Annual O&M/Remedy Evaluation Checklist for Contaminated Sediment Remedies
OSWER 9355.0-118
RECOMMENDED ANNUAL O&M/REMEDY EVALUATION CHECKLIST
FOR CONTAMINATED SEDIMENT REMEDIES
Introduction and Purpose
Effective operation and maintenance (O&M) at Superfund sites generally is critical to ensure that
remedies remain protective of human health and the environment.
This Recommended Annual O&M/Remedy Evaluation Checklist for Contaminated Sediment Remedies has
been designed to help Regions capture data routinely collected during O&M in a way that assists the
Remedial Project Manager (RPM) in evaluating the efficiency and effectiveness of the remedial action.
This recommended checklist may also be useful when evaluating a contaminated sediment remedy
before transferring the site to the State for O&M. In addition, remedy performance summarized using
this checklist can be used for other purposes, such as communicating remedy progress to the local
community, highlighting potential issues before they become problems, and assisting the RPM in
completing the five-year review evaluation more efficiently.
The recommended checklist was developed specifically to address contaminated sediment remedies. It
is recommended that any information and data that you use to complete this evaluation be attached to
the checklist, as this should make completing the next year's evaluation easier.
Instructions:
The recommended checklist can be downloaded in Microsoft Word, and filled out electronically. You
may answer most questions with a short narrative statement, with a yes/no response, or by simply
checking the box. Questions that involve a narrative answer will have an expandable text box. For
responses that ask you to "select one," please click on "select one" and choose the correct answer. To
enter text, the user should click to get a cursor in the box and begin typing. If information is not
available or not required for the site, indicate N/A. A site visit is strongly encouraged, but not required
prior to completing the checklist.
1. Generally, RPMs should carry out an O&M remedy evaluation yearly; the information generated by
the recommended checklist can be stored and maintained in an electronic format.
2. For large, complex contaminated sediment sites, RPMs should consider completing a separate
checklist for each Operable Unit (OU).
3. Typically, this evaluation should be based on information already documented for the site. If
appropriate, attach or cite the data that have been used to complete this evaluation (i.e., O&M
reports, monitoring data, etc.), especially when they are readily available to the RPM.
4. Each section of the checklist has specific instructions for completing that part of the checklist. For
example, Section VIII, "Technical Data and Remedy Performance" provides instructions regarding
what data and information should be evaluated and the specific technology that should be used for
that remedial action (RA).
5. When finished, please sign and date the first page. The completed form should be placed in the site
file and saved electronically for use in completing future evaluations.
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Annual O&M/Remedy Evaluation Checklist for Contaminated Sediment Remedies
OSWER 9355.0-118
Acronym List
CSM
CUL
ICs
MNA
MNR
NPL
O&F
O&M
Conceptual Site Model
Cleanup Levels
Institutional Controls
Monitored Natural Attenuation
Monitored Natural Recovery
National Priorities List
Operational and Functional
Operation and Maintenance
OSHA
OU
PCOR
RAO
ROD
RPM
RSE
RG
Occupational Safety and Health
Administration
Operable Unit
Preliminary Close Out Report
Remedial Action Objective
Record of Decision
Remedial Project Manager
Remediation System Evaluation
Remediation Goal
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Annual O&M/Remedy Evaluation Checklist for Contaminated Sediment Remedies
OSWER 9355.0-118
RECOMMENDED ANNUAL O&M/REMEDY EVALUATION CHECKLIST
FOR CONTAMINATED SEDIMENT REMEDIES
Please save electronically and send this completed checklist and any attachments to the site file and site
repository.
I. SIGNATURES AND APPROVALS
RPM
Federal Facilities RPM (if appropriate)
Name:
Name:
Telephone:
Telephone:
Signature:
Date:
Signature:
Date:
State Contact (If appropriate)
Name:
Telephone:
Signature:
II. GENERAL SITE INFORMATION
Date:
A. General Site Information
Complete the following information pertaining to the overall site.
Site Name:
State:
Period Covered:
to
EPA Site ID:
Site Lead:
(Select one)
Other, specify:
Organization responsible for O&M operations:
(Select one)
Number of OUs:
Sediment Remedy Components:
PCOR date:
O&F date:
Last Five-year review date:
NPL deletion date:
B. Sediment Remedy Information
Complete the following information pertaining to the sediment remedy (or portion thereof) being addressed by this
form.
Is this one of multiple OUs or remedy components for the site?
Yes
No
If yes, are you are also completing the overarching O&M checklist form for the site?
If no, please explain.
Yes
No
N/A
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Annual O&M/Remedy Evaluation Checklist for Contaminated Sediment Remedies
OSWER 9355.0-118
Is this one of multiple sediment OUs or one of multiple sediment areas being addressed by the
remedy?
If yes, are you are completing multiple copies of the sediment remedy O&M checklist for the
site this year?
If no, please explain.
If you are completing multiple copies of the sediment remedy O&M checklist for the site this year,
the sediment remedy OU or area being addressed by this form:
Did you make a site visit during this review?
Date of last review:
Location of Administrative Record/Site Files:
What type of monitoring is taking place at the site?
Check all that apply.
DYes
D No
DYes
DNo
D N/A
please identify
D Yes D No Date:
CD Chemical D Bathymetry
D Toxicity D Sediment Transport
CD Benthic Diversity d Other, Please Specify:
During the site visit, was monitoring equipment associated with this sediment remedy C
operational? C
Please elaborate:
Yes D No
N/A
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Annual O&M/Remedy Evaluation Checklist for Contaminated Sediment Remedies
OSWER 9355.0-118
Describe the Chronology of events since the last annual evaluation report (e.g. site visits, receipt of reports,
equipment failures, shutdowns, vandalism, storm events, etc.) that have impacted or may impact this sediment
remedy:
Elaborate on significant events or site visits:
III. DOCUMENTS AND RECORDS
Because these documents may be needed for the five-year review, verify what documents are
currently available on-site, or note off-site location. Identify only those documents associated with
the sediment remedy or part of the sediment remedy being addressed by this form.
Document
O&M Manual
O&M Maintenance Logs
O&M Annual Reports
RA as-built drawings modified during O&M
Site-Specific Health and Safety Plan
Contingency/Emergency Response Plan
O&M/OSHA Training Records
Surface Water/Sediment/Biota Monitoring Records
Cap Inspection Records
On-site Combined Disposal Facility/Landfill Compliance
Records
Institutional Controls Review
Previous Five-Year Review Report
Other(s) (Please name each)
Required
n
n
n
n
n
n
n
n
n
n
n
n
n
n
n
n
n
Not
required
n
n
n
n
n
n
n
n
n
n
n
n
n
n
n
n
n
On-
site
n
n
n
n
n
n
n
n
n
n
n
n
n
n
n
n
n
Off-site (indicate
where)
n
n
n
n
n
n
n
n
n
n
n
n
n
n
n
n
n
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Annual O&M/Remedy Evaluation Checklist for Contaminated Sediment Remedies
OSWER 9355.0-118
IV. ADMINISTRATIVE ISSUES
Identify only those administraw"° :
being addressed by this fo
Check aII that apph
Explanation of Significant Differences for OU involving
sediment in progress
ROD Amendment for OU involving sediment in progress
Site (and sediment remedy component) in operational and
functional (O&F) period
Notice of Intent to Delete site in progress
Partial site deletion (of portion of the site involving
sediment) in progress
Surface water/sediment reuse assessment or reuse plan in
progress
Revised surface water/sediment-related risk assessment in
progress
EH Ecological OR EH Human Health
Other administrative issues:
VI. O&M COSTS
The purpose of this s.
What was the total annual O&M cost for the previous year?
Please provide the breakout of costs below.
Use either $ or %
Analytical (e.g., lab costs):
Materials (e.g., cap materials):
Oversight (e.g., project management):
Monitoring (e.g. sediment sampling):
Utilities (e.g., electric, gas, phone, water):
Institutional Controls (implementation and maintenance):
Other (e.g., capital improvements, equipment repairs):
What is the expected total annual O&M cost for the upcoming year?
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Annual O&M/Remedy Evaluation Checklist for Contaminated Sediment Remedies
OSWER 9355.0-118
Describe any unanticipated/unusually high or low O&M costs and potential future O&M funding
issues.
VII. INSTITUTIONAL CONTROLS (ICs)
Identify each institutional control (media, objective, instrument) implemented/to be implemented at the site.
Attach an extra sheet if necessary.
Are the institutional controls adequate for site protection?
If no, please explain further (and include in the recommendations section).
Yes
No
Please identify the party responsible for compliance and enforcement of the 1C.
Please describe what the ICs are intended to accomplish, who they were designed to inform, the source document
for the 1C, and where the 1C information is located.
Please identify the date when the ICs were implemented. If the institutional controls have yet to be implemented,
please identify the scheduled implementation date.
If the ICs have been implemented, are they still in place?
Yes
No
If the ICs remain in place, please identify whether there is a planned termination date and, if so, what it is.
Are the institutional controls being properly implemented and enforced?
If no, please explain.
VIII. TECHNICAL DATA AND REMEDY PERFORMANC
Yes
No
The purpose of this section is to document remedy performanc
performance, and identify events in the upcoming year that may affect remedy effectiveness/performance. The
following abbreviated set of questions addresses O&M of sediment remedies, including in-situ sediment capping,
dredging, enhanced MNR, MNR and combination remedies. Refer to the following document, as needed, when
completing this form:
• Contaminated Sediment Remediation Guidance for Hazardous Waste Sites
This Guidance encourages the development and use of several measures to monitor short-term and long-term
remedy performance, short-term risk reduction, and long-term risk reduction. A fully successful remedy is defined
as one where chemical or biological cleanup levels have been met and maintained over time, and where all relevant
risks have been reduced to acceptable levels.
A. Remedy, Goals, and Conceptual Site Model (CSM)
1. Summary of remedy components
Dredging
Engineered Cap
Enhanced MNR
Waterbody Use ICs
Wetland Restoration
Excavation
Thin-layer Cap
MNR
Fish Consumption Advisories
Other - please specify
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Annual O&M/Remedy Evaluation Checklist for Contaminated Sediment Remedies
OSWER 9355.0-118
2. Review the Current Remedy Goals
What are the RAOs, cleanup levels (CULs), or remediation goals (RGs) for sediment, water, and/or biota, for each
COC?
What is the time frame to achieve the RAOs and CULs?
Is there a reason to change the RAOs or CULs? Note: this might be due to unrealistic RAOs or CULs or
RAOs or CULs that were based on inaccurate models - e.g., even though sediment CULs have been
achieved, fish tissue CULs or benthic toxicity have not been appropriately reduced.
If yes, please explain.
D Yes
D No
3. Review of Changes to the CSM
Have new contaminant sources been identified?
If yes, please describe the new sources and how they are being addressed:
Have changes in land use or water body use that could impact the CSM occurred since the ROD?
Please explain.
Should the CSM be modified to reflect changes in exposure pathways, other sources, new fate and
transport information, new hydrology, erosion or deposition data, etc.? Please explain.
If a computer model was used to help select the remedy and/or CULs, have monitoring data been used
to validate it? Please explain.
D Yes
D No
D Yes
D No
D Yes
D No
D Yes
D No
B. Remedy Performance Assessment
This section contains a series of questions that can be used to help assess a sediment remedy's effectiveness and
evaluate the collection and analysis of performance monitoring data.
1. Monitoring Program
The following questions can be used to assess the effectiveness of the remedy performance monitoring program
and apply to monitoring of sediment, surface water, and biota, monitoring of in-situ cap integrity, and monitoring
of natural recovery processes.
Is the monitoring program accomplishing the objectives outlined in the ROD or in a subsequent
enforceable document?
If no, identify the objectives that are not being met.
Do field parameter data indicate trends/patterns that are consistent with CSM used as the basis for the
sediment remedy?
Have there been changes in field conditions (e.g., change in flow/deposition rates or patterns) that
suggest that the monitoring program should be reevaluated?
Are the baseline data and post-remedy data adequate to perform statistical comparisons to post-
remedy data? If no, please explain how remedy effectiveness will be evaluated.
D Yes
D No
D Yes
D No
D Yes
D No
D Yes
D No
What techniques and/or models are being used to evaluate the adequacy/redundancy of the monitoring network
(i.e., sediment, surface water, and biota sampling locations) and the adequacy/redundancy associated with
sampling frequency?
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Annual O&M/Remedy Evaluation Checklist for Contaminated Sediment Remedies
OSWER 9355.0-118
How do the sampling and analytical methods, monitoring parameters, and test methods - including methods
associated with monitoring sediment and surface water quality, toxicity and bioassessment studies, and monitoring
cap integrity - reflect a cost-effective approach to meet monitoring performance objectives?
Does the monitoring program need to be modified in order to make scientifically defensible decisions
on reduction in risk? Please explain.
D Yes
D No
Describe changes to the monitoring program that have been made since the last time you completed the O&M
checklist for this remedy or that are planned to address each of the following conditions:
Reason for Change Description of Change ijf I?65
One or more monitoring performance D
objectives not being met
Cost-effectiveness of monitoring program d
Do you have adequate documentation (e.g., good quality O&M reports) to effectively manage and
interpret monitoring data?
If no, please explain.
Changes
Planned
°
n
D Yes
D No
2. Evaluating Remedy Performance
Have both interim and final goals been established as a means for d Yes, final goals only
evaluating remedy performance? Q Yes, interim and final goals
D Goals have not been established
Please explain. f°r this purpose
What timeframe(s) has (have) been established to reach the remediation interim and final goal(s)?
Is the sediment remedy performing as expected relative to the remediation interim and final goal(s)?
Have the appropriate CULs been achieved and maintained? Check all that apply:
D Sediment CULs D Fish CULs D Surface Water CULs Please explain.
Is the rate of change in risk measures large enough to determine remedy is likely to be effective in the
timeframe allotted; i.e., RAOs and CULs will be achieved? Please explain.
For capping components, do the data demonstrate that the level of cap erosion and/or contaminant
flux, if any, have not and will not compromise the integrity of the cap or the protectiveness of the
remedy? Please explain.
For MNR areas, do the data demonstrate that deposition or other processes are occurring at the rates
that will achieve RAOs in the time frame allotted? Please explain.
D Yes
D No
D Yes
D No
D Yes
D No
D Yes
D No
D Yes
D No
3. Maintenance (In-situ Capping)
If some cap erosion has been observed, was it enough to warrant cap repair?
If no, how was this decision made?
Have any major repairs to the in-situ cap(s) been required since the last time you completed the O&M
checklist for this remedy?
D Yes
D No
D Yes
D No
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Annual O&M/Remedy Evaluation Checklist for Contaminated Sediment Remedies
OSWER 9355.0-118
If yes,
• What major repairs were required?
• How did the need for repairs affect progress toward meeting remediation milestones and goals?
• What actions have been taken to minimize repairs in the future?
• What effects were caused by the cap breach?
C. Remedial Decisions: Indicate which of the following remedial decisions are appropriate at the present time
and provide a basis for each decision:
No Change to the Remedy is Needed (Remedy is Performing as Designed)
No Decision Can be Made due to Inadequate Data
Modify/Optimize Remedy
Contingency/Alternative Remedy (i.e., Change Remedy)
Modify/Optimize Operation and Maintenance Program
Modify Institutional Controls
Terminate Some or All Monitoring Requirements
Basis for decision:
IX. RECOMMENDATIONS
Recommendations associa
addressed by this form
Recommendations, based on this annual review:
Recommendation
Party
Responsible
Milestone Date
Affects Protectiveness (Y/N)
10
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