Recommended Annual O&M/Remedy Evaluation Checklist
OSWER 9355.0-87
         ECOMMENDED ANNUAL O&M /REMEDY EVALUATION CHECKLIS
 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.

 The recommended Annual O&M Remedy Evaluation  Checklist has been  designed to help the Remedial Project
 Manager (RPM) capture data routinely collected during O&M in a way that can better evaluate the efficiency and
 effectiveness of the remedial action. This recommended checklist may  also be used to  evaluate an operating
 remedy prior to transferring the site to  the State for O&M.  In addition,  remedy performance summarized  using
 this recommended checklist can be used to communicate  remedy  progress to the local community,  highlight
 potential issues before they become problems and help the RPM complete five-year reviews  more efficiently.

 The information that you collect using this recommended form should  help you answer the following questions:

 •  Is the remedy achieving the remedial action objectives  (RAOs),  maintaining cleanup goals and/or achieving
    technology-specific performance goals?
 •  If the remedy is not achieving the established objectives and goals,  what must I do to correct this  and how
    can I document this?
 •  If the remedy is  achieving the performance goals, objectives and  performance standards,  are there any
    opportunities to optimize the remedy to make it work more efficiently?

 This recommended checklist is intended  to be completed annually. It is recommended that any data that you use
 to complete this evaluation be attached to the checklist, as this will  make completing the next year's evaluation
 easier.

 This  recommended checklist  does not  recommend  the level of review  carried out in the U.S.  Environmental
 Protection Agency (EPA) five-year review process. However the recommended checklist contains review  elements
 that are consistent with a five-year review process.
 Instructions:
 The recommended checklist is in Microsoft Word and was designed to be completed electronically. Most questions
 involve a short answer, yes/no response or simply checking the box.  Questions that involve a short answer will
 have an expandable text box.  For responses that ask to you to "select one," please double click on "select one"
 and choose the correct answer.  If the information is not available for a  particular question, please indicate this
 with a N/A. A site visit is strongly encouraged, but not required prior to completing the recommended checklist.

 1. This evaluation is intended to be completed yearly once O&M activities have begun at a site and can be stored
    and maintained  in an  electronic format.
 2. For large complex sites, consider completing a separate checklist for each Operable Unit (OU).
 3. This evaluation  should be based on information and documentation (e.g., O&M  reports and  monitoring data)
    that is readily available to the RPM.
 4. Section VIII, "Technical  Data  and  Remedy  Performance," provides specific instructions regarding what data
    and  information are important for this section. Data entered in Section VIII are used  to evaluate the specific
    technology used  in  that remedial action  (RA).  Please  note:   Section VIII, Appendix E, Other Remedy
     Types/Components was designed to be used by the RPM for the annual review of O&M remedies and remedy
    components that are  not addressed in Appendices A through D or by the separate Recommended Annual O&M
    Remedy Evaluation Checklist for Contaminated Sediment Remedies, OSWER #9355.0-118.
 5. When you have completed the recommended checklist, please sign and date page 1 and place the completed
    document in the site  file. Additionally, we recommend that you save the completed  checklist electronically for
    use in completing the next year's evaluation.

 Generally,  including the Recommended Annual O&M/Remedy Evaluation Checklist in the site repository can provide
 the community with information about O&M status and remedy performance and can demonstrate that the Region
 is tracking performance to ensure that the remedy remains protective.

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Recommended Annual O&M/Remedy Evaluation Checklist
OSWER 9355.0-87
Acronym List

AS
CSM
GAC
ICs
LEL
LIRA
MNA
NPL
O&F
O&M
OSHA
OU
Air Sparging
Conceptual Site Model
Granular Activated Carbon
Institutional Controls
Lower Explosive Limit
Long-Term Response Action
Monitored Natural Attenuation
National Priorities List
Operational and Functional
Operation and Maintenance
Occupational Safety and Health
Administration
Operable Unit

PCOR
PRGs
PRP
RAO
ROD
RPM
RSE
SVE
TI Waivers
USAGE
VEB
VOCs
Preliminary Close Out Report
Preliminary Remediation Goals
Potentially Responsible Party
Remedial Action Objective
Record of Decision
Remedial Project Manager
Remediation System Evaluation
Soil Vapor Extraction
Technical Impracticability Waivers
U.S. Army Corps of Engineers
Vertical Engineered Barrier
Volatile Organic Compounds

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 Recommended Annual O&M/Remedy Evaluation Checklist
                                                                                    OSWER 9355.0-87
       RECOMMENDED ANNUAL O&M /REMEDY EVALUATION CHECKLIST
Please save electronically and send this completed checklist and any attachments to the site file and site repository.
    ra
RPM
              S AND APPROV
                                                  RPM (If appropriate)
Name:
                                                  Name:
Telephone:
                                                  Telephone:
Signature:
                                      Date:
Signature:
             Date:
State Contact (if appropriate)
Name:
Telephone:
Signature:
II. GENERAL SITE INFORMATION
Site Name:
                                                                                          Date:
State:
Period Covered:
                                           to
                                                                             EPA Site ID:
Site Lead:
                (Select one)
                                           Other, specify:
Organization responsible for O&M operations:     (Select one)
Other, specify:
Site Remedy Components (ref. Section VIII):
Preliminary Close Out Report (PCOR) date:
Operational & Functional (O&F) date:
Last five-year review date:
NPL deletion date:
Did you make a site visit during this review?
                                         D Yes
        D  No
Date:
If no, why:
Date of next planned checklist evaluation:
Location of Administrative Record/Site Files:
During the site visit, was monitoring equipment operational?
                                                                             D Yes D No   D N/A
Please elaborate:
                                                  D  N/A   D Yes  D  No
Has an Optimization Study been conducted at the site?
                           Date:
If not, is one planned?
List all site events since the last evaluation that impact or may impact remedy performance.
Chronology of events since last report (e.g., site visits, receipt of reports, equipment failures, shutdowns, vandalism,
storm events):
Elaborate on significant site events or visits to site:

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 Recommended Annual O&M/Remedy Evaluation Checklist
OSWER 9355.0-87
III. DOCUMENTS AND RECORD
Because  these  documents may
currently available on-site, or note off-site location:
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/Occupational Safety and Health Administration
(OSHA) Training Records
Settlement Monument Records
Gas Generation Records
Ground Water Monitoring Records
Surface Water/Sediment/Fish Monitoring Records**
Cap/Cover System Inspection Records
Leachate Extraction Records
Discharge Compliance Records
Institutional Controls (ICs) Review
Other(s) (Please name each)




Required
D
D
D
D
D
D
D
D
D
D
D
D
D
D
D
D
D
D
D
D
Not
required
D
D
D
D
D
D
D
D
D
D
D
D
D
D
D
D
D
D
D
n
On-
site
n
n
n
n
n
n
n
n
n
n
n
n
n
n
n
n
n
n
n
n
Off-site (indicate
where)
D
D
D
D
D
D
D
D
D
n
n
n
n
n
n
n
n
n
n
n
   Note: A separate O&M checklist has been developed for surface water/sediment remedies. For completeness, answer this question
 regarding documentation requirements and availability, and enter more detailed information in the surface water/sediment checklist.
 IV. ADMINISTRATIVE I
 Check aII that apph
     Explanation of Significant Differences in progress
     Record of Decision (ROD) Amendment in progress
     Site in O&F period
     Long-Term Response Action (LTRA) in progress
     LTRA Transition to O&M in progress
     Notice of Intent to Delete site in progress
     Partial Site Deletion in progress
     Technical Impracticability (TI) Waivers in progress
     Reuse Assessment or Reuse Plan in progress
     Revised Risk Assessment in progress
     CD Ecological OR d Human Health
     Other administrative issues:

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Recommended Annual O&M/Remedy Evaluation Checklist
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VI. O&M COSTS
The purpose of this s
cost information will be readily available, but to the extent possible, please provide the following information, as this
will help identify cost increases and flag potential budget issues before they arise.
HMMMM(IHilM(MIBMMMI(MMI1MMIMilHIM(.MlaBM(MMIHalML mmmimtmm
What was the total annual O&M cost for the previous year?
What is the expected total annual O&M cost for the upcoming year?
Please provide an approximate breakout of the previous
year's O&M costs below.
Analytical (e.g., lab costs):
Materials (e.g., treatment chemicals, cap materials):
Oversight (e.g., project management):
Monitoring (e.g., ground water sampling):
Utilities (e.g., electric, gas, phone, water):
ICs (implementation and enforcement):
Other (e.g., capital improvements, equipment repairs):


Use either $ or %







Describe any unanticipated/unusually high or low O&M costs and potential future O&M funding issues.


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Recommended Annual O&M/Remedy Evaluation Checklist
                                                                                       OSWER 9355.0-87
VII. INSTITUTIONAL CONTROLS (ICs)**
The purpose of the 1C evaluation at the O&M phase is to determine if the ICs are implemented, effective and
durable. The following references may be useful for completing this evaluation:
•  Institutional Controls Bibliography:  Institutional Control, Remedy Selection, and Post Construction Completion
   Guidance and Policy (OSWER 9355.0110, December 2005);
•  Supplement to the Comprehensive Five- Year Review Guidance; Evaluation of Institutional Controls (OSWER
   9355.7-12, working draft 3/17/05);
•  National 1C Strategy to Ensure Institutional Controls Implementation at Supetfund Sites (OSWER 9355.0-106,
   September 2004); and
•  Institutional Controls: A Site Manager's Guide to Identifying, Evaluating and Selecting Institutional Controls at
   Superfund and RCRA Corrective Action Cleanup (OSWER 9355.0-7-4FS-P, September 2000).
** Note: A separate O&M checklist has been developed for surface water/sediment remedies. For completeness,
answer this question regarding ICs, and enter more detailed information in the surface water/sediment checklist.
Identify each 1C (media, objective, and instrument) implemented/to be implemented at the site. Attach an extra
sheet if necessary.
Are the ICs adequate to minimize the potential for human exposure and protect the integrity of the
remedy?
    If no, please explain.
                                                                                                  B
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 are 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 ICs have yet to be implemented, please identify the
party responsible for implementing the ICs and the scheduled implementation date.
If the ICs have been implemented, are they still in place?  If the ICs remain in place, please identify whether there is
a planned termination date and, if so, what it is.
                                                                                                 H
Are there reasons to clarify or modify the appropriate decision document(s) to improve the effectiveness
and/or durability of the ICs?
    If yes, please explain and describe any plans to clarify/modify the document(s).
Yes
No

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Recommended Annual O&M/Remedy Evaluation Checklist
                           OSWER 9355.0-87
VIII. TECHNICAL DATA AND REMEDY PERFORMANCE
The purpose of this section is to help prompt questions about remedy performance over the past year, the adequacy
of monitoring activities to assess remedy performance, and changes in field conditions or understanding that could
affect the remedy. Specific sections also prompt questions about remedy optimization. Addressing these questions
on an annual basis can help to flag opportunities and potential issues to watch in the coming year and help inform
future improvements in remedy O&M. The collection of annual checklists can also serve as documentation of when
a potential  issue was first identified, what was done to address it, and  when it was addressed. Thus, an  annual
checklist can be a useful, succinct source of information to help RPMs recount O&M history.
Questions for specific remedy types (e.g., ground water pump-and-treat) are contained in Appendices A through D
at the end of the form. Appendix E contains general questions that can be  used to document technical data and
remedy performance for remedies and remedy components that do not fit within the specific  categories identified in
the remainder of this checklist.  Identify the remedy types in Section VIII.A, below, and complete a copy of each
appendix that is applicable to the site.  If the site includes multiple remedies or remedy components of the same
type, please complete a copy of the applicable appendix for each remedy/component (e.g.,  if the remedy includes
two separately managed containment areas, complete two copies of Appendix C, one for each area).  A separate
O&M checklist  has been developed for  surface water/sediment remedies and  remedy  components.   If the site
includes a surface water/sediment remedy, note  this below and complete the surface water/sediment checklist.
A. Please identify the type(s) of remedy(ies) this Annual O&M Remedy Evaluatior
                            clist addresses:
    Ground Water Pump-and-Treat (please complete Appendix A)
    Ground Water Monitored Natural Attenuation (MNA) (please complete Appendix B)
    Ground Water or Soil Containment (please complete Appendix C)
    Soil Vapor Extraction/Air Sparging (please complete Appendix D)
    Other Remedy Types (please complete Appendix E)
IX. RECOMMENDATIO.
New Recommendations, from this annual review:
                Recommendation
Party Responsible
Milestone Date

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Recommended Annual O&M/Remedy Evaluation Checklist
OSWER 9355.0-87
                                         APPENDICES
                       TECHNICAL DATA AND REMEDY PERFORMANCE
                      ANNUAL O&M /REMEDY EVALUATION CHECKLIST
 RECOMMENDED APPENDIX A. GROUND WATER PUMP-AND-TREAT

 REMEDIES
 The following checklist is an abbreviated set of questions that could be used by an EPA RPM for annually reviewing
 the O&M of a ground water pump-and-treat remedy, including  pump-and-treat remedies designed for hydraulic
 containment. This checklist was developed using  concepts presented  in EPA guidance, Elements for Effective
 Management of Operating Pump and Treat Systems (EPA 542-R-02-009, December 2002).  This guidance is part
 of a series of fact sheets that EPA OSRTI has prepared as guidance to the ground water remediation community
 on  effectively and efficiently designing and operating long-term ground water remedies.  For more information,
 including the guidance O&M Report Template for Ground Water Remedies (with Emphasis on Pump and  Treat
 Systems} (EPA 542-R-05-010, April 2005) and report Pilot Project to Optimize Superfund-Financed Pump and Treat
 Systems:  Summary Report  and  Lessons  Learned  (EPA  542-R-02-008a),  visit  EPA's  CLU-IN  Website
 (www.cluin.org/).
A. Remedy Goals and Conceptual Site Model (CSM)
 1. Review of the current remedy goals and measurements: Remedy goals may be expressed in terms of a
 broad, long-term purpose or intent specified in a decision document (e.g., cleanup to a specified concentration), a
 performance-based metric  or  milestone intermediate in  duration  (e.g.,  a 20% decrease  in monthly  influent
 concentrations within 24 months of operation);  or a specific and  short-term objective  (e.g., demonstration of
 plume containment).
 List the short-term objectives and intermediate system goals:
 List the final system goals:
What metrics (performance criteria) are being implemented to measure  project progress towards meeting each
goal?
What schedule has been established for measuring and reporting each metric?
 Based on new information or events since the last O&M review, is there a reason to re-evaluate the
 system goals?  Note: this might be due to factors such as regulatory framework has been revised; better
 technology/strategy alternatives available; existing goals appear unrealistic; costs greater than originally
 anticipated; extent of plume has changed; new sources of contamination removed and/or discovered; or
 land use or ground water production near site has changed.
 If yes, identify the  remedy  goals that  should be re-evaluated, the  rationale, and any plans for re-
 evaluating the goals.
 2.  Review of changes to the  CSM:   The CSM is  a combination  of text and figures that describe the
 hydrogeologic system, the cause of the ground water impacts, and the fate and transport of the ground water
 contaminants.  If monitoring data during active remediation do not agree with expectations, this could point to a
 gap in the conceptual model that should be addressed with a focused investigation. This does not imply a return to
 the "remedial investigation" phase. The CSM should evolve over time, including during active remediation, as more
 information about the site becomes available.  The following  questions  may be used to evaluate the need for
 updating the CSM:
Since the last time you completed the O&M checklist for this system, have new contaminant sources
been identified  or have  previously  suspected contaminant sources been  eliminated  from further
consideration?
       If yes, use this space to comment.
Since the last time you completed an O&M  checklist for this system, have new contaminants been
identified in the ground water that could affect remedy effectiveness?
       If yes, use this space to comment.
 Based on your answers to the above questions, would it be useful to update the CSM at this time?
                                                                                                A-1

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Recommended Annual O&M/Remedy Evaluation Checklist OSWER 9355.0-87
If yes, please describe any plans to update the CSM.
B. Remedy Performance Assessment
1. Evaluate remedy effectiveness: The following questions are intended to review whether the ground water
pump-and-treat remedy is performing as intended and whether there are opportunities for optimizing the remedy.
Plume Capture
When addressing these questions, it may be useful to refer to A Systematic Approach for Evaluation of Capture
Zones at Pump and Treat Systems (EPA 600/R-08/003, January 2008).
Has a three-dimensional target capture zone been clearly defined? Q yes
If no, use this space to explain why not. Q No
If not clearly defined, describe plans to better define the target capture zone.
What lines of evidence have been used to evaluate actual capture achieved (e.g., flow budget and/or capture zone
width calculations, potentiometric surface maps, water elevation pairs, concentration trends at wells beyond the
target capture zone, particle tracking in conjunction with ground water modeling, tracer tests)
System Equipment/Structures (e.g., extraction wells, collection systems)
Since the last time you completed an O&M checklist for this system, has the downtime associated with
non-routine operations and maintenance exceeded expectations?
If yes, what systems have been responsible for unplanned downtime (e.g., extraction pumps,
wastewater facilities)?
If yes, what corrections have been or are being made to minimize downtime?
Since the last time you completed the O&M checklist for this remedy/remedy component, have any
major repairs to the pump-and-treat system(s) been required?
If yes, describe the repairs, their impact on progress toward remediation milestones, and
actions taken to minimize similar repairs in the future.
Since the last time you completed an O&M checklist for this system, have the extraction/injection well
rates changed significantly?
If yes, describe the known/suspected source of the change, if identified.
If yes, is the change reflective of a long-term condition and, if so, how will this be addressed in
the O&M of the system?
Since the last time an O&M checklist was completed for this system, have air emissions from the
system met permit requirements, if any?
If not, what is being done to meet the permit requirements?
Since the last time an O&M checklist was completed for this system, has effluent discharge met permit
requirements?
If not, what was (is) the problem and what was (or will be) done to correct it?
D Yes
D No
D Yes
n NO
D Yes
n NO
D Yes
n NO
n N/A
D Yes
n NO
Optimization
Has an optimization study been conducted for this system?
If an optimization study has been conducted, have any of the optimization recommendations been
implemented since the last time an O&M checklist was completed for this system?
D Yes
n NO
D Yes
n NO
n N/A
If optimization recommendations have been implemented (during this or prior review periods), describe any new
results observed or conclusions drawn since the last time an O&M checklist was completed for this system.
If optimization recommendations have not been implemented, why not?
A-2

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2. Evaluate collection and analysis of performance monitoring data
Do the approaches used to interpret ground water monitoring data (e.g., concentration trend analyses,
plume contour and/or bubble maps, plume cross-sections, potentiometric surface maps) provide
adequate information to assess the performance of the pump-and-treat remedy?
If no, describe plans, if any, to implement new approaches.
Based on information collected since the last O&M review, is there a need to re-evaluate the
parameters, sampling methods, sampling frequency, and monitoring locations used to evaluate remedy
performance?
Are ground water data managed electronically?
If no, use this space to explain why not.
Are performance-monitoring reports of sufficient quality and frequency to evaluate the efficacy of the
remedy and recognize protectiveness problems in time for effective action?
If no, what actions, if any, have been taken or are planned to address this situation?
D Yes
D No
DYes
DNo
D Yes
D No
D Yes
n NO
C. Cost Effectiveness
Are actual parameters consistent with design parameters (based on process monitoring)?
If not, how do they differ? (check all that apply)
D Influent rate to treatment plant
D Influent concentrations
n Mass loading to the system
D Removal efficiency for each treatment component
D Air to water ratio (air strippers)
D Materials usage (e.g., granular activated carbon (GAC), chemicals)
D Other (please explain )
Based on the above comparisons, have any above ground systems or process monitoring procedures
been evaluated/implemented to reduce costs?
If yes, please identify which of the following have been done to reduce costs, (check all that
apply)
D Ensuring proper maintenance and efficiency of equipment
D Replacing treatment components with alternate technologies (e.g., replace UV/Oxidation
with air stripping) or more appropriately sized components
D Eliminating unnecessary or redundant treatment components that are no longer needed
(e.g., metals removal or GAC polishing system)
D Changing discharge
n Automating system to reduce labor
D Optimizing ground water extraction rates and/or locations
D Other (please explain )
D Yes
n NO
D Yes
n NO
D. Remedial Decisions: Indicate which of the following remedial decisions is appropriate at the present time
and provide the basis for the decision.
n No Change to the System
D Modify/Optimize System
_ Modify/Optimize Monitoring Program
D 1C Modifications
n Implementation of Contingency/Alternative Remedy
Basis for decision:
                                                                                          A-3

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Recommended Annual O&M/Remedy Evaluation Checklist
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RECOMMENDED APPENDIX B.  GROUND WATER MONITORED NATURAL
ATTENUATION (MNA) REMEDIES

The following checklist is an abbreviated set of questions that could be used by an EPA RPM for annually reviewing
the O&M of a MNA remedy for ground  water. This MNA guidance  checklist was developed  using concepts
presented in EPA guidance, Performance Monitoring of MNA Remedies for [volatile organic compounds] (VOCs) in
Ground Water (EPA/600/R-04/027; April 2004). For some approaches, a more detailed remedy optimization study
or remediation system evaluation (RSE) may be beneficial. For guidance on remedy optimization studies or RSEs,
visit EPA's CLU-IN Website (www.cluin.org/) or the U.S. Army Corps of Engineers (USAGE) Hazardous, Toxic and
Radioactive Waste Center of Expertise RSE Website (www.environmental.usace.army.mil/)
A. Remedy Goals and Conceptual Site Model (CSM)
1. Review of the current remedy goals and measurements: The remedy goals may be expressed in the
ROD as remedial action objectives (RAOs) and  preliminary remediation goals (PRGs).  RAOs provide a  general
description of what the cleanup will accomplish  (e.g., restoration of ground water). PRGs are the more  specific
statements of the desired endpoint concentrations or risk levels, for each  exposure route, that are believed to
provide adequate protection of human health and the environment.
List the intermediate system goals (RAOs and PRGs).
List the final system goals (RAOs and PRGs).
What metrics (performance criteria) are being  implemented to measure project progress towards meeting each
goal?
What schedule has been established for measuring and reporting each metric?
Based on new information or events since the last review, is there a need to  re-evaluate the
remedy goals? Note: this might be due to factors such as whether the regulatory framework has
been revised, whether existing goals appear realistic, and if there have been changes to land use
or ground water production near the site.
If yes, identify the remedy goals that should be re-evaluated, the rationale, and any plans for re-
evaluating the goals.
  B
Yes
No
2. Review of changes to the  CSM:   The CSM for natural attenuation is the  site-specific  qualitative  and
quantitative description of the migration and fate  of contaminants with respect to possible receptors and the
geologic, hydrologic,  biologic,  geochemical  and anthropogenic factors that  control  contaminant  distribution.
Because the CSM provides the  basis for the remedy and monitoring plan, it can be reevaluated as new data are
developed throughout the lifetime of the remedy. The following questions may be used to evaluate the need for
updating the CSM:
Have  new  contaminant sources been  identified  or have previously suspected contaminant
sources been eliminated from further consideration since the last time you completed the O&M
checklist for this remedy?
If yes, use this space to comment.
  B
Yes
No
Has there been an increase or decrease in size of the plume since the last time you completed an
O&M checklist for this remedy?
Comments (e.g., what is the nature and magnitude of the change).
  D
Increase
Decrease
No change
Has there been an increase or decrease in vertical extents of the plume since the last time you
completed an O&M checklist for this remedy?
Comments (e.g., what is the nature and magnitude of the change).
  D
Increase
Decrease
No change
Has there been an increase or decrease  in the maximum contaminant concentrations  in the
plume since the last time you completed an O&M checklist for this remedy?
Comments (e.g.,  have maximum concentrations changed for all or a  subset of contaminants,
which ones, and by how much).
  D Increase
  CD Decrease
  CD No change
What types of reaction zone(s) are present in the plume (aerobic, anaerobic, or both)?
                                                                                                 B-1

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Based on information collected since the last O&M review, is there a need to re-evaluate the
number and/or location of monitoring points in the reaction zone(s)?
If yes, use this space to comment.
Based on information collected since the last O&M review, is there a need to re-evaluate the
number and/or location of monitoring points in the target zones?
If yes, use this space to comment.
Has there been a change in ground water flow rate or direction that may suggest monitoring
frequency or locations may need to be reevaluated?
If yes, use this space to comment.
Is there evidence of periodic pulses of residual contamination from the vadose zone that suggest
new monitoring points should be added in the vadose zone?
If yes, use this space to comment.
D Yes
D No
D Yes
D No
D Yes
D No
D Yes
D No
If there is reason to re-evaluate the number and location of monitoring points and/or monitoring frequency (as
indicated in above responses), identify any plans for re-evaluating the monitoring program.
Based on your responses to the above questions, would it be useful to update the CSM at this time?
If yes, please describe any plans to update the CSM.
D Yes
D No
B. Remedy Performance Assessment
1. Review performance monitoring objectives. The OSWER Directive 9200.4-17P (U.S.
eight specific objectives for the performance-monitoring program of an MNA remedy.
EPA, 1999a) provides
For each of the following eight performance monitoring objectives, identify which are currently being met, which
are currently being met but could benefit from further review, and which are currently not being met.
Objective
1) Demonstrate that natural attenuation is occurring according to expectations
2) Detect changes in environmental conditions that may reduce the efficacy of
any of the natural attenuation processes
3) Identify any potentially toxic and/or mobile transformation products
4) Verify that the plume(s) is not expanding downgradient, laterally or vertically
5) Verify no unacceptable impact to downgradient receptors
6) Detect new releases of contaminants to the environment that could impact
the effectiveness of the natural attenuation remedy
7) Demonstrate the efficacy of ICs that were put in place to protect potential
receptors
8) Verify attainment of remediation objectives
Status
Being
met
D
D
D
D
D
D
D
D
If any of these objectives are not being met or would benefit from review, please describe
the objective not being met, why might the objective benefit from further review).
Benefit
from
review
D
D
D
E
D
D
D
D
Not
being
met
Q
D
D
3
Q
D
D
G
(e.g., in what way is
Describe any plans to review and/or change the location, frequency or types of samples and measurements to
meet this (these) objective(s).
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2. Evaluate remedy effectiveness: The following questions are intended to review whether the MNA remedy is
performing as intended, or whether there may be a need to implement a contingency remedy.  A contingency
remedy is a cleanup technology or approach that  functions as a backup  remedy in the event that the selected
remedy fails to perform as anticipated.
Since the last O&M  review,  have contaminant concentrations in soil or ground  water at specified
locations exhibited an increasing trend not originally predicted during remedy selection?	
                                                                                                   Yes
                                                                                                   No
Since the last O&M review, have near-source wells exhibited large concentration increases indicative of a
new or renewed release?
                                                                                                   Yes
                                                                                                   No
Since the last O&M review, have contaminants been detected in monitoring wells located outside of the
original plume boundary or other compliance-monitoring boundary?
                                                                                                   Yes
                                                                                                   No
Since the last O&M review, have analyses concluded that the rate of decrease of contaminant
concentrations may be inadequate to meet the remediation objectives?

-
Yes
No
Since the last O&M review,  have changes in land  and/or ground water use been  suggested  and or
implemented that have the potential to reduce the protectiveness of the MNA remedy?
                                                                                                   Yes
                                                                                                   No
Since the last review, have contaminants been identified in  locations that pose or have the potential to
pose unacceptable risk to receptors?
                                                                                                   Yes
                                                                                                   No
If you answered yes to any of the above questions, did the information suggest the
need for immediate action or is the condition being monitored to evaluate the need for
future action?
       Use this space to comment.
                                                                                    Immediate action
                                                                                    Monitored for future
                                                                                    N/A
Based on your answers to the above questions, is there  reason to evaluate the need for a contingent
remedy at this time?
       If yes, use this space to comment.
                                                                                                   Yes
                                                                                                   No
3. Evaluate collection and analysis of performance monitoring data
What evidence  has been used to evaluate actual plume  dissipation (e.g., temporal trends in individual wells,
estimation of mass  reduction, comparisons of observed contaminant distributions with predictions and required
milestones, comparison of field-scale attenuation rates)?
Since the last O&M review, has it been necessary to modify the site-specific plans (e.g., Sampling and
Analysis Plan, Quality Assurance  Project Plan, Data  Management Plan) to account for new information
and/or unforeseen circumstances?
       If yes, use this space to comment.
                                                                                                B
Yes
No
                                                                                                H
Does  information collected  since the  last O&M review suggest the  need to evaluate  whether field
parameters that are critical to an MNA evaluation (e.g., dissolved  oxygen, redox potential) are being
collected at appropriate monitoring points?
       If yes, use this space to comment.
Yes
No
                                                                                                H
Do the approaches used to interpret ground water monitoring data (e.g., concentration trend analyses,
plume  contour and/or  bubble  maps,  plume  cross-sections,  potentiometric surface maps) provide
adequate information to assess the performance of the natural attenuation remedy?
       If no, describe plans, if any, to implement new approaches.
Yes
No
                                                                                                H
                                                                                                H
Does information collected since the last O&M review suggest the need to re-evaluate the ground water
and soil-monitoring program to more accurately delineate and monitor the plume boundary?
       If yes, use this space to comment.
Yes
No
Since the  last O&M review,  has it been necessary to modify the data quality assessment, including
statistical tests (if appropriate),  regression  analysis, scatter plots, etc. to account for new information
and/or unforeseen circumstances?
       If yes, use this space to comment.
Yes
No
Are ground water data managed electronically?
       If no, use this space to explain why not.
                                                                                                   Yes
                                                                                                   No
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       If statistical tests are used, do the data meet the assumptions of the statistical test?
                                                                                                    Yes
                                                                                                    No
If no, does this suggest the need to change the monitoring program or re-
evaluate the statistical approach?
       Use this space to comment.
                                                                         CD Evaluate monitoring program
                                                                         CD Evaluate statistical approach
                                                                         n Neither
Is high variability in the data interfering with or preventing a meaningful interpretation of the data?

If yes, could this situation be mitigated by increasing the density or frequency of sampling?

       Use this space to comment.
       Are performance-monitoring reports of sufficient quality and frequency to evaluate the efficacy of
       MNA as a remedy and recognize protectiveness problems in time for effective action?
       If no, what actions, if any, have been taken or are planned to address this situation?
                                                                                                 B
Yes
No
                                                                                                 H
Are techniques or models being used  to  evaluate  adequacy/redundancy  of individual  wells in the
monitoring network, and adequacy/redundancy of sampling frequency?  Note that techniques may range
from statistical trend analysis to application of a decision support tool.
Yes
No
If  no,  are there plans  to  evaluate  the  adequacy/redundancy of individual  monitoring wells and/or
sampling frequency?
       Use this space to comment.
                                                                                                 B
Yes
No
C.  Cost Effectiveness:  Key considerations in looking  at cost-effectiveness of an MNA remedy are the list of
parameters for monitoring,  as well  as the frequency and  location of monitoring.   Decreases in monitoring
parameters, frequency or locations may be appropriate and allow for reductions in project monitoring costs.  For
example, decreases in monitoring frequency for certain parameters may be warranted if the remedy is proceeding
according to expectations  and trends are stable after evaluation of data from a  sufficient number of monitoring
periods (e.g., many years). To support such a decision, the available data generally cover a time period sufficient
to allow for an evaluation of seasonal trends and other long-term cycles and trends.	
                                                                                                 H
Does  information collected since  the  last O&M review suggest opportunities to eliminate monitoring
points (e.g., because of redundancy, unreliability, or changes in program objectives)?
       If yes, use this space to comment.
Yes
No
                                                                                                 H
Does information collected since the last O&M review suggest opportunities to replace current analytical
and sampling methods with less expensive methods and still meet the data quality objectives?
       If yes, use this space to comment.
Yes
No
Can the analyte list be shortened to focus on the known contaminants of concern?
                                                                                                    Yes
                                                                                                    No
D.  Remedial Decisions: Following data evaluation, decisions are routinely made regarding the effectiveness of
the MNA remedy, monitoring  program, and  ICs, and  the need for contingency or alternative remedies. The
following remedial decisions are discussed in Section 4 of the EPA guidance document Performance Monitoring of
MNA Remedies for VOCsin Ground Wafer (EPA/600/R-04/027; April 2004).  Indicate which of the following remedial
decisions is appropriate at the present time and provide the basis for the decision.	
     No Change to the Monitoring Program
     Modify/Optimize Monitoring Program
     1C Modifications
     Implementation of Contingency/Alternative Remedy
     Terminate Performance Monitoring and Initiate Verification Monitoring
Basis for decision:
                                                                                                      B-4

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RECOMMENDED APPENDIX C. CONTAINMENT REMEDIE
The following checklist is an abbreviated set of questions that could be used by a EPA ,.,,-,
of the O&M of a containment remedy  and associated off-gas treatment system.   This  checklist focuses on
engineered  containment remedies, including landfill  caps, covers,  and  vertical engineered barriers (VEB).
Containment by other means such as hydraulic control and  in-situ sediment containment remedies are not
addressed by this appendix.   See separate surface water/sediment remedy  checklist for  sediment  remedies.
Although the checklist includes items for off-gas systems, it focuses on off-gas collection. The checklist does not
address off-gas management using combustion systems  because such systems are uncommon at Superfund sites.
A. Remedy Description, Goals and Conceptual Site Model (CSM)
1. Review of the current remedy
Identify the containment systems in place:
       D  Cap/cover
       D  VEB
       n  Liner
       D  Landfill gas collection
       D  Landfill gas management
Leachate detection
Leachate collection
Leachate management
Other (Describe:      )
Identify the O&M components:
       D  Inspection
       D  Monitoring
       n  Testing
       D  Ground water monitoring
       D  Surface water monitoring
Landfill gas monitoring
Vapor intrusion monitoring
Leachate monitoring
Other (Describe:      )
2. Review of the current remedy goals
Identify the remedy goals (RAOs):
       D  Prevent direct contact with a contaminant source
       D  Prevent migration of a contaminant source to:
                 A drinking water aquifer
                 Surface water
                 Soil or other solid media
Air (via wind-borne material)
Air (via volatilization)
Other (Describe:      )
          Prevent migration of contaminated ground water
          Prevent vapor intrusion or indoor air exposure
          Control off-gas
          Other remedy goals (Describe:       )
What metrics (performance criteria) are being implemented to measure project progress towards meeting each
goal?
What schedule has been established for measuring and reporting each metric?
Based on new information or events since the  last O&M review, is there a need to re-evaluate the
remedy goals? This might be due to factors such as whether the regulatory framework has been revised,
whether existing  goals appear to be realistic, and  whether there have been changes  in land use or
ground water production near the site. If yes, identify the remedy goals that should be re-evaluated, the
rationale, and any plans for re-evaluating the goals.
                                            Yes
                                            No
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3.  Review of changes to the CSM:  The CSM for a containment remedy is the site-specific, qualitative and
quantitative  description of the migration and fate of contaminants  with respect to  possible receptors and the
geologic, hydrologic, biological, geochemical and  anthropogenic factors that control contaminant  distribution.
Because the CSM provides the basis for the remedy and the post-closure maintenance plan or O&M plan, the
model should be re-evaluated as new data are collected throughout the lifetime of the remedy.
Does new information gathered or conclusions reached since the last time the O&M checklist was
completed indicate a change in understanding about the sources, types, migration, and fate of
contaminants?
    Note that indicators could include (1) the remedy not functioning as designed,  (2)  unexpected
    contaminants or contaminant concentrations above the required levels at the point of compliance, (3)
    unexpected trends in  contaminant concentrations,  (4) unexpected changes in the flow rate or
    direction  of ground water, (5) unexpected changes in off-gas characteristics,  or (6)  unexpected
    evidence of vapor intrusion in nearby structures.
               Yes
               No
Based on new information and/or conclusions, would it be useful to update the CSM at this time?
If yes, please describe any plans to update the CSM.
               Yes
               No
B. Remedy Performance Assessment
This section contains a series of questions that can be used to help assess a containment remedy's effectiveness
and evaluate the collection and analysis of performance monitoring data. For each potential problem identified, an
analysis should be performed to determine what, if anything should be done.
1. Evaluate remedy effectiveness:  The following questions are intended to review whether the containment
remedy is performing as intended or whether there is a need to implement a contingency remedy.  A contingency
remedy is a cleanup technology or approach  that functions as a backup remedy in the event that the selected
remedy fails to perform as anticipated.  A contingency remedy may be considered if there is a "yes" answer to one
or more of the following three questions.
    Note that additional measures and methods for evaluating the effectiveness of containment remedies can be
    found in "EPA/USACE Draft Technical Guidance for RCRA/CERCLA Final Covers"(EPA 540-R-04-007) and "EPA
    Comprehensive 5-Year Review Guidance, AppendixD, Five-Year Review Site Inspection Checklist" (OSWER
    Directive 9355.7-03B-P).
Since the last O&M review,  has inspection or testing of the cap, cover, liner, or VEB indicated that the
system is failing or could eventually fail?
               Yes
               No
Since the last O&M review,  have changes in land, surface water, or ground water use been suggested
and or implemented that have the potential to reduce the protectiveness of the containment remedy?
               Yes
               No
Since the  last O&M  review,  have  contaminants been  identified  in  new  locations or  at  higher
concentrations where they pose or have the potential to pose unacceptable risks to receptors?
               Yes
               No
If you answered yes to any of the above questions, did the information suggest the
need for immediate action or is the condition being monitored to evaluate the need for
future action?
    Use this space to comment.
    What actions, if any, have been taken and/or are planned in response to the new
    information?
Immediate action
Monitored for future
N/A
For VEB Only: Note that additional measures and methods for evaluating VEB effectiveness can be found in "EPA
Evaluation of Subsurface Engineered Barriers at Waste Sites".
Have
bulk
integrity
tests
been
performed
since
the
last
O&M
review?
DYes
DNO
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If bulk integrity tests have been performed since the last review, do test results indicate that need to
evaluate possible breaches or excessive leakage in the VEB over the short and long terms?
If yes, what actions have been taken and/or are planned in response?
            Yes
            No
           IN/A
Based on information collected since the last O&M review, do contaminant concentrations upgradient of
the VEB indicate the need to evaluate actions to prevent possible contaminant migration?
If yes, what actions have been taken and/or are planned in response?
            Yes
            No
Does information collected since the last O&M review suggest the need to evaluate hydraulic controls as
an additional measure to control possible contaminant migration around the VEB (answer N/A if hydraulic
controls are already part of the remedy)?
If yes, what actions have been taken and/or are planned in response?
            Yes
            No
           IN/A
For Off-Gas Collection Management Only: Note that additional measures and methods for evaluating off-gas
collection and management effectiveness can be found in "USAGE Landfill Off-Gas Treatment, Thermal Oxidation
Checklist".
Since the last O&M review for this system, have off-gas volume and composition been consistently within
equipment design parameters?
If no, what actions have been taken and/or are planned in response?
            Yes
            No
Since the last O&M review for this system,  have off-gas system operational characteristics,  such  as
required temperatures and pressures, been maintained within system design parameters?
If no, what actions have been taken and/or are planned in response?
            Yes
            No
Since the  last time an  O&M checklist was completed for this  system, have  off-gas emissions met all
federal, state, and local  regulatory requirements?
If no, what is being done to meet these requirements?
            Yes
            No
Based on information collected since the last O&M review, is there any evidence of unacceptable vapor
intrusion in nearby structures?
If yes, what actions have been taken and/or are planned in response?
            Yes
            No
Based on information collected since  the  last O&M review, have concentrations of off-gases  inside
buildings or at the site fence line suggested the need to assess safety and human health threats?
If yes, what actions have been taken and/or are planned in response?
            Yes
            No
2. Evaluate collection and analysis of performance monitoring data
Note that more detailed information about performance parameters can be found in the following documents:
    •   "EPA/USACE Draft Technical Guidance for RCRA/CERCLA Final Covers" (EPA 540-R-04-007)
    •   "EPA Comprehensive 5-Year Review Guidance, Appendix D, Five-Year Review Site Inspection Checklist"
       (OSWER Directive 9355.7-03B-P)
    •   "USAGE Landfill Off-Gas Treatment, Thermal Oxidation Checklist"
    •   "EPA Evaluation of Subsurface Engineered Barriers at Waste Sites"(EPA 542-R-98-005; August 1998).
Since the last O&M review, has it been necessary to modify planned inspections, sampling events, and
sample analyses, as reflected in the site post-closure maintenance plan  or O&M plans, to account for
new information and/or unforeseen circumstances?
If yes, use this space to comment.
            Yes
            No
Has  information collected since  the last O&M  review suggested the need to re-evaluate whether
performance parameters that are  critical to evaluation of the containment remedy are being collected at
appropriate monitoring points?
If yes, what actions have been taken and/or are planned in response?
            Yes
            No
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Are ground water and off-gas system monitoring data managed electronically?

If no, use this space to explain why not.
            Yes
            No
Since the last O&M review, have monitoring data been analyzed to identify trends and their significance?

    If no, use this space to explain why not.
            Yes
            No
Is high variability in the data interfering with or preventing a meaningful interpretation of the data?
            Yes
            No
    If yes, could this situation be mitigated by increasing the density or frequency of data collection?

    Use this space to comment.
            Yes
            No
Are inspection and performance  monitoring reports of sufficient quality and frequency to evaluate the
efficacy of containment as a remedy and recognize protectiveness problems in time for effective action?

    If no, what actions, if any, have been taken or are planned to address this situation?
            Yes
            No
C.  Cost-Effectiveness
If off-gas is currently being treated, can it be vented to the atmosphere without treatment in compliance
with all applicable federal, state, and local regulations?
            Yes
            No
           IN/A
    If yes, has the possibility of discontinuing off-gas treatment been explored?

    Use this space to comment.
            Yes
            No
           IN/A
If leachate is currently being collected  and treated, is operation  of the leachate  system necessary for
proper functioning of the containment system?
            Yes
            No
           IN/A
    If no, has the possibility of discontinuing leachate collection and treatment been explored?

    Use this space to comment.
            Yes
            No
           IN/A
If  hydraulic controls  are  being used  in  conjunction with  a VEB,  would the VEB  provide  passive
containment without these controls?
            Yes
            No
           IN/A
    If yes, has the possibility of discontinuing the hydraulic controls been explored?

    Use this space to comment.
            Yes
            No
           IN/A
D.  Remedial Decisions: Indicate which of the following remedial decisions is appropriate at the present
and provide the basis for the decision.
         time
    No change to the remedy
    Modify or optimize remedy
    Modify or optimize O&M
    Modify ICs
    Implement contingency or alternative remedy
    Terminate inspections or monitoring	
Basis for decision:
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RECOMMENDED APPENDIX D. SOIL VAPOR EXTRACTION/AIR SPARGIN
REMEDIES
   •   The following checklist is an abbreviated set of questions that EPA RPMs could use when conducting an
r       annual review of the O&M of a soil vapor extraction (SVE), air sparging (AS), or combined SVE/AS remedy.
       This checklist does not represent the level of review used in EPA's five-year review process to determine
       whether the remedy is or will be protective of human health and the environment.  However, the checklist
       does contain review elements regarding the performance of SVE and/or AS remedies that are consistent
       with the comprehensive  five-year review process.
A. Remedy Description, Goals and Conceptual Site Model (CSM)
1. Review of the current remedy
Identify the current remedy:
   D  SVE
   D  AS
How many extraction wells or trenches are used for SVE (if applicable)?
How many injection wells are used for AS (if applicable)?
2. Review of the current remedy goals
List the remedy goals (RAOs):
    D  Prevent migration of a contaminant source to:
          n A drinking water aquifer
          D Surface water
          D Soil or other solid media
    n  Prevent migration of contaminated ground water
    D  Restore ground water
    D  Other (Describe:      )
List the short-term objectives and intermediate system goals.
List the long-term soil and ground water cleanup goals.
What metrics (performance criteria) are being implemented to measure project progress towards meeting each
goal?
What schedule has been established for measuring and reporting each metric?
Based on new  information or events since the last O&M review, is there a reason to re-evaluate the
remedy goals?  Note that this might be due to factors such as whether the regulatory framework has
been revised, whether existing goals appear to be realistic, and whether there have been changes in
land or ground water use near the site.
      If yes, identify the remedy goals that should be re-evaluated, the rationale, and any plans for re-
      evaluating the goals.
           Yes
           No
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3.  Review of changes to the CSM: The  CSM  for a  SVE/AS remedy is the  site-specific,  qualitative and
quantitative  description of the migration and fate of contaminants with respect to possible  receptors and the
geologic, hydrologic, biological,  geochemical and  anthropogenic factors that control contaminant  distribution.
Because the CSM provides the basis for the remedy and the O&M plan, the  model should be re-evaluated as new
data are collected throughout the lifetime of the  remedy.
Does new information gathered or conclusions reached since the last time the O&M checklist was
completed indicate a change in understanding about the sources, types, migration, and fate of
contaminants?
    Note that indicators could include: (1)  the remedy not functioning as designed,  (2)  unexpected
    contaminants or contaminant concentrations above the required levels at the point of compliance, (3)
    unexpected trends in  contaminant concentrations, (4) unexpected changes in the flow rate or
    direction  of ground water, (5) unexpected  changes in off-gas characteristics,  (6)  unexpected
    evidence of vapor intrusion in nearby structures; or (7) identification of new sources.
                Yes
                No
Based on new information and/or conclusions, would it be useful to update the CSM at this time?
       If yes, please describe any plans to update the CSM.
                Yes
                No
B. Remedy Performance Assessment
This  section contains a series of questions that can be used to help assess a SVE/AS remedy's effectiveness and
evaluate the collection and analysis of performance monitoring data.
1.  Evaluate remedy effectiveness:  The following  questions are intended  to  review whether the  SVE/AS
remedy is performing as intended, or whether there is a need to implement a contingency remedy.  A contingency
remedy is a cleanup technology or approach that functions as a backup remedy in the event that the selected
remedy fails to perform as anticipated.  A contingency remedy may be considered if there is a "yes" answer to
either of the following five questions.
Based on information collected since the last O&M review, do monitoring data indicate that the system is
failing or could eventually fail to meet remedy goals?
             B
Yes
No
Since the last O&M review, has the areal extent of contamination (or plume) increased in a manner not
originally predicted during remedy selection?
             B
Yes
No
Since the last O&M  review, have monitoring data exhibited trends indicative of a new or renewed
release?
                Yes
                No
Since the last O&M review,  have changes in land  and/or ground  water use been suggested and  or
implemented that have the potential to reduce the protectiveness of the SVE/AS remedy?
                Yes
                No
Since the  last O&M  review,  have  contaminants been  identified  in  new  locations or  at  higher
concentrations where they pose or have the potential to pose unacceptable risks to receptors?
             B
Yes
No
If you answered yes to any of the above questions, did the information suggest the
need for immediate action or is the condition being monitored to evaluate the need for
future action?

       Use this space to comment.
       What actions, if any, have been taken and/or are planned in response to the
       new information?
Immediate action
Monitored for future
N/A
Based on your answers to the above questions, is there reason to evaluate the need for a contingent
remedy at this time?
If yes, use this space to comment.
                Yes
                No
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Blowers and Piping
Since the last O&M  review for this system, has evidence of excessive corrosion of system components
been observed?
       If yes, what actions have been taken and/or are planned in response?
                                                                                                   Yes
                                                                                                   No
Since the last O&M review, if blowers are operated intermittently, do VOC concentrations increase after
they are shut off?
How has this information been interpreted and what actions, if any, have been taken and/or are planned
in response?
                                                                                                   Yes
                                                                                                   No
                                                                                                  IN/A
Since the last O&M review, have blower operational  characteristics, such as flow rate,  pressure, and
discharge temperatures, been consistently within equipment design parameters?
       If no, what actions have been taken and/or are planned in response?
                                                                                                   Yes
                                                                                                   No
Since the last O&M review, if water is manually removed from the extraction blower water separator, has
water accumulation been observed that could adversely impact blower operation?
       If yes, what actions have been taken and/or are planned in response?
                                                                                                   Yes
                                                                                                   No
                                                                                                  IN/A
Since the last O&M review,  have all  blowers, water separators, valves, and  piping components been
consistently operational?
                                                                                                   Yes
                                                                                                   No
Has the downtime associated with non-routine operations and maintenance of the blowers since the last
time you completed an O&M checklist for this system exceeded expectations?
       If yes, what have been identified as the causes?
       If yes, what corrections have been  or are being made to minimize downtime?
                                                                                                   Yes
                                                                                                   No
Does the operational history suggest that the preventative maintenance plan for the blowers needs to be
re-evaluated?
       If yes, what actions have been taken and/or are planned in response?
Soil Vapor Extraction System
Identify the SVE system  characteristics, if  any,  that  have deviated  consistently/frequently from  operational
expectations since the last time an O&M checklist was completed for this system:
    D Vapor flow rates at one or more extraction wells
    D Vapor compositions (VOCs, C02, 02) at one or more extraction wells
    D Pressures at one or more extraction wells
    D Flow at blower (prior to entry of any dilution air if used)
    D Accumulation  of water in the water separator
Does this (do these) deviation(s) indicate a new condition since the last O&M review or an
ongoing trend?
                                                                                         New condition
                                                                                         Ongoing trend
                                                                                         N/A	
What has been identified as the cause for this (these) deviation(s)?
What actions, if any, have been or are being taken in response to this (these) deviation(s)?
Based on information collected since the last O&M review, is there any evidence of unacceptable vapor
intrusion in nearby structures?
If yes, what actions have been taken and/or are planned in response?
                                                                                                   NO
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Since the last O&M review, have gas concentrations in the blower discharge been running close enough
to the lower explosive limit (LEL) or shown an increasing trend that suggests the need for action?  Note
that specific compound LEL data are available in many chemistry texts as well as National Fire Protection
Agency guidelines.
What actions, if any, have been taken and/or are planned in response to the new information?
            Yes
            No
Air Sparging System
Since the last O&M review of the AS system, have flow  rates at each  injection well been  consistently
maintained within system design parameters?
       If no, what actions, if any, have been or are being  taken in response?
            Yes
            No
Based on information collected since the last O&M review,  have dissolved oxygen concentrations been
maintained at a level sufficient to promote biological activity?
       If no, what actions, if any, have been or are being taken in response?
            Yes
            No
Since the last O&M review, are measured dissolved oxygen concentrations consistently indicative of good
air/water contact rates (i.e., are concentrations near saturation)?
       If no, what actions, if any, have been or are being taken in response?
            Yes
            No
VOC Control System
If the SVE system contains a VOC control  device, has the device consistently met performance and
compliance  monitoring  requirements  (e.g., total  VOC emission  limits,  specific  compound  limits,
monitoring, air permit) since the  last O&M review for this system?
       If no, what actions have been taken and/or planned in response?
            Yes
            No
           IN/A
Since the last O&M review, has the VOC control system consistently meet required  destruction  and
removal efficiencies?
       If no, what actions have been taken and/or planned in response?
            Yes
            No
Since the last O&M review, have any violations of air permits been reported?
       If yes, what has been or is being done to meet permit requirements?
            Yes
            No
Since the last time you completed an O&M checklist for this system, has the VOC control  system been
responsible for downtime associated with non-routine operations and maintenance?
       If yes,
           •   What was (were) the cause(s) for unplanned shutdown(s)?
           •   What has been done or is being done to minimize future downtime?
            Yes
            No
Thermal Oxidizers
Since the last O&M review for this system, have the operational characteristics (e.g., LEL history of feed
gas, operating temperature, inlet flow, oxygen level in flue gas, fuel  use)  been consistently within
equipment design parameters?
       If no, what actions, if any, have been or are being taken in response?
            Yes
            No
           IN/A
Since the last O&M review, has there been any indication of improper operation of flashback protection
equipment (e.g., detonation arrester, sealed drum)?
       If yes, what actions have been taken and/or planned in response?
            Yes
            No
Since the last O&M review, has there been any indication of improper operation of safety interlocks (e.g.,
high LEL, high oxidizer temperature, loss of flame, low fuel pressures)?
       If yes, what actions have been taken and/or planned in response?
            Yes
            No
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If acid gases are present, have  scrubber operations  (e.g., scrubber liquid flow and pH, caustic use,
scrubber blowdown and its treatment) been consistent with operational expectations since the last O&M
review?
       If no, what actions have been taken and/or planned in response?
            Yes
            No
Carbon Adsorbers
Does the unit have humidity controls?
            Yes
            No
Since the last O&M review for this system, have the operational characteristics (e.g., relative humidity
data at adsorber inlet, adsorber operating temperature, carbon breakthrough, carbon change out history,
operating velocity through adsorbers, adsorber discharge VOC data) been consistently within equipment
design parameters?
       If no, what actions, if any, have been or are being taken in response?
            Yes
            No
           IN/A
Other Control Devices
Since the last O&M review for this system, have the operational characteristics (e.g., biofiltration media
surface loading rate, temperature controls, nutrient addition rate) been consistently within equipment
design parameters?
       If no, what actions, if any, have been or are being taken in response?
            Yes
            No
           IN/A
2. Evaluate collection and analysis of performance monitoring data
Since the last O&M review, has it been  necessary to modify sampling frequency relative to the original
O&M plan to account for new information and/or unforeseen circumstances?
       If yes, use this space to comment.
            Yes
            No
Does soil and/or ground water data collected since the previous O&M review (e.g., VOCs concentrations,
ground water elevations) suggest the need to re-evaluate other aspects of the monitoring program (e.g.,
monitoring locations, test parameters) to account for new information/unforeseen circumstances?
       If yes, use this space to comment.
            Yes
            No
C. Cost Effectiveness: Key considerations in looking at cost-effectiveness are the O&M costs incurred relative to
design and reduction in VOC removal rates.  Opportunities to reduce costs can be potentially found in the following
areas:
Does information collected since the last O&M review suggest that flows could be redistributed to speed
overall remediation  (i.e.,  reduce or eliminate  flow  to/from wells where removals have  reached near
asymptotic conditions or where cleanup goals have been achieved)?
       Use this space to comment.
            Yes
            No
Does information collected since the last O&M review show evidence of diffusion-limited VOC movement?
            Yes
            No
   If yes, has the idea of modifying operation to pulsing (intermittent) been considered to speed overall
   remediation?
   Use this space to comment.
            Yes
            No
Does  information  collected  since the last O&M  review  show reduced VOC removal  rates that might
warrant a reduction in monitoring frequencies?
       Use this space to comment.
            Yes
            No
Does  information collected  since the last  O&M review suggest that VOC  recovery rates have been
reduced to the extent that the VOC control device can be eliminated?
       Use this space to comment.
            Yes
            No
           IN/A
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Does information collected since the last O&M review suggest that an alternative, lower cost VOC control
device could be used?
       Use this space to comment.
            Yes
            No
Does information collected since the last O&M review suggest that operation of the VOC control device
could be modified to reduce costs, e.g., operate thermal oxidizer at lower temperatures or lower dilution
air flows  (e.g., when LEL  basis no longer requires design flow) or use larger carbon  beds to reduce
carbon supplier charges for change outs?
       Use this space to comment.
            Yes
            No
Has maintenance history since the last O&M review identified high-maintenance equipment that could be
replaced?
       Use this space to comment.
            Yes
            No
E. Remedial Decisions: Indicate which of the following remedial decisions are appropriate at the present time
and provide a basis for each decision:
    Continue current remedy
    Goals have been achieved ~ system can be shutdown in favor of MNA
    Modify/optimize remedial system(s)  - use intermittent operation; optimize flows to/from wells to promote
    increased  removals;  increase use of sparging to promote biodegradation;  add new wells  if contaminant
    movement is indicated to areas currently not being influenced; implement cost reduction measures; conduct
    more detailed evaluation of the contaminated zone using a tool such as Pneulog.
    Modify/optimize O&M - increase monitoring to provide additional data for more definitive assessment at the
    next review
    Modify ICs
    Implement contingent or alternative remedy
Basis for decision:
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RECOMMENDED APPENDIX E. OTHER REMEDY TYPES/COMPONENTS
The following checklist is a set of questions that may be used by EPA RPMs for an annual review of the O&M of
remedies and remedy components that are not addressed in Appendices A through  D or the separate surface
water/sediment remedy O&M checklist. This could include  remedies/components that involve a technology that is
not covered  in these other materials or remedies/components where the O&M can be more efficiently reviewed
using the  more  streamlined  questions below.   If the site includes multiple  remedy components  that are not
covered elsewhere, multiple  copies of this appendix, each applying to a different component or rel;
components, could be comple
A. Remedy Description and Goals
1. Review of current remedy goals, and measurements
The following questions can be used  to document basic information about the remedy and remedy goals to
provide context for the remainder of the information in this appendix.	
Identify the remedy component(s) and associated systems and technologies being covered on this form:
What are the intermediate and final system goals?
What metrics (performance criteria) are being  implemented to measure project progress towards meeting each
goal?
What schedule has been established for measuring and reporting each metric?
Based on new information or events since the last O&M review of this system/technology, is there a need
to re-evaluate the remedy goals?
       If yes, identify the remedy goals that should be re-evaluated, the rationale, and any plans for re-
       evaluating the goals.
           Yes
           No
2. Review of changes to the CSM
The following questions ask about changes in contamination and other field conditions that could affect the
monitoring program, system operations, and other aspects of O&M. They provide context for questions  in
subsequent sections that ask whether action should be taken to modify the O&M program.
Do monitoring data indicate trends/patterns that are inconsistent with the CSM (or similar conceptual
understanding of site conditions) that was used as the basis for design of the remedy/remedial
component(s)?
       If yes, use this space to comment.
           Yes
           No
Have there been changes in field conditions (e.g., change in land/water use) that differ significantly from
the conditions incorporated in the CSM (or similar conceptual understanding of site conditions) that was
used as the basis for design of the remedy/remedial component(s)?
       If yes, use this space to comment.
           Yes
           No
Have new contaminant sources been identified?
       If yes, please describe the new sources and how they are they being addressed:
           Yes
           No
B. Remedy Performance Assessment
This section contains a series of questions that can be used to help assess whether the monitoring program and
remediation systems O&M should be adjusted.
1. Monitoring Program
Describe changes to the monitoring program that have been made since the last time you completed the O&M
checklist for this remedy component.
Are the baseline data and post-remedy data adequate to perform statistical comparisons and evaluate
remedy performance?
       If no, what actions have been or are being taken in response?
           Yes
           No
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Is high variability in the data interfering with or preventing a meaningful interpretation of the data?
            Yes
            No
    If yes, could this situation be mitigated by increasing the density or frequency of data collection?
    Use this space to comment.
            Yes
            No
Based on changes in contamination or field conditions (see A.2 of this appendix), is there reason to
modify the monitoring program?
       If yes, describe changes to the monitoring program that are most necessary.
            Yes
            No
Has  the  adequacy/redundancy  and  cost-effectiveness  of  the monitoring  program  been evaluated,
including evaluation of sampling  locations, frequency,  sampling  and analytical  methods, monitoring
parameters, and test methods?
       Use this space to comment.
            Yes
            No
Is there reason to modify the monitoring program to address inadequacies, remove redundancies, and/or
improve its cost-effectiveness?
       If yes, describe changes to the monitoring  program that would likely have the greatest impact.
            Yes
            No
Do you have adequate documentation (e.g., good quality O&M  reports) and tools (e.g., software) to
effectively manage and interpret monitoring data?
       If no, please explain how documentation and/or tools could be improved.
            Yes
            No
2.  System Operations
Describe changes to system operations that have been made since the last time you completed the O&M checklist
for this remedy component.
Is (are) the remedial  system(s) covered under this appendix performing  as  expected  relative to the
remediation milestones and goal(s)?
       If no, what actions have been or are being taken in response?
            Yes
            No
Do  monitoring data  indicate trends/patterns that are consistent with remedial  design  expectations?

       If no, what actions have been or are being taken in response?
            Yes
            No
Based on observations regarding contamination or field conditions (see A.2 of this appendix and previous
questions in this section), is there reason to modify systems operations to improve remedy performance?
       If yes, describe changes to system operations that are most necessary.
            Yes
            No
Has an optimization study been conducted for the remedy/remedy component(s)?
       Use this space to comment.
            Yes
            No
Has the downtime associated with non-routine operations and maintenance exceeded expectations?
       If yes, what actions have been or are being taken to minimize downtime?
            Yes
            No
Based on optimization and downtime considerations, is there reason to modify systems operations to
improve remedy performance?
       If yes, describe changes to system operations that are most necessary.
            Yes
            No
3. Maintenance
Are routine maintenance activities adequate to ensure the reliable operation of the remedial system(s)?
       If no, what changes to the maintenance program are most necessary?
            Yes
            No
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Have any major repairs to the remedial system(s) been required since the last time you completed the
O&M checklist for this remedy/remedy component?
       If yes, describe the repairs, their impact on progress toward remediation milestones, and actions
       taken to minimize similar repairs in the future.
            Yes
            No
C. Cost Effectiveness
Does information collected since the last O&M review suggest opportunities to reduce costs associated
with equipment operations and maintenance?
       If yes, use this space to comment.
            Yes
            No
Does information collected since the last O&M review suggest opportunities to reduce costs associated
with the monitoring program?

       If yes, use this space to comment.
            Yes
            No
D.  Remedial Decisions:  Indicate which of the following remedial decisions is appropriate at the present time and
provide the basis for the decision.
    No Change
    Modify/Optimize System
    Modify/Optimize Monitoring Program
    Modify ICs
    Implement Contingency/Alternative Remedy
Basis for decision:
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