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

·e.,~ .

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.

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II. 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

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establishing 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. .

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The 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.

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A. 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:

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•

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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.

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funding 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

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regional 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

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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.

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•

ATTACHMENT NO.1

DATE: July 2, 1992

CANCELS: Interim Policy (1/22/92)

POLICY 340 PRIORITY SETTING FOR SITES

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POLICY:

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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)

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POLICY:

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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)

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POLICY:

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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.)

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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

•

CANCELS: NEW .

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 . .- ,::;e ~:.:.~c::ea;

.'_. ..... .-.... _.a _-"---_ . ')

--, :!.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

c

NOTE: Please attach one copy of any pertinent, technical documents to

the technical reviewer's copy.

o

I

I,

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

o

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

c

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

%

%

%

%

c

Si:.e ~ana~emenc. 1-112 November 18, 1992
ATTACHMENT NO; 3

Washington State Department of Ecology

Guidance for

. Clean Closure of Dangerous Waste Facilities

** DRAFT **

Solid and Hazardous Waste Program

Mail Stop 7600

Olympia, WA 98504-7600

April 1993 ().Printed on Recycled Paper
TABLE OF CONTENTS

PAGE c

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 CONSTITUENTS TO ~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 QUAUTY CONTROL REQUIREMENTS .

8.1 LABORATORY QUAUTY CONTROL/QUAUTY ASSURANCE .

8.2 DOCUMENTATION OF FIELD ACTlVmES AND QAlQC IN THE FIELD .

9.0 REFERENCES .

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1.0 CLEAN CLOSURE REQUIREMENTS

1.1 PURPOSE

The purpose of this document is to provide technical gUidance for clean closing dangerous

waste management units at Interim and Final Status Treatment, Storage and Disposal Facilities.

This document provides specific direction for cleanup and removal of wastes in soil, concrete, and

above-ground storage tanks and for demonstrating that clean closure standards are met. This

guidance can be used to assist in determining sampling strategies, cleanup techniques and

cleanup levels, analytical techniques, and statistical methods for clean closure of dangerous waste"

management units. Alternative methods to those presented here can be used if approved by'

Ecology.

In addition to providing guidance at the time of closure, the elements of this guidance

should be addressed in the facility's closure plan. Minimum requirements for final status closure

plans for final status facilities are contained in WAC 173-303-610 (3)(a)(i-viQ and requirements for

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 operators of dangerous waste facilities must comply with the 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 implement these regulations in Washington and has adopted regulatory language

in Chapter 173-303 WAC. Sections 610 through 680, and section 400 of Chapter 173-303 WAC

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

structures and equipment at a dangerous waste management unit. Dangerous waste constituents

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in all media will be removed or decontaminated to 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, requirements of this chapter utilize a combination of background, practical quantification

levels,.arid other applicable and relevant state or federal laws to establish cleanup levels. For

purposes of demonstrating clean closure, there is no point of compliance in the dangerous waste

management unit as discussed in WAC 173-303-645(6)(a) or as defined in WAC 173-340-200.

Instead, clean closure levels must be obtained throughout the 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 :may prefer to conduct individual risk aSsessments on concrete

structures that will be left in place after closure. Cleanup levels and procedures for other bases,

liners, or equipment encountered during closure will be handled on a case-by-case basis..

Method C of Chapter 173-340 WAC is not applicable to clean closure of dangerous waste

management units because pursuant to WAC 173-340-420, cleanup actions which leave waste ,

constituents in place that exceed Method A or 8 levels, require a periodic review no less than

once every five years. Similarty, Method A of WAC 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

generated or managed at 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 IX of 40 CFR 264 may be appropriate. When groundwater monitoring is required by

Ecology for purposes of 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

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preexisting background exceeds the appropriate MTCA standards for clean closure). In these .

cases, clean closure of individual units may occur so long as 1) all the dangerous waste

constituents that originated from the unit are removed to appropriate cleanup levels and 2) at

Ecology's discretion, any dangerous waste 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 of waste material must fully

describe, in the closure plan, each step in removing waste, contaminated equipment, and

contaminated soil from the property and estimate volumes and type of waste that will be removed.

This includes a description of staginQ-andcontainerization of waste or reagents, equipment used;i'

removal pattern and depth increments, loading areas or any other step 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 air emissions during treatment or loading, including volatiles

and dust, should be described when applicable.

Wastes: All wastes, debris, and contaminated media generated through closure activities

must be managed in accordance with applicable requirements in Chapter 173-303 and applicable

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

facilities undergoing closure to practice waste minimization when developing closure 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, but exceeds the detection limit for any dangerous waste 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

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landfill 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

hazardous waste land disposal restrictions to 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 as contaminated materials with a particle size of greater than 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 groundwater or soil, may be subject to special management standards such as the -

"Contained In" policy. The contained in policy states that environmental media such as soils and

groundwater which contain dangerous waste must be managed as if they are a dangerous waste .

until or unless they no longer contain a listed wastes, exhibit a characteristic or are delisted.

Contaminated environmental media are deemed to no longer contain dangerous waste when the

dangerous constituents in the media fall below site specific heatth-risk based levels and the media

does not exhibit a dangerous characteristic. All decisions in application of this 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

Pursuant to WAC 173-303-610(6) a qualified, independent, registered Professional Engineer

must certify closure of a dangerous waste management unit. In order to certify closure, t~

engineer shall be involved in sample location planning, sampling, and site reclamation activities.

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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 usect1odetennine where sampling will occur.

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

methods.

" Sampling locations and unique 10number for each location (if final location deviates

significantly from plan, Ecology must approve); .

" Sample container and 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 264 Appendix IX that may be at the facility or in the

waste;

" Sampling and analysis procedures to verify decontamination of above-ground tanks

and concrete containment systems and other media or equipment;

" Description 01 OA/OC procedures to be used.

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

" Personnel safety procedures for 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

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waste streams with similar dangerous constituents, a limited number of analytes may be selected,

However, for commercial facilities which handle wastes with a large variety of dangerous C

constituents, the sampling may cover the entire suite of dangerous waste constituents in 40 CFR,

Part 264, Appendix IX.

At Ecology's discretion, and depending on facility design and past management practices,

a portion of the samples to demonstrate clean closure may be done for a list of indicator

parameters instead of the full list of dangerous waste constituents generated or managed at the -

facility. The indicator parameters should be the most likely to have been released based on types

and amounts of wastes accepted or generated at the facility. Final verification sampling must

include the full suite of dangerous waste constituents that were generated or managed at the

. facility.

Selection of constituents should not only be based on knowledge of the wastes managed

at the unit, but may also include other potential elements or compounds used at the facility which

generated the waste. For example, soil underlying an FOO6 surface impoundment might also 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 of the

analysis. An example would be Vinyl chloride for a unit where chlorinated solvents were used. 0

2.3 IMPLEMENTATION OF A SAMPUNG PROGRAM AND STATISTICAL ANALYSIS 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 of the facility operation rNAC 173-303-610(3)(a)(iQ. If any cleanup and removal

efforts are needed on-site, sampling should be conducted again to confirm that cleanup levels

have been obtained.

To determine the maXimum extent of contamination, a grid system should be used. Each

node of the grid is a sampling location with an assigned number. A grid system uses a regular

pattern, either rectangular or triangular to determine regular sampling points. One variation of

regular sampling would include linear sampling 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

of contamination·at a unit, or 2) extent of variability of constituent levels of interest across the unit.

If it is likely that hot spots are present, Gilbert (1987) is an appropriate reference for determining

0 \ a grid interval based on the size of hot spots. An example of an area where it may be appropriate

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to base a sampling strategy on size of hot spots is a tank storage area Alternatively, the number

of samples to be collected which ultimately determine the grid interval can be based on the mean

and standard deviation of indicator constituents calculated from a pilot sampling study. The mean

and standard deviation can then be used in the equation presented in Chapter 6 of EPA (1989a)

to determine the number of samples to be taken.

Grid sampling density may vary across the unit, and may not include the entire unit

depending on the level of concern of the Ecology representative based on what is known about--

past management practices at the facility.

In addition to sampling at the nodes of the 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 or any other units (such as appurtenant pipes) in contact with soil; (2) below any sumps or--

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 of time 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 met following removal or remediation, the

grid approach outlined above is generally appropriate. Again, however, it may be 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 areas discovered during the initial sampling

at the unit.

To confirm clean closure, statistical tests as described in Washington 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).

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3.0 DECONTAMINATION PROCEDURES FOR TANKS

3.1 DECONTAMINATING TANKS

The decontamination procedures discussed here are designed for metal tanks including

ancillary components to the tank system, i.e., pumps, piping, etc. If fiberglass tanks need to be

addressed, contact Ecology to discuss proposed cleaning procedures prior to closure plan

submittal. This guidance does not apply to metal tanks that have contained radionuclides.

The sampling analysis plan within the closure plan will specify the personnel, equipment,

and procedures which shall be used for rinsing and collection activities. This shall include

personnel protection requirements, all equipment and operational specifications, cleansing agents,

volume of washwater generated and special temporary waste accumulation/staging areas,

including identification of their location, and final disposition of the tank. 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 other openings through

which washing fluid may reach underlying soil. All identified cracks or openings shall be sealed

with a sealant resistant to both water and any cleanser designated 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 dimension of

cracks. If cracks have been identified or if there is any other indication that leakage has occurred,

the tank must be removed and the soil, concrete, etc., underneath the tank must be evaluated.

The first step in tank decontamination is to remove all pumpable wastes from the tank and

all residual sludge and bottom sediment must be scraped, shoveled, or otherwise 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 tank with

water or other appropriate solvent or cleaning fluid. Upon removal of the fluid, all metal tanks will

be rinsed using either steam cleaning or high pressure wash (or an equivalent method) which

contains an appropriate cleanser or solvent. All free liquids/solids shall be removed between each

rinse by vacuum truck or equivalent means.

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All waste and cleaning residues generated during this cleaning process shall be

designated. Sludge, residue, and rinsewater that designates as dangerous waste will be treated

or sent off-site to a permitted treatment, storage, or disposal facility. Tanks destined for metal

scrap shall be rendered unusable prior to leaving the facility. If the tank is to be sold immedlatety

and used for a similar purpose, then testing is notnecessBry, however, the applicant must.

document this transaction.

3.2 TANK CLOSURE PERFORMANCE STANDARD

To be considered decontaminated, the final ri~ater from the tank should have ~::~

dangerous waste constituents that were managed in the tank present in quantities that exceed~.

levels in a rinsewater blank.

Wipe samples may be required to demonstrate the tank has been decontaminated if there

are questions about Whether the cleaning methods or solutions used removed all waste

constituents stored or managed in the tank.

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4.0 CONCRETE DECONTAMINATION PROCEDURES

Decontamination of concrete containment systems consists of scrubbing the surface, power

washing, and then taking a surface chip sample to a depth of approximately 1/2-inch to confirm

that the closure performanCe standard has been met If the surface chip sample has

contamination, a concrete core will be necessary to determine the 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. to verify 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 be used for rinsing, scrubbing, and collection activities,

including cleansing agents and volumes of washwater generated.

4.1 CLEANING PROCEDURES

At the start of closure, all surface areas shall be visually inspected for cracks and other

openings through which washing fluid may reach underlying soil. All identified cracks or openings

shall be sealed with a sealant resistant to both water and any cleanser designated for 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

appropriate cleanser. Refer to U.S. EPA (1985) for specifics on steam cleaning and high pressure

wash.

The extent of rinsing of concrete surfaces should be determined on a case-by-case. Care

should be taken to avoid generating unnecessary quantities of rinsewater.

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Rinsate 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 management containment systems be commingled. All accumulated rinsate and cleaning

residue shall be considered dangerous waste unless it passes the designation requirements of

Chapter 173-303 WAC.

4.2 SURFACE SAMPUNG OF CONCRETE

After rinsing operations have been completed,. surface sampling of the ~~

containment systems and sumps shall be undertaken. Each individual containment system~-f

sump will be sampled. Surface sampling will be accomplished by collecting chips to a depth of

approximately 1/2 inch from the surface of the containment system and sump. Where surface

contamination is present or in areas containing constituents (Le.,solvents, etc.) that can ~f

the concrete containment system or sump, Ecology mayrequire core samples be taken through:

the concrete. The surface sample and core sample should be segregated and analyzed..

separately. Samples shall be analyzed for those dangerous waste constituents expected to bepart of, or derived from, the waste historically managed within the unit. Sampling locations are

discussed in Section 2.3. The number of samples collected must be sufficient to provide.a

representative measure of surface concentrations.

If a sample designates as a dangerous waste pursuant to Chapter 173-303 WAC, then the·

area represented by the sample (subunit) shall be considered to be a dangerous waste. Subunits

should be established in the sampling and analysis plan. Ecology may verity sample results by

either resampling and analysis of a new sample from the same location as the sample in question

or by analysis of the remaining sample split.

Concrete structures that remain on-site must be evaluated for clean closure requirements

(using chipping and coring) in accordance with WAC 1~740 or alternatively, the facility

proponent can conduct a risk assessment for the structure.

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5.0 SOIL SAMPLING

Sampling locations within the dangerous waste management unit will typically be located

over structures 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 disturbance to the undertying soil. Procedures

will be subject to approval by Ecology.

Concrete structures should not be removed until after Ecology has reviewed soil analytical

data After concrete removal the undertying soil shall be subject to inspection by Ecology. Areas

under documented spills and areas susceptible to 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 magnitude of surface contamination; (3)

physical state of the waste and its mobility; (4) groundwater level; (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.

For further information on soil sampling consult U.S. EPA (1986b), U. S. EPA (1984), and

Schweitzer, et al. (1984).

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6.0 GROUNDWATER MONITORING

In the event of confirmed or potential soil contamination, verification groundwater

monitoring may also be required through the closure plan. If the unit "is already subject to ground

water monitoring" requirements, the well location, frequency of sampling, or constituents for

groundwater sampling may be modified for a period oftime beyond completion of a clean closure "

to verify the effectiveness of ctosure activities. The length of verification monitoring required shaJJ

be decided on a "case-by-case" basis taking into account hydrogeologic conditions, .waste

characteristics, and other factors. Closure will not be certified until it is clear that clean ctosure

levets are obtained. When groundwater is contaminated, post-closure monitoring will generally

be required. For further information on evaluating groUndwater, refer to U.S. EPA (1988).

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7.0 ANALYTICAL METHODS

7.1 ANALYTICAL METHODS

The methods used for sample collection, sample preservation, transportation, allowable

time before analysis, sample preparation, analysis, method detectionlimits, practical quantification

limits, quality control, quality assurance and other technical requirements and specifications shall

comply with the following requirements as applicable (from Chapter 173-340 WAC).

Method 1. Test Methods for Evaluating Solid Waste, Physical Chemical Methods, Third

Edition, US EPA, SW-846 and any revisions or amendments thereto;

Method 2. Methods for Chemical Analysis of Water and Wastes, U.S. EPA, EPA-600/4-79-

020 and any revisions or amendments thereto;

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 should be used to determine contaminant levels in soil and solid waste. Methods

1, 2, 3, and 4 may be used to determine contaminant levels in groundwater for 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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Tests for which methods have not been specified in this section shatl be performed using

standard methods or procedures such as those specified by the ASTM When available.

Ecology may require an analysis to be conducted by more than one method in order to

provide higher data qUality•.

7·2
8.0 QUALITY ASSURANCE AND QUALITY CONTROL REQUIREMENTS

o

During a closure investigation, samples must be collected and analyzed with sufficiem

quality assurance and quality control (OA/OC) procedures in order to ensure represemative and

reliable results. The validity of both sampling techniques and laboratory analytical procedures

must be assured so that the data from sampling activities can be used to accurately assess the

presence or absence of comamination at the site.

Before any sampling is conducted, facility proponents should consider data qUality

objectives, which are statements of the precision, bias, represemativeness, completeness, and

comparability of the data necessary for the data to serve the objectives of the project. Guidance

on data qUality objectives and other elemems of a sampling and analysis plan are found in the

Departmem of Ecology's Guidelines and Specifications for Preparing Ouality Assurance Project

Plans (1991), which is available from the Environmemallnvestigation and Lab Service, OUaiity

Assurance Section.

8.1 LABORATORY QUAUTY CONTROljQUAUTY ASSURANCE

At the presem time, Ecology has a list of accredited laboratories for performing water

analyses, including groundwater analyses. All surface water and groundwater samples taken to

documem compliance with the regulations implememed by Ecology must be submitted to a

laboratory accredited under Chapter 173-50 WAC. A listing of laboratories accredited to perform

water analyses may be obtained from Ecology's Environmemal Investigations and Laboratory

Services Program (ElLS).

A similar accreditation program for soil analyses does not presemly exist, but is amicipated

to be established within the next few years. In the meamime, we recommend that all solid matrix

samples be analyzed in a lab accredited by Ecology for water analyses.

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Analytical methods specified in Section 7 require similar OA/OC to Ecology's Manchester

Lab. These requiremems include analysis of check standards, duplicate samples, spike samples,

and blanks should be routinely run because they provide information for imerpreting the accuracy,

precision, and detection capabilities ofthe analytical procedures used, Check standards are used

to estimate the precision of the method and to check for bias due to canbration Duplicate

analyses of samples are used to check the 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

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the method and to check for laboratory comamination. ONOC methods must be specified in the

closure plan.

Facility proponems conducting clean closure must obtain from the laboratory the OA/OC

results run with each batch of laboratory analyses performed for addition to the detailed records

of the closure demonstration. OA/QC data is to be reviewed by the person conducting closure

demonstrations and ultimately delivered to the owner along with the other documemed results of

the site check or site assessmem.

Environmemal Protection Agency Comract Lab Procedures (CLP) developed for the

Superfund Program, employ an extensive primout of data with corresponding QNQC results. The

CLP reporting format can be a useful reporting format if there are extensive quamities of data to

be reviewed, however it is expensive and only a few labs in the state have CLP contracts.

Moreover CLP does not have a bearing on the quality of the data Use of CLP will be impractical

for most closures in the state but may have applications for large facility closures.

U.S. EPA (1986a) has a well thought out full menu of OA/OC options. As an alternative to

CLP, a facility proponem may request the lab manager to submit all QA/QC data with sampte

data OUaiity Assurance/QC data should be kept as part of the operating record of the facility.

8.2 DOCUMENTATION OF FIELD ACTIVITIES AND QAtQe IN THE FIELD

A field notebook must be used by the person conducting a closure to record times, dates,

and locations of all 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 be taken of each sampling location and of any

unusual circumstances encoumered in the investigation. Field notebooks and photographs

should be kept for a minimum of fIVe 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).

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9.0 REFERENCES

American Public Health Association, American Water Works Association and Water Pollution

Control Federation, Standard Methods for the Examination of Water 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., and J.A. Santolucito, 1984, Environmental Sampling for 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 Methods for 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 of Cleanup 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 Establishing Test Procedures for the Analysis of Pollutants Under the Clean

W~er Act, 40 CFR 136, and Appendices A, B, and C.

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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 Department of Ecology, 1992 Statistical Guidance for Ecology Site Managers,

Toxies Cleanup Program, Document 92054.

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