### CORRECTIVE ACTION INTERPROGRAM POLICY BETWEEN NUCLEAR 

### &MIXED WASTE MANAGEMENT, SOLID AND HAZARDOUS WASTE, TOXICS CLEANUP, AND CENTRAL PROGRAMS

Department of Ecology Waste Management Assistant Directo Department of Ecology Central Programs and Enforcement Assistant Director Department of Ecology Solid and Hazardous Waste Program Department of Ecology Toxics Cleanup Program 

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### Department of Ecology Central Programs Department of Ecology Nuclear and Mixed Waste Management Program

I. INTRODUCTION AND PURPOSE

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The purpose of this interprogram policy is to define the department and program specific roles and responsibilities for implementing the Resource Conservation and Recovery Act (RCRA) Corrective Action Program1 

### through the use of the Model Toxics Control Act (MTCA) at RCRA Subtitle C hazardous waste treatment,
--- storage or disposal facilities (TSDFs). This policy will be provided to the Environmental Protection Agency as part of Ecology's application for authorization for RCRA corrective action, to explain the working relationship between the programs and to establish management responsibilities for corrective actions at RCRA TSDFs.

lThe RCRA Corrective Action Program is mandated by RCRA 3004(u),

. 3004(v) , 3008(h) , and 40 CFR § 

### 264.101 which require TSDs to implement

corrective action as necessary to protect human health and the environment for all releases of hazardous waste or constituents from any solid waste management unit at a TSDF which is seeking or required to have a permit under RCRA 3005. Page 1 of 9II. REGULATION AND POLICY DEVELOPMENT A. The Solid and Hazardous Waste Program (SHWP) is responsible for developing and maintaining the RCRA/State Dangerous Waste Regulations, Chapter 173-303 RCW, adopted under the authority of Chapter 70.105 RCW. SHWP also develops dangerous waste policies and other guidance for implementation of the delegated portions of the federal RCRA Hazardous Waste Program. 

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B. The Toxics Cleanup Program (TCP) is responsible for developing and maintaining the Model Toxics Control Act Cleanup Regulation, Chapter 173-340 WAC, adopted under the authority of Chapter 70.l05D RCW. The 

## rcp also develops policies, guidelines and procedures for implementation of the state hazardous waste cleanup program established by the MTCA. C. The Nuclear and Mixed Waste Management Program (NMWMP) is responsible for implementing all Ecology statutes and regulations on the Hanford site. The NMWMP has developed the regulation which establishes a fee schedule for mixed waste treatment, storage and disposal facilities, Mixed Waste Management Fees Rule, Chapter 173- 328 WAC, which is effective on May 21, 1993. The Department of Ecology will collect fees for permitting and regulating mixed waste facilities under the State Dangerous Waste Regulations. Facilities that generate both mixed and hazardous waste will be managed by NMWMP or SHWP as determined on a case-by-case basis consistent with guidance from the Waste Programs Assistant Director. D. The Central Programs' Industrial Section is responsible for regulating the major aluminum smelters, pulp mills, and oil refineries in the state, including activities for air quality, water quality, dangerous waste, solid waste, and

-- toxic waste cleanup. Central Programs develops policies and procedures as needed to effectively implement the Industrial Section's cross-program responsibilities. For RCRA corrective action, the Industrial Section will implement the regulations and policies developed by the Solid and Hazardous Waste Program. III. PRIORITIZATION OF RCRA SITES The EPA has established a national corrective action priority system (NCAPS) to establish consistent priorities nation-wide and to direct its and authorized states' efforts at working on the worst sites first. Ecology's intent is also to work on the worst sites first. In Ecology, the means of ranking sites and Page 2 of 9 

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# oestablishing priorities for the order in which sites are to be addressed is discussed below. A. Ranking Sites

- NCAPS or Washington Ranking Method (WARM)2 The SHWP and Central Programs will continue to use the NCAPS system in conjunction with EPA for ranking corrective action sites and establishing workload planning for the biennial State-EPA**Agre~ment.** The TCP utilizes the WARM method for scoring sites. Policy number 340 (Attachment No.1) is used to prioritize sites for workload planning. The NMWMP uses the Hanford Federal Facility Agreement and Consent Order (HFFACO) to establish priorities for cleanup of the Hanford site. B. Ranked List Ecology is required by RCW 70.l05D.030(3) to maintain a ranked list of sites requiring remedial action which must be reported to the state Legislature each even-numbered year. SHWP RCRA TSDF corrective action sites will be added to the TCP's list and reported to the Legislature. This report will identify the projects and expenditures and will show site priority ranking and requested funding for each site. C. Workload Prioritization The list of corrective action sites to be addressed each year by the SHWP and the Industrial Section will be negotiated in the biennial State-EPA Agreement. Priorities will be based on the RCRA Implementation Plan and guidance from the State Hazardous· Waste Policy Forum.3 The TCP will utilize its Policy Number 340 (Attachment No.1) to determine the sites it will address each year.
2The Washington Ranking Method is a scoring system that uses the data gathered from a site hazard assessment to estimate a site's potential threat to human health and the environment. The scores of all sites are placed on the Hazardous Sites List in descending order. The list, updated with new sites every six months, is divided into 5 quintiles. Those sites in the first quintile are all ranked 1; sites in the second quintile are ranked 2; etc. Sites ranked 1 have the highest level of concern, and sites ranking 5, the lowest. 3The Hazardous Waste (HW) Policy Forum is chaired by the Program Manager and consists of the section supervisors for the HW Regulatory, HW Information and Planning, HW Permits, Program Support Sections, the Regional SHW Section Supervisors, and representatives are invited from the Industrial Section and the NMWMP. This forum meets every five to six weeks to discuss and decide on HW policy issues.
. Page 3 of 9The NMWMP will negotiate the sites it will address in the annual update to the HFFACO with EPA and the Department of Energy. IV. ESTABLISHING SITE LEAD FOR RCRA SITES BETWEEN SHWP AND TCP The SHWP will manage the corrective actions at RCRA TSDFs. There may be some extremely complex sites which require a different approach. Responsibility for these corrective actions and compliance will be decided on a site-by-site basis jointly between the program managers. TCP will not issue any RCRA permits for any facilities. EPA will be informed how these exceptional sites will be managed. Criteria to be considered when determining whether SHWP or TCP will be lead on the exceptional sites include: 1. Available staff and financial resources for term of project. 2. Expertise regarding particulars of site. 3. Most efficient and effective use of agency resources. 4. Need for a multi-program team due to size, political sensitivity, or complexity of site. 5. Interim or final status RCRA facility. 6. Site is part of a much larger area-wide cleanup. 7. Relationship between the agency and the regulated facility.- 8. Role of EPA on site. For hazardous waste generator sites, SHWP will continue to manage these sites through-available authority (i.e., WAC 173-303-145) to clean up spills and other recent releases. Generator sites which have been stabilized may then be transferred to TCP if further cleanup is necessary but not time critical. When generators are found to have contaminated sites because they operated a regulated unit without obtaining interim status. the site will be handled in accordance with the Contaminated Sites Agreement of November 1988, or as amended. Any sites EPA and SHWP agree to add to the RCRA TSDF universe will be administered by the SHWP. unless otherwise specified by agreement between the appropriate program managers. V. JOINT PROCESSES The programs will be engaged in the following joint processes to carry out site cleanups in the most effective and efficient manner.

Page 4 of 9 

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cA.**Ne~otiation** Review Team The SHWP and Central Programs' Industrial Section will utilize the Negotiation Review Team4 established by TCP Policy SOOA (Attachment No.2) for review of the following:



### • • 

### • •



### • draft orders, consent decrees, cleanup action plans, cleanup standards or levels being set for closures, and significant amendments to draft orders and consent decrees B. Site**Re~ister** The SHWP and the Central Programs' Industrial Section will provide information on the status of sites to be published in the Site Register5 established per WAC 

### 173-340-600(6) by the TCP. C. Cost Recovery The Central Programs' Industrial Section will use the established procedures for cost recovery developed by the TCP and the Fiscal Office. The SHWP will establish its own policy and procedures for implementing cost recovery in the SHWP which will be consistent with those established by the TCP and Ecology Fiscal Office. D. Public Participation and Public Notices To the extent feasible and as time allows, the public participation coordinators in the TCP will assist the site managers in the SHWP and the Central Programs' Industrial Section in carrying out public participation activities such as developing public participation plans and working with the Regional citizens' advisory committees. Public notices will be issued by headquarters or regional staff of the SHWP for sites being administered by the SHWP. These notices will meet the requirements of both MTCA and RCRA. Costs of these activities will be recovered. When appropriate, the notice may also incorporate requirements of the State Environmental Policy Act (SEPA). If additional
4The purpose of the Negotiation Review Team is to provide quality assurance for the implementation of MTCA and is made up of two technical reviewers, a policy reviewer, a cost recovery reviewer, and an Assistant Attorney General. 5The Site Register is a periodic TCP publication which alerts the public to the availability of reports, public comment periods, and other activities related to the study and cleanup of hazardous waste sites. Page S of 9funding becomes available, a public participation coordinator position will be established in the SHWP. The headquarters staff of SHWP will assist Central Programs' Industrial Section in preparing and issuing public notices. The NMWMPwill**implem~nt** the public participation process as outlined in the HFFACO and negotiated between EPA., U.S. Department of Energy, and Ecology (NMWMP). E. Final Clean Closure Review The SHWP will conduct final clean closure reviews using the "Guidance for Clean Closure of Dangerous Waste Facilities" (Attachment No.3) for the TCP's RCRA TSDFs, and obtain EPA's concurrence before a site has its RCRA interim status terminated. The Central Programs' Industrial Section will conduct the final clean closure reviews for its facilities using the same guidance and coordinate with the SHWP and EPA before terminating interim status. The NMWMP will conduct the final clean closure reviews for Hanford and some mixed waste facilities in accordance with regulations and policies established by the SHWP and the NMWMP. F. Cleanup Standards

- RCRA Regulated Units and Solid Waste Management Units The intent is that all programs will utilize the MTCA cleanup standards for all RCRA closures and corrective actions. G. Training The TCP will provide training to the staff in the other three Ecology programs regarding use of the MTCA regulations to accomplish RCRA closures and corrective actions. The SHWp will provide training and assistance to staff in the other three programs on the RCRA closure and corrective action processes. H. Data Management/Information Management/Tracking and Reporting The regional data entry staff of the SHWP will report changes in the status of all RCRA sites going through corrective action quarterly into the RCRA Information System (RCRIS). The RCRIS will be used by SHWP to produce end-ofthe-year reports and mid-year reports to EPA. The SHWP site managers will provide information on site status for RCRA corrective action sites using MTCA so the Page 6 of 9 

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oregional data entry staff of TCP can put the information into the TCP site information system (SIS). The SIS tracks the status of all MTCA sites. Central Programs' Industrial Section will continue to provide direct input into the RCRIS and SIS tracking and reporting systems for its sites. VI. RCRA PERMITS Corrective action will be addressed in RCRA permits in one of the following ways. A. Operating Facilities Some operating facilities have been issued joint State/EPA permits where corrective action provisions were developed by EPA using federal authorities. EPA will continue to administer and enforce the corrective action requirements of· these permits until the permit is replaced with one issued by Ecology under state authorities. The lead Ecology program will reissue such a permit where Ecology wishes to assume the lead for corrective action and has the resources available to provide the oversight. The TCP will not reissue permits. If an operating facility has not been issued a final status permit and is operating under interim status, corrective actions will generally be handled by the lead Ecology program using the MTCA process. When a permit is issued after the MTCA process has been initiated, the permit will incorporate the MTCA action by reference. If corrective actions are needed, any permit issued must have a schedule of compliance for corrective action. When a permit is issued to a facility where the corrective actions have not been initiated because it is a low priority site, the permit will indicate the permittee will be required to initiate corrective action using the MTCA process when required to do so by Ecology. The TCP will not issue any RCRA permits for operating facilities. B. Post-Closure Permits For non-operating TSDF closures (i.e., facilities with no units treating, storing, disposing, or recycling hazardous wastes) and corrective actions for SWMUs at such' sites, the Ecology lead program will use the MTCA for corrective actions or a RCRA post-closure permit. Any ongoing requirements at the facility after closure or corrective action (i.e., monitoring) will be spelled out in a court issued consent decree or in an enforcement order as specified in the MTCA. A model consent decree is being Page 7 of 9second of

·The and drafted which contains an optional section with post-closure provisions which can be used for sites requiring a postclosure permit. If the potentially liable parties refuse to enter into a consent decree, such post-closure provisions will be incorporated into .an enforcement order. The long-term maintenance and monitoring requirements of the consent decree or enforcement order would be incorporated into a· post-closure permit upon issuance of the post-closure permit. The TCP will not issue any RCRA post-closure permits. VII. RCRA STATE-EPA AGREEMENT The SHWP will be responsible for developing the biennial RCRA State-EPA Agreement (SEA). The biennial SEA will include RCRA corrective action work conducted in the TCP, the NMWMP, and the Central Programs' Industrial Section. RCRA corrective actions on the Hanford site will be addressed through updates to the Hanford Federal Facility Agreement and Consent Order, and when issued, the facility-wide dangerous waste permit. VIII. CONFLICT RESOLUTION PROCESS A. Conflicts Between Ecology Programs If a conflict occurs between Ecology Programs**~egarding** the implementation of this agreement, the matter will be referred to the involved section supervisors in the programs for resolution. If the section supervisors can not resolve the issue, then it will be elevated to the program managers. If the program managers are not able to come to a resolution, then the third and final level will be the assistant directors. The parties in conflict are encouraged to utilize informal working-level efforts to resolve problems before elevating them. Conflicts regarding important issues should be addressed and resolved, never ignored. B. Conflicts Between Ecology and EPA If conflicts occur between Ecology and EPA regarding the terms of this agreement on corrective action that cannot be worked out by the respective section supervisors, the issue will be referred to the SHWP Manager and the Waste Management Branch Chief of EPA. If not resolved, the level will be the Waste Management Assistant Director Ecology and Hazardous Waste Division Director of EPA. third and final level will be the Director of Ecology the Regional Administrator of EPA.

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### This process is outlined in the draft RCRA State-EPA Memorandum of Agreement prepared for the Corrective Action Authorization Application. C. Conflicts Between Ecology and EPA Concerning Hanford Site Conflicts' will be resolved using the dispute resolution process described in the Hanford Federal Facility Agreement and Consent Order.

Page 9 of 9

# • ATTACHMENT NO.1 

### DATE: July 2, 1992 CANCELS: Interim Policy (1/22/92)

POLICY 340 PRIORITY SETTING FOR SITES PAGE: POLICY: 1 

### of 4 340



### This policy outlines the steps and criteria that the Toxics Cleanup Program (TCP) will use in determining which sites will be worked on in any given year. The factors to be considered when setting priorities for conducting remedial actions at sites do not effect the WARM ranking of a site. 1. Washington Ranking Method (WARM) 

### Score Is A primary Factor In priority setting. sites with a Washington Ranking Method (WARM) ranking of 1 or 2 will generally be given priority over those sites having a WARM ranking of 3, 4, or 5. 2. Other Factors Considered In priority setting. other factors, besides the WARM· rank, may be considered

. when setting priorities for conducting remedial actions

at sites. Factors which can raise the priority of a site and which are generally considered in the following descending order of importance are: A. Contaminant Pathway. The WARM ranking reflects overall potential impacts to public health and the environment. Therefore, sites posing a high threat to pUblic health or the environment through a single pathway may be raised in priority over other sites with higher, or equal, WARM rankings. When available, the Washington Department of Health Preliminary Health Assessment will be used when evaluating the priority of a site based on public health considerations. B. National Priorities List (NPL) Sites. NPL sites may be raised in priority since Ecology has to be prepared to respond to EPA to protect the state's interests during site work. C. Need for Interim Action. sites with the potential for getting substantially worse unless interim action is taken may be given higher priority. D. Actual Impacts. sites with actual impacts may be given higher priority over those with potential impacts. E. Resource commitments. When the department has previously committed 

## or**allocate~** 

### resources to the

Administration 

### 2-95 August 17, 1992

### DATE: 

### JUly 2, 1992 

### CANCELS: Interim Policy (1/22/92) PAGE: 

### POLICY: 2 of 4 340 site and has made a commitment to complete the 

# c=J work done at the site, then the priority of that site may be raised. F. Funding Agreements. sites at which the PLP is willing to pre-pay for Ecology staff to work on· oversight, or sites at which there is a federal funding agreement, may be given higher priority than their rank would indicate (POL 500C). G. 

### Resource availability. The availability of dedicated regional staff time or contract dollars SUfficient to work on additional sites may allow lower priority sites to be worked on sooner. Other considerations are the balancing of sites with staff availability in regional offices and the use of dedicated resources. 

### H. Public concern. If the pUblic concern about a specific· site is 

### known to be high, then the program may raise the priority of the site if environmental conditions warrant. I. Economic Factors. If the expedited cleanup of a site will save or create substantial jobs or money, then the site may**b~** 

### given priority. 

# c=) J. Potentially liable person (PLP) readiness. If the potentially liable person(s) has indicated a willingness to participate in negotiations for a consent decree, discussions for an agreed order, or has had previous cooperative**participatio~** 

### under an order or decree, the program may raise the priority of the site. 

### K. "Do-ability". If the site can be cleaned up within a fairly short time frame, with a minimal investment of resources, or with a well known cleanup methodology or technology, then the program may increase the priority of the site in order to facilitate a speedy cleanup. 3. Biennial Program Report Is A preliminary Report Of Program Priorities. The Biennial Program Report, described in WAC 173-340- 340, is a preliminary report of Toxics Cleanup Program priorities prepared for pUblic review by September of each even-numbered year. The report will describe remedial action activities by phase and report those sites at which remedial action is anticipated to**ecc~r** 

### during the following two fiscal
Administration 

### 2-96 

### August 17, 1992

### DATE: July 2, 1992 CANCELS: Interim Policy (1/22/92) PAGE: POLICY: 3 of 4 340 years. This report will be sUbject to pUblic review and comment, including Regional citizens' Advisory Committee review. It is then submitted to the legislature by November 1 of each even-numbered year. The list of "sites and planned activities included in the Biennial Program Report is refined during the spring program planning process. 4. Priorities Established On A Biennial Basis.

5. 

### Every two years the Toxics Cleanup Program will set priorities for work on sites on the Hazardous sites List. These priorities will be established as part of the program planning process beginning in February and approved by the Program Manager by July 1 of each oddnumbered year. The formal updating of this plan takes place in February of even-numbered years. (See paragraph 7 for the policy for informal updating.) High Priority sites Will Be Identified. A subset of those sites identified as program plan sites under paragraph 3 will be designated as high priority sites. The same factors identified in paragraphs 1 and 2 will be used in selecting these sites. In January and July, the TCP Management Team shall identify a total of 35 sites with completed initial investigations that are high priority for site Hazard Assessments (SHAs) for the next fiscal year. within 30 days after the Hazardous sites List is published 

### in February and August, the TCP Management Team shall decide which sites are high priority for Remedial Investigation/Feasibility Studies (RIfFS) 

### in the next (or current) fiscal year. Additional sites may be added following SUbsequent printing of the Hazardous Sites List until a total of 10 high priority sites for the fiscal year have been named. 6. High Priority sites Have Deadlines For Task completion. High priority sites shall follow the deadlines described in WAC 173-340-140. The PLP will be sent a letter upon satisfactorily completing the RI/FS. This letter will be sent after the pUblic has had an opportunity to review and comment on the report, as required by WAC 173-340-600. The date of this letter will be the beginning of the time period for the selection of the final cleanup action. This date still applies when the draft Cleanup Action Plan and RI/FS are simUltaneously made available for pUblic review and comment.
Administration 

### 2-97 August 17, 1992

### DATE: July 2, 1992 

### CANCELS: Interim Policy (1/22/92.) 

### PAGE: POLICY: 4 of 4 340 

### It is recognized that some high priority sites will 

# C require more than the 18 month timeframe allowed to / complete an RI/FS. For these sites, the pUblic notice designating the site schedule shall state the predicted amount of time that is expected to be needed (18 months, plus up to 12 

### month extension). sites that are complex or have a large number of potentially liable persons are anticipated to fall into this category. Other high priority sites may require an unanticipated time extension prior to completion of a remedial action phase. Ecology shall provide an opportunity for the public to comment on any deadline extension required for these sites.
. site schedules for all high priority sites will be pUblished in the site Register. 7. Priorities May Be Adiusted As Necessary. since situations at individual sites may·change, priorities may be adjusted as necessary. These adjustments may be made at any time. Since they could result in delaying anticipated work at a site currently on the biennial program plan, justification for such changes will be necessary. To change priorities, the section Manager must insure that conceptual approval forms and work plan addition and reduction sheets are completed when sites are added or removed from the program plan, consistent with the procedure for obtaining a program index code. Attachment (Timeline Chart)

Administration 

### 2-98 

### August 17, 1992

### DATE: ATTACHMENT NO.2 

### April :7, 

### :991 ?AGE: 1 

### of 6 

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.

POLICY POL SOOA NEGOTIATION REVIEW TEAM SEE ALSO: NONE



### The Negotiation Review Team is established to provide program wide quality assurance in the clean UP 

### of hazardous waste sites. It will provide a clearinghouse for the implementation of the Model Toxics Control Act and a focal point for policy and technical issues. It is advisory in nature and will elevate to management any major program issues needing resolution. 1. The Negotiation Review Team Consists Of Four Persons. 

### The Negotiation Review Team will be made up of a technical reviewer, policy reviewer, cost recovery reviewer and an Assistant Attorney General. Each will focus their review to issues appropriate to their expertise. The cost recovery and policy reviewers will be assigned by the Program Manager. The technical reviewer is selected by the site manager from the list found in Attachment A. The policy reviewer will be the Review Team Contact. Alternates to the review team will be designated. 2. The Following Documents Shall Be Submitted To The Review Team Prior To External Distribution: 

### (a) All draft orders and decrees proposed by Cleanup staff. All remedial actions orders and decrees prepared by the Industrial Section of Central Program shall also be submitted. This would include orders (excluding emergency orders) or decrees prepared pursuant to Chapters 70.1050, 70.105 and 90.48 RCW. (For 90.48 or 70.105 orders only those orders which are used to conduct remedial actions. For example, Urban Bay source control orders do not need to be submitted for review.) At least one copy of any pertinent technical documents needed to understand the requirements of the order or decree should be attached; (b) Significant amendments to all previously signed orders and decrees prepared pursuanc to Chapters 70.105D, 70.105B, 70.105 and 90.48 RCW and proposed by Cleanup or Industrial scaff (this would also include amendments to emergency orders. for all non-emergency actions)
. At leasc one copy of any pertinent technical documencs should



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..... .-

### ....

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_ 

## . ') 

### --, :!.992

### DATE: 

### April 17, 1991 PAGE: 2 

### of 6



### (c) Draft cleanup action plans; (d) Draft cleanup standards or**l~vels** 

### whenever they are being set for a site specific cleanup action; 

### CANCELS: NEW SEE ALSO: NONE 

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(e) Mixed funding requests if separate from consent decree; (f) Draft Applicable or Relevant and Appropriate Requirements (ARARs) letter to EPA; (g) Draft Records of Decision (ROD); (h) Draft site specific Superfund Memorandum Of Agreement (SMOA); and (i) Section 120 Federal Facility Agreements. 3. 

### The Site Manager Shall Submit 4 

### Copies Of 

### The Document With Completed Cover Form. The site manager will submit a completed cover form (Attachment B) with 

### four copies of the document to the Review Team Contact before sending the documents to the potentially liable person(s)
. 

# c=J One copy each of pertinent technical documents shall also be attached. 

### 4. The Review Team Will Generallv Provide Review Within 5 Working Days From The Date Of 

### Receipt Of 

### Documents. The Review Team, when necessary, will review documents within 5 working days, however, if the document can be submitted for a longer time period that should be indicated. The Review Team wiliattempt to provide quicker review under certain circumstances. The request for a quicker review time must be discussed and cleared with the Review Team Contact. If, on receipt, the Review Team Contact is aware of other**tim~** 

### commitments such that the team cannot meet the normal deadline, the site manager will be notified immediately. 

### S. The Review Team Will Contact The Site Manager With Comments. If any member of the Review Team has comments on the document being reviewed they will either 

# c= notify the site manager directly or submit / comments to the Review Team Contact to be forwarded. 1-108 November 18, 1992

### DATE: 

### April 17, 1991 PAGE: 3 

### of 6 CANCELS: NEW SEE ALSO: NONE 

### Generally the comments will be relayed orally. If written comments are requested then the review team will submit comments to the site manager in writing. If the site manager does not hear from the review team by the agreed upon date they are free to proceed.
6. The Review Team Will Elevate Major Issues To Management . 

### If, during the course of the review, a major policy or technical issue is discovered that requires resolution, the Review Team Contact will elevate the issue through the Policy Section Head. Only major issues will be elevated and only after discussion with the staff and Section Head**involved~** 

### 7. If, During The Negotiations, The Document Is Substantively Changed. Then The Review Team Contact Shall Be Apprised Of Changes. 

### If, during the negotiations, elements of the document have changed substantively, then the site manager shall notify the Review Team**Contact~** 

### Of particular concern to the Review Team are significant changes in the Cost Recovery provisions or cleanup levels. The Review Team will provide immediate feedback if any problems are perceived. The Review Team will not participate in negotiations but may be relied on to provide technical assistance throughout the process. 8. Final Documents Shall Be Submitted To The Review Team Contact For The Central File. 

### Two copies of all final consent decrees, orders, emergency orders, cleanup action plans, RODs, SMOAS and Federal Facility Agreements and all subseauent amendments shall be submitted to the**Revie~** 

### Team Contact within lS 

### days of finalization of the document. A copy of the "Cost Recovery Information Form" (Attachment C) must be completed and submitted with the document.
9. The Management Team Will Review The Ongoing Need For And Membership Of The Neaotiation Review Team 

### On A Yearly Basis.

:-**~09** 

### :;ovemoer 18, 1992

### DATE: CANCELS: 

### April 17, 1991 NEW 

### PAGE: 4 of 

### 6 SEE ALSO: NONE 

### NEGOTIATION REVIEY TEAM COVER FORM DATE

_ TO: Curtis Dahlgren, Woodland Square Pat Melone, Woodland Square Jay Manning, Eikenberry Building Technical Reviewer FROM: (Site Manager) Site Name:



# ----------------------- Assigned Assistant Attorney General,

__ 

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Date Comments Needed (S-day Review Minimum) Site PIC (if known) Tvpe of Document: 

### ----/_---/_--

Agreed Order Cleanup Action Plan Emergency Order Enforcement Order Consent Decree Fed. Fac. Agreement Phase of Work: Site Hazard Assessment Routine Action Rem. Investigation Other Information: Ch. 90.48 ROW Order Ch. 70.105 ROW Order Record of Decision (ROD) State Memorandum of Agreement (SMOA) Other
Feasibility Study Interim Action Cleanup Action 

### 1 1 

### 1 

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NOTE: Please attach one copy of any pertinent, technical documents to the technical reviewer's copy. 

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II, 5:ite Managemenr. 1-110 

### November 18, 1992

### DATE: April 17, 1991 

### PAGE: 5 

### of 6

The site manager is responsible for routing one copy of the document, with any technical appendices necessary. directly to the appropriate Technical Reviewer. It is only necessary to send the document to one of the technical reviewers for each particular phase of work. Technical Reviewers 

# • CANCELS: 

### NEW SEE ALSO: 

### NONE

The decision of which technical reviewer should look at the document is left to the discretion of the site manager. Carol Kraege and Ching-Pi Wang are engineers. and Mark Fuchs and Bob Swackhammer are hydrogeologists. The following table lists the technical. reviewers available for the different phases of work.
Phase of Work
Site Hazard Assessment Routine Action Rem. Investigation Feasibility Study Interim Action Cleanup Action Cleanup Action Plan**;;"~. ~ana~.m.nc.**  1-
....u. 

### TechnLcal Reviewers
Fuchs or Swackhammer Kraege or Wang Fuchs or Swackhammer Kraege or Wang Kraege or Wang Kraege or Wang Kraege



## .,., .LO,

### DATE: April 17, 1991 

### PAGE: 6 of 

### 6 CANCELS: NEW 

### TO: Negotiation Review Team Coordinator FROM: SUBJECT: Final Document DATE: SEE ALSO: NONE 

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PROJECT NO. (Cost Rec. Coor. PrOVides) SITE NAME: OFFICE LOC:

_ Type of Document: Agreed Order Cleanup Action Plan Emergency Order Enforcement Order Consent: Decree Fed. Fac. Agreement SITE PIC: SITE MANAGER:

Ch. 90.48 RCW Order Ch. 70.105 RCW Order Record of Decision (ROD) State Memorandum of Agreement (SMOA) Other 

### [ 1 [ 1 [ 1

EFFECTIVE DATE OF DOCUMENT: ASSISTANT ATTORNEY GENERAL

_ IS PLP ADDRESS SHOWN IN DOCUMENT: YES (If NO, put: address here:

Are past coses included? YES NO (If YES,for what time period? Billing restrictions? YES NO (If YES, describe: NO 

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If 

### more than one PLP, how should invoice amount: be apportioned? PLP 

## x PLP PLP i. 

### PLP PLP i. 

### PLP PLP i. 

### PLP FISCAL OFFICE USE ONLY % % % %



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Si:.e**~ana~emenc.** 

### 1-112 November 18, 1992

### ATTACHMENT NO; 

### 3



## Washington State Department of Ecology



# Guidancefor

.Clean Closure of Dangerous Waste Facilities



# ** DRAFT 

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Solid and Hazardous Waste Program Mail Stop 7600 Olympia, WA 98504-7600 April 1993 ()

.Printed on Recycled PaperTABLE OF CONTENTS PAGE 

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1.0 CLEAN CLOSURE REQUIREMENTS

. 1.1 PURPOSE "

. 1.2 AUTHORITY

. 1.3 CLEAN CLOSURE PERFORMANCE STANDARD

. 1.4 REMOVING CONTAMINANTS FROM THE SITE

. 1.5 CERTIFICATION OF CLOSURE

. 2.0 SAMPUNG AND ANALYSIS PLANS

. 2.1 PREPARATION OF A FIELD SAMPUNG PLAN

. 2.2 SELECTION OF CONSTITUENTSTO**~E** ANAlYZED

.. "

. 2.3 IMPLEMENTATION OF A SAMPUNG PROGRAM AND STATISTICAL ANAlYSIS OF DATA .....•..................................... 3.0 DECONTAMINATION PROCEDURES FOR TANKS

. 3.1 DECONTAMINATING TANKS "

. 3.2 TANK CLOSURE PERFORMANCE STANDARD

. 4.0 CONCRETE DECONTAMINATION PROCEDURES

. 4.1 CLEANING PROCEDURES

. 4.2 SURFACE SAMPUNG OF CONCRETE

. 5.0 SOil SAMPUNG

. 6.0 GROUNDWATER MONITORING

. 7.0 ANALYTICAl METHODS "

. 7.1 ANAlYTICAL METHODS

. 7.2 MULTIPLE METHODS

. 8.0 QUAUTY ASSURANCE AND QUAUTYCONTROL REQUIREMENTS

. 8.1 LABORATORYQUAUTY CONTROL/QUAUTYASSURANCE

. 8.2 DOCUMENTATION OF FIELD ACTlVmES AND QAlQC IN THE FIELD . 9.0 REFERENCES

. 1-1 1-1 1-1 1-1 1-3 14 2-1 2-1 2-1 2-2 3-1 3-1 3-2 4-1 4-1 4-2 5-1 

# (j 6-1 7-1 7-1 7-1 8-1 8-1 8-2 9=1



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### 1.0 CLEAN CLOSURE REQUIREMENTS
1.1 PURPOSE
Thepurposeofthis documentis to providetechnicalgUidanceforcleanclosing dangerous waste management unitsat Interim and Final StatusTreatment, Storage and Disposal Facilities. Thisdocumentprovidesspecificdirectionforcleanupand removal ofwastesin soil, concrete, and above-ground storagetanks and fordemonstrating that clean closure standards are met. This guidance can be used to assist in determining sampling strategies, cleanup techniques and cleanuplevels,analyticaltechniques, and statisticalmethodsforcleanclosureofdangerouswaste" management units. Alternative methods to those presented here can be used if approved by' Ecology.
In addition to providing guidance at the time ofclosure, the elements ofthis guidance shouldbeaddressed in the facility's closure plan. Minimum requirementsforfinal status closure plans for final statusfacilities arecontained in WAC 173-303-610 (3)(a)(i-viQand requirementsfor interim status facilities are referenced in WAC 173-303400(3)(a). Post-closuremonitoring is required when wastes are left in place at a dangerous waste management unit. This guidance does not address these snuanons. In addition, closure administrative procedures are not included in this document.
1.2 AUTHORITY
Owners and operatorsofdangerouswaste facilities mustcomplywiththe Federal Resource Conservation and Recovery Act (RCRA) and its implementing requlatlons in Chapter 40**Cf.~,** inclUding 40 CFR Part 264 and 265. The Washington State Department of Ecology has been authorized to implementthese regulations in Washington and has adopted regulatory language in Chapter 173-303 WAC. Sections 610 through 680, and section 400 of Chapter 173-303WAC provides specific regulatory requirements for the closure of dangerous waste facilities.
1.3 CLEAN CLOSURE PERFORMANCE STANDARD
Clean closure will require the removal of all dangerous waste constituents inclUding contaminated containment system components, contaminated soils, and other contaminated structuresand equipmentat adangerouswaste managementunit. Dangerouswasteconstituents
1-1in all media will be removed or decontaminatedto the cleanup levels established by WAC 173- 340-700 through 760 WAC, excluding Section 745. Cleanup levels will be established using· 

# C Method A, or 8, as defined in Chapter 173-340 WAC. The basis of Chapter ·173-340 WAC is cleanup to health-risk based levels, however, in addition, requirementsofthischapterutilize a combination ofbackground, practical quantification levels,.arid other applicable and relevant state or federal laws to establish cleanup levels. For purposesofdemonstrating clean closure, there is no point ofcompliancein the dangerous waste management unit as discussed in WAC 173-303-645(6)(a)or as defined in WAC 173-340-200. Instead, clean closurelevels mustbeobtainedthroughoutthe unit and will include contamination released from the unit.
The cleanup levels specified in WAC**173-34~74O** for soils may be applied to concrete; however, the facility proponent:mayprefer to conduct individual risk aSsessments on concrete structuresthat will be left in place after closure. Cleanup levels and procedures for otherbases, liners, or equipment encountered during closure will be handled on a case-by-case basis

.. Method CofChapter 173-340 WACis not applicable to clean closureofdangerous waste management units because pursuantto WAC 173-340-420,cleanup actions which leave waste
, constituents in place that exceed Method A or 8 levels, require aperiodic review no less than once every five years. Similarty, Method AofWAC**173-34~745** js not applicable to clean closure requirements because of the requirements of institutional controls.
The cleanup standards in WAC**1~700** - 760 (excluding 745) reference the following sections in Chapter 173-340: 130, 350, 360, 410, 440. These sections do not apply to clean closure.
The demonstration of clean closure must consider all dangerous waste constituents generatedormanagedat the facility. For commercial facilities managing a large number of waste streams or if waste streams are unknown or suspect, then analysis of the constituent list in Appendix IXof40 CFR 264 maybe appropriate. When groundwater monitoring is required by Ecology for purposesof confirming clean closure, the clean closure decision will be delayed until Ecology is satisfied that groundwater meets the clean closure level. In some cases, constituent concentrations may have exceeded Chapter 173-340WAC, Method A or 8 cleanup standards, prior to operations of the dangerous waste management units (i.e.,

1-2 

# o

opreexisting background exceeds the appropriate MTCAstandards for clean closure). In these

. cases, clean closure of individual units may occur so long as 1) all the dangerous waste constituents that originated fromthe unit are removed to appropriate cleanup levels and 2) at Ecology'sdiscretion, 

### any dangerouswaste constituents remaining in the unit will be removed to the appropriate cleanup level through RCRA corrective action or through a MTCA or CERCLA action.
1.4 REMOVING CONTAMINANTS FROM THE SITE Any project which is attempting to clean close by removal ofwaste material must fully describe, in the closure plan, each step in removing waste, contaminated equipment, and contaminated soil from the propertyand estimatevolumes andtypeof waste that will be removed. This includes adescriptionofstaginQ-andcontainerizationofwaste or reagents, equipmentused;i' removal pattern and depth increments, loading areas or

### any otherstep critical to removal. l1le. plan should clearly define how soil will be removed, stored, loaded and managed, both on the site and once it leaves the property. In addition, efforts to minimize airemissionsduringtreatmentor loading, includingvolatiles and dust, should be described when applicable. Wastes: All wastes, debris, and contaminated media generatedthrough closure activities must be managed inaccordancewithapplicablerequirements inChapter173-303andapplicable Federal hazardous waste requirements. Specific waste management strategies for the facility must be presented in the closure. plan or an addendum to the closure plan. Ecology requires facilitiesundergoingclosure to practicewaste minimization when developingclosure management strategies.
For units which were used to manage listed wastes, wastes removed at closure will continue to hold applicable listings. Care should be taken to properly manage and dispose of dangerous wastes generated during closure, including proper application of State and Federal hazardous waste land disposal restrictions.
If a waste, waste residue, or other media does not designate as a dangerous waste constituent, butexceedsthe detection limit for anydangerouswaste constituent, and the material is to be removed from the site, then it must be disposed of

### at a municipal solid waste landfill in compliance with Chapter 173-304 WAC or a permitted dangerous waste facility. Disposal at a


### 1-3landfill may only take place if the operator of the landfill and the County Heatth Department provide approval for disposal after reviewing the analytical results. 

# C

Contaminated Debris: EPA has promulgated rules governing the application of Federal hazardouswaste land disposal restrictionsto contaminated debris. These rules are effective in Washington and are presently being implemented by the EPA Region 10 in conjunction with Ecology. Debris are defined ascontaminated materials with a particle size of greaterthan 60 mm (approximately 2.5 inches). Debris intended for disposal in the land, on or off site, must meet: applicable land disposal restrictions (Federal Register, August 18, 1992).

.Contaminated Environmental Media: Contaminated environmental media, such as; contaminated groundwateror soil, may be subjectto special managementstandardssuch asthe
- "Contained In" policy. The contained in policystates that environmental media such as soilsand groundwaterwhich contain dangerouswaste mustbe managedasiftheyare adangerouswaste
. until or unless they no longer contain a listed wastes, exhibit a characteristic or are delisted. Contaminated environmental media aredeemedto no longercontain dangerouswaste when the dangerousconstituentsin the media fall belowsitespecificheatth-riskbasedlevels and themedia does not exhibit adangerous characteristic. All decisions in application ofthis policy are made case-by-case at the discretion of Ecology. Facilities proponents which anticipate management 

# 0 of contaminated environmental media as a portion of their closure activities should plan on working closely with Ecology.
1.5 CERTIFICATION OF CLOSURE
PursuanttoWAC 173-303-610(6) aqualified, independent, registeredProfessional Engineer must certify closure of a dangerous waste management unit. In order to certify closure,**t~** engineershall be involved in sample location planning, sampling, and sitereclamation activities.



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14

### 2.0 SAMPLING AND ANALYSIS PLANS
2.1 PREPARATION OF A FIELD SAMPUNG PLAN Closure plans must contain a sampling and analysis plan. Each sampling and analysis plan should explicitly state the intent to define contamination to the full extent. An adequate sampling and analysis plan should include the following infonnation and rationale for'each"· selection:

" Sampling approach and methOds including the rationale and methods 

### usect1odetenninewhere sampling will occur.

" Detailed description 01 sampling methods including references to the standard"" methods.

" Sampling locationsand unique10numberfor each location (if final location deviates significantlyfrom plan, Ecology must approve);

.

" Sample containerand preservation requirements;

" Laboratory analyses to be perfonned, including rationale for analyses, analytical techniques, and expected detection limits; constituents may include any found in WAC 173-303-9905 or 40 CFR 264Appendix IX that may be at the facility or in the waste;

" Samplingand analysis proceduresto verifydecontaminationofabove-groundtanks and concrete containment systems and other mediaor equipment;

" Description 01 OA/OC proceduresto be used.

" Description of what data will be reported to**ECOI~.**

" Personnel safety proceduresfor decontamination.
In addition to these elements of a sampling and analysis plan, data quality objectives should be considered (see Section 8).
2.2 SELECTION OF CONSTITUENTS TO BE ANALVZED
Selection of the proper analytical constituents must reflect on-site operations during the waste management unit's life. In many instances, if a storage area only managed one or two
2-1waste streamswith similardangerousconstituents, alimited numberof analytes may be selected, However, for commercial facilities which handle wastes with a large variety of dangerous 

# C constituents, thesampling maycoverthe entire suite ofdangerouswaste constituents in 40 CFR, Part 264, Appendix IX.
At Ecology'sdiscretion, and dependingonfacilitydesign and pastmanagementpractices, a portion of the samples to demonstrate clean closure may be done for a list of indicator parameters instead ofthefull listofdangerouswaste constituents generated or managed atthe
- facility. The indicatorparametersshould be the most likely to have been released basedontypes and amounts of wastes accepted or generated at the facility. Final verification sampling must include the full suite ofdangerous waste constituents that were generated or managed at the . facility.
Selectionofconstituentsshould not only bebasedon knowledgeofthe wastes managed

at the unit, butmayalso includeotherpotential elementsorcompounds used at the facilitywhich generatedthewaste. For example, soil underlying an FOO6surface impoundment mightalso be analyzed for 1,1,1-trichloroethane, a solvent likely to be used at a plating facility. Some dangerous waste management units should also include degradation products as part ofthe analysis. An examplewould be Vinylchloride for a unit where chlorinated solvents were used. 

# 0

2.3 IMPLEMENTATION OF ASAMPUNG PROGRAM AND STATISTICALANALYSIS OF DATA
A sampling program should include sampling to determine the maximum horizontal and vertical extent of contamination from any unit undergoing closure and must encompass the maximum extent ofthefacility operation rNAC 173-303-610(3)(a)(iQ. Ifany cleanup and removal efforts are needed on-site, sampling should be conducted again to confirm that cleanup levels have been obtained.
To determinethe maXimum extent of contamination, a grid system should be used. Each node ofthe grid is a sampling location with an assigned number. A grid system uses a regular pattern, either rectangular or triangularto determine regular sampling points. One variation of regular sampling would include linearsampling along a drainage-way, boundary or other linear dimension. Length of the grid interval should be based on either 1) size of potential hot spots ofcontamination·ata unit, or 2) extent ofvariabilityofconstituentlevels of interest acrossthe unit. Ifit is likely that hot spots are present, Gilbert (1987) is an appropriate reference for determining 

# 0\ a grid interval based on thesize of hot spots. An exampleofan areawhere it may be appropriate
2-2to base a sampling strategy on size of hot

### spots is a tankstoragearea Alternatively, the number ofsamples to becollectedwhich ultimately determine the grid interval can bebased on the mean and standard deviation ofindicatorconstituents calculated from apilotsamplingstudy. The mean and standard deviation can then beused in the equation presented in Chapter6 of EPA (1989a) to determine the numberof samples to be taken.
Grid sampling density may vary across the unit, and may not include the entire unit depending on the levelofconcern ofthe Ecology representative based on what is known about-- past management practices

### atthe facility.
In addition to sampling 

### at the nodesofthe grid, biased sampling should be

### conducted

.. where there is evidence of potential for leaks or spills or potential for a dangerous 

### waste.- constituent to migrate. Ukely areas for biased sampling include: (1) containers, tanks, waste" piles orany other units (such asappurtenantpipes) in contactwith soil; (2) belowany sumpsor-- valves; (3) load or unload areas (4) storage units with underlying pavements or concrete that appears to be cracked or broken; (5) areas receiving runoff or discharge, such as a ditch, a swale, or the discharge point downgradient from a pipe. Evidence for additional areas of sampling would include: (1) visual or olfactory evidence of contamination; (2) knowledge, 

### such as reports by employees, inspectors, or others, that releases had or may have occurred; .(3) length oftime the unit has been in existence, (4) entries into the unit operating record, and (5) soil gas surveys or soil borings.
For small units where there is some documentation of extent of contamination, biased sampling may be used exclusive of grid sampling. For sampling to confirm that cleanup levels are metfollowing removal or remediation, the grid approach outlined above is generally appropriate. Again, however, it maybe more practical in very small units, and at Ecology's discretion, to require biased sampling only. The grid used to confirm clean closure should overlay contaminated areasdiscoveredduringthe initialsampling at the unit. To confirm clean closure, statistical tests as described inWashington State Department of Ecology's Statistical Guidance for Ecology Site Managers (1992) shall be used. Additional information on sampling statistics is available in U. S. EPA (1986b) and Schweitzer, et aI. (1984).

2-3

### 3.0 DECONTAMINATION PROCEDURES FOR TANKS
3.1 DECONTAMINATING TANKS
The decontamination procedures discussed here are designed for metal tanks including ancillary componentstothe tank system, i.e., pumps, piping, etc. Iffiberglasstanks need to be addressed, contact Ecology to discuss proposed cleaning procedures prior to closure plan submittal. This guidance does not applyto metal tanksthat have contained radionuclides.
The sampling analysis plan within the closure plan will specifythe personnel, equipment, and procedures which shall be used for rinsing and collection activities. This shall include personnelprotectionrequirements, allequipmentandoperationalspecifications,cleansingagents, volume of washwater generated and special temporary waste accumulation/staging areas, including identification oftheirlocation, and final dispositionofthetank. Refer to U.S. EPA (1985) for specifics on steam cleaning and high pressure washing.
All tank surface areas shall be visually inspected for cracks and otheropenings through which washingfluid may reach underlying soil. All identified cracks or openingsshall be sealed with a sealant resistantto both waterand 

### any cleanserdesignated for use in the area
The facility proponent shall maintain a record of all cracks identified. These records may consist of photographs and documentation identifying and describing location and dimensionof cracks. Ifcracks have been identifiedorifthereis

### anyotherindicationthatleakage hasoccurred, the tank must be removed and the soil, concrete, etc., underneath the tank must be evaluated.
Thefirst step in tankdecontamination is to remove all pumpablewastesfrom thetankand all residual sludge and bottom sediment must be scraped, shoveled, orotherwise removed from the tank to the fullest extent practicable (following WISHNOSHA regulations). Following waste removal, the interior of the tank

.and all appurtenances must be decontaminated. Typically this will be accomplished by backflushing the piping and tankwith wateror otherappropriate solventor cleaningfluid. Upon removal ofthefluid, all metaltankswill be rinsed using either steam cleaning or high pressure wash (or an equivalent method) which containsan appropriatecleanseror solvent. All freeliquids/solidsshall be removed betweeneach rinse by vacuum truck or equivalent means.

3-1 

# c

c



# oAll waste and cleaning residues generated during this cleaning process shall be designated. Sludge, residue, and rinsewaterthat designatesas dangerouswastewill betreated or sent off-site to a permitted treatment, storage, or disposal facility. Tanks destined for metal scrap shallberendered unusablepriorto leavingthefacility. Ifthetank isto be sold immedlatety and used for a similar purpose, then testing is notnecessBry, however, the applicant must. documentthis transaction.
3.2 TANKCLOSURE PERFORMANCESTANDARD
To be considered decontaminated, the final**ri~ater** from the tank should have**~::~** dangerouswaste constituentsthatwere managed in the tank present in quantitiesthat**exceed~** . levels in a rinsewater blank. Wipesamples maybe requiredtodemonstratethetankhas been decontaminated ifthere are questions about Whether the cleaning methods or solutions used removed all waste constituents stored or managed in the tank.



### 3-2

### 4.0 CONCRETE DECONTAMINATION PROCEDURES
Decontaminationofconcretecontainmentsystemsconsistsofscrubbingthe surface, power washing, and then taking a surface chip sampleto a depth ofapproximately 1/2-inchto confirm that the closure performanCe standard has been met If the surface chip sample has contamination, a concrete core will be necessaryto determinethe extent of the contamination
Concrete containment systems with liners will be evaluated on a case-by-case baSis. Ecology may use discretion on the amount of chipping and coring required for sampling and analysis.toverify closure performance standards on a site-specific basis.
The sampling and analysis plan within the closure plan will specify the personnet, equipment, and procedures which shall beused for rinsing, scrubbing, and collection activities, including cleansing agents and volumes ofwashwatergenerated.
4.1 CLEANING PROCEDURES
At the start of closure, all surface areas shall be visually inspected for cracks and other openingsthroughwhichwashingfluid mayreach underlyingsoil. Allidentifiedcracksoropenings shall be sealedwith a sealant resistantto both waterand any cleanserdesignatedfor use in the area
The facility proponent shall keep, as part of a field notebook, records of all cracks or openings identified in the concrete containment systems. These records may consist of photographs and correlating written documentation identifying and describing the location and dimensions of the cracks. These shall be identified as biased sampling locations. Any areas which show visual signs of past spillage shall receive a preliminary cleaning. Scrubbing down an area with a cleaning solution is an example of an acceptable preliminary cleaning method. Any other method that is approved by Ecology is also appropriate. Containment areas may then be rinsed by steam cleaning or high pressure wash using an appropriatecleanser. Refer to U.S. EPA (1985) forspecificson steam cleaning and high pressure wash.
Theextentofrinsing ofconcrete surfacesshould be determined on acase-by-case. Care should be taken to avoid generating unnecessary quantities of rinsewater.
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o

oRinsate and cleaning residue from rinsing operations shall be collected by vacuum truck or equivalent means. At no time shall rinsate and cleaning residue from incompatible or unlike waste managementcontainmentsystemsbecommingled. All accumulated rinsate and cleaning residue shall be considered dangerous waste unless it passesthe designation requirements of Chapter 173-303 WAC.
4.2 SURFACE SAMPUNG OF CONCRETE
After rinsing operations have been completed,. surface sampling of the**~~** containmentsystems and sumpsshall be undertaken. Each individual containment**system~-f** sumpwill besampled. Surface sampling will beaccomplished by collecting chipsto a depth of approximately 1/2 inch from the surface ofthe containment system and sump. Where surface contamination ispresentor in areascontainingconstituents(Le.,solvents, etc.)that

# can**~f** the concretecontainmentsystem orsump, Ecology

### mayrequire coresamplesbetaken

### through: the concrete. The surface sample and core sample should be segregated and analyzed.. separately. Samples shall be analyzed for those dangerouswaste constituents expected to 

### bepart of, or derivedfrom, the waste historically managed within the unit. Sampling locationsare discussed in Section 2.3. The number of samples collected must be sufficient to provide.a representative measure ofsurface concentrations.
Ifasampledesignatesas adangerouswaste pursuantto Chapter 173-303WAC, thenthe· arearepresented bythesample (subunit) shallbeconsideredtobeadangerouswaste. Subunits should beestablished in the sampling and analysis plan. Ecology may verity sample results by eitherresampling andanalysis ofa new sample from the same locationas the sample inquestion or by analysis of the remaining sample split.
Concrete structuresthat remain on-site must beevaluated for clean closure requirements (using chipping and coring) in accordance with WAC**1~740** or alternatively, the facility proponent can conduct a risk assessmentfor the structure.

4-2

### 5.0 SOIL SAMPLING Sampling locations within the dangerouswaste management unit will typically be located overstructures as well as exposed soil. Where the grid system for sampling the unit overlies concrete structures, the soil undertying the concrete will be sampled to check for the presence of contamination caused by facility operation, following cleaning of the concrete but before removal. Sampling of soils will be done through holes bored in the overtying concrete. This avoids soil disturbance likely to arise when the concrete is removed. Additionally, concrete borings must be made in a manner to minimize disturbanceto the undertying soil. Procedures will be subjectto approval by Ecology.
Concretestructuresshould notbe removed until after Ecology has reviewed soil analytical data Afterconcrete removal the undertying soil shall besubject to inspection by Ecology. Areas underdocumentedspills and areassusceptibleto releases will receive close scrutiny. Indications of irregular coloration of soil, the presence of wet areas, volatile emissions detected on field detection equipment, odor or other signs of potential contamination may trigger additional sampling and testing if these areas are not already sufficiently characterized in Ecology's judgement. The interval for sampling soil at various depths may be dependent on several factors, including: (1) soil type and permeability; (2)suspected magnitudeof surface contamination; (3) physical state of the waste and its mobility; (4) groundwaterlevel; (5) length of time that waste was present at the site; and (6) relative toxicity of the waste. If surface samples demonstrate contamination, then sampling should be conducted at depth to determine the extent of contamination.
Forfurther information on soil sampling consult U.S. EPA (1986b), U. S. EPA (1984), and Schweitzer, et al. (1984).

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o

o

### 6.0 GROUNDWATER MONITORING
In the event of confirmed or potential soil contamination, verification groundwater monitoring mayalsoberequiredthroughthe closureplan. If the unit"isalreadysubjectto ground water monitoring"requirements, the well location, frequency of sampling, or constituents for groundwatersampling maybemodifiedfor aperiodoftime beyond completionofacleanclosure " to verify the effectivenessofctosureactivities. The lengthofverification monitoring requiredshaJJ be decided on a "case-by-case" basis taking into account hydrogeologic conditions,

. waste characteristics, and otherfactors. Closurewill not be certified until it is clearthat clean ctosure levets are obtained. When groundwater is contaminated, post-closure monitoring will generally be required. Forfurther information on evaluating groUndwater, referto U.S. EPA (1988).



### 6-1

### 7.0 ANALYTICAL METHODS
7.1 ANALYTICAL METHODS
The methods used for sample collection, sample preservation, transportation, allowable time before analysis,samplepreparation, analysis, methoddetectionlimits, practicalquantification limits, quality control, qualityassuranceand othertechnical requirementsandspecifications shall comply with the following requirements

### as applicable (from Chapter 173-340 WAC).
Method 1. 

### Test Methodsfor Evaluating Solid Waste, Physical Chemical Methods, Third Edition, US EPA, SW-846 and any revisions oramendmentsthereto;
Method 2. Methodsfor Chemical Analysis of Water and Wastes, U.S. EPA, EPA-600/4-79- 020 and any revisions or amendmentsthereto;
Method 

### 3. Guidelines Establishing

### Test Procedures for the Analysis of Pollutants Under the Clean Water Act, 40 CFR 136 and Appendix A, B,and C, U.S. EPA and any revisions or . amendments thereto;
Method 4. Standard Methods for the Examination of Water and Wastewater, American Public Health Association, American Water Works Association and Water Pollution Control Federation and 

### any revisions or amendments thereto.
Method 1 shouldbeused to determinecontaminantlevels in soil and solid waste. Methods 1, 2, 3, and 4 may be used to determine contaminant levels in groundwaterfor confirmational monitoring.
7.2 MULTIPLE METHODS
Where there is more than one method specified in subsection 7.1 of this section with a . practical quantification limit less than the cleanup standard, any of these methods may be

selected. In these situations, considerations in selecting a particular method may include confidence in the data, analytical costs, and considerations relating to the quality assurance or analysis efficiencies.

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oTests forwhich methods have not been specified in this section shatl be performed using standard methods or procedures such asthose specified by the ASTMWhenavailable. Ecology may require an analysisto be conducted by more than one method in orderto provide higher data qUality•.



### 7·2

### 8.0 QUALITY ASSURANCE AND QUALITYCONTROL REQUIREMENTS 

# o During a closure investigation, samples must be collected and analyzed with sufficiem qualityassuranceand qualitycontrol (OA/OC) procedures in orderto ensure represemativeand reliable results. The validity of both sampling techniques and laboratory analytical procedures must beassured so thatthe datafrom sampling activities can be used to accurately assess the presence or absence ofcomamination at the site.
Before 

### any sampling is conducted, facility proponents should consider data qUality objectives, which are statements ofthe precision, bias, represemativeness, completeness, and comparabilityofthe data

### necessaryfor thedatato serve the objectivesofthe project. Guidance on data qUality objectives and other elemems ofa sampling and analysis plan arefound in the Departmem of Ecology's Guidelines and Specificationsfor Preparing Ouality Assurance Project Plans (1991), which is available from the Environmemallnvestigation and Lab Service, OUaiity Assurance Section.
8.1 LABORATORY QUAUTYCONTROljQUAUTYASSURANCE
At the presem time, Ecology has a list of accredited laboratories for performing water analyses, including groundwateranalyses. All surfacewaterand groundwatersamples taken to documem compliance with the regulations implememed by Ecology must be submitted to a laboratoryaccredited underChapter 173-50WAC. Alisting of laboratoriesaccreditedto perform water analyses may be obtained from Ecology's Environmemal Investigations and Laboratory Services Program (ElLS).
Asimilaraccreditation programfor soil analysesdoesnot presemlyexist, but isamicipated to beestablished within the nextfewyears. In the meamime, we recommend that all solid matrix samples be analyzed in a lab accredited by Ecologyfor water analyses. 

# o

Analytical methods specified in Section 7 require similarOA/OC to Ecology's Manchester Lab. These requiremems includeanalysisofcheckstandards, duplicatesamples, spike samples, and blanksshouldberoutinely run becausetheyprovideinformationforimerpretingtheaccuracy, precision, anddetectioncapabilitiesoftheanalytical proceduresused, Checkstandardsare used to estimate the precision of the method and to check for bias due to canbration Duplicate analyses of samples are used to checkthe precision of the actual samples. Spikes are used to test for bias due to chemical imerference. Blanks are used to estimate the limit of detection of 

# 0

8-1the method and to check for laboratorycomamination. 

### ONOCmethods mustbe specified in the closure plan. Facility proponems conducting clean closure must obtainfrom the laboratorythe OA/OC results run with each batch oflaboratoryanalyses performedfor addition to the detailed records ofthe closure demonstration. OA/QC data isto be reviewed by the person conducting closure demonstrationsand ultimately deliveredto the owner along with the otherdocumemed results of the site check or site assessmem.
Environmemal Protection Agency Comract Lab Procedures (CLP) developed for the Superfund Program, employan extensiveprimoutofdatawith corresponding

### QNQCresults. The CLP reporting format can be a useful reportingformat ifthere are extensive quamitiesofdatato be reviewed, however it is expensive and only a few labs in the state have CLP contracts. Moreover CLPdoes not have abearing on the qualityofthe data Use of CLP will be impractical for most closures in the state but may have applicationsfor large facility closures. U.S. EPA (1986a) has a well thoughtout full menu ofOA/OC options. As an alternativeto CLP, a facility proponem may request the lab managerto submit all QA/QC datawith sampte data OUaiityAssurance/QC datashould be kept as partofthe operating record of the facility.
8.2 DOCUMENTATION OF FIELD ACTIVITIES AND 

### QAtQe IN THE FIELD
A field notebookmust be used by the person conducting aclosureto record times, dates, and locationsofall samples as well as daily evems, observations, field measuremems, and

### any other applicable information obtained during the field investigation. All sntnes should be made in ink, signed, and dated. Photographs should betaken of each sampling location and of

### any unusual circumstances encoumered in the investigation. Field notebooks and photographs should be kept for a minimum offIVe years to help reconstruct sampling procedures and to aid, if necessary, in legal testimony.
Additional information on documemation and custody can be found in U.S. EPA (1984), U.S. EPA (1986a).

8-2

### 9.0 REFERENCES
American Public Health Association, American Water Works Association and Water Pollution Control Federation, Standard Methodsfor the Examination ofWater and Wastewater.
American Standard Testing Methods, 1916 Race Street, Philadelphia, PA 19103.

Gilbert, A.O., 1987, Statistical Methods for Environmental Pollution Monitoring, Van Nostrand Reinhold Company, New York, NY, 320 pp. . Schweitzer, G.E., andJ.A. Santolucito, 1984,EnvironmentalSamplingfor Hazardous Wastes,

### ACS Symposium Series No. 267, American Chemical Society, Washington, D.C. U.S. EPA, 1985, Guide for Decontaminating Buildings Structures and Equipment at Superfund Sites, U.S. EPA, Cincinnati, 600/2-85/028, March 1985. U.S. EPA, 1986(a), Test Methodsfor Evaluating Solid Waste, Vol. 1 (Lab ManuaQ, EPA OSWER SW-846, Third Edition and Subsequent Updates.
U.S. EPA 1986(b), Test Methods for Evaluating Solid Waste, Vol. 2, EPA OSWER SW-846, Third Edition and Subsequent Updates. U.S. EPA, 1988, Methods for Evaluating the Attainment of Cleanup Standards - Volume 2: Groundwater. Draft 2.0, U.S. Environmental Protection Agency. U.S. EPA, 1989(a), Methods for Evaluating the Attainment ofCleanup Standards - Volume 1: Soils and Solid Media, EPA 230/02-89-042, U. S. Environmental Protection Agency Office of Policy, Planning, and Evaluation, Washington, D.C.
U.S. EPA 1989(b), Soil Sampling Quality Assurance, EPA 600/8-89/046, U.S. Environmental Protection Agency, Environmental Monitoring System Laboratory, Los Vegas, NV. U.S. EPA,Guidelines EstablishingTest Proceduresfor the Analysis of Pollutants Under the Clean**W~er** Act, 40 CFR 136, and Appendices A, B, and C.

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o

## u.s. EPA, Methods for Chemical Analysis of Water and Wastes, EPA-600/4-79-020. Washington State Department of Ecology, 1991, Guidelines and Specifications for Preparing Quality Assurance Plans, Environmental Investigation and Laboratory Service Program, Washington State Department of Ecology, Document 91-16. .

.Washington State Departmentof Ecology, 1992 Statistical Guidancefor EcologySite Managers, Toxies Cleanup Program, Document 92054.

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