible?
No vertical dimensions have been estimated
for the plume. Does the future monitoring
need to consider vertical dimension?
The ground waler contamination has been
cleaned up and monitoring efforts are ceasing.
Should 1 answer "no" to this question if EPA
ceases monitoring in the future?
Monitoring efforts are being halted (by
outside agency, state, etc); however,
contamination still exists at the site. How do 1
answer this question if site conditions are thus
changed?
Answer
Documents such as RODs, Action Memoranda,
POLREPS, Close Out Reports, Five-Year Reviews,
etc. are good sources of information.
Base the existing area of contaminated ground water
consistent with step 3.
Your answer to this step should be based only on
whether or not monitoring is planned for the future. If
the plume characteristics change in the future, the El
will need lo be re-evaluated.
The decision not to monitor surface water suggests that
future impacts are unlikely; therefore, there is no need
to consider whether surface water monitoring is
planned when answering this question. However, if
future ground water monitoring suggests changing
conditions that could result in surface water impacls,
the El determination should be reconsidered.
If vertical dimensions have not been established for the
existing area of contamination, future monitoring does
not need to consider vertical dimensions in order for
you to answer "yes" to this step.
If the site has been cleaned-up or otherwise addressed,
ground water will likely be below protective risk-based
levels. If this is the case, you would answer "no" to
step 2 and the site would meet the definition for
migration of contaminated ground water under control.
If site conditions do not allow you to answer "no" to
step 2, continue with worksheet. In step 6, you need to
evaluate your answer based on current known
decisions. If monitoring is being ceased in the future,
answer "no" to this question.
-43-
-------
SUPERFUND ENVIRONMENTAL
INDICATORS
GUIDANCE MANUAL
APPENDICES - DATA VIEWING AND ENTRY
Office of Superfund Remediation and Technology Innovation
U.S. Environmental Protection Agency
Washington, D.C. 20460
September 2004
-------
APPENDIX A - El DATA VIEWING AND ENTRY
The purpose of the Data Viewing/Entry guide is to describe the methods used to view and enter
current Environmental Indicator data in WasteLAN. These data will serve as an effective tool to
help the Regions monitor their cleanup progress, support Government Performance and Results
Act (GPRA) reporting, and construct accurate fact sheets. The frequency of data entry should, at
a minimum, be one per year. However, by entering data at more frequent intervals, the El
module will serve as a better tool for the Regions to monitor their progress. Covered in
Appendix A is the step-by-step process to view and enter data for the following Environmental
Indicators:
POPULATIONS PROTECTED—The Populations Protected Superfund El was developed to
measure the progress made in protecting individuals living at or near Superfund sites from
immediate threats of exposure to contaminated media. Specifically, this El measures the number
of individuals protected through the provision of alternate drinking water and the number of
individuals temporary or permanently relocated in response to contamination.
CLEANUP VOLUMES—The Cleanup Volumes indicator reports the amount of contaminated
materials that have been treated, stabilized, or disposed of at Superfund sites through the user of
risk management, engineering techno logics, and institutional controls.
HUMAN EXPOSURE UNDER CONTROL—Describes whether contamination is below protective,
risk-based levels or, if not, whether adequate controls arc in place to prevent unacceptable human
exposure to contamination based on current land and ground water use conditions at NPL sites.
MIGRATION OF CONTAMINATED GROUND WATER UNDER CONTROL—Describes whether
contamination is below protective, risk-based levels or, if not, whether the following conditions
arc met at NPL sites:
migration of contaminated ground water is stabilized;.
there is no unacceptable discharge to surface water; and
monitoring will be conducted to confirm that affected groundwater remains in the original
area of contamination.
-1-
-------
APPENDIX A - El DATA VIEWING AND ENTRY
A.I. ACCESSING AND VIEWING THE ENVIRONMENTAL INDICATORS MODULE
IN WASTELAN
OR
From the Views menu, select Program Management, then Environmental Indicators.
From the Removal or Remedial Schedule, the Add/Edit El icon can be selected when
one of the following actions are highlighted on the schedule: Removal; PRP Removal; FF
Removal; Remedial Action; PRP RA; FF RA; PRP Emergency Removal; and Initial
Remedial Measure,
Add/Edit El Icon on
Project Schedule
m 9 m 1= •
; nu-im. tiinui *#*<#** *«
*i*M««r~rr~{
SfntOfOaat
GmaH
-1-
-------
APPENDIX A - El DATA VIEWING AND ENTRY
A.2. ENVIRONMENTAL INDICATOR TABS - DATA VIEWING AND ENTRY
The Environmental Indicators (El) Module displays and allows for data entry of the Human
Exposure Under Control, Migration of Contaminated Ground Water Under Control, Cleanup
Volumes, and Populations Protected Environmental Indicators. The El Module consists of five
tabs including:
Summary;
Headquarters Review/Summary;
Human Exposure Under Control;
Migration of Contaminated Ground Water Under Control;
Cleanup Volumes; and
• Populations Protected
-3-
-------
APPENDIX A - El DATA VIEWING AND ENTRY
A.3. ENVIRONMENTAL INDICATORS SUMMARY TAB - DATA VIEWING/ENTRY
The Summary tab is the first tab that appears when entering the El Module. All fields on the
Summary screen are greyed out and uneditable. The following data is displayed on the Summary
Screen:
• Cumulative totals of Cleanup Volumes and Populations Protected data for all actions
selected at a site as well as a summary of the HE and GM determinations, last Regional
and HQ review dates, and estimated controlled data.
• The Cleanup Volumes data is displayed by media, volume and standard unit (gallons or
cubic yards).
The Populations Protected portion of the Summary tab displays the protection level
(permanent, temporary, or returned/reinstated).
Utfefcs
*
* v m
s*M>s*tt*>s*>Mw**frf>+ff>f.
-4-
-------
APPENDIX A - El DATA VIEWING AND ENTRY
A.4. HEADQUARTERS REVIEW/SUMMARY TAB - DATAVlEWING/ENTRY
The Headquarters Review/Summary tab is the second tab that appears in the El module. This tab
is named Headquarters Review in the Headquarters instance of WasteLAN and the Summary tab
in the Regional instances of WasteLAN.
All fields on the Headquarters Review/Summary screen are greyed out and uneditable. This
screen is used by the Headquarters Environmental Indicators Coordinator to approve and make a
final HE and GM determination based upon the data entered by the Regions on the Human
Exposure and Ground Water Releases tabs.
Headquarters Review/Summary Tab
-5-
-------
APPENDIX A - El DATA VIEWING AND ENTRY
A.5. HUMAN EXPOSURE TAB - DATA VIEWING/ENTRY
The Human Exposure tab allows the user to complete, or save as draft, the Human Exposure
survey for the selected site. This tab documents whether contamination is below protective, risk-
based levels or whether adequate controls are in place to prevent human exposure to
contamination based on current land and groundwater use conditions.
1. Each question consists of a drop-down and a text box. To answer a question, simply click
on the drop-down and select from the list of possible answers. Answers consist of Yes,
No, and Insufficient Data.
2. Once you have answered the question, enter reference documents in the text box.
Documents such as RODs, Action Memorandums, POLREPS, and Close Out Reports
often provide necessary information.
3. Once all information has been entered, the results of the responses will be displayed in
the Survey Status box on the Headquarters Review tab.
4. Once all data has been entered, and the survey has been certified by the appropriate
person(s), click on the RPM Certified checkbox.
5. Select either the "Final" or "Draft" radio button. Please note: The "Draft" option is not
meant to be a substitute for cases when insufficient data is available at a site. It is
included in the survey with the intention of functioning as a short-term placeholder for
cases where the user has not completed the survey and wishes to save without losing
information. Once a survey is saved as "Draft," the survey will display the determination
of "Online Worksheet saved as Draft". Once the user is able to complete the survey, the
"Final" radio button should be selected.
6. If the survey determination is either "Site Does Not Meet Definition" or "Insufficient Data
Needed to Make a Determination," enter an estimated date at which Human Exposure at
the site will be under control.
7. In cases where the Human Exposure Under Control survey determination is changed from
"Site Does Meet Definition" to one of the following: "Site Does Not Meet Definition";
"Insufficient Data Needed to Make Determination"; or "Online Worksheet Saved as
Draft", you will be required to enter a justification of why the site determination is no
longer "Under Control".
-6-
-------
APPENDIX A - El DATA VIEWING AND ENTRY
Human Exposure Tab
;:-;;--;-;^^
-7-
-------
APPENDIX A - El DATA VIEWING AND ENTRY
A.6. GROUNDWATER RELEASES TAB - DATA VIEWING/ENTRY
The Groundwater Releases tab allows the user to complete, or save as draft the Ground Water
Releases survey for the selected site. This tab documents whether contamination is below
protective, risk-based levels, or if not, whether the migration of contaminated ground water is
stabilized and there is no unacceptable discharge to surface water. It also document whether
monitoring will be conducted to confirm that affected ground water remains in the original area
of contamination. This determination should be make on a site-wide basis, with reasonable
certainty, based on the existing plume, with on-going monitoring, and limited migration.
1. Each question consists of a drop-down and a text box. To answer a question, simply click
on the drop-down and select from the list of possible answers. Answers consist of
(Blank), Yes, No, and Insufficient Data.
2. Once you have answered the question, enter reference documents in the text box.
3. Once all information has been entered, the results of the responses will be displayed in
the Survey Status box on the Headquarters Review tab.
4. Once all data has been entered, and the survey has been certified by the appropriate
person(s), click on the RPM Certified checkbox.
5. Select either the "Final" or "Draft" radio button. Please note: The "Draft" option is not
meant to be a substitute for cases when insufficient data is available at a site. It is
included in the survey with the intention of functioning as a short-term placeholder for
cases where the user has not completed the survey and wishes to save without losing
information. Once a survey is saved as "Draft," the survey will display the determination
of "Online Worksheet saved as Draft". Once the user is able to complete the survey, the
"Final" radio button should be selected.
6. If the survey determination is either "Site Does Not Meet Definition" or "Insufficient Data
Needed to Make a Determination," enter an estimated date at which Migration of
Contaminated Ground Water at the site will be under control.
7. In cases where the Migration of Contaminated Ground Water Under Control survey
determination is changed from "Site Does Meet Definition" to one of the following: "Site
-8-
-------
APPENDIX A - El DATA VIEWING AND ENTRY
Does Not Meet Definition"; "Insufficient Data Needed to Make Determination"; or
"Online Worksheet Saved as Draft", you will be required to enter a justification of why
the site determination is no longer "Under Control".
Groundwater Releases Tab
• •; ':•>'•:» V :•': 'ri*fiii&ii'' '^«*i', •:&&*' :^-*?^Sf:':'vJMiifuib1; j V. t*; »_SIJT '': "^ '• :••;••;•:• ^X;';.; o - : '•"' |-^*'" : '•';;
-9-
-------
APPENDIX A - El DATA VIEWING AND ENTRY
A.7. CLEANUP VOLUME TAB - DATA ENTRY/VIEWING
The Cleanup Volumes tab displays and allows for entry of incremental cleanup data. This
incremental data is then rolled up on the Summary tab as a cumulative number.
Note: When entering a new cleanup volume, it is important to enter a new row rather than edit
an existing cleanup value. This screen is different than the previous Add/Edit El module in that
new volumes should be entered separately, not added to an existing volume for a particular
action. The original amount and unit fields were designed to be editable in the case an incorrect
volume was entered.
1. Select the action from the Action drop-down menu for which the cleanup volume you
wish to enter has been applied. (Note: Selecting "All" from the Action Drop-down will
display all actions and corresponding media at a site).
2. Once the relevant action has been selected, select "Add Row". A blank row will appear.
3. Once you have selected the appropriate action or have chosen to view all actions, enter
the date the volume was cleaned up in the Cleanup Date field.
4. Select the Media Name drop-down menu and select the appropriate Media Name and
Media Type for the particular action for which you wish to enter a volume. (Note: if the
media name for which the cleanup volume was applied is not available for the particular
action you selected, it must be entered on the Add/Edit Media screen via the SCAP or
Remedy screens. Once entered, it will then be available on the Media Name drop-down
menu).
5. Enter the volume of waste treated for the particular action and media name in the
Original Cleanup Amount and Original Unit fields. Units can be entered as "non-
standard" units as they are automatically converted to standard units of gallons or cubic
yards, once selected in the Converted Amount and Converted Unit fields. (Note: Non-
standard units available from the "Original Unit" drop-down include: (Cubic Feet;
Drums; Liters; Tons; Pounds; Cubic Meters; Tanks; Cylinders; and Battery Casings).
6. To save a new entry, select the "Summary" tab and click on the "OK" button. Cumulative
volumetric totals can be viewed on the "Summary" tab.
-10-
-------
APPENDIX A - El DATA VIEWING AND ENTRY
Note: An action must be selected from the action drop-down in order to enter a cleanup volume.
If the action for which you wish to enter a volume is not available on the drop-down, it must be
entered on the Add/Edit Response Action screen via the SCAP screens.
Cleanup Volumes Tab
«?»pi»P?^^
^«^&&$*s4$^^^*.s^
...^.,~.... •<• .•;••-•; ;;.•. • >J-.'•^." •.:>':;'-'•'•..•><•:••. •"*•:"''' .'^-'' ''»-• «JS)*i
np:viP-0<^^^
: Staii* : fc.-- n.-.uttt tair*-' '•&-;. -**«*i& tW4*o **;,••• *•:•'».•. '**•' .:• ' ':••'• T--. •
-11-
-------
APPENDIX A - El DATA VIEWING AND ENTRY
A.8. POPULATIONS PROTECTED TAB - DATA VIEWING/ENTRY
The Populations Affected tab allows for the data entry of the number of people supplied
alternative drinking water and the population relocated at a particular site. The Populations
Affected tab displays incremental population numbers by action, while the Summary screen
displays the site-wide cumulative population relocated and/or provided alternative drinking water
at a site. As such, it is important to add a row for entry of new Populations Protected data rather
than editing existing data.
1. Select an action from the Action drop-down menu for which the Population Relocated
or Alternate Drinking Water Supplied response was applied. (Note: Unlike on the
Cleanup Volume tab, data entry is not permitted when "AH" is displayed on the Action
drop-down box. This is due to the feet that on the Cleanup Volume tab you are still
required to select an action associated to a medium on the Media Name drop-down-box.
Because Population Protected data is not associated with a Medium, you are required to
select a specific action (rather than "All") to which either population relocated or alternate
drinking water supplied data is associated).
2. Select the Add Row button. (Note: You may receive a data warning message stating "No
Populations Relocated Response Actions Currently Exist for this Site or No Alternative
Drinking Water Response Actions Currently Exist for this Site". If this message appears,
you will still be permitted to enter data, however for data quality purposes, the applicable
population relocated and/or alternate water supplied response action should be entered on
the Add/Edit Response Actions screen via the SCAP or Remedy Screens.).
3. Enter the Affected Date the population was either relocated or provided alternative
drinking water.
4. Enter the Protection Level (either Permanent, Temporary or Returned/Reinstated)
applied toward the population.
5. Enter the number of individuals relocated or receiving alternative drinking water in the
Number Affected field.
6. To save a new entry, select the Summary tab and click on the OK button. Cumulative
Population Relocation and Alternative Drinking Water Supplied data can be viewed on
the "Summary" tab.
-12-
-------
APPENDIX A - El DATA VIEWING AND ENTRY
Populations Affected Tab
-13-
-------
APPENDIX B - ENVIRONMENTAL INDICATOR REPORTS
B.1 ENVIRONMENTAL INDICATOR REPORTS
As described in Section 2.7 of the Guidance, a number of El Reports are available at both the
Regional and National levels.
These include:
PGMT-08 Environmental Indicators Audit Report
Displays sites were there is incomplete Cleanup Volume data. This report can be used to
identify discrepancies in Cleanup Volume data at the National, Regional, State, or site-specific
levels.
PGMT-09 Data Compilation Report
Summary of site Population Protected and Cleanup Volume data. This report can be used to
ensure that all data for a site are entered completely and accurately.
PGMT-10 Site Turnaround Report
Summary of site Population Protected and Cleanup Volume data. This report was designed to be
used in conjunction with the PGMT-09 as a data entry guide.
PGMT-11 Environmental Indicators HE/GM Report
Site summary detail and Regional summary count of HE and GM determinations and last
Regional and Headquarters review dates.
PGMT-12 Environmental Indicators HE/GM Error Report
Displays a site summary of data gaps and potential reporting errors for the Human Exposure and
Migration of Contaminated Ground Water Under Control El's.
PGMT-13 Environmental Indicators Summary Report
Quick reference cumulative summary of all El data-Populations Protected, Cleanup Volumes,
Human Exposure Under Control, and Migration of Contaminated Ground Water Under Control.
-14-
-------
APPENDIX B - ENVIRONMENTAL INDICATOR REPORTS
B.4 ACCESSING ENVIRONMENTAL INDICATOR REPORTS
1. Select the Reports icon located on the CERCLIS toolbar.
2. After the "Reports Library-" screen is displayed, select "Program Management" in the
Program Area filter. This will display the list of reports associated with "Program
Management".
-f Ratal ! ««K (fc»k*i,.; ;. t*
ChmDe Leg Report
; Construction Completion Pfenning end Tricking Report
! CnwonmenM kidfciloii AudM Report
Environment*) Indkftore Det« Compilation Report
Cmfe onmentil Indicvteie SMe Tu nwound Report
Non-Site Inc Klerit Mvreemnce Report
PGMt-11 bHnnmnealel ImkcXuo MEJCM Deport
i PGMT-1J Ernkonrneatel kldicMort HE«M Error Report
! SC AP-iZ Site Sumnury Roport
; SCAP-M FelHKM Svnnury Report n 2M2
SCAP-M FtntncKI Swnnury Report FY 2M>
SCAP-M FnincM Suranury Report FY MM
SCAP-UD FkiinclK sumnury Report FY 20111
SCAP g* EnToiMment FlnencM Report
SCAP-H OilPoeuboii Act (OPA] Mereuree Repoll FV 2M2
There tre )• reporte
PGMT-M
PGMl-tt
PGHI-lt
K5i-n
PGMT-11
PCUT-12
SCAP.I2
SCAP-M
SCAP-M FVMtJ
SCAP-M FV i*H >1.*2
SCAP-MD FV2H1 1.9*
ECAPME 1U1
SCAP M FY 2M2 1.11
1.K
1,05
1.M
1.N
tl.lt
M.M
J
SS
-15-
-------
APPENDIX B - ENVIRONMENTAL INDICATOR REPORTS
3. By highlighting and selecting any of the PGMT reports described above, the "Options"
menu will appear,
4. Select applicable Region, fiscal year, selection criteria, and report type (summary or
detail).
5. Once the criteria is selected, click "Run".
PGMT-IJ En*onme«ii kuflcM
PGUT-li Er>(*onm*nt«l Indictt
PGMT-11 Enfkonnwntil IndiMrt
PGMT-11 EnrironnMnM lralc«
: SC W-«2 Site Summiiy Report
: SCMMM fliuncftl Summary Re
; SCAP.MFkniKitiStimrraryRe^
SCM>44 HrancM Summary Report FV 2M4 Pralolype
: SCAPXDrjnmciilSumnvfyRsp«tFV2IO}
i SCM>44E EnToreemant Finaneiil Raport
: SCAP44E tnforcemem F(n«vci«l RcpoO FY2U4
SCAP*4Piotot)fp 31.ll
SCAP-HO FY2M3 t.«f
SC«P-(« 11.03
SCAP-D« FV2N4 1JI
: There *n 13 reports
-16-
------- |