UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, B.C. 20460
OFFICE OF
SOLID WASTE AND EMERGENCY RESPONSE
OSWER-9200-9355.4-28
April 5, 2004 .
MEMORANDUM
SUBJECT: Distribution of OSWER Guidance for Monitoring at Hazardous Waste Sites: Framework
for Monitoring Plan Development and Implementation
FROM: Michael B. Cook, Director/s/
Office of Superfund Remediation and Technology Innovation
TO: Superfund National Policy Managers, Regions 1-10
Purpose
The purpose of this memorandum is to transmit to you the guidance entitled: Guidance for
Monitoring at Hazardous Waste Sites: Framework for Monitoring Plan Development and Implementation.
Specifically the purpose of this guidance is to provide a framework for the development of scientifically
defensible monitoring plans, facilitate consistency of monitoring across U.S. EPA regions, and establish
procedures for identifying decision criteria prior to data collection.
Background
The document was written to fill a gap in the guidance for hazardous waste sites as well as in
response to a review by the National Research Council (NRC) which concluded that monitoring is
essential to evaluate effectiveness and ensure adequate protection of human health and the environment.
The Office of Solid Waste and Emergency Response recognizes the need to address monitoring at
hazardous waste sites as part of it's One Cleanup Program Initiative. This guidance is intended to serve as
a.reference for multiple programs, both removal and remedial. Since the U.S. EPA conducts monitoring
activities under many different programs (e.g., Superfund, RCRA, Federal Facilities, and Underground
Storage Tanks) the monitoring framework describes a process that can be adapted to meet the regulatory
requirements of these programs.
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The guidance was written in response to and is directed to the site managers (On-Scene
Coordinators and Remedial Project Managers) who are legally responsible for managing removal and
remedial site activities. It is anticipated that risk assessors supporting Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 (CERCLA) and Resource Conservation and Recovery
Act of 1976 (RCRA) activities will use this document.
Conclusion/Implementation
Copies of this document are available on our web site at
http://www.epa.gov/superfund/action/index.htm. General questions about this topic should be referred to
the Call Center at 1-800-424-9346. The subject matter specialist for this document is Bethany Grohs of
OSRTI. Bethany can be reached at 732-906-6168.
Attachment
cc: Nancy Riveland, Superfund Lead Region Coordinator, USEPA Region 9
Jeff Josephson
NARPM Co-Chairs
Joanna Gibson, OSRTI Documents Coordinator
OSRTI Managers
Ramona Trovata,, Senior Advisor to OSWER AA
Jim Woolford, FFRRO
Debbie Dietrich, OEPPR
Robert Springer, OSW
Cliff Rothenstein, OUST
Linda Garczynski, OBCR
Dave Kling, FFEO
Susan Bromm, OSRE
John Michaud, OGC
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OSWER Directive No. 9355.4-28
GUIDANCE FOR MONITORING
AT HAZARDOUS WASTE SITES:
FRAMEWORK FOR
MONITORING PLAN DEVELOPMENT AND IMPLEMENTATION
January 2004
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ACKNOWLEDGEMENTS
The authors wish to acknowledge all the reviewers that have assisted the authors
with constructive comments and assistance. We also wish to acknowledge the assistance
of the Argonne National Laboratory Environmental Assessment Division task leader, Dr.
Ihor Hlohowskyj, and the editorial assistance of the Argonne National Laboratory
Information Publishing Division, especially primary editor Patricia Hollopeter and the
staff of the Document Processing Center. We further wish to acknowledge the
Monitoring working group members that assisted in the development of this guidance.
Bethany Grohs, V.M.D.
Environmental Response Team
Office of Superfund Remediation and Technology Innovation
U.S. Environmental Protection Agency
EPA Working Group Members:
Clarence Callahan, Ph.D., Region IX
James Chapman, Ph.D., Region V
Bruce Duncan, Ph.D., Region X
Stiven Foster, ORD
Bruce Pluta, Ph.D., Region III
Parti Tyler, Region VIII
Other Working Group Members:
Amy Hawkins, Naval Facilities Engineering Service Center
Jody Wireman, Ph.D., MSPH, CIH, U.S. Air Force
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EXECUTIVE SUMMARY
This guidance document presents a framework for developing and implementing
technically defensible Monitoring Plans for hazardous waste sites. In support of the One
Hazardous Waste Cleanup Program, this document was written in direct response to, and for, site
managers who are legally responsible for managing removal and remedial site activities. It is
intended for use at hazardous waste sites that have completed site characterization, risk
assessment, and remedy selection and are in the process of implementing a removal action or site
mitigation.
This guidance presents a six-step framework for developing and documenting a
Monitoring Plan that will support management decisions. The framework includes the
identification of monitoring objectives and development of monitoring hypotheses to focus the
monitoring program, and the development of decision rules (exit criteria) that include action
levels and alternative actions for terminating or continuing the site activity and/or its monitoring
program.
Within the framework, Steps 1 through 3 document the logic and rationale of the
monitoring program by developing monitoring objectives that are directly related- to the
objectives of the site activity and by developing decision rules that will support site management
decisions. Steps 4 through 6, which include the development of a Monitoring Quality Assurance
Project Plan (QAPP), ensure that this logic is maintained by focusing data needs and data
collection and analysis methods to directly support the monitoring objectives, decision rules, and
subsequent management decisions. The framework is iterative and allows for the evaluation of
the monitoring data as they are generated, thus supporting adaptive management of the site
activity and the monitoring program.
This guidance document is not intended to specify the scale, complexity, protocols, data
needs, or investigation methods for meeting the needs of site-specific monitoring. Rather, it
presents a framework that can be used to develop and implement scientifically defensible and
appropriate monitoring plans that promote national consistency and transparency in the
decision-making process. This guidance is fully consistent with the Agency-Wide Quality
System and may be adapted to meet the regulatory requirements of other U.S. Environmental
Protection Agency programs.
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