United
States
Solid
Waste
and
EPA530­
R­
02­
003
Environmental
Protection
Emergency
Response
July,
2002
Agency
(5305W)
www.
epa.
gov/
osw
Office
of
Solid
Waste
Guidance
on
Demonstrating
Compliance
With
the
Land
Disposal
Restrictions
(LDR)
Alternative
Soil
Treatment
Standards
Final
Guidance
i
Disclaimer
The
United
States
Environmental
Protection
Agency's
Office
of
Solid
Waste
(EPA
or
the
Agency)
has
prepared
this
document
to
provide
guidance
to
EPA,
the
states,
the
public,
and
the
regulated
community
regarding
how
to
measure
attainment
of
the
alternative
LDR
soil
treatment
standards.
Alternative
approaches
for
planning
and
implementing
a
sampling
program
and
for
assessing
the
data
may
be
appropriate
where
waste
or
facility­
specific
circumstances
do
not
match
the
underlying
assumptions,
conditions,
and
models
of
the
guidance.

This
guidance
is
not
a
final
Agency
action;
it
is
intended
solely
as
guidance.
This
guidance
does
not
amend
or
otherwise
alter
any
promulgated
regulation.
This
guidance
is
not
intended
to
and
cannot
be
relied
upon,
to
create
any
rights
enforceable
by
any
party
in
litigation
with
the
United
States,
or
create
any
rights
enforceable
by
the
United
States.
EPA
officials
may
decide
to
follow
the
guidance
provided
in
this
document,
or
to
act
at
variance
with
the
guidance,
based
on
an
analysis
of
specific
site
or
facility
circumstances.
The
Agency
also
reserves
the
right
to
change
this
guidance
at
any
time
without
public
notice.
ii
Table
of
Contents
1.
INTRODUCTION
AND
BACKGROUND
.........................................
1
1.1
What
Is
the
Purpose
of
This
Guidance?
.................................
2
1.2
What
Are
the
LDR
Alternative
Soil
Treatment
Standards?
...................
2
1.3
Why
Did
EPA
Develop
Alternative
Soil
Treatment
Standards?
................
2
1.4
When
Are
Alternative
Soil
Treatment
Standards
Available
in
Authorized
and
Unauthorized
States?
...............................................
3
1.5
When
Do
LDR
Treatment
Standards
Apply
to
Hazardous
Soils?
..............
3
1.6
Can
the
Alternative
Soil
Treatment
Standards
Be
Used
to
Establish
Site­
Specific
Cleanup
Standards?
................................................
4
2.
GUIDANCE
FOR
DETERMINING
COMPLIANCE
WITH
THE
ALTERNATIVE
TREATMENT
STANDARDS
FOR
CONTAMINATED
SOIL
..........................
5
2.1
What
Steps
Should
I
Use
to
Plan
the
Sampling
and
Analysis
Program?
.........
7
2.2
How
Do
I
Implement
the
Sampling
and
Analysis
Program?
..................
14
2.3
How
Should
I
Evaluate
the
Data
to
Determine
Attainment
of
the
Treatment
Standards?
......................................................
15
2.3.1
What
Simple
Nonstatistical
Method
Can
I
Use
to
Evaluate
Attainment
of
the
Soil
Treatment
Standards?
..............................
18
2.3.2
What
Methods
Can
I
Use
to
Determine
Attainment
of
the
UTS
or
10
x
UTS?
..................................................
20
2.3.3
What
Statistical
Methods
Can
I
Use
to
Determine
Attainment
of
the
Alternative
Soil
Treatment
Standard
of
90­
Percent
Reduction?
......
21
2.3.3.1
A
"Quick
and
Simple"
Statistical
Method
for
Determining
90­
Percent
Reduction
................................
23
2.3.3.2
Welch's
t­
Test
...................................
25
2.3.3.3
Wilcoxon
Rank­
Sum
Test
...........................
27
3.
WHAT
ARE
THE
NOTIFICATION,
CERTIFICATION,
AND
RECORDKEEPING
REQUIREMENTS
FOR
CONTAMINATED
SOILS?
...............................
31
References
..................................................................
32
APPENDIX
A:
"MANAGEMENT
OF
REMEDIATION
WASTE
UNDER
RCRA"

APPENDIX
B:
STATISTICAL
TABLES
iii
List
of
Acronyms
AOC
Area
of
Contamination
ASTM
American
Society
for
Testing
and
Materials
BTU
British
Thermal
Unit
CFR
Code
of
Federal
Regulations
CMI
Corrective
Measures
Investigation
DQA
Data
Quality
Assessment
DQO
Data
Quality
Objective
EPA
Environmental
Protection
Agency
FR
Federal
Register
HSWA
Hazardous
and
Solid
Waste
Amendments
of
1984
LDRs
Land
Disposal
Restrictions
mg/
kg
milligrams
per
kilogram
mg/
L
milligrams
per
Liter
QAPP
Quality
Assurance
Project
Plan
RCRA
Resource
Conservation
and
Recovery
Act
RFI
RCRA
Facility
Investigation
TC
Toxicity
Characteristic
TCLP
Toxicity
Characteristic
Leaching
Procedure
TSDF
Treatment,
Storage,
or
Disposal
Facility
UHC
Underlying
Hazardous
Constituent
USACE
United
States
Army
Corps
of
Engineers
UTS
Universal
Treatment
Standard
WAP
Waste
Analysis
Plan
1
A
site­
specific
LDR
treatment
variance
from
otherwise
applicable
LDR
treatment
standards
for
contaminated
soil
under
40
CFR
268.44(
h)
also
may
be
an
option.
See
Appendix
A,
"Management
of
Remediation
Waste
Under
RCRA."

1
1.
INTRODUCTION
AND
BACKGROUND
1.1
What
Is
the
Purpose
of
This
Guidance?

The
purpose
of
this
guidance
is
to
provide
suggestions
and
perspectives
on
how
you,
as
members
of
the
regulated
community,
states,
and
the
public,
can
demonstrate
compliance
with
the
alternative
treatment
standards
for
certain
contaminated
soils
that
will
be
land
disposed
and,
therefore,
will
be
subject
to
the
RCRA
land
disposal
restrictions
(LDR)
regulations.
On
May
26,
1998,
EPA
promulgated
land
disposal
restriction
treatment
standards
specific
to
contaminated
soils
(see
63
FR
28555
and
40
CFR
268.49).
Under
these
regulations,
when
disposing
of
contaminated
soils,
you
may
elect
to
comply
with
either
the
alternative
soil
treatment
standards
at
40
CFR
268.49
or
the
generic
treatment
standards
at
40
CFR
268.40
which
apply
to
all
hazardous
wastes.
1
The
LDR
alternative
treatment
standards
require
that
contaminated
soils
which
will
be
land
disposed
must
be
treated
to
reduce
concentrations
of
hazardous
constituents
by
90
percent
or
meet
hazardous
constituent
concentrations
that
are
10
times
the
universal
treatment
standard
(UTS),
whichever
is
greater.

You
should
use
this
guidance
only
in
connection
with
compliance
with
the
LDR
alternative
treatment
standards
that
apply
to
contaminated
soil
which
will
be
land
disposed
(e.
g.,
soil
generated
during
a
cleanup),
and
you
should
not
use
it
to
establish
site­
specific
cleanup
standards.

This
guidance
document
first
describes
the
alternative
treatment
standards
in
some
detail
and
then
explains
why
they
were
developed,
and
their
implementation.
It
then
presents
step­
by­
step
guidance
on
approaches
that
can
assist
you
in
achieving
compliance
with
the
Agency's
alternative
soil
treatment
standards.

This
guidance
document
also
can
be
used
to
assess
attainment
of
the
Corrective
Action
Management
Unit
treatment
standards.
Corrective
Action
Management
Units,
or
"CAMUs,"
are
special
units
created
under
RCRA
to
facilitate
treatment,
storage,
and
disposal
of
hazardous
wastes
managed
for
implementing
cleanup,
and
to
remove
the
disincentives
to
cleanup
that
the
application
of
RCRA
to
these
wastes
can
sometimes
impose
(see
67
FR
2961,
January
22,
2002).
Similar
to
the
LDR
alternative
soil
treatment
standards,
the
CAMU
minimum
national
treatment
standards
require
a
90­
percent
reduction
in
constituent
concentrations,
capped
at
10
times
the
UTS.
2
1.2
What
Are
the
LDR
Alternative
Soil
Treatment
Standards?

Under
the
LDR
alternative
soil
treatment
standards
in
40
CFR
268.49(
c)(
1),
there
are
two
approaches
to
achieving
compliance:

°
hazardous
constituents
must
be
reduced
by
at
least
90
percent
through
treatment
so
that
no
more
than
10
percent
of
their
initial
concentration
remains
or
comparable
reductions
in
mobility
for
metals,
OR
°
hazardous
constituents
must
not
exceed
10
times
the
universal
treatment
standards
(10
x
UTS)
at
40
CFR
268.48.

If
you
treat
the
soil
to
achieve
the
90­
percent
reduction
standard,
or
the
treatment
reduces
constituent
concentrations
to
levels
that
achieve
the
standard
of
10
x
UTS,
then
further
treatment
is
not
required.

Under
40
CFR
268.49(
c),
treatment
for
non­
metals
must
achieve
90­
percent
reduction
in
total
constituent
concentrations.
Treatment
for
metals
must
achieve
90­
percent
reduction
as
measured
in
leachate
from
the
treated
soil
(testing
according
to
the
TCLP)
when
a
metal
stabilization
treatment
technology
is
used,
and
as
measured
in
total
constituent
concentrations
when
a
metal
removal
technology
is
used.

In
addition
to
the
treatment
required
by
§
268.49(
c)(
1),
under
§
268.49(
c)(
2)
prior
to
land
disposal,
soils
that
exhibit
the
characteristic
of
ignitability,
corrosivity,
or
reactivity
must
be
treated
to
eliminate
these
characteristics.

A
hazardous
constituent
is
a
regulated
constituent
specified
in
the
treatment
standard
at
40
CFR
268.40,
or
it
may
be
an
underlying
hazardous
constituent
(UHC).
Any
constituent
that
is
listed
in
the
UTS
Table
at
§
268.48,
except
for
fluoride,
selenium,
sulfides,
vanadium,
and
zinc,
can
be
a
UHC.
You,
as
a
facility
owner
or
operator,
may
use
knowledge
of
the
waste
to
identify
those
UHCs
reasonably
expected
to
be
present
when
hazardous
soils
are
generated.
You
should
use
such
a
waste
knowledge
determination
judiciously
in
identifying
which
UHCs
are
reasonably
expected
to
be
present
in
a
volume
of
soil.
For
more
information
on
appropriate
use
of
knowledge
of
the
waste,
see
EPA's
Waste
Analysis
At
Facilities
That
Generate,
Treat,
Store,
And
Dispose
Of
Hazardous
Wastes:
A
Guidance
Manual,
April
1994,
available
at
http://
www.
epa.
gov/
epaoswer/
hazwaste/
ldr/
wap330.
pdf.
If
you
choose
to
use
the
soil
treatment
standards,
all
UHCs
present
at
levels
greater
than
10
x
UTS
must
be
treated
regardless
of
whether
the
soil
contains
a
listed
waste
or
exhibits
a
characteristic
when
the
soil
is
generated.

A
hazardous
waste
contaminated
soil
that
is
going
to
be
used
in
products
which
are
subsequently
used
in
a
manner
constituting
disposal
must
meet
the
treatment
standards
developed
for
as­
generated
industrial
waste
at
40
CFR
268.40.

1.3
Why
Did
EPA
Develop
Alternative
Soil
Treatment
Standards?

The
alternative
soil
treatment
standards
are
designed
to
encourage
more
cost­
effective
cleanup
of
hazardous
contaminated
soils
subject
to
LDRs
and
to
address
the
unique
characteristics
of
soils.
Before
these
treatment
standards
were
developed,
soils
subject
to
LDRs
were
required
to
3
comply
with
traditional
technology­
based
treatment
standards
developed
for
industrial
hazardous
waste
(see
40
CFR
268.40).
Aside
from
potentially
discouraging
some
remediations,
these
treatment
standards
sometimes
proved
to
be
inappropriate
(e.
g.,
impracticable
or
not
costeffective
or
unachievable
(e.
g.,
did
not
account
for
heterogeneous
soil
matrices)
when
applied
to
hazardous
constituents
present
in
soils.
The
soil
treatment
standards
at
40
CFR
268.49
continue
to
minimize
threats
to
human
health
and
the
environment
(as
required
by
RCRA
section
3004(
m)),
but
provide
for
more
flexible
treatment
requirements
that
consider
the
unique
characteristics
of
soils
and
applicable
treatment
technologies,
and
can
be
achieved
by
using
non­
combustion
treatment
technologies.

1.4
When
Are
Alternative
Soil
Treatment
Standards
Available
in
Authorized
and
Unauthorized
States?

Like
all
LDR
treatment
standards,
the
soil
treatment
standards
are
promulgated
pursuant
to
the
Hazardous
and
Solid
Waste
Amendments
of
1984
(HSWA).
Because
the
alternative
soil
treatment
standards
are
generally
less
stringent
than
the
general
federal
LDR
standards,
as
applied
to
soils,
they
would
not
be
available
in
states
authorized
for
the
land
ban
until
the
state
had
adopted
them.

EPA
encourages
states
to
implement
the
revised
soil
standards
as
rapidly
as
possible.
If
a
state
–
through
implementation
of
State
waiver
authorities
or
other
State
laws
–
were
to
allow
compliance
with
the
soil
treatment
standards
in
advance
of
adoption
or
authorization,
EPA
generally
would
not
consider
such
application
of
the
soil
treatment
standards
for
purposes
of
enforcement
or
State
authorization.
Thus,
by
using
State
law
to
waive
authorized
or
nonauthorized
State
requirements,
a
State
can
allow
immediate
implementation
of
the
soil
treatment
standards
without
jeopardizing
its
RCRA
authorization.
(See
EPA
guidance
memorandum
from
Elizabeth
A.
Cotsworth
to
RCRA
Senior
Policy
Advisors,
Regions
I
­
X,
"Phase
IV
Land
Disposal
Restrictions
Rule
–
Clarification
Of
Effective
Dates"
October
19,
1998
at:
http://
www.
epa.
gov/
epaoswer/
hazwaste/
ldr/
ldrmetal/
memos/
effectiv.
pdf,
especially
page
13).
To
date,
according
to
EPA
records,
29
states
have
adopted
the
LDR
Phase
IV
rule,
and
five
of
these
have
received
authorization
(see
http://
www.
epa.
gov/
epaoswer/
hazwaste/
state/
charts/
chart2.
pdf).
Because
the
availability
of
the
soil
treatment
standards
will
vary
from
state
to
state,
EPA
recommends
that
you
contact
your
state
regulatory
agency
if
you
have
any
questions.

1.5
When
Do
LDR
Treatment
Standards
Apply
to
Hazardous
Soils?

LDR
treatment
standards
apply
to
hazardous
soils
that
are
"generated"
and
managed
in
a
manner
that
qualifies
as
"placement"
on
the
land
for
the
purposes
of
the
Land
Disposal
Restriction
Program.
Soils
to
which
the
standards
apply
are
those
soils
that:
(1)
are
removed
from
the
area
of
contamination
or
are
"placed"
within
the
area
of
contamination
(i.
e.,
"generated");
(2)
are
a
hazardous
waste
(either
because
they
contain
a
listed
hazardous
waste
or
because
they
exhibit
a
hazardous
waste
characteristic);
(3)
are
prohibited
from
land
disposal
(e.
g.,
because
they
do
not
meet
the
applicable
LDR
treatment
standard(
s)
and
they
are
not
eligible
for
a
variance,
extension,
or
exemption);
and
(4)
are
destined
for
land
disposal.

Whether
a
soil
is
both
generated
and
managed
in
a
unit
that
qualifies
as
placement
is
dependent
on
a
number
of
factors.
For
example,
if
hazardous
soil
is
consolidated
within
an
area
of
4
contamination,
it
would
not
be
considered
generated
under
the
LDR
program.
If
the
soil
is
removed
from
the
area,
it
is
considered
to
be
generated
for
the
purposes
of
LDRs,
and
it
may
not
be
managed
in
a
manner
that
qualifies
as
placement
without
prior
treatment.
For
more
specific
information
about
when
LDR
treatment
standards
apply
to
the
soil
due
to
placement
on
the
land,
see
the
Phase
IV
Land
Disposal
Restrictions
(63
FR
28556,
May
26,
1998,
especially
pages
28617
through
28620).
See
also
the
memo
entitled
"Management
of
Remediation
Waste
Under
RCRA"
(EPA/
530­
F­
98­
026,
Office
of
Solid
Waste
and
Emergency
Response),
which
can
be
found
in
Appendix
A
of
this
document.

1.6
Can
the
Alternative
Soil
Treatment
Standards
Be
Used
to
Establish
Site­
Specific
Cleanup
Standards?

The
alternative
soil
treatment
standards
should
not
be
used
to
establish
site­
specific
soil
cleanup
standards.
The
purpose
of
the
land
disposal
restriction
treatment
standards
is
to
ensure
that
prohibited
hazardous
wastes
are
properly
treated
before
disposal
(i.
e.,
treated
so
that
short­
and
long­
term
threats
to
human
health
and
the
environment
posed
by
land
disposal
are
minimized).
The
soil
treatment
standards,
like
other
land
disposal
restriction
treatment
standards,
are
based
on
the
performance
of
specific
treatment
technologies.
In
contrast,
most
soil
cleanup
levels
are
based
not
on
the
performance
of
specific
treatment
technologies
but
on
an
analysis
of
risk.
Technology­
based
treatment
standards
are
not
necessarily
appropriate
surrogates
for
site­
specific
risk­
based
cleanup
levels.
In
a
circumstance
where
the
soil
treatment
standards
result
in
constituent
concentrations
that
are
higher
than
those
determined
on
a
site­
specific
basis
to
be
required
for
soil
cleanup,
existing
remedial
programs
such
as
RCRA
Corrective
Action,
CERCLA
and
state
cleanup
programs
could
be
applied
to
ensure
that
remedies
are
adequately
protective
(e.
g.,
require
a
site­
specific
cleanup
standard
that
is
lower
than
the
soil
treatment
standard).
Conversely,
for
contaminated
soil
only,
under
40
CFR
268.44(
h)(
3),
a
site­
specific,
risk­
based
variance
may
be
an
option
where
treatment
to
the
soil
treatment
standards
would
result
in
concentrations
of
hazardous
constituents
that
are
lower
than
concentrations
necessary
to
minimize
short­
and
long­
term
risks
to
human
health
and
the
environment.
5
2.
GUIDANCE
FOR
DETERMINING
COMPLIANCE
WITH
THE
ALTERNATIVE
TREATMENT
STANDARDS
FOR
CONTAMINATED
SOIL
If
LDR
treatment
standards
apply
to
your
soil,
or
if
you
think
the
standards
will
apply
(for
example,
because
hazardous
soils
will
be
excavated
as
part
of
the
remedy),
then
you
can
use
the
guidance
in
this
section
to
help
determine
how
to
comply
with
the
standards.

The
first
step
is
to
identify
whether
contaminated
soil
is
hazardous
and
if
so,
what
constituents
require
treatment
under
the
LDR
program.
With
the
exception
of
transporters,
every
hazardous
waste
handler
along
the
cradle­
to­
grave
spectrum
has
waste
analysis
requirements.

Hazardous
Waste
Handler
Waste
Analysis
Requirements
Generators
§
262.11
for
hazardous
waste
identification
§
268.7(
a)(
1)
to
determine
if
the
soil
has
to
be
treated
before
it
can
be
land
disposed
Generators
that
treat
in
their
tanks,
containers,
or
containment
buildings
In
addition
to
the
requirements
above,
§
268.7(
a)(
5)
requires
a
written
waste
analysis
plan
(WAP)

Treatment
Facilities
§
264.13
(permitted
facilities)
and
§
265.13
(interim
status
facilities)
require
a
written
WAP
§
268.7(
b)
requires
treatment
facilities
to
test
for
LDR
requirements
according
to
the
WAP
Disposal
Facilities
§
264.13
(permitted
facilities)
and
§
265.13
(interim
status
facilities)
require
a
written
WAP
§
268.7(
c)
requires
disposal
facilities
to
test
for
LDR
requirements
according
to
the
WAP
Compared
to
TSDFs,
generators
are
not
required
to
maintain
a
written
waste
analysis
plan
unless
they
are
treating
in
their
tanks,
containers,
or
containment
buildings.
However,
generators
are
required
to
characterize
their
waste
with
a
high
degree
of
certainty
and
maintain
records
showing
how
they
made
their
determinations
(under
§
262.40
and
§268.7(
a)(
8)).

For
detailed
information
about
how
to
develop
a
waste
analysis
plan,
see
EPA's
Waste
Analysis
At
Facilities
That
Generate,
Treat,
Store,
And
Dispose
Of
Hazardous
Wastes:
A
Guidance
Manual,
April
1994,
available
at
http://
www.
epa.
gov/
epaoswer/
hazwaste/
ldr/
wap330.
pdf.
To
briefly
summarize,
compliance
with
the
waste
analysis
requirements
can
be
demonstrated
by
sampling
and
analysis,
by
using
acceptable
knowledge
or
by
a
combination
of
sampling
and
laboratory
analysis
and
acceptable
knowledge.
You
can
show
acceptable
knowledge
by
using:

°
process
knowledge,
or
detailed
information
on
the
wastes
obtained
from
existing
published
or
documented
waste
analysis
data
or
studies
conducted
on
hazardous
wastes
generated
by
similar
processes;

°
waste
analysis
data
obtained
from
facilities
which
send
wastes
off­
site
for
treatment,
storage,
or
disposal
(e.
g.,
generators);
or
6
°
facility
records,
which
must
be
current
and
accurate,
of
analyses
performed
before
or
after
the
effective
date
of
RCRA
regulations.

The
waste
knowledge
approach(
es)
may
be
particularly
useful
if
hazardous
constituents
in
wastes
from
specific
processes
are
well
documented
or
if
discarded
wastes
are
unused
commercial
chemical
products
or
reagents
with
known
physical
or
chemical
constituents.
Also,
you
may
choose
to
use
waste
knowledge
if
conditions
are
not
conducive
to
sampling
and
analysis
due
to
health
and
safety
risks
or
the
physical
nature
of
the
actual
wastes.
However,
consider
that
if
you
are
excavating
a
site
with
unclear
historical
sources
of
contamination,
it
is
unlikely
you
will
be
able
to
characterize
the
soil
using
acceptable
knowledge.
If
you
choose
to
use
waste
knowledge
or
a
combination
of
waste
knowledge
and
sampling
and
analysis,
documentation
is
essential
to
demonstrate
that
the
information
used
identifies
the
waste
accurately
and
completely.

Compliance
is
best
ensured
through
sampling
and
analysis.
Because
RCRA
is
a
selfimplementing
program,
the
burden
is
on
you,
the
individual
facility
owner/
operator,
to
demonstrate
that
you
are
operating
in
compliance
with
all
applicable
regulations.

You
should
determine
as
early
as
possible
in
the
site
characterization
process
whether
LDRs
might
apply
to
your
soils.
To
do
this,
you
will
need
to
integrate
site
characterization,
hazardous
waste
determination,
and
LDR
compliance
activities
early
in
the
corrective
action.
If
you
anticipate
that
generation
of
hazardous
soils
will
occur
and
that
those
soils
will
be
subject
to
LDRs
due
to
land
placement,
then
you
could
plan
to
generate
site
characterization
data
that
also
meet
the
performance
and
acceptance
criteria
for
LDR
compliance.
This
strategy
could
minimize
redundant
waste
analyses,
reduce
costs,
and
save
time.

As
discussed
earlier
in
Section
1.2,
the
alternative
soil
treatment
standard
under
40
CFR
268.49(
c)(
1)
includes
treatment
of
soil
to
one
of
two
standards,
whichever
is
higher:

°
hazardous
constituents
must
be
reduced
by
at
least
90­
percent
through
treatment,
OR
°
hazardous
constituents
must
not
exceed
10
x
UTS
at
40
CFR
268.48.

The
data
collection
and
assessment
methods
needed
to
demonstrate
attainment
of
the
90­
percent
reduction
standard
will
differ
from
those
needed
to
demonstrate
attainment
of
10
x
UTS.
Specifically,
if
you
plan
to
use
sampling
and
analysis
to
determine
compliance
with
the
90­
percent
reduction
standard,
then
you
may
need
to
obtain
TWO
sets
of
samples
as
part
of
the
sampling
strategy:

°
Obtain
one
set
of
samples
prior
to
treatment
to
estimate
concentrations
of
contaminants
of
concern
in
the
soil
for
comparison
to
LDR
standards
and
to
determine
if
treatment
is
needed,
AND
°
If
treatment
is
needed,
obtain
another
set
of
samples
after
treatment
to
estimate
concentrations
of
contaminants
of
concern
in
the
same
volume
of
soil
and
to
determine
if
the
treatment
has
attained
the
standard.
2
For
treatment,
storage,
or
disposal
facilities
(TSDFs),
the
sampling
and
analysis
procedures
typically
are
documented
in
a
waste
analysis
plan
(WAP).
For
RCRA
corrective
actions
or
Superfund
remedies,
sampling
and
analysis
procedures
may
be
described
in
any
of
a
number
of
planning
documents
(e.
g.,
RFI
Work
Plan,
CMI
Work
Plan,
Remedial
Action
Plan,
etc.)
which
we
refer
to
generically
as
the
quality
assurance
project
plan
(QAPP).

7
Specify
Limits
on
Decision
Errors
Develop
a
Decision
Rule
Define
the
Study
Boundaries
Identify
Inputs
to
the
Decision
Identify
the
Decision
State
the
Problem
Optimize
the
Design
for
Obtaining
Data
Figure
1:
The
Seven
Steps
in
the
DQO
Process
(from
USEPA
1994a).
If
you
elect
to
use
the
UTS
or
10
x
UTS
(rather
than
90­
percent
reduction),
then
it
will
not
be
necessary
to
obtain
an
initial
set
of
samples
from
the
untreated
soil
for
comparison
to
the
samples
obtained
from
the
treated
soil.

Note
also
that
the
regulations
at
40
CFR
Part
268.44(
h)(
4)
allow
EPA
and
authorized
states
to
grant
site­
specific
LDR
treatment
variances
for
contaminated
soil
if
the
level
or
the
method
specified
in
the
soil
treatment
standards
would
result
in
concentrations
of
hazardous
constituents
that
are
below
(i.
e.,
lower
than)
natural
background
concentrations
at
the
site
where
the
contaminated
soil
will
land
disposed.
Natural
background
concentrations
are
constituent
concentrations
that
are
present
in
soil
which
have
not
been
influenced
by
human
activities
or
releases.
Because
natural
background
concentrations
may
vary
across
geographic
areas,
and
to
ensure
that
LDRs
will
only
be
capped
at
background
where
appropriate,
EPA
requires
that
individuals
who
wish
to
cap
LDR
treatment
at
natural
background
concentrations
apply
for
and
receive
a
treatment
variance.
Information
on
how
to
determine
background
concentrations
can
be
found
in
an
issue
paper
entitled
Determination
of
Background
Concentrations
of
Inorganics
in
Soils
and
Sediment
at
Hazardous
Waste
Sites
(USEPA
1996)
published
by
EPA's
Office
of
Research
and
Development
and
the
Office
of
Solid
Waste
and
Emergency
Response
(http://
www.
epa.
gov/
nerlesd1/
pdf/
engin.
p
df).
In
addition,
consultation
with
a
professional
statistician
may
be
necessary
before
preparing
a
request
for
a
variance
from
LDR
treatment
standards
for
soil
based
on
background
concentrations.

2.1
What
Steps
Should
I
Use
to
Plan
the
Sampling
and
Analysis
Program?

Prior
to
conducting
any
sampling
or
data
collection
activities,
we
suggest
you
use
a
systematic
planning
process
such
as
EPA's
Data
Quality
Objectives
(DQO)
process
(Figure
1),
followed
by
development
of
a
quality
assurance
project
plan
(QAPP)
and
waste
analysis
plan
(WAP).
2
The
DQO
process
is
a
systematic
data
collection
planning
process
developed
by
EPA
to
ensure
that
the
right
type,
quality,
and
quantity
of
data
are
collected
to
support
decision
making.
The
DQO
Process
is
intended
to
be
flexible,
and
the
depth
and
detail
of
DQO
8
development
should
be
scaled
to
the
study's
size
and
complexity.
While
one
output
of
the
DQO
Process
typically
is
a
statistical/
probabilistic
sampling
design,
not
every
sampling
problem
must
be
resolved
with
a
probabilistic
sampling
design
(e.
g.,
a
nonprobabilistic
or
judgmental
method
may
suffice).

You
can
find
detailed
guidance
on
the
DQO
process
in
Data
Quality
Objectives
Process
for
Hazardous
Waste
Site
Investigations,
EPA
QA/
G­
4HW
(USEPA
2000a)
and
the
Guidance
for
the
Data
Quality
Objectives
Process,
EPA
QA/
G­
4
(USEPA
1994a).

To
help
you
get
started,
you
can
use
the
following
seven­
step
DQO
process
to
plan
a
sampling
program
to
demonstrate
compliance
with
the
alternative
soil
treatment
standards.
Based
on
these
general
steps,
you
should
develop
detailed
DQO
outputs
for
your
specific
project.

Step
1:
State
the
Problem
–
The
outputs
of
this
step
will
include
a
list
of
members
of
the
planning
team,
the
resources
available,
the
schedule,
and
a
concise
description
of
the
problem.
For
the
purpose
of
a
90­
percent
reduction
or
10
x
UTS
attainment
determination,
the
"problem"
is
to
identify
those
soils
that
attain
the
90­
percent
reduction
standard
or
that
have
concentrations
less
than
10
x
UTS.

Step
2:
Identify
the
Decision
–
The
decision
is
to
determine
whether
the
concentrations
of
contaminants
of
concern
in
a
given
volume
of
soil
after
treatment
have
been
reduced
by
at
least
90
percent
from
the
concentrations
prior
to
treatment
or
whether
they
have
concentrations
less
than
10
x
UTS.
If
either
condition
has
been
satisfied,
then
the
treatment
standard
has
been
attained.
If
not,
then
the
soils
must
be
re­
treated
or
an
alternative
waste
management
option
must
be
found.

Step
3:
Identify
Inputs
to
the
Decision
–
This
step
of
the
DQO
process
requires
a
list
of
informational
inputs
needed
to
resolve
the
decision
statement.
For
the
purpose
of
complying
with
the
alternative
soil
treatment
standards,
these
inputs
would
include,
at
a
minimum,
a
list
of
the
underlying
hazardous
constituents,
the
units
of
measure
(e.
g.,
mg/
kg
or
mg/
L),
and
a
listing
of
appropriate
analytical
methods,
method
performance
criteria
(e.
g.,
for
precision
and
accuracy),
required
quantitation
limits,
and
other
existing
soil
characterization
data.

If
you
elect
to
use
10
x
UTS
as
the
treatment
standard,
then
the
analytical
methods
must
be
capable
of
measuring
the
concentration
of
constituents
of
concern
at
quantitation
limits
less
than
10
x
UTS.
Data
of
sufficient
quality
to
measure
attainment
of
10
x
UTS
also
should
be
adequate
to
measure
attainment
of
the
90­
percent
reduction
standard.

Note
that
under
40
CFR
268.49(
c),
treatment
for
non­
metals
must
achieve
90­
percent
reduction
in
total
constituent
concentrations.
Treatment
for
metals
must
achieve
90­
percent
reduction
as
measured
in
leachate
from
the
treated
soil
(testing
according
to
the
TCLP)
when
a
metal
stabilization
treatment
technology
is
used,
and
as
measured
in
total
constituent
concentrations
when
a
metal
removal
technology
is
used.

Step
4:
Define
the
Boundaries
–
Under
40
CFR
268.49(
d),
the
treatment
standards
apply
to
"any
given
volume
of
contaminated
soil"
that
meets
the
definition
of
a
hazardous
waste
when
generated
(e.
g.,
is
a
hazardous
waste
upon
excavation),
does
not
already
meet
applicable
LDR
treatment
requirements,
AND
will
be
land
disposed.
The
decision
to
generate
a
hazardous
soil
3
Note
that
the
treatment
standards
do
not
apply
to
in
situ
soils,
nor
do
they
force
soils
to
be
excavated.
If
contaminated
soil
is
managed
within
an
area
of
contamination
(AOC)
and
is
being
treated
in
situ
or
consolidated
within
an
AOC,
then
the
LDR
treatment
requirements
do
not
apply.

4
For
guidance
on
how
to
identify
"hot
spots,"
see
Gilbert
(1987,
page
119),
USEPA
(1989),
and
the
ELIPGRID
software
(Davidson
1995).

5
In
addition,
per
40
CFR
268.2(
k)
hazardous
waste
may
not
be
deliberately
mixed
with
soil
solely
to
change
its
treatment
classification
from
waste
to
soil.

9
usually
will
be
made
within
a
risk­
based
corrective
action
decision­
making
context.
3
For
additional
information
regarding
hazardous
soil
generation,
see
the
memo
in
Appendix
A
of
this
document,
entitled
"Management
of
Remediation
Waste
Under
RCRA"
(EPA/
530­
F­
98­
026,
Office
of
Solid
Waste
and
Emergency
Response).

If
the
remedy
involves
excavation
of
soil,
you
must
determine
whether
the
soil
or
identifiable
portions
of
that
soil
(i.
e.,
"any
given
volume")
are
subject
to
the
LDRs.
In
practice,
site
characterization
data
or
waste
knowledge
may
allow
you
to
determine
a
priori
which
soils
will
be
subject
to
LDRs
upon
excavation.
The
volume
of
soil
subject
to
LDRs
could
be
defined
as:

°
single
volumes
of
soil
(e.
g.,
soil
contained
in
a
drum),

°
manageable
subsets,
strata,
or
units
of
soil
with
distinct
characteristics
(e.
g.,
cleanup
units
consisting
of
½­
acre
lots
at
6­
inch
intervals),
or
°
one
or
more
"hot
spots"
(that
is,
localized
areas
of
high
contamination).
4
You,
as
the
generator,
should
determine
the
physical
size
of
each
"given
volume"
of
soil
on
a
site­
specific
basis.
Note
that
each
volume
of
hazardous
soil
that
will
be
treated
using
the
alternative
standards
does
not
necessarily
need
to
remain
segregated
from
other
similarly
classified
hazardous
soil
for
the
purpose
of
treatment.
If
a
given
volume
of
soil
is
a
mixture
of
hazardous
soils
from
different
locations
at
a
site,
then
the
entire
mixed
volume
must
be
treated
to
meet
the
applicable
standard.

Subject
to
some
limited
exceptions,
you
should
not
mix
hazardous
soil
(e.
g.,
soil
that
exhibits
the
TC)
with
nonhazardous
soils
prior
to
treatment.
To
do
so
may
be
impermissible
dilution.
For
example,
once
a
hazardous
contaminated
soil
has
been
generated
and
becomes
subject
to
LDR
treatment
standards,
dilution
of
that
soil
solely
as
a
substitute
for
adequate
treatment
to
achieve
compliance
with
LDR
treatment
standards
is
considered
impermissible
dilution
and
is
prohibited
under
40
CFR
268.3.
5
However,
there
are
exceptions:

(1)
If
mixing
occurs
through
the
normal
consolidation
of
contaminated
soil
from
various
portions
of
a
site
that
typically
occurs
during
the
course
of
remedial
activities
or
in
the
course
of
normal
earthmoving
and
grading
activities,
then
the
Agency
does
not
consider
this
to
be
intentional
mixing
of
soil
with
nonhazardous
soil
for
the
purposes
of
evading
LDR
treatment
standards.
Therefore,
it
is
not
viewed
as
a
form
of
impermissible
dilution.
See
63
FR
28605
and
28621
(May
26,
1998).
Indeed,
if
a
contaminated
soil
is
consolidated
within
an
area
of
10
contamination
before
it
is
removed
from
the
land
(i.
e.,
generated),
the
determination
as
to
whether
the
soil
exhibits
a
characteristic
of
hazardous
waste
may
be
made
after
such
consolidation.
If
the
soil
is
determined
not
to
be
hazardous
when
removed,
neither
Subtitle
C
nor
the
land
disposal
restriction
requirements
would
apply.

(2)
Some
situations
may
require
soil
mixing,
as
part
of
a
pre­
treatment
process,
to
facilitate
and
ensure
proper
operation
of
the
final
treatment
technology
to
meet
the
LDR
treatment
standards.
If
the
mixing
or
other
pre­
treatment
is
necessary
to
facilitate
proper
treatment
in
meeting
the
LDR
standards,
then
dilution
is
permissible.
For
example,
addition
of
less
contaminated
soil
may
be
needed
to
adjust
the
contaminated
soil
BTU
value,
water
content,
or
other
properties
to
facilitate
treatment.
These
adjustments
would
be
for
meeting
the
energy
or
other
technical
requirements
of
the
treatment
unit
to
ensure
its
proper
operation.
The
Agency
views
this
type
of
pre­
treatment
step
as
allowable,
provided
the
added
reagents
or
other
materials
produce
chemical
or
physical
changes
and
do
not
(1)
merely
dilute
the
hazardous
constituents
into
a
larger
volume
of
waste
so
as
to
lower
the
constituent
concentration
or
(2)
release
excessive
amounts
of
hazardous
constituents
to
the
air.
See
51
FR
40592
(November
7,
1986)
and
53
FR
30911
(August
16,
1988).

In
addition,
the
Agency
recognizes
that
it
may
be
advantageous
to
over­
excavate
contaminated
soils
to
implement
a
cost­
effective
cleanup
and
to
minimize
the
need
for
multiple
mobilizations
of
a
field
team
for
sampling,
analysis,
and
soil
excavation/
removal.
Because
each
site­
specific
situation
is
unique,
the
extent
to
which
over­
excavation
can
be
performed,
if
at
all,
must
be
determined
on
a
site­
specific
basis.
Gross
over­
excavation,
however,
could
be
viewed
as
impermissible
dilution
and
should
be
avoided.

In
practice,
without
sampling
all
of
the
soil
mass,
it
is
not
statistically
possible
to
ensure
that
all
portions
of
soil
submitted
for
treatment
have
concentrations
greater
than
10
x
UTS.
Thus,
you
should
have
sufficient
data
or
waste
knowledge
to
indicate
that
a
large
proportion
of
the
soil
in
a
given
volume
has
concentrations
greater
than
10
x
UTS
for
one
or
more
of
the
UHCs
of
interest.
You
will
need
to
use
educated
judgment
to
avoid
unnecessary
treatment.

If
you
plan
to
determine
the
volume
of
soil
subject
to
the
treatment
standard
prior
to
excavation
(i.
e.,
in
situ
soils),
then
you
could
delineate
the
soils
using
a
spatial
analysis
(for
example,
by
using
geostatistical
techniques).
For
assistance
with
application
of
geostatistical
methods,
consult
a
professional
geostatistician
or
see
Myers
(1997),
Isaaks
and
Srivastava
(1989),
Journel
(1988),
USACE
(1997),
and
USEPA
(1991a).

If
you
plan
to
determine
the
volume
of
soil
subject
to
the
treatment
standard
when
the
soil
is
excavated
(i.
e.,
at
the
point
of
generation)
and
placed
in
temporary
piles,
or
stored
(e.
g.,
in
drums
or
roll­
off
boxes),
then
the
piles,
drums,
and/
or
roll­
off
boxes
could
define
the
boundaries.

Note
that
if
the
90­
percent
reduction
standard
is
used,
then
the
estimate
of
post­
treatment
concentrations
should
apply
to
the
same
unit
of
soil
characterized
initially.
Even
though
handling
and
treatment
of
the
soil
may
significantly
change
its
volume
and/
or
mass
between
its
point
of
generation
and
final
treatment,
the
"identity"
of
the
soil
should
remain
intact
throughout
to
11
facilitate
consistent
comparison
of
the
soil
before
and
after
treatment.
One
approach
is
to
track
each
batch
of
soil
through
the
characterization
and
treatment
process.
As
an
alternative,
you
could
conduct
an
initial
study
to
demonstrate
that
the
treatment
process
achieves
at
least
90­
percent
reduction.
For
subsequent
treatment
of
the
same
type
of
contaminated
soil,
you
should
monitor
the
treatment
process
variables,
controls,
and
operating
conditions
and
establish
waste
and/
or
process
knowledge,
in
lieu
of
testing,
to
support
your
claim
that
the
standard
has
been
achieved.
For
long­
term
treatment
projects,
you
should
retest
periodically
to
confirm
that
the
standard
continues
to
be
achieved.
This
strategy
offers
increased
flexibility
to
operators
and
could
reduce
overall
costs
for
sampling
and
analysis.

Hypothetical
example
of
defining
a
"given
volume"
of
contaminated
soil
subject
to
LDRs:

During
a
construction
project
at
an
active
refinery,
the
facility
identified
soil
contaminated
with
benzene.
A
riskbased
cleanup
level
of
1.5
mg/
kg
was
established
for
the
site,
and
a
decision
was
made
to
excavate
all
soil
with
concentrations
exceeding
the
cleanup
level.
The
UTS
for
benzene
for
nonwastewaters
is
10
mg/
kg.
Note
that
soils
with
benzene
concentrations
less
than
0.5
ppm
in
TCLP
extract
are
not
classified
as
hazardous
under
the
Toxicity
Characteristic
for
benzene
(see
40
CFR
261.24),
but
may
still
be
subject
to
cleanup
requirements.

The
site
characterization
determined
that
the
contaminated
soil
was
confined
to
a
horizontal
area
40
feet
wide
by
90
feet
long.
The
depth
of
contamination
was
approximately
six
feet.
To
characterize
the
site,
the
soils
were
divided
into
a
series
of
10
ft
x
10
ft
x
3
ft
"blocks"
so
that
a
remedial
decision
could
be
made
for
each
block
based
upon
sample
analysis
results.
Using
this
approach,
each
block
of
contaminated
soil
was
placed
into
one
of
the
following
three
categories
for
subsequent
removal,
treatment,
and
disposal:

1.
Nonhazardous
soils.
Nonhazardous
soils
were
those
soils
with
TCLP
concentrations
less
than
0.5
ppm
but
with
total
concentrations
exceeding
the
risk­
based
cleanup
level
of
1.5
mg/
kg.
To
conserve
analytical
costs,
TCLP
benzene
concentrations
were
estimated
from
total
benzene
concentrations
by
comparing
each
total
result
to
20
times
the
TC
regulatory
limit,
or
10
mg/
kg
(to
account
for
the
20:
1
dilution
used
in
the
TCLP).
Therefore,
soils
with
total
benzene
concentrations
between
1.5
mg/
kg
and
10
mg/
kg
were
placed
in
this
category.
Based
on
the
sample
analysis
results,
the
facility
identified
52
"blocks"
or
approximately
578
cubic
yards
of
soil
in
this
category.
The
LDR
treatment
standards
do
not
apply
to
these
soils,
and
upon
removal,
the
soils
were
treated
and/
or
disposed
in
accordance
with
the
state's
risk­
based
corrective
action
program.

2.
TC
hazardous
soils
with
total
concentrations
less
than
10
x
UTS.
These
soils
exhibited
the
TC
for
benzene
(using
10
mg/
kg
as
a
screening
level)
but
had
total
benzene
concentrations
less
than
10
x
UTS
(i.
e.,
less
than
100
mg/
kg).
Therefore,
soils
with
total
benzene
concentrations
between
10
mg/
kg
and
100
mg/
kg
were
placed
in
this
category.
The
facility
identified
six
"blocks"
or
approximately
67
cubic
yards
of
soil
in
this
category.
Upon
removal,
the
facility
considered
the
soil
to
meet
the
alternative
soil
treatment
standard
of
10
x
UTS
without
further
treatment,
and
upon
removal,
the
soils
were
treated
and/
or
disposed
in
accordance
with
the
state's
risk­
based
corrective
action
program.

3.
TC
hazardous
soils
with
total
concentrations
greater
than
10
x
UTS.
These
soils
exhibited
the
TC
for
benzene
and
had
total
benzene
concentrations
greater
than
10
x
UTS
(i.
e.,
greater
than
100
mg/
kg).
The
facility
identified
14
"blocks"
or
approximately
155
cubic
yards
of
soil
in
this
category.
This
volume
of
soil
(155
cubic
yards)
was
designated
as
the
"given
volume"
to
which,
upon
generation,
the
facility
elected
to
apply
the
alternative
soil
treatment
standards
at
40
CFR
268.49
(10
x
UTS
or
90%
reduction).
12
Step
5:
Develop
a
Decision
Rule
–
In
this
step,
you
specify
the
parameter
of
interest,
specify
an
action
level,
and
develop
a
decision
rule.
A
"parameter"
is
a
descriptive
measure
of
a
population
such
as
the
population
mean
(or
average),
median,
or
some
percentile
(such
as
the
99
th
percentile).
An
action
level
is
a
concentration
limit
that
would
cause
you
to
choose
between
alternative
actions.

If
you
elect
to
apply
the
90­
percent
reduction
standard,
then
the
parameter
of
interest
is
the
difference
in
the
mean
concentrations
"before"
treatment
and
"after"
treatment.
The
action
level
is
implicitly
defined
as
the
mean
concentration
in
the
untreated
soil.

If
you
elect
to
use
10
x
UTS
as
the
action
level,
then
the
parameter
of
interest
is
the
maximum
(i.
e.,
no
sample
analysis
result
can
exceed
10
x
UTS).
Note
that
the
standard
of
10
x
UTS
is
more
practicable
when
there
is
relatively
low
variability
in
constituent
concentrations
in
the
treated
soil
and
average
concentrations
are
well
below
their
applicable
standards
(see
also
Section
2.3.2).

The
decision
rule
for
contaminated
soils
subject
to
the
alternative
soil
treatment
standards
is:

If
treatment
of
the
contaminated
soil
has
achieved
on
average
at
least
90
percent
reduction
in
constituent
concentrations,
or
maximum
concentrations
do
not
exceed
10
x
UTS,
then
the
alternative
treatment
standard
for
contaminated
soil
has
been
attained.

Step
6:
Specify
Limits
on
Decision
Errors
–
You
will
use
the
sample
analysis
results
to
support
a
decision
about
whether
a
given
volume
of
soil
attains
the
standard.
Because
of
variability
in
contaminant
concentrations
within
a
given
volume
of
soil,
practical
constraints
on
the
number
of
samples
that
can
be
obtained
and
analyzed,
and
random
variability
and
biases
that
can
be
introduced
in
the
sampling
and
measurement
processes,
the
data
collected
may
not
be
representative
and
may
mislead
the
decision
maker
into
making
an
incorrect
decision.
A
decision
error
occurs
when
sampling
data
mislead
the
decision
maker
into
choosing
a
course
of
action
that
is
different
from
or
less
desirable
than
the
course
of
action
that
would
have
been
chosen
with
perfect
information
(i.
e.,
with
no
constraints
on
sample
size
and
no
measurement
error).

We
recognize
that
data
obtained
from
sampling
and
analysis
are
never
perfectly
representative
and
accurate,
and
that
the
costs
of
trying
to
achieve
near­
perfect
results
can
outweigh
the
benefits.
Uncertainty
in
data
must
be
tolerated
to
some
degree.
The
DQO
process
controls
the
degree
to
which
uncertainty
in
data
affect
the
outcomes
of
decisions
that
are
based
on
those
data.
This
step
of
the
DQO
process
allows
the
decision
maker
to
set
limits
on
the
probabilities
of
making
an
incorrect
decision.

Hypothesis
tests
can
be
used
to
control
decision
errors.
When
performing
a
hypothesis
test,
a
presumed
or
baseline
condition,
referred
to
as
the
"null
hypothesis"
(Ho
),
is
established.
This
baseline
condition
is
presumed
to
be
true
unless
the
data
conclusively
demonstrate
otherwise,
which
is
called
"rejecting
the
null
hypothesis"
in
favor
of
an
alternative
hypothesis
(Ha
).
For
the
purpose
of
determining
compliance
with
the
90­
percent
reduction
alternative
soil
treatment
standard,
the
baseline
condition,
or
Ho
,
is
that
the
given
volume
of
soil
does
not
attain
the
6
The
symbol
":"
is
used
to
represent
the
population
arithmetic
mean.
The
mean
is
the
best
parameter
for
determining
90­
percent
reduction.
Where
normality
assumptions
are
grossly
violated,
however,
another
central
tendency
estimator
such
as
the
median
may
be
used
instead.
For
more
information,
see
"Checking
Data
for
Normality"
in
Section
2.3.3.

7
It
also
is
possible
to
specify
a
Type
II
error
rate
($),
however,
specification
of
the
Type
II
error
rate
is
not
required
to
perform
the
statistical
tests
described
in
this
guidance.
Additional
guidance
on
decision
errors
can
be
found
in
EPA's
"G­
4"
and
"G­
9"
guidance
documents
(USEPA
1994a
and
1998c).

13
standard.
Using
the
statistical
notation
for
hypothesis
testing
6
,
these
hypotheses
can
be
stated
as
follows:

H
o
Treated
Untreated
:
.
m
m
-
>
01
0
H
a
Treated
Untreated
:
.
m
m
-
£
01
0
When
the
hypothesis
test
is
performed,
one
of
two
possible
decision
errors
may
occur:

1.
Deciding
the
soil
treatment
achieves
90­
percent
reduction,
when
the
correct
decision
(with
complete
and
perfect
information)
would
be
"the
soil
treatment
does
not
achieve
90­
percent
reduction,"
or
2.
Deciding
the
soil
treatment
does
not
achieve
90­
percent
reduction,
when
the
correct
decision
would
be
that
the
treatment
does
in
fact
achieve
90­
percent
reduction.

Because
the
soil
is
known
to
be
contaminated
and
known
to
have
concentrations
greater
than
10
x
UTS,
we
can
presume
(as
a
"null
hypothesis")
that
the
soil
does
not
attain
the
standard.
The
sampling
data
must
provide
clear
evidence
that
the
soil
treatment
achieves
90­
percent
reduction
or
that
the
concentrations
are
less
than
10
x
UTS;
otherwise,
we
must
presume
that
the
soil
treatment
standard
has
not
been
achieved.
This
presumption
provides
the
basis
for
classifying
the
two
types
of
decision
errors.
To
decide
that
the
soil
treatment
achieves
the
standard,
when
in
fact
it
does
not,
is
designated
as
a
Type
I
decision
error
(also
known
as
a
"false
rejection"
of
the
null
hypothesis).
To
decide
that
the
soil
treatment
does
not
achieve
the
standard,
when
in
fact
it
does,
is
designated
as
a
Type
II
decision
error
(also
known
as
a
"false
acceptance"
of
the
null
hypothesis).
The
probability
of
making
a
Type
I
error
is
denoted
by
a
("
alpha").
7
We
recommend
you
set
the
Type
I
error
rate,
,
equal
to
0.10.
Setting
the
error
rate
at
this
a
level
will
ensure
there
is
only
a
10%
chance
of
falsely
rejecting
the
null
hypothesis.
In
other
words,
when
the
standard
has
not
truly
been
met,
the
test
will
erroneously
conclude
it
has
been
achieved
only
one
time
in
10.

Step
7:
Optimize
the
Design
for
Obtaining
the
Data
–
The
objective
of
this
step
is
to
develop
a
sampling
and
analysis
plan
that
obtains
the
requisite
information
from
the
samples
for
the
lowest
cost
and
still
satisfies
the
DQOs.
The
output
of
this
step
is
the
sampling
design
that
will
guide
the
development
of
QA
project
documentation
such
as
a
project­
specific
QAPP
or
WAP.
Key
activities
in
this
step
include
reviewing
the
DQO
outputs
and
existing
environmental
14
information,
developing
data
collection
design
alternatives,
calculating
the
optimal
number
of
samples
for
each
candidate
sampling
design,
selecting
the
most
resource­
effective
design
that
will
satisfy
the
DQOs,
and
documenting
the
outputs
of
the
DQO
Process.

Key
outputs
of
this
step
include
documentation
of
the
following:

°
sample
size
(number
of
samples)

°
sample
type
°
sample
collection
and
handling
techniques
°
sample
support
(i.
e.,
the
size,
shape,
and
orientation
of
soil
to
be
collected
for
each
sample)

°
sample
locations
°
timing
issues
for
sample
collection,
handling,
and
analysis
°
analytical
methods
or
the
performance
criteria
for
sample
analysis
°
QA
and
QC
protocols.

Formulas
for
calculating
the
appropriate
number
of
samples
are
given
in
Data
Quality
Objectives
Process
for
Hazardous
Waste
Site
Investigations
EPA
QA/
G­
4HW
Final
(USEPA
2000a)
and
described
in
depth
in
EPA's
Guidance
for
Data
Quality
Assessment,
EPA
QA/
G­
9
(QA00
Update,
revised
July
2000)
(USEPA
1998c).

You
can
find
detailed
guidance
on
the
development
and
optimization
of
a
sampling
plan
in
the
following
references:
ASTM
(1998a),
Mason
(1992),
Myers
(1997),
and
USEPA
(2000a
and
2000b).

2.2
How
Do
I
Implement
the
Sampling
and
Analysis
Program?

To
implement
the
sampling
and
analysis
program,
you
should
develop
and
follow
a
projectspecific
QAPP
or
WAP.
Guidance
for
developing
a
QAPP
can
be
found
in
EPA
Guidance
For
Quality
Assurance
Project
Plans,
EPA
QA/
G­
5
(USEPA
1998b).
Guidance
for
developing
a
WAP
can
be
found
in
Waste
Analysis
at
Facilities
That
Generate,
Treat,
Store,
and
Dispose
of
Hazardous
Wastes,
a
Guidance
Manual
(USEPA
1994b)
available
at:
http://
www.
epa.
gov/
epaoswer/
hazwaste/
ldr/
wap330.
pdf
Detailed
guidance
on
implementing
a
field
sampling
program
to
characterize
soil
can
be
found
in
Preparation
of
Soil
Sampling
Protocols:
Sampling
Techniques
and
Strategies,
EPA/
600/
R92
128
(Mason
1992),
and
in
a
variety
of
other
publications
including
ASTM
(1995,
1998b,
1998c,
1999),
Myers
(1997),
and
USEPA
(1991b).

Again,
as
emphasized
in
the
beginning
of
section
2.1,
the
DQO
process,
including
development
of
QAPPs
or
WAPs,
is
intended
to
be
flexible,
and
the
degree
of
detail
should
be
commensurate
15
with
the
study
size
and
complexity.

2.3
How
Should
I
Evaluate
the
Data
to
Determine
Attainment
of
the
Treatment
Standards?

You
should
perform
two
data
assessment
activities
to
evaluate
your
sample
analysis
results:
(1)
data
verification
and
validation
and
(2)
data
quality
assessment.
Perform
data
verification
and
validation
in
accordance
with
procedures
specified
in
the
QAPP
or
WAP
to
ensure
that
the
sampling
and
analysis
protocols
specified
in
the
planning
documents
were
followed
and
that
the
measurement
systems
performed
in
accordance
with
the
specified
criteria.

Following
data
verification
and
validation,
you
should
perform
data
quality
assessment
(DQA).
DQA
is
the
scientific
and
statistical
evaluation
of
data
to
determine
if
the
data
are
of
the
right
type,
quality,
and
quantity
to
support
their
intended
purpose.
You
can
find
detailed
guidance
on
DQA
in
EPA's
Guidance
for
Data
Quality
Assessment,
EPA
QA/
G­
9
(USEPA
1998c).

As
one
of
the
final
activities
in
the
DQA
process,
you
should
evaluate
the
data
to
determine
whether
or
not
you
have
attained
the
alternative
treatment
standards.
You
can
select
the
appropriate
method
for
data
evaluation
based
on
the
type
of
treatment
standard
being
used
and
other
site­
specific
conditions
(such
as
the
volume
of
soil
subject
to
the
treatment
standards
and
the
physical
characteristics
of
the
soil).

Figure
2
provides
a
generalized
flow
diagram
indicating
the
decision­
making
process
for
determining
attainment
of
the
alternative
soil
treatment
standards.

Table
1
provides
an
overview
of
the
various
data
evaluation
methods
available
for
determining
attainment
of
the
alternative
soil
treatment
standards
along
with
their
appropriate
conditions
for
use,
advantages,
and
limitations.
Note
that
the
statistical
methods
included
here
are
provided
as
guidance
only.
In
those
cases
where
you
require
additional
information
or
more
advanced
statistical
methods,
we
suggest
you
seek
assistance
from
a
statistician.

Section
2.3.1
describes
a
simple
nonstatistical
method
that
can
be
used
when
only
a
small
volume
of
soil
is
in
question
or
when
relatively
small
individual
"batches"
of
soil
are
subject
to
treatment.
Section
2.3.2
describes
methods
that
can
be
used
to
evaluate
attainment
of
the
UTS
or
10
x
UTS.
Section
2.3.3
describes
statistical
methods
that
can
be
used
to
evaluate
attainment
of
the
90­
percent
reduction
standard.
16
Start*
Define
the
"given
volume
of
soil"
subject
to
LDRs
per
268.49(
a)(
use
DQO
Process
Step
4).

If
the
90%
reduction
standard
is
selected,
then
obtain
n
U
samples
representing
the
untreated
soil.

Obtain
n
T
random
samples
representing
the
treated
soil.
Treat
the
soil
to
achieve
90%
reduction
or
10
x
UTS.

Does
the
data
evaluation
indicate
that
90%
reduction
is
achieved?

Soil
attains
the
standard.
Yes
No
Soil
does
not
attain
the
standard.
Does
the
soil
attain
the
standard
of
<
10
x
UTS?
Yes
No
Does
the
soil
attain
the
standard
of
10xUTS?

Select
a
data
evaluation
method
and
perform
evaluation
of
data
(see
Table
1
in
Section
2.3).
Yes
n
U
=
number
of
samples
representing
the
untreated
soil
n
T
=
number
of
samples
representing
the
treated
soil
*
Use
of
the
chart
assumes
the
generator
or
treater
has
elected
to
use
the
alternative
soil
treatment
standards
and
has
not
obtained
a
site­
specific
variance
under
40
CFR
268.44(
h).
No
Figure
2.
Flow
Chart
for
Determining
Attainment
of
the
Alternative
Soil
Treatment
Standards
17
Table
1.
Summary
of
Data
Evaluation
Methods
Data
Evaluation
Method
Type
of
Standard
Guidance
Section
No.
Appropriate
Conditions
for
Use
Advantages
Limitations
90%
Reduction
10
x
UTS
Nonstatistical
Method
T
T
2.3.1
°
Useful
when
sampling
and
measurement
error
can
be
minimized,
and
the
volume
of
soil
is
relatively
small
°
Useful
when
only
a
rough
estimate
of
the
constituent
concentration
is
required
°
Simple
°
Easy
to
use
and
understand
°
Low­
cost
°
Only
provides
a
"point
estimate"
of
the
constituent
concentration
°
Does
not
provide
information
about
variability
°
Does
not
quantify
the
uncertainty
associated
with
the
estimate
Simple
Exceedance
Rule
V
T
2.3.2
°
Analytical
quantitation
limit
must
be
less
than
the
treatment
standard.
°
Simple,
easy
to
use
and
understand
°
Easy
to
enforce
°
Data
set
can
include
nondetects.
°
Requires
a
large
number
of
samples
to
provide
high
confidence
that
the
standard
is
achieved
Tolerance
Limit
V
T
2.3.2
°
Most
useful
when
the
analytical
quantitation
limit
is
well
below
the
treatment
standard
and
sampling
and
measurement
error
are
minimal
°
Data
must
exhibit
an
approximately
normal
distribution.
°
A
small
number
of
samples
can
be
used
(we
recommend
at
least
four
random
samples).

°
Relatively
easy
to
calculate
°
The
calculated
limit
will
be
very
sensitive
to
the
size
of
the
standard
deviation
relative
to
the
mean.

Nonparametric
Test
of
Location
T
V
2.3.3.1
°
Useful
if
there
are
no
extreme
values
in
the
data
sets
°
Quick
°
Simple
°
Easy
to
use
°
Does
not
require
the
assumption
that
the
data
exhibit
a
normal
distribution.

°
Can
be
used
with
data
sets
that
include
"nondetects"
°
Provides
less
statistical
"power"
than
Welch's
t­
Test
or
the
Wilcoxon
Rank

Sum
test
(i.
e.,
the
test
may
indicate
that
90­
percent
reduction
has
not
been
achieved,
when
in
fact
it
has)

Welch's
t­
Test
T
V
2.3.3.2
°
Data
must
exhibit
an
approximately
normal
distribution.
°
Provides
more
statistical
"power"

than
the
test
of
location
if
the
underlying
assumptions
for
the
test
are
satisfied
°
Cannot
be
used
when
a
large
percentage
(>
20%)
of
the
data
are
reported
as
nondetect
°
Requires
more
statistical
calculations
than
other
methods
(e.
g.,
calculation
of
the
mean,
variance,
and
degrees
of
freedom)

Wilcoxon
Rank­
Sum
Test
T
V
2.3.3.3
°
Useful
when
the
underlying
distribution
of
the
data
is
unknown
or
cannot
be
readily
identified
°
Useful
when
a
significant
percentage
(>
20%)
of
the
data
are
reported
as
nondetect
°
Easy
to
compute
and
understand
°
Can
be
used
with
data
sets
that
include
"nondetects"
°
Provides
less
statistical
"power"
than
Welch's
t­
Test
if
the
data
follow
a
normal
distribution
or
are
approximately
symmetrical
T
=
appropriate
for
use.

V
=
not
appropriate
for
use.
8
Sampling
error
can
be
minimized
by
using
an
optimal
sample
mass,
obtaining
the
correct
shape
and
orientation
of
individual
samples
(known
as
the
sample
"support"),
and
by
using
sampling
devices
and
subsampling
procedures
that
will
minimize
biases.
For
detailed
guidance
on
controlling
error
in
sampling,
see
Mason
(1992)
and
Myers
(1997).

18
2.3.1
What
Simple
Nonstatistical
Method
Can
I
Use
to
Evaluate
Attainment
of
the
Soil
Treatment
Standards?

As
part
of
the
planning
process,
the
planning
team
must
define
the
volume
of
soil
that
needs
to
be
characterized
for
the
purpose
of
evaluating
attainment
of
the
alternative
soil
treatment
standards.
If
the
"given
volume"
(as
specified
at
40
CFR
268.49(
d))
is
relatively
small
and
the
sampling
and
measurement
error
can
be
minimized
8
,
then
a
single
representative
sample
(within
the
meaning
of
a
representative
sample
given
at
40
CFR
260.10)
may
be
adequate
to
estimate
the
concentration
in
the
volume
of
soil,
and
use
of
a
statistical
method
to
determine
attainment
of
soil
treatment
standards
may
not
be
necessary
or
appropriate.

As
a
practical
matter,
the
volume
of
soil
characterized
using
this
nonstatistical
method
could
be
defined
operationally,
such
as:
(1)
the
volume
of
soil
that
will
fit
in
a
55­
gallon
drum,
(2)
some
reasonably
small
volume
that
could
be
excavated
by
a
backhoe
during
remedial
activities
(such
as
a
10
ft­
by­
10
ft­
by
2
ft
block
of
soil),
or
(3)
small
volumes
of
soil
that
are
considered
"batches"
in
a
batch
treatment
process.

This
approach
can
be
used
to
evaluate
attainment
of
either
the
90­
percent
reduction
standard
or
the
standard
of
10
x
UTS.
If
the
90­
percent
reduction
standard
is
used,
then
a
representative
sample
must
be
obtained
and
analyzed
before
treatment
of
the
given
volume
and
a
second
representative
sample
obtained
from
the
same
unit
of
soil
and
analyzed
after
treatment.
Only
those
two
data
points
would
be
used
to
determine
90­
percent
reduction.
Using
this
nonstatistical
approach,
the
decision
rule
to
determine
compliance
with
the
90­
percent
reduction
standard
is
simple:
the
concentration
of
the
constituent
of
concern
in
the
sample
of
the
(
)
C
treated
soil
must
be
less
than
or
equal
to
1/
10
of
the
concentration
found
in
the
sample
of
the
untreated
soil.

(
)
C
C
treated
untreated
£
01
.

One
of
the
key
underlying
assumptions
of
this
approach
is
that
a
single
soil
sample
can
provide
an
adequate
estimate
of
the
concentration
within
a
given
volume
of
soil.
If
the
soil
is
heterogeneous,
then
a
single
soil
sample
(such
as
a
core
a
few
centimeters
in
diameter)
may
not
provide
a
good
estimate
of
the
mean
concentration
within
the
given
volume
of
soil.

The
nonstatistical
procedure
for
evaluating
attainment
of
the
90­
percent
reduction
standard
is
performed
as
follows:

Step
1.
Define
a
small
"given
volume"
of
soil
to
be
characterized
and
treated
(see
DQO
process
Step
4).
19
Step
2.
Obtain
a
representative
sample
from
the
given
volume
and
submit
the
sample
for
laboratory
analysis.

Step
3.
After
treatment
of
the
given
volume
of
soil,
obtain
another
sample
from
the
same
given
volume
using
the
same
sampling
and
analysis
procedures
used
in
Step
2.

Step
4.
If
the
concentration
in
the
sample
from
the
treated
soil
is
less
than
or
equal
to
the
1/
10th
of
the
concentration
in
the
sample
of
the
untreated
soil
(or
less
than
10
x
UTS),
then
you
can
conclude
that
the
alternative
soil
treatment
standard
has
been
attained
for
that
volume
of
soil.
Otherwise,
you
cannot
conclude
that
the
treatment
standard
has
been
attained.

If
10
x
UTS
is
the
selected
standard,
then
the
decision
rule
is
simplified
even
further:
the
sample
analysis
result(
s)
(from
one
or
more
grab
samples
representing
the
given
volume
of
soil)
must
be
less
than
10
x
UTS.

Hypothetical
Example:
Using
the
Nonstatistical
Method
to
Evaluate
Attainment
of
the
90­
Percent
Reduction
Standard
A
wood
preserving
facility
is
closing
a
tank
that
contained
spent
formulations
from
a
wood
preserving
process
(F035).
Upon
removal
of
the
tank,
the
operator
discovered
a
small
patch
of
soil
contaminated
with
F035.
The
operator
excavated
the
soil
and
placed
it
into
a
55­
gallon
drum.
Because
the
excavated
soil
contains
a
listed
hazardous
waste,
Land
Disposal
Restrictions
under
RCRA
apply.
The
applicable
standard
is
for
"nonwastewaters"
and
can
be
found
in
the
table
at
40
CFR
268.40.
The
facility
operator
decides
to
apply
the
alternative
treatment
standards
for
contaminated
soil
(10
x
UTS
or
90­
percent
reduction).
Because
the
volume
of
soil
subject
to
LDRs
is
small,
the
operator
decides
to
use
the
"small
volume"
approach
to
determine
attainment
of
the
90­
percent
reduction
standard:

Step
1.
The
"given
volume"
of
soil
is
the
volume
of
soil
in
the
drum.

Step
2.
The
operator
obtains
a
soil
core
representing
the
full
thickness
of
the
soil
in
the
drum
and
submits
this
sample
for
laboratory
analysis.
The
concentrations
of
the
hazardous
constituents
are
as
follows:

Hazardous
Constituent
UTS
for
Nonwastewaters
(ppm
TCLP)
(from
the
UTS
Table
at
§
268.48)
10
x
UTS
(ppm
TCLP)
Conc.
In
Sample
Obtained
From
Untreated
Soil
(ppm
TCLP)
Target
Treatment
Level
For
90%
Reduction
(ppm
TCLP)

Arsenic
5.0
50
420
42*

Chromium
0.6
6.0
120
12
*
Compliance
also
may
be
demonstrated
by
achieving
10
x
UTS,
or
50
ppm.
20
Frequency
Concentration
Sample
Mean
Regulatory
Threshold
UCL
on
Upper
Percentile
or
"Tolerance
Limit"

"Point
estimate"
of
99th
percentile
Confidence
Interval
on
99th
Percentile
Figure
3.
To
comply
with
the
alternative
soil
treatment
standard
of
10
x
UTS,
the
mean
concentration
must
be
well
below
the
standard
for
all
portions
of
the
soil
to
be
at
or
below
the
treatment
standard.
Step
3.
After
treatment
of
the
soil,
the
treatment
facility
obtains
another
sample
using
the
same
sampling
and
analysis
procedures
used
in
Step
2.
The
concentrations
of
hazardous
constituents
are
as
follows:

Arsenic
(TCLP):
48
ppm
Chromium
(TCLP):
10
ppm
Step
4.
The
concentration
of
arsenic
in
the
treated
soil
is
not
less
than
the
target
treatment
level
for
90­
percent
reduction;
however,
it
is
less
than
10
x
UTS.
Therefore,
the
alternative
treatment
standard
is
attained
for
arsenic.
The
concentration
of
chromium
in
the
treated
soil
is
less
than
the
target
treatment
level
for
90­
percent
reduction.
Therefore,
the
alternative
treatment
standard
also
is
attained
for
chromium.

2.3.2
What
Methods
Can
I
Use
to
Determine
Attainment
of
the
UTS
or
10
x
UTS?

The
concentration
level
treatment
standards
established
for
compliance
with
RCRA
Land
Disposal
Restrictions,
such
as
the
universal
treatment
standards
(UTS),
represent
concentration
levels
that
should
never
be
exceeded.
To
comply
with
the
UTS
(or
to
comply
with
the
alternative
of
10
x
UTS
for
hazardous
soils),
no
portion
of
the
waste
may
exceed
the
standard.
If
testing
results
show
that
"hot
spots"
remain,
this
is
evidence
that
the
treatment
was
not
effective
and
there
is
noncompliance
with
the
LDR
treatment
requirements
(see
63
FR
28567,
May
26,
1998).
You
should
consider
the
amount
of
variability
in
the
treated
soil
to
ensure
compliance
with
the
UTS
or
10
x
UTS.
Statistical
variability
is
"built
in"
to
the
LDR
treatment
standards
(USEPA
1991c),
and
it
is
expected
that
the
mean
will
be
well
below
the
standard
for
all
portions
of
the
waste
to
be
below
the
standard
(see
Figure
3).

To
determine
attainment
of
a
concentration
level
LDR
treatment
standard
such
as
the
UTS
(or
10
x
UTS),
conduct
waste­
testing
in
accordance
with
your
WAP
and
determine
whether
or
not
any
sample
analysis
result
exceeds
the
standard.
If
any
sample
analysis
results
exceed
the
standard,
then
you
must
conclude
that
the
standard
is
not
met.
(Note
that
samples
of
the
untreated
soil
are
not
required
to
determine
attainment
of
the
UTS
or
10
x
UTS).
Though
simple
in
practice,
this
simple
exceedance
rule
has
a
potential
limitation:
a
large
number
9
The
exceedance
rule
has
statistical
properties.
The
statistical
performance
can
be
(
)
1-
a
determined
for
given
number
of
samples,
(all
less
than
or
equal
to
the
standard),
by
n
(
)
1
1
-
=
-
a
p
n
where
equals
the
proportion
(e.
g.,
0.99)
of
the
waste
that
must
have
concentrations
less
than
or
equal
to
the
p
standard.

21
of
samples
are
required
to
have
a
high
degree
of
confidence
that
little
or
no
portion
of
the
waste
exceeds
the
standard.
9
The
LDR
regulations
do
not
require
hazardous
waste
generators
or
treaters
to
conduct
statistical
sampling,
however,
some
waste
handlers
may
wish
to
evaluate
their
sample
analysis
data
statistically
to
quantify
the
level
of
"comfort"
they
can
have
in
concluding
that
a
standard
has
been
met.
This
could
be
done
by
testing
whether
a
high
percentile
(such
as
the
99
th
percentile)
or
proportion
of
the
soil
(that
is,
all
possible
soil
samples
of
a
given
sample
"support")
comply
with
the
standard.
An
upper
percentile
serves
as
a
reasonable
approximation
of
the
maximum
concentration
found
in
any
portion
of
the
waste.
This
approach
is
consistent
with
the
manner
in
which
the
LDR
concentration
level
treatment
standards
are
calculated
––
each
standard
is
calculated
as
the
99
th
percentile
of
the
data
obtained
from
a
properly
operating
waste
treatment
process
(USEPA
1988,
1991c).

The
99
th
percentile
can
be
estimated
from
a
set
of
samples
drawn
from
the
waste
or
soil
by
using
an
upper
confidence
limit
for
a
percentile.
You
can
use
an
upper
confidence
limit
on
a
percentile
to
determine
attainment
of
the
standard
as
follows:

°
If
the
upper
confidence
limit
on
the
percentile
is
less
than
or
equal
to
the
applicable
LDR
standard
(such
as
the
UTS
or
10
x
UTS),
then
the
waste
can
be
judged
in
compliance
with
the
standard
(see
Figure
3),
as
long
as
no
individual
sample
values
exceed
the
standard.

°
If
the
upper
confidence
limit
on
the
percentile
exceeds
the
standard
(but
all
sample
values
are
less
than
or
equal
to
the
standard),
then
the
waste
still
could
be
judged
in
compliance
with
the
standard.
However,
you
would
not
have
the
specified
level
of
confidence
that
the
specified
proportion
(e.
g.,
0.99)
of
the
waste
complies
with
the
standard.

Methods
for
testing
a
percentile
against
a
fixed
standard
are
fairly
simple
and
are
described
in
several
USEPA
guidance
documents
(for
example,
see
Chapter
7
in
USEPA
1989,
and
USEPA
1992)
and
statistical
references
(e.
g.,
Hahn
and
Meeker
1991,
and
Guttman
1970).

2.3.3
What
Statistical
Methods
Can
I
Use
to
Determine
Attainment
of
the
Alternative
Soil
Treatment
Standard
of
90­
Percent
Reduction?

Statistical
methods
can
be
used
to
determine
if
a
given
volume
of
soil
has
been
treated
such
that
there
is
a
90­
percent
reduction
from
the
initial
concentration
of
hazardous
constituents.
This
involves
use
of
a
statistical
test
selected
from
a
category
of
tests
known
as
"two­
sample"
tests.
The
statistical
tests
are
called
two­
sample
tests
because
they
involve
two
sets
of
samples,
one
drawn
independently
from
the
untreated
soil
and
another
drawn
independently
from
the
treated
soil,
so
that
a
comparison
can
be
made
between
the
"before"
and
"after"
10
The
statistical
methods
for
determining
90­
percent
reduction
described
in
this
guidance
involve
the
use
of
independent
samples
obtained
from
the
untreated
and
treated
soil.
These
tests
should
not
be
confused
with
a
set
of
statistical
tests
that
deal
with
analyzing
"paired"
data.

22
conditions
of
the
soil.
10
That
is,
the
generator
will
test
the
soil
before
treatment
and
again
after
treatment,
then
perform
the
statistical
test
to
determine
if
90­
percent
reduction
has
been
attained.
For
all
of
the
statistical
tests
presented
in
this
guidance,
it
is
necessary
that
the
samples
be
obtained
using
a
random
or
systematic
sampling
plan.

We
present
two
"tiers"
of
statistical
tests
for
determining
attainment
of
the
90­
percent
reduction
standard.
Under
the
first
tier,
we
present
a
"quick
and
simple"
method
that
does
not
require
statistical
calculations
or
assumptions
about
the
distributional
form
of
the
data
(see
Section
2.3.3.1).
The
test
is
known
as
the
Nonparametric
Test
of
Location.
The
test
is
quick
and
easy
to
use
and
may
be
preferred
by
users
of
this
guidance
who
have
little
or
no
training
in
statistics.
The
test
does
not
require
the
assumption
of
normally
distributed
data.
One
limitation
of
the
test
is
that
it
lacks
statistical
"power"
–
that
is,
compared
with
other
statistical
methods
(described
below)
the
test
is
less
likely
to
show
that
90­
percent
reduction
has
been
attained.

The
statistical
tests
in
the
second
tier
are
more
powerful
but
require
more
calculations.
If
both
sets
of
data
(i.
e.,
the
data
representing
the
untreated
soil
and
the
data
representing
the
treated
soil)
exhibit
an
approximately
normal
distribution
or
can
be
transformed
to
a
normal
distribution,
then
Welch's
t­
Test
can
be
used
(see
Section
2.3.3.2).
Welch's
t­
Test
does
not
require
the
same
number
of
samples
in
each
group
of
data
and
does
not
require
that
the
variances
of
the
two
groups
of
data
be
equal.
If
the
distributions
of
the
two
groups
of
data
are
unknown
or
cannot
be
readily
identified
as
normal
or
lognormal,
a
non­
parametric
alternative
to
Welch's
test
should
be
used.
The
Wilcoxon
Rank
Sum
test
is
recommended
for
use
where
the
underlying
distribution
of
the
data
is
unknown
and
cannot
be
readily
identified,
or
when
a
significant
percentage
(e.
g.,
20
to
90%)
of
the
combined
data
set
are
reported
as
"nondetects"
(see
Section
2.3.3.3).

Checking
Data
for
Normality:

The
assumption
of
normality
is
very
important,
as
it
is
the
basis
for
many
statistical
tests.
While
the
assumption
of
a
normal
distribution
(i.
e.,
a
"mound­
shaped"
frequency
distribution)
is
convenient
for
statistical
testing
purposes,
it
is
not
always
appropriate.
For
example,
sometimes
data
are
highly
skewed
(such
as
with
a
lognormal
distribution
in
which
the
natural
logarithms
of
the
data
exhibit
a
normal
distribution),
or
they
may
have
no
specific
shape
at
all.
If
the
assumption
of
normality
is
not
satisfied,
then
you
should
consider
using
an
alternative
nonparametric
test
(see
list
of
tests
in
Table
1).

You
can
check
data
sets
for
normality
by
using
graphical
methods,
such
as
histograms,
box
and
whisker
plots,
and
normal
probability
plots,
or
by
using
numerical
tests
such
as
Filliben's
Statistic
or
the
Shapiro­
Wilk
test.
We
recommend
the
Shapiro­
Wilk
test
as
a
superior
method
for
testing
normality
of
the
data.
The
specific
method
for
implementing
the
Shapiro­
Wilk
Test
is
described
in
Gilbert
(1987)
and
can
be
performed
with
EPA's
DataQUEST
free
software
(USEPA
1997)
or
other
commercially
available
statistical
software.
EPA's
Guidance
for
Data
Quality
Assessment,
EPA
QA/
G9
(USEPA
1998c)
also
describes
methods
you
can
use
to
check
data
for
normality.
23
2.3.3.1
A
"Quick
and
Simple"
Statistical
Method
for
Determining
90­
Percent
Reduction
To
test
whether
the
treatment
process
has
resulted
in
90­
percent
reduction
from
the
initial
concentration
in
the
untreated
soil,
the
quick
and
simple
statistical
method
described
here
can
be
used.
All
that
is
required
to
perform
the
test
is
knowing
the
number
of
samples
representing
the
soil
before
treatment,
the
number
of
samples
representing
the
soil
after
treatment,
identification
of
the
smallest
observation
in
the
"before"
treatment
data
set,
and
use
of
a
lookup
table.
The
method
described
below
is
a
modification
of
the
nonparametric
test
of
location
(Rosenbaum
1954).
Also,
note
that
the
presence
of
one
or
more
extreme
values
within
the
data
sets
could
further
reduce
the
power
of
the
test
(i.
e.,
if
there
is
a
value
in
the
untreated
soil
data
set
that
is
much
lower
than
the
bulk
of
the
other
values,
and/
or
there
is
a
value
in
the
treated
soil
data
set
that
is
much
higher
than
the
bulk
of
the
other
values
in
the
data
set,
then
the
test
will
have
reduced
statistical
power).

The
procedure
for
performing
the
nonparametric
test
of
location
is
as
follows:

Step
1.
Count
the
number
of
samples
used
to
characterize
the
untreated
soil,
and
(
)
n
U
count
the
number
of
samples
used
to
characterize
the
treated
soil.
(
)
n
T
Step
2.
Use
Table
B­
1
(found
in
Appendix
B
­
Statistical
Tables)
(for
90%
confidence)
or
Table
B­
2
(for
95%
confidence)
to
obtain
the
critical
value
corresponding
to
n
U
and
.
nT
Step
3.
Identify
the
smallest
value
in
the
set
of
samples
obtained
from
the
untreated
soil
and
divide
the
value
by
10.

Step
4.
Count
the
number
of
samples
(s)
from
the
treated
soil
that
are
less
than
or
equal
to
the
value
obtained
in
Step
3.
If
s
is
greater
than
or
equal
to
the
critical
value
from
the
table,
then
you
can
conclude
that
90­
percent
reduction
has
been
attained.
If
s
is
less
than
the
value
in
the
table,
then
you
cannot
conclude
that
90­
percent
reduction
has
been
achieved.
If
the
"quick
and
simple"
test
fails
to
show
that
90­
percent
reduction
has
been
achieved,
then
consider
evaluating
the
data
using
a
more
powerful
statistical
method
such
as
Welch's
t­
Test
(Section
2.3.3.2)
or
the
Wilcoxon
Rank
Sum
test
(Section
2.3.3.3).
24
Excavation
and
Ex
Situ
Treatment
Volume
of
Untreated
Soil
Pile
of
Treated
Soil
n
u
=
8
random
samples
n
T
=
7
random
samples
Figure
4.
Sample
collection
strategy
for
measuring
attainment
of
90­
percent
reduction.
Hypothetical
Example:
Using
the
"Quick
and
Simple"
Nonparametric
Statistical
Test
to
Evaluate
Attainment
of
the
90­
Percent
Reduction
Standard
Using
data
obtained
from
a
site
characterization,
the
site
operator
delineates
a
volume
of
hazardous
soil
known
to
have
contaminant
concentrations
greater
than
10
x
UTS
within
the
defined
volume
(Figure
4).
To
determine
attainment
of
the
90­
percent
reduction
standard,
the
operator
obtains
eight
random
samples
from
the
volume
of
untreated
soil
(note
that
the
samples
also
could
be
obtained
from
a
pile
of
soil
that
is
the
complete
excavation
of
the
block).
The
volume
of
soil
is
then
treated
using
an
ex
situ
soil
washing
technology.

After
treatment,
a
new
set
of
seven
samples
is
obtained
and
analyzed.
The
analytical
results
are
as
follows
(in
ppm):

Untreated
Soil
(ppm):
1200,
800,
400,
540,
370,
260,
230,
200
Treated
Soil
(ppm):
25,
18,
15,
14,
12,
8,
6
Use
the
"quick
and
simple"
nonparametric
method
to
determine
if
the
treatment
process
has
attained
the
90­
percent
reduction
standard:

Step
1.
The
number
of
samples
used
to
characterize
the
untreated
soil
is
8.
The
(
)
n
U
number
of
samples
used
to
characterize
the
treated
soil
is
7.
(
)
nT
Step
2.
Using
Table
B­
1
(for
90%
confidence)
found
in
Appendix
B,
we
obtain
a
critical
value
of
3
corresponding
to
=
8
and
=
7.
n
U
n
T
Step
3.
The
smallest
value
in
the
set
of
samples
obtained
from
the
untreated
soil
is
200
ppm.
200
divided
by
10
equals
20.

Step
4.
There
are
6
samples
from
the
treated
soil
that
are
less
than
or
equal
to
20.
Because
6
is
greater
than
or
equal
to
3
(the
critical
value
from
the
table),
then
you
can
conclude
with
90%
confidence
that
90­
percent
reduction
has
been
attained.
25
2.3.3.2
Welch's
t­
Test
If
both
sets
of
data
(i.
e.,
the
data
representing
the
untreated
soil
and
the
data
representing
the
treated
soil)
exhibit
an
approximately
normal
distribution
or
can
be
transformed
to
a
normal
distribution,
then
Welch's
t­
Test
can
be
used.
Welch's
t­
Test
does
not
require
the
same
number
of
samples
in
each
group
of
data
and
does
not
require
that
the
variances
of
the
two
groups
of
data
are
equal.
If
the
distributions
of
the
two
groups
of
data
are
unknown
or
cannot
be
readily
identified
as
normal
or
lognormal,
or
a
large
percentage
of
the
data
(e.
g.,
20
to
90%)
is
reported
as
"nondetect",
then
the
nonparametric
Wilcoxon
Rank­
Sum
test
should
be
used
instead
(see
Section
2.3.3.3).

Procedure
Using
a
simple
random
or
systematic
sampling
design,
obtain
a
set
of
samples
representing
the
untreated
soil
known
to
have
contamination
with
concentrations
greater
than
10
x
UTS.
After
treatment
of
the
soil,
obtain
a
new
set
of
samples
representing
the
same
mass
of
soil.

Multiply
each
datum
from
the
untreated
soil
by
0.1
such
that
each
is
reduced
by
90
(
)
U
i
percent
of
its
original
value.
The
90­
percent
reduced
data
will
serve
as
the
reference
data
set
("
ref").
If
90­
percent
reduction
has
been
attained,
then
the
mean
concentration
in
the
treated
soil
should
be
the
same
as
the
mean
concentration
in
the
reference
data
set
or
shifted
to
the
left
of
the
mean
of
the
reference
data
set.

Step
1:
Calculate
the
sample
mean
and
the
sample
variance
for
the
"Treated"
x
T
s
T
2
soil.
Calculate
the
sample
mean
and
the
sample
variance
for
the
x
ref
s
ref
2
reference
data
set.
The
number
of
samples
representing
the
untreated
and
treated
soil
do
not
need
to
be
the
same.

Step
2:
Calculate
Welch's
t­
Statistic
as
follows:

(
)
t
x
x
s
n
s
n
T
ref
T
T
ref
ref
=
-
+
2
2
Equation
1
Step
3:
Calculate
the
approximate
degrees
of
freedom
as
follows:

(
)
(
)
df
s
n
s
n
s
n
n
s
n
n
T
T
ref
ref
T
T
T
ref
ref
ref
=
+
é
ë
ê
ê
ù
û
ú
ú
-
+
-
é
ë
ê
ê
ù
û
ú
ú
2
2
2
2
2
2
2
1
1
Equation
2
Round
to
the
nearest
integer.
df
26
Excavation
and
Ex
Situ
Treatment
In
Situ
Untreated
Soil
Pile
of
Treated
Soil
n
U
=
n
ref
=
6
n
T
=
8
Figure
5.
Sample
collection
strategy
for
measuring
attainment
of
90­
percent
reduction
using
Welch's
t­
Test.
Step
4:
Use
Table
B­
3
in
Appendix
B
to
find
the
critical
value
such
that
100
t1-a
%
of
the
t­
(
)
1-
a
distribution
for
the
nearest
degrees
of
freedom
.
(
)
df
Step
5:
If
,
then
conclude
t
t
£
-
-
1
a
that
90
percent
reduction
has
been
attained.
If,

however,
,
then
t
t
>
-
-
1
a
you
cannot
conclude
that
90­
percent
reduction
has
been
attained.

Hypothetical
Example:
Using
Welch's
t­
Test
to
Evaluate
Attainment
of
the
90­
Percent
Reduction
Standard
Using
data
obtained
from
a
site
characterization,
the
site
operator
delineates
a
unit
of
hazardous
soil
known
to
have
contaminant
concentrations
greater
than
10
x
UTS
within
the
defined
volume
(Figure
5).
To
determine
the
mean
and
the
variance
of
the
concentration
of
the
constituent
of
concern,
the
operator
obtains
six
random
samples
from
the
unit
of
untreated
soil
(note
that
the
samples
also
could
be
obtained
from
a
pile
of
soil
that
is
the
complete
excavation
of
the
unit).
The
unit
of
soil
is
then
treated
using
an
ex
situ
soil
washing
technology.

After
treatment,
a
new
set
of
eight
random
samples
is
obtained
and
analyzed.
The
sample
analysis
results
are
as
follows:

Untreated
Soil
(ppm)
:
400,
540,
260,
160,
370,
80
(
)
Ui
Reference
(ppm),
0.1
:
40,
54,
26,
16,
37,
8
(
)
Ui
Treated
Soil
(ppm)
:
25,
12,
18,
8,
14,
6,
15,
21
(
)
Ti
Calculate
Welch's
t
statistic
to
determine
if
the
treatment
process
has
attained
the
90­
percent
reduction
standard:
27
Step
1:
Calculate
the
sample
mean
and
the
variance
for
the
treated
soil
and
the
reference
data
set.

Treated
Soil
Reference
Data
Number
of
Samples
8
6
n
T
=
n
ref
=
Sample
Mean
14.9
30.2
x
T
=
x
ref
=
Sample
Variance
40.7
284.3
s
T
2
=
s
ref
2
=
Step
2:
Calculate
Welch's
t
statistic
as
follows:

(
)
t
x
x
s
n
s
n
T
ref
T
T
ref
ref
=
-
+
2
2
(
)
=
-
+
=
302
407
8
6
-211
14.9
.
.
284.3
.

Step
3:
Calculate
the
approximate
degrees
of
freedom
as
follows:

(
)
(
)
df
s
n
s
n
s
n
n
s
n
n
T
T
ref
ref
T
T
T
ref
ref
ref
=
+
é
ë
ê
ê
ù
û
ú
ú
-
+
-
é
ë
ê
ê
ù
û
ú
ú
2
2
2
2
2
2
2
1
1
(
)
(
)
=
+
é
ë
ê
ù
û
ú
-
+
-
é
ë
ê
ê
ù
û
ú
ú
=
407
8
2843
6
8
8
1
6
6
1
61
2
2
2
.
.
40.7
284.3
.

Rounding
down
to
the
nearest
integer,
we
get
6.
df
Step
4:
Using
Table
B­
3
in
Appendix
B,
we
find
the
90%
critical
value
for
6
-
t1
-a
degrees
of
freedom
is
­1.440.

Step
5:
Welch's
t­
Statistic
(­
2.11
)
is
less
than
the
critical
value
of
­1.440
therefore
we
can
conclude,
with
90­
percent
confidence,
that
the
90
percent
reduction
soil
treatment
standard
has
been
attained
for
the
given
volume
of
soil.

2.3.3.3
Wilcoxon
Rank­
Sum
Test
The
Wilcoxon
Rank
Sum
test
is
recommended
for
use
where
the
underlying
distribution
of
the
data
is
unknown
and
cannot
be
readily
identified
or
when
a
significant
percentage
(e.
g.,
between
20
and
90%)
of
the
combined
data
sets
are
reported
as
"nondetects."
The
assumptions
for
the
28
Wilcoxon
Rank
Sum
test
include
the
following:
(1)
both
sets
of
samples
are
random
samples
from
their
respective
populations,
(2)
in
addition
to
independence
within
each
sample,
there
must
be
mutual
independence
between
the
two
samples
(i.
e.,
there
can
not
be
spatial
correlation
between
observations
and
the
samples
must
not
be
"paired"),
and
(3)
the
measurement
scale
is
at
least
ordinal
(i.
e.,
you
can
rank
the
sample
values
from
highest
to
lowest).
In
addition,
it
is
assumed
that
the
two
populations
are
identical
in
shape
(variance),
however,
the
test
is
relatively
robust
with
respect
to
violations
of
the
equal
variance
assumption

that
is,
the
test
is
approximately
correct
even
when
the
variances
of
the
two
populations
differ.

Procedure
Let
represent
the
number
of
samples
obtained
from
the
"Treated"
soil.
Let
represent
the
n
T
n
U
number
of
samples
obtained
from
the
"Untreated"
soil.
Multiply
each
datum
from
the
untreated
soil
by
0.1
such
that
each
is
reduced
by
90
percent
of
its
original
value.
The
90­
percent
reduced
data,
,
will
serve
as
the
reference
data
set.
If
90­
percent
reduction
has
been
attained,
then
n
ref
the
concentrations
in
the
treated
soil
should
tend
to
be
the
same
as
or
less
than
the
concentrations
in
the
reference
data
set.

Step
1:
Combine
all
of
the
reference
data
(i.
e.,
the
untreated
data
reduced
by
90­
percent)
and
the
treated
soil
data
into
a
single
data
set.
Sort
and
rank
the
combined
values
from
smallest
to
largest,
assigning
the
rank
of
1
to
the
smallest
result,
the
rank
of
2
to
the
next
smallest
result,
and
so
on.
Keep
track
of
which
samples
belong
to
the
reference
population
and
the
treated
population.
If
two
or
more
measurements
are
the
same,
assign
all
of
them
a
rank
equal
to
the
average
of
the
ranks
they
occupy.

Step
2:
Calculate
as
the
sum
of
the
ranks
of
the
data
from
the
treated
soil,
then
R
calculate
(
)
W
R
n
n
T
T
=
-
+
1
2
Equation
3
Step
3:
Use
Table
B­
4
in
Appendix
B
to
find
the
critical
value
for
the
appropriate
w
a
values
of
,
,
and
.
If
,
reject
the
null
hypothesis
and
conclude
n
T
n
ref
a
W
w
<
a
that
90­
percent
reduction
is
attained
(i.
e.,
conclude
that
the
concentrations
in
the
treated
soil
tend
to
be
the
same
as
or
less
than
the
concentration
found
in
the
reference
soil
data
set).
Otherwise,
you
cannot
conclude
that
90­
percent
reduction
was
attained.
29
Excavation
and
Ex
Situ
Treatment
In
Situ
Untreated
Soil
Pile
of
Treated
Soil
n
U
=
n
ref
=
8
n
T
=
7
Figure
6.
Sample
collection
strategy
for
measuring
attainment
of
90­
percent
reduction
using
the
Wilcoxon
Rank
Sum
test.
Hypothetical
Example:
Using
the
Wilcoxon
Rank
Sum
Test
to
Evaluate
Attainment
of
the
90­
Percent
Reduction
Standard
Using
data
obtained
from
a
site
characterization,
the
site
operator
delineates
a
unit
of
soil
known
to
have
contaminant
concentrations
no
less
that
10
x
UTS
within
the
defined
volume
(Figure
6).

The
operator
obtains
n
n
U
ref
=
=
8
random
samples
from
the
unit
of
untreated
soil
(note
that
the
samples
also
could
be
obtained
from
a
pile
of
soil
that
is
the
complete
excavation
of
the
unit
of
soil).
The
unit
of
soil
is
then
treated
using
an
ex
situ
soil
washing
technology.

After
treatment,
a
new
set
of
n
T
=
7
samples
is
obtained
from
the
treated
soil
and
analyzed.
A
table
of
the
data
is
created
denoting
data
representing
the
untreated
soil,
the
reference
data,
and
the
treated
soil.

Calculate
the
Wilcoxon
Rank­
Sum
Test
to
determine
if
the
treatment
process
has
attained
the
90
percent
reduction
standard:

Treated
Soil
(ppm)
:
17,
23,
26,
5,
13,
13,
12
(
)
T
i
Untreated
Soil
(ppm)
:
160,
200,
50,
40,
80,
100,
70,
30
(
)
U
i
Reference
(ppm),
0.1
:
16,
20,
5,
4,
8,
10,
7,
3
(
)
U
i
Step
1:
Combine
the
data
for
the
treated
soil
and
the
data
from
the
reference
data
set
and
sort
and
rank
the
values
(the
treated
soil
data
are
denoted
by
*):

Data:
3
4
5
5*
7
8
10
12*
13*
13*
16
17*
20
23*
26*

Rank:
1
2
3.5
3.5*
5
6
7
8*
9.5*
9.5*
11
12*
13
14*
15*

Note
that
the
data
occupying
ranks
3
and
4
are
"ties"
(both
value
are
5).
Therefore,
we
assign
both
values
a
rank
equal
to
the
average
of
the
ranks
they
occupy
(i.
e.,
(3+
4)/
2=
3.5).
The
same
situation
occurs
at
ranks
9
and
10
and
both
values
are
assigned
a
rank
equal
to
the
average
of
9
+
10
(i.
e.,
(9+
10)/
2=
9.5).
30
Step
2:
Calculate
as
the
sum
of
the
ranks
of
the
data
from
the
treated
soil:
R
R
=
3.5
+
8
+
9.5
+
9.5
+
12
+
14
+
15
=
71.5
Then
calculate
:
W
(
)
(
)
W
R
n
n
T
T
=
-
+
=
-
+
=
1
2
715
7
7
1
2
435
.
.

Step
3:
Using
Table
4
in
Appendix
B,
the
critical
value
is
found
to
be
17.
(
)
w
0
10
.

Because
43.5
>
17,
do
not
reject
the
null
hypothesis.
In
other
words,
we
cannot
conclude
with
90­
percent
confidence
that
90­
percent
reduction
has
been
attained.
31
3.
WHAT
ARE
THE
NOTIFICATION,
CERTIFICATION,
AND
RECORDKEEPING
REQUIREMENTS
FOR
CONTAMINATED
SOILS?

Contaminated
soil
subject
to
the
land
disposal
restrictions
must
comply
with
the
same
recordkeeping
requirements
as
other
wastes
subject
to
LDR.
The
generator
of
a
hazardous
soil
must
comply
with
the
applicable
provisions
of
40
CFR
268.7(
a).
This
would
include
a
certification
statement
sent
with
the
initial
waste
shipment
and
retained
in
the
generator's
files.
The
statement
must
certify
that
the
soil
[does/
does
not]
contain
a
listed
hazardous
waste
and
[does/
does
not]
exhibit
a
hazardous
characteristic.
Note
that
certifications
accompanying
waste
shipments
need
only
be
provided
for
hazardous
soils
shipped
off
site.
For
hazardous
soils
remaining
on
site,
this
certification
is
not
required.

Once
a
characteristic
soil
is
treated
to
remove
its
hazardous
characteristic,
it
no
longer
must
be
disposed
in
a
hazardous
waste
(Subtitle
C)
land
disposal
unit.
However,
it
could
require
further
treatment
if
the
soils
were
prohibited
from
land
disposal
at
the
point
of
generation
and
the
underlying
hazardous
constituents
remain
present
at
concentrations
greater
than
10
x
UTS
after
treatment
to
remove
the
characteristic.
Special
notification
requirements
for
treated
characteristic
wastes
(found
at
40
CFR
268.9(
d))
allow
generators
to
send
a
one­
time
notice
to
the
EPA
region
or
their
state
agency
instead
of
the
Subtitle
D
disposal
facility.
This
notification
must
be
placed
in
the
generator's
files
and
include
the
following
information:

C
the
name
and
address
of
the
receiving
facility;
and
C
a
description
of
the
waste
including
hazardous
waste
codes,
treatability
groups
and
subcategories,
and
any
underlying
hazardous
constituents
The
generator
also
must
prepare
a
certification
statement
in
accordance
with
§
268.7(
b)(
5)
to
accompany
the
notification.
Both
the
certification
and
notification
statements
must
be
updated
if
there
are
any
changes
to
the
waste
or
receiving
facility.
Such
changes
must
be
submitted
to
the
appropriate
EPA
region
or
state
agency
on
an
annual
basis.

Facilities
should
also
be
able
to
demonstrate
how
the
alternative
soil
treatment
standards
have
been
met.
As
a
result,
you
should
keep
records
documenting
the
following:

°
The
rationale
for
arriving
at
a
manageable
list
of
monitoring
constituents
for
the
hazardous
soil
to
be
treated,

°
The
rationale
for
sampling
protocols
or
methodology
for
collecting
representative
samples
of
hazardous
constituents
of
concern
in
the
contaminated
soil
(e.
g.,
QAPP,
sampling
plan,
and
spatial
analyses
to
delineate
volumes
of
soil
with
constituent
concentrations
greater
than
10
x
UTS
soils),

°
The
methodology
for
determining
attainment
of
the
standard
of
90­
percent
reduction
or
10
x
UTS,
and
°
Treatment
data
used
to
verify
attainment
of
90­
percent
reduction
or
10
x
UTS.
32
References
Note:
Due
to
the
dynamic
nature
of
the
Internet,
the
location
and
content
of
web
sites
given
in
this
document
may
change
over
time.
If
you
find
a
broken
link
to
an
EPA
document,
use
the
search
engine
at
http://
www.
epa.
gov/
to
find
the
document.
Links
to
web
sites
outside
the
U.
S.
EPA
web
site
are
listed
for
the
convenience
of
the
user,
and
the
U.
S.
EPA
does
not
exercise
any
editorial
control
over
the
information
you
may
find
at
these
external
web
sites.

ASTM
D
4220­
95.
1995.
Standard
Practices
for
Preserving
and
Transporting
Soil
Samples.
West
Conshohocken,
PA.
http://
www.
astm.
org
ASTM
D
6311­
98.
1998a.
Standard
Guide
for
Generation
of
Environmental
Data
Related
to
Waste
Management
Activities:
Selection
and
Optimization
of
Sampling
Design.
West
Conshohocken,
PA.

ASTM
D
4547­
98.
1998b.
Standard
Guide
for
Sampling
Waste
and
Soils
for
Volatile
Organics.
West
Conshohocken,
PA.

ASTM
D
6169­
98.
1998c.
Standard
Guide
for
Selection
of
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htm#
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018.
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2000a.
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Process
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G­
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007.
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January
2000.
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epa.
gov/
quality1/
qa_
docs.
html
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a
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Design
for
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Data
Collection,
Use
in
the
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of
a
Quality
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EPA
QA/
G­
5S.
Quality
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Office
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August
2000.
http://
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epa.
gov/
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qa_
docs.
html
APPENDIX
A:
"MANAGEMENT
OF
REMEDIATION
WASTE
UNDER
RCRA"
October
14,
1998
MEMORANDUM
SUBJECT:
Management
of
Remediation
Waste
Under
RCRA
TO:
RCRA/
CERCLA
Senior
Policy
Managers
Regional
Counsels
FROM:
Timothy
Fields,
Jr.,
Acting
Assistant
Administrator
for
Solid
Waste
and
Emergency
Response
/signed/

Steven
A.
Herman,
Assistant
Administrator
for
Enforcement
and
Compliance
Assurance
/signed/

Rapid
clean
up
of
RCRA
corrective
action
facilities
and
Superfund
sites
is
one
of
the
Agency's
highest
priorities.
In
this
context,
we
often
receive
questions
about
management
of
remediation
waste
under
the
Resource
Conservation
and
Recovery
Act
(RCRA).
To
assist
you
in
successfully
implementing
RCRA
requirements
for
remediation
waste,
this
memorandum
consolidates
existing
guidance
on
the
RCRA
regulations
and
policies
that
most
often
affect
remediation
waste
management.
We
encourage
you
to
work
with
the
regulations,
policies
and
approaches
outlined
in
this
memorandum
to
achieve
our
cleanup
goals
as
quickly
and
efficiently
as
possible.

Note
that
not
all
remediation
wastes
are
subject
to
RCRA
Subtitle
C
hazardous
waste
requirements.
As
with
any
other
solid
waste,
remediation
wastes
are
subject
to
RCRA
Subtitle
C
only
if
they
are
listed
or
identified
hazardous
waste.
Environmental
media
are
subject
to
RCRA
Subtitle
C
only
if
they
contain
listed
hazardous
waste,
or
exhibit
a
characteristic
of
hazardous
waste.
These
distinctions
are
discussed
more
completely
below.

The
information
in
this
memo
is
divided
into
three
categories:
information
on
regulations
and
policies
that
apply
to
all
remediation
waste;
information
on
regulations
and
policies
that
apply
only
to
contaminated
media;
and,
information
on
regulations
and
policies
that
apply
only
to
contaminated
debris.
Most
of
the
references
cited
in
this
memo
are
available
over
the
Internet.
The
Federal
Register
notices
published
after
1994
are
available
at
www.
access.
gpo.
gov/
nara;
the
guidance
memos
and
other
EPA
documents
are
available
at
www.
epa.
gov/
correctiveaction.
Federal
Register
notices
and
other
documents
are
also
available
through
the
RCRA/
CERCLA
hotline:
in
Washington
D.
C.,
call
(703)
412­
9810;
outside
Washington
D.
C.,
call
(800)
424­
9346;
and
hearing
impaired
call
(800)
553­
7672.
The
hotline's
hours
are
Monday
­
Friday,
excluding
3
Federal
holidays,
8:
00
­
5:
00,
eastern
standard
time.
Many
EPA
guidance
memos
and
other
documents
may
also
be
obtained
through
the
RCRA/
CERCLA
hotline
fax­
back
system.
To
obtain
a
list
of
documents
available
over
the
fax­
back
system,
and
fax­
back
system
code
numbers,
call
the
RCRA/
CERCLA
hotline
at
the
numbers
listed
above.

I
hope
this
information
will
assist
you
as
you
continue
to
make
protective,
inclusive,
and
efficient
cleanup
decisions.
If
you
have
additional
questions
or
require
more
information,
please
contact
Robert
Hall
or
Greg
Madden,
of
our
staffs,
on
(703)
308­
8484
or
(202)
564­
4229
respectively.

Regulations
and
Policies
that
Apply
to
All
Remediation
Wastes
Area
of
Contamination
Policy.
In
what
is
typically
referred
to
as
the
area
of
contamination
(AOC)
policy,
EPA
interprets
RCRA
to
allow
certain
discrete
areas
of
generally
dispersed
contamination
to
be
considered
RCRA
units
(usually
landfills).
Because
an
AOC
is
equated
to
a
RCRA
land­
based
unit,
consolidation
and
in
situ
treatment
of
hazardous
waste
within
the
AOC
do
not
create
a
new
point
of
hazardous
waste
generation
for
purposes
of
RCRA.
This
interpretation
allows
wastes
to
be
consolidated
or
treated
in
situ
within
an
AOC
without
triggering
land
disposal
restrictions
or
minimum
technology
requirements.
The
AOC
interpretation
may
be
applied
to
any
hazardous
remediation
waste
(including
non­
media
wastes)
that
is
in
or
on
the
land.
Note
that
the
AOC
policy
only
covers
consolidation
and
other
in
situ
waste
management
techniques
carried
out
within
an
AOC.
For
ex
situ
waste
management
or
transfer
of
wastes
from
one
area
of
contamination
to
another,
see
discussion
of
corrective
action
management
units,
below.

The
AOC
policy
was
first
articulated
in
the
National
Oil
and
Hazardous
Substances
Pollution
Contingency
Plan
(NCP).
See
53
FR
51444
for
detailed
discussion
in
proposed
NCP
preamble;
55
FR
8758­
8760,
March
8,
1990
for
final
NCP
preamble
discussion.
See
also,
most
recent
EPA
guidance,
March
13,
1996
EPA
memo,
"Use
of
the
Area
of
Contamination
Concept
During
RCRA
Cleanups."

Corrective
Action
Management
Units
(CAMUs).
The
corrective
action
management
unit
rule
created
a
new
type
of
RCRA
unit
–
a
Corrective
Action
Management
Unit
or
CAMU

specifically
intended
for
treatment,
storage
and
disposal
of
hazardous
remediation
waste.
Under
the
CAMU
rule,
EPA
and
authorized
states
may
develop
and
impose
site­
specific
design,
operating,
closure
and
post­
closure
requirements
for
CAMUs
in
lieu
of
MTRs
for
land­
based
units.
Although
there
is
a
strong
preference
for
use
of
CAMUs
to
facilitate
treatment,
remediation
waste
placed
in
approved
CAMUs
does
not
have
to
meet
LDR
treatment
standards.

The
main
differences
between
CAMUs
and
the
AOC
policy
(discussed
above)
are
that,
when
a
CAMU
is
used,
waste
may
be
treated
ex
situ
and
then
placed
in
a
CAMU,
CAMUs
may
be
located
in
uncontaminated
areas
at
a
facility,
and
wastes
may
be
consolidated
into
CAMUs
from
areas
that
are
not
contiguously
contaminated.
None
of
these
activities
are
allowed
under
the
AOC
policy,
which,
as
discussed
above,
covers
only
consolidation
and
in
situ
management
techniques
carried
out
within
an
AOC.
4
CAMUs
must
be
approved
by
EPA
or
an
authorized
state
and
designated
in
a
permit
or
corrective
action
order.
In
certain
circumstances,
EPA
and
states
(including
states
that
are
not
authorized
for
the
CAMU
regulations)
may
use
other
mechanisms
to
approve
CAMUs.
See,
58
FR
8677,
February
16,
1993;
appropriate
use
of
RCRA
Section
7003
orders
and
comparable
state
orders
is
discussed
below
and
in
an
EPA
guidance
memo
from
J.
Winston
Porter
to
EPA
Regional
Administrators,
"RCRA
Permit
Requirements
for
State
Superfund
Actions,"
November
16,
1987,
OSWER
Directive
9522.00­
2.
In
addition,
as
appropriate,
CAMUs
may
be
approved
by
EPA
as
an
applicable
or
relevant
and
appropriate
requirement
during
a
CERCLA
cleanup
using
a
record
of
decision
or
by
an
authorized
state
during
a
state
cleanup
using
a
CERCLA­
like
authority
and
a
similar
state
document.
See,
e.
g.,
58
FR
8679,
February
16,
1993.
An
opportunity
for
the
public
to
review
and
comment
on
tentative
CAMU
approvals
is
required
by
the
regulations
when
CAMUs
are
approved
using
permitting
procedures
and
as
a
matter
of
EPA
policy
when
CAMUs
are
approved
using
orders.
EPA
recommends
that,
whenever
possible,
remediation
project
managers
combine
this
public
participation
with
other
public
involvement
activities
that
are
typically
part
of
remediation.
For
example,
public
notice
of
tentative
approval
of
a
CAMU
could
be
combined
with
public
notice
of
a
proposed
plan
under
CERCLA.

The
CAMU
rule
is
currently
subject
to
litigation;
however,
the
suit
has
been
stayed
pending
promulgation
of
the
final
HWIR­
Media
regulations.
Although
EPA
proposed
to
withdraw
CAMUs
as
part
of
the
HWIR­
Media
proposal,
the
Agency
now
intends
to
retain
the
CAMU
rule.
The
Agency
encourages
approval
of
CAMUs
when
they
are
appropriate
given
the
site­
specific
conditions.

The
CAMU
regulations
are
at
40
CFR
264.552,
promulgated
February
16,
1993
(58
FR
8658).
The
differences
between
CAMUs
and
AOCs
are
discussed
in
more
detail
in
the
March
13,
1996
EPA
guidance
memo,
"Use
of
the
Area
of
Contamination
Concept
During
RCRA
Cleanups."

Corrective
Action
Temporary
Units
(TUs).
Temporary
units,
like
corrective
action
management
units,
are
RCRA
units
established
specifically
for
management
of
hazardous
remediation
waste.
The
regulations
for
temporary
units
(TUs)
were
promulgated
at
the
same
time
as
the
regulations
for
corrective
action
management
units.
The
CAMU
regulations
established
land­
based
units
for
treatment,
storage
and
disposal
of
remediation
waste;
the
TU
regulations
established
non­
land
based
units
for
treatment
and
storage
of
hazardous
remediation
waste.
Under
the
TU
regulations,
EPA
and
authorized
states
may
modify
existing
MTR
design,
operating
and
closure
standards
for
temporary
tank
and
container
units
used
to
treat
and
store
hazardous
remediation
waste.
Temporary
units
may
operate
for
one
year,
with
an
opportunity
for
a
one
year
extension.

Like
CAMUs,
temporary
units
must
be
approved
by
EPA
or
an
authorized
state
and
designated
in
a
permit
or
corrective
action
order.
In
certain
circumstances,
EPA
and
states
(including
states
that
are
not
authorized
for
the
TU
regulations)
may
use
other
mechanisms
to
approve
TUs.
See,
58
FR
8677,
February
16,
1993;
appropriate
use
of
RCRA
Section
7003
orders
and
comparable
state
orders
is
discussed
below
and
in
an
EPA
guidance
memo
from
J.
Winston
Porter
to
EPA
Regional
Administrators,
"RCRA
Permit
Requirements
for
State
Superfund
Actions,"
November
16,
1987,
OSWER
Directive
9522.00­
2.
In
addition,
as
appropriate,
TUs
may
be
approved
by
EPA
as
an
applicable
or
relevant
and
appropriate
1
Listing
determinations
are
often
particularly
difficult
in
the
remedial
context
because
the
listings
are
generally
identified
by
the
sources
of
the
hazardous
wastes
rather
than
the
concentrations
of
various
hazardous
constituents;
therefore,
analytical
testing
alone,
without
information
on
a
waste's
source,
will
not
generally
produce
information
that
will
conclusively
indicate
whether
a
given
waste
is
a
listed
hazardous
waste.

5
requirement
during
a
CERCLA
cleanup
using
a
record
of
decision
or
by
an
authorized
state
during
a
state
cleanup
using
a
CERCLA­
like
authority
and
a
similar
state
document.
Placement
of
waste
in
tanks
or
containers,
including
temporary
units,
is
not
considered
land
disposal.
Therefore,
waste
does
not
have
to
be
treated
to
meet
LDR
treatment
standards
prior
to
being
placed
in
a
TU.
Of
course,
LDRs
must
be
met
if
hazardous
remediation
wastes
are
eventually
land
disposed,
for
example,
after
they
are
removed
from
the
TU;
however,
if
treatment
in
a
TU
results
in
constituent
concentrations
that
comply
with
applicable
land
disposal
restriction
treatment
standards,
no
further
treatment
prior
to
land
disposal
is
required
as
a
condition
of
the
LDRs.

An
opportunity
for
the
public
to
review
and
comment
on
tentative
TU
approvals
is
required
by
the
regulations
when
TUs
are
approved
using
permitting
procedures
and
as
a
matter
of
EPA
policy
when
TUs
are
approved
using
orders.
As
with
CAMUs,
EPA
recommends
that
whenever
possible,
remediation
project
managers
combine
this
public
participation
with
other
public
involvement
activities
that
are
typically
part
of
remediation.
For
example,
public
notice
of
tentative
approval
of
a
temporary
unit
could
be
combined
with
public
notice
of
a
proposed
plan
under
CERCLA.

The
TU
regulations
are
at
40
CFR
264.553,
promulgated
February
16,
1993
(58
FR
8658).

Determination
Of
When
Contamination
is
Caused
by
Listed
Hazardous
Waste.
Where
a
facility
owner/
operator
makes
a
good
faith
effort
to
determine
if
a
material
is
a
listed
hazardous
waste
but
cannot
make
such
a
determination
because
documentation
regarding
a
source
of
contamination,
contaminant,
or
waste
is
unavailable
or
inconclusive,
EPA
has
stated
that
one
may
assume
the
source,
contaminant
or
waste
is
not
listed
hazardous
waste
and,
therefore,
provided
the
material
in
question
does
not
exhibit
a
characteristic
of
hazardous
waste,
RCRA
requirements
do
not
apply.
This
approach
was
first
articulated
in
the
Proposed
NCP
preamble
which
notes
that
it
is
often
necessary
to
know
the
source
of
a
waste
(or
contaminant)
to
determine
whether
a
waste
is
a
listed
hazardous
waste
under
RCRA
1
and
also
notes
that,
"at
many
CERCLA
sites
no
information
exists
on
the
source
of
the
wastes."
The
proposed
NCP
preamble
goes
on
to
recommend
that
the
lead
agency
use
available
site
information
such
as
manifests,
storage
records
and
vouchers
in
an
effort
to
ascertain
the
sources
of
wastes
or
contaminants,
but
that
when
this
documentation
is
not
available
or
inconclusive
the
lead
agency
may
assume
that
the
wastes
(or
contaminants)
are
not
listed
RCRA
hazardous
wastes.
This
approach
was
confirmed
in
the
final
NCP
preamble.
See,
53
FR
51444,
December
21,
1988
for
proposed
NCP
preamble
discussion;
55
FR
8758,
March
13,
1990
for
final
NCP
preamble
discussion.

This
approach
was
also
discussed
in
the
HWIR­
Media
proposal
preamble,
61
FR
18805,
April
29,
1996,
where
it
was
expanded
to
also
cover
dates
of
waste
disposal
–
i.
e.,
if,
after
a
good
faith
effort
to
determine
dates
of
disposal
a
facility
owner/
operator
is
unable
to
make
such
a
determination
because
documentation
of
dates
of
disposal
is
unavailable
or
inconclusive,
one
may
6
assume
disposal
occurred
prior
to
the
effective
date
of
applicable
land
disposal
restrictions.
This
is
important
because,
if
hazardous
waste
was
originally
disposed
of
before
the
effective
dates
of
applicable
land
disposal
restrictions
and
media
contaminated
by
the
waste
are
determined
not
to
contain
hazardous
waste
when
first
generated
(i.
e.,
removed
from
the
land,
or
area
of
contamination),
the
media
are
not
subject
to
RCRA
requirements,
including
LDRs.
See
the
discussion
of
the
contained­
in
policy,
below.

Site
Specific
LDR
Treatment
Variances.
The
regulations
for
site­
specific
LDR
treatment
variances
allow
EPA
and
authorized
states
to
establish
a
site­
specific
LDR
treatment
standard
on
a
case­
by­
case
basis
when
a
nationally
applicable
treatment
standard
is
unachieveable
or
inappropriate.
Public
notice
and
a
reasonable
opportunity
for
public
comment
must
be
provided
before
granting
or
denying
a
site­
specific
LDR
treatment
variance.
EPA
recommends
that
remediation
project
managers
combine
this
public
involvement
with
other
public
involvement
activities
that
are
typically
part
of
remediation.
Regulations
governing
site­
specific
LDR
treatment
variances
are
at
40
CFR
268.44(
h),
promulgated
August
17,
1988
(53
FR
31199)
and
clarified
December
5,
1997
(62
FR
64504).
The
most
recent
EPA
guidance
on
site­
specific
LDR
treatment
variances,
which
includes
information
on
establishing
alternative
LDR
treatment
standards,
is
in
the
January
8,
1997
guidance
memo,
"Use
of
Site­
Specific
Land
Disposal
Restriction
Treatability
Variances
Under
40
CFR
268.44(
h)
During
Cleanups."

In
1996,
EPA
revised
its
policy
on
state
authorization
for
site­
specific
LDR
treatment
variances
and
began
encouraging
states
to
become
authorized
to
approve
variances.
See,
HWIRMedia
proposal,
61
FR
18828
(April
29,
1996).

On
May
26,
1998,
EPA
promulgated
additional
site­
specific
land
disposal
restriction
treatment
variance
opportunities
specific
to
hazardous
contaminated
soil.
These
opportunities
are
discussed
below.

Treatability
Studies
Exemption.
The
term
"treatability
study"
as
defined
at
40
CFR
260.10
refers
to
a
study
in
which
a
hazardous
waste
is
subjected
to
a
treatment
process
to
determine:
(1)
whether
the
waste
is
amenable
to
the
treatment
process;
(2)
what
pretreatment
(if
any)
is
required;
(3)
the
optimal
process
conditions
needed
to
achieve
the
desired
treatment;
(4)
the
efficiency
of
a
treatment
process
for
a
specific
waste
or
wastes;
or,
(5)
the
characteristics
and
volumes
of
residuals
from
a
particular
treatment
process.
Under
regulations
at
40
CFR
261.4(
e)
and
(f),
hazardous
wastes
managed
during
a
treatability
study
are
exempt
from
many
RCRA
Subtitle
C
requirements.
The
regulations
limit
the
amount
of
waste
that
may
be
managed
under
an
exempt
treatability
study
to,
generally,
1000
kg
of
hazardous
waste
or
1
kg
of
acutely
hazardous
waste
per
study.
For
contaminated
environmental
media,
the
volume
limit
is,
generally,
10,000
kilograms
of
media
that
contain
non­
acutely
hazardous
waste
and
2,500
kilograms
of
media
that
contain
acutely
hazardous
waste
per
study.
There
are
also
limits
on
the
types
and
lengths
of
studies
that
may
be
conducted
under
the
exemption
and
record
keeping
and
reporting
requirements.
Regulations
governing
treatability
studies
are
at
40
CFR
261.4(
e)
and
(f),
associated
preamble
discussions
at
52
FR
27290
(July
19,
1988)
and
59
FR
8362
(February
18,
1994).

Exemption
for
Ninety
Day
Accumulation.
Management
of
hazardous
waste
in
tanks,
containers,
drip
pads
and
containment
buildings
does
not
constitute
land
disposal.
In
addition,
2
Note
that,
under
certain
circumstances,
substantive
requirements
may
be
waived
using
CERCLA.
See
the
ARAR
waiver
provisions
at
40
CFR
300.430(
f)(
1)(
ii)(
C).

7
EPA
has
provided
an
exemption
for
generators
of
hazardous
waste
which
allows
them
to
accumulate
(i.
e.,
treat
or
store)
hazardous
waste
at
the
site
of
generation
in
tanks,
containers,
drip
pads
or
containment
buildings
for
up
to
ninety
days
without
RCRA
interim
status
or
a
RCRA
permit.
Accumulation
units
must
meet
applicable
design,
operating,
closure
and
post­
closure
standards.
Because
putting
hazardous
waste
in
a
tank,
container,
drip
pad
or
containment
building
is
not
considered
land
disposal,
LDR
treatment
standards
do
not
have
to
be
met
before
putting
waste
in
such
units.
LDRs
must
be
met
if
hazardous
wastes
are
eventually
land
disposed,
for
example,
after
they
are
removed
from
the
accumulation
unit;
however,
if
treatment
in
an
accumulation
unit
results
in
constituent
concentrations
that
comply
with
applicable
land
disposal
restriction
treatment
standards,
no
further
treatment
prior
to
land
disposal
is
required
as
a
condition
of
the
LDRs.
The
exemption
for
ninety­
day
accumulation
is
found
in
regulations
at
40
CFR
262.34;
associated
preamble
discussion
is
at
51
FR
at
10168
(March
24,
1986).

Permit
Waivers.
Under
CERCLA
Section
121(
e),
no
Federal,
state
or
local
permit
is
required
for
on­
site
CERCLA
response
actions.
EPA
has
interpreted
CERCLA
Section
121(
e)
to
waive
the
requirement
to
obtain
a
permit
and
associated
administrative
and
procedural
requirements
of
permits,
but
not
the
substantive
requirements
that
would
be
applied
through
permits.
2
In
addition,
on
a
case­
by­
case
basis,
where
there
may
be
an
imminent
and
substantial
endangerment
to
human
health
or
the
environment,
EPA
has
broad
authority
to
require
corrective
action
and
other
appropriate
activities
under
RCRA
Section
7003.
Under
RCRA
Section
7003,
EPA
has
the
ability
to
waive
both
the
requirement
to
obtain
a
permit
and
the
substantive
requirements
that
would
be
imposed
through
permits.
When
EPA
uses
RCRA
Section
7003,
however,
the
Agency
seldom
uses
RCRA
Section
7003
to
waive
substantive
requirements.
In
rare
situations
where
substantive
requirements
are
waived,
the
Agency
would
impose
alternative
requirements
(e.
g,
waste
treatment
or
storage
requirements)
as
necessary
to
ensure
protection
of
human
health
and
the
environment.
EPA
may
issue
RCRA
Section
7003
orders
at,
among
other
sites,
facilities
that
have
been
issued
RCRA
permits
and
facilities
that
are
authorized
to
operate
under
RCRA
interim
status.
In
discussing
the
use
of
7003
orders,
where
other
permit
authorities
are
available
to
abate
potential
endangerments,
EPA
generally
encourages
use
of
those
other
permit
authorities
(e.
g.,
3005(
c)(
3)
omnibus
permitting
authority)
rather
than
RCRA
Section
7003.
Similarly,
if
RCRA
Section
3008(
h)
or
RCRA
Section
3013
authority
is
available,
EPA
generally
encourages
use
of
these
authorities
rather
than
RCRA
Section
7003.
If
permit
authorities
or
non­
RCRA
Section
7003
enforcement
authorities
are
inadequate,
cannot
be
used
to
address
the
potential
endangerment
in
a
timely
manner,
or
are
otherwise
inappropriate
for
the
potential
endangerment
at
issue,
use
of
RCRA
Section
7003
should
be
considered.
See,
"Guidance
on
the
Use
of
Section
7003
of
RCRA,"
U.
S.
EPA,
Office
of
Enforcement
and
Compliance
Assurance,
October
1997.

In
1987,
EPA
issued
guidance
indicating
that
RCRA­
authorized
states
with
state
waiver
authorities
comparable
to
CERCLA
121(
e)
or
RCRA
Section
7003
could
use
those
state
waiver
authorities
to
waive
RCRA
requirements
as
long
as
the
state
did
so
in
a
manner
no
less
stringent
than
that
allowed
under
the
corresponding
Federal
authorities.
These
waivers
are
most
often
8
used,
as
are
the
Federal
waivers,
to
obviate
the
need
to
obtain
a
RCRA
permit,
rather
than
to
eliminate
substantive
requirements.
See,
EPA
guidance
memo
from
J.
Winston
Porter
to
EPA
Regional
Administrators,
"RCRA
Permit
Requirements
for
State
Superfund
Actions,"
November
16,
1987,
OSWER
Directive
9522.00­
2.

Exemption
from
40
CFR
Part
264
Requirements
for
People
Engaged
in
the
Immediate
Phase
of
a
Spill
Response.
Regulations
at
40
CFR
264.1(
g)(
8)
provide
that
people
engaged
in
treatment
or
containment
activities
are
not
subject
to
the
requirements
of
40
CFR
part
264
if
the
activities
are
carried
out
during
immediate
response
to:
(1)
a
discharge
of
hazardous
waste;
(2)
an
imminent
and
substantial
threat
of
a
discharge
of
hazardous
waste;
(3)
a
discharge
of
a
materials
which,
when
discharged,
becomes
a
hazardous
waste;
or,
(4)
an
immediate
threat
to
human
health,
public
safety,
property
or
the
environment
from
the
known
or
suspected
presence
of
military
munitions,
other
explosive
material,
or
an
explosive
device.
This
means
that,
during
the
immediate
phase
of
a
spill
response,
hazardous
waste
management
activities
do
not
require
hazardous
waste
permits
(or
interim
status)
and
hazardous
waste
management
units
used
during
immediate
response
actions
are
not
subject
to
RCRA
design,
operating,
closure
or
post­
closure
requirements.

Of
course,
if
hazardous
waste
treatment
activities
or
other
hazardous
waste
management
activities
continue
after
the
immediate
phase
of
a
spill
response
is
over,
all
applicable
hazardous
waste
management
and
permitting
requirements
would
apply.
In
addition,
if
spills
occur
at
a
facility
that
is
already
regulated
under
40
CFR
part
264,
the
facility
owner/
operator
must
continue
to
comply
with
all
applicable
requirements
of
40
CFR
Part
264
Subparts
C
(preparedness
and
prevention)
and
D
(contingency
plan
and
emergency
procedures).
See
regulations
at
40
CFR
260.1(
g)
and
associated
preamble
discussion
at
45
FR
76626
(November
19,
1980).
See
also,
Sept.
29,
1986
memo
from
J.
Winston
Porter
(EPA
Assistant
Administrator)
to
Fred
Hansen
interpreting
the
40
CFR
264.1(
g)
regulations.

Changes
During
Interim
Status
to
Comply
with
Corrective
Action
Requirements.
Under
regulations
at
40
CFR
270.72(
a)(
5),
an
owner
or
operator
of
an
interim
status
facility
may
make
changes
to
provide
for
treatment,
storage
and
disposal
of
remediation
wastes
in
accordance
with
an
interim
status
corrective
action
order
issued
by
EPA
under
RCRA
Section
3008(
h)
or
other
Federal
authority,
by
an
authorized
state
under
comparable
state
authority,
or
by
a
court
in
a
judicial
action
brought
by
EPA
or
an
authorized
state.
These
changes
are
limited
to
treatment,
storage
and
disposal
of
remediation
waste
managed
as
a
result
of
corrective
action
for
releases
at
the
facility
in
question;
however,
they
are
exempt
from
the
reconstruction
ban
under
40
CFR
270.72(
b).
Under
this
provision,
for
example,
EPA
could
approve
a
corrective
action
management
unit
for
treatment
of
remediation
waste
using
a
3008(
h)
order
(or
an
authorized
state
could
approve
a
CAMU
using
a
similar
state
authority),
even
if
that
unit
would
otherwise
amount
to
"reconstruction."
Of
course,
units
added
at
interim
status
facilities
in
accordance
with
this
provision
must
meet
all
applicable
unit
requirements;
for
example,
in
the
case
of
a
CAMU,
the
CAMU
requirements
apply.
See,
regulations
at
40
CFR
270.72(
a)(
5)
promulgated
March
7,
1989
and
associated
preamble
discussion
at
54
FR
9599.

Emergency
Permits.
In
the
event
of
an
imminent
and
substantial
endangerment
to
human
health
or
the
environment,
EPA,
or
an
authorized
state,
may
issue
a
temporary
emergency
permit
for
treatment,
storage
or
disposal
of
hazardous
waste.
Emergency
permits
may
allow
treatment,
9
storage
or
disposal
of
hazardous
waste
at
a
non­
permitted
facility
or
at
a
permitted
facility
for
waste
not
covered
by
the
permit.
Emergency
permits
may
be
oral
or
written.
(If
oral,
they
must
be
followed
within
five
days
by
a
written
emergency
permit.)
Emergency
permits
must
specify
the
hazardous
wastes
to
be
received
and
managed
and
the
manner
and
location
of
their
treatment,
storage
and
disposal.
Emergency
permits
may
apply
for
up
to
ninety
days,
but
may
be
terminated
at
any
point
if
EPA,
or
an
authorized
state,
determines
that
termination
is
appropriate
to
protect
human
health
or
the
environment.
Emergency
permits
must
be
accompanied
by
a
public
notice
that
meets
the
requirements
of
40
CFR
124.10(
b),
including
the
name
and
address
of
the
office
approving
the
emergency
permit,
the
name
and
location
of
the
hazardous
waste
treatment,
storage
or
disposal
facility,
a
brief
description
of
the
wastes
involved,
the
actions
authorized
and
the
reason
for
the
authorization,
and
the
duration
of
the
emergency
permit.

Emergency
permits
are
exempt
from
all
other
requirements
of
40
CFR
part
270
and
part
124;
however,
to
the
extent
possible
and
not
inconsistent
with
the
emergency
situation,
they
must
incorporate
all
otherwise
applicable
requirements
of
40
CFR
part
270
and
parts
264
and
266.

See,
regulations
at
40
CFR
270.61,
originally
promulgated
as
40
CFR
122.27
on
May
19,
1987
(45
FR
33326).
EPA
has
also
written
a
number
of
letters
interpreting
the
emergency
permit
regulations,
see,
for
example,
November
3,
1992
letter
to
Mark
Hansen,
Environmental
Products
and
Services
Inc.,
from
Sylvia
Lowrance,
Director
Office
of
Solid
Waste
(available
in
the
RCRA
Permit
Policy
Compendium).

Temporary
Authorizations
at
Permitted
Facilities.
Under
regulations
at
40
CFR
270.42(
e),
EPA,
or
an
authorized
state,
may
temporarily
authorize
a
permittee
for
an
activity
that
would
be
the
subject
of
a
class
two
or
three
permit
modification
in
order
to,
among
other
things,
facilitate
timely
implementation
of
closure
or
corrective
action
activities.
Activities
approved
using
a
temporary
authorization
must
comply
with
applicable
requirements
of
40
CFR
part
264.
Temporary
authorizations
are
limited
to
180
days,
with
an
opportunity
for
an
extension
of
180
additional
days.
To
obtain
an
extension
of
a
temporary
authorization,
a
permittee
must
have
requested
a
class
two
or
three
permit
modification
for
the
activity
covered
in
the
temporary
authorization.
Public
notification
of
temporary
authorizations
is
accomplished
by
the
permittee
sending
a
notice
about
the
temporary
authorization
to
all
persons
on
the
facility
mailing
list
and
to
appropriate
state
and
local
governments.
See
regulations
at
40
CFR
270.42,
promulgated
on
September
28,
1988,
and
associated
preamble
at
53
FR
37919.

Regulations
and
Policies
that
Apply
to
Contaminated
Environmental
Media
Only
Contained­
in
policy.
Contaminated
environmental
media,
of
itself,
is
not
hazardous
waste
and,
generally,
is
not
subject
to
regulation
under
RCRA.
Contaminated
environmental
media
can
become
subject
to
regulation
under
RCRA
if
they
"contain"
hazardous
waste.
As
discussed
more
fully
below,
EPA
generally
considers
contaminated
environmental
media
to
contain
hazardous
waste:
(1)
when
they
exhibit
a
characteristic
of
hazardous
waste;
or,
(2)
when
they
are
contaminated
with
concentrations
of
hazardous
constituents
from
listed
hazardous
waste
that
are
above
health­
based
levels.

If
contaminated
environmental
media
contain
hazardous
waste,
they
are
subject
to
all
applicable
RCRA
requirements
until
they
no
longer
contain
hazardous
waste.
EPA
considers
10
contaminated
environmental
media
to
no
longer
contain
hazardous
waste:
(1)
when
they
no
longer
exhibit
a
characteristic
of
hazardous
waste;
and
(2)
when
concentrations
of
hazardous
constituents
from
listed
hazardous
wastes
are
below
health­
based
levels.
Generally,
contaminated
environmental
media
that
do
not
(or
no
longer)
contain
hazardous
waste
are
not
subject
to
any
RCRA
requirements;
however,
as
discussed
below,
in
some
circumstances,
contaminated
environmental
media
that
contained
hazardous
waste
when
first
generated
(i.
e.,
first
removed
from
the
land,
or
area
of
contamination)
remain
subject
to
LDR
treatment
requirements
even
after
they
"no
longer
contain"
hazardous
waste.

The
determination
that
any
given
volume
of
contaminated
media
does
not
contain
hazardous
waste
is
called
a
"contained­
in
determination."
In
the
case
of
media
that
exhibit
a
characteristic
of
hazardous
waste,
the
media
are
considered
to
"contain"
hazardous
waste
for
as
long
as
they
exhibit
a
characteristic.
Once
the
characteristic
is
eliminated
(e.
g.,
through
treatment),
the
media
are
no
longer
considered
to
"contain"
hazardous
waste.
Since
this
determination
can
be
made
through
relatively
straightforward
analytical
testing,
no
formal
"contained­
in"
determination
by
EPA
or
an
authorized
state
is
required.
Just
like
determinations
about
whether
waste
has
been
adequately
decharacterized,
generators
of
contaminated
media
may
make
independent
determinations
as
to
whether
the
media
exhibit
a
characteristic
of
hazardous
waste.
In
the
case
of
media
that
are
contaminated
by
listed
hazardous
waste,
current
EPA
guidance
recommends
that
contained­
in
determinations
be
made
based
on
direct
exposure
using
a
reasonable
maximum
exposure
scenario
and
that
conservative,
health­
based,
standards
be
used
to
develop
the
site­
specific
health­
based
levels
of
hazardous
constituents
below
which
contaminated
environmental
media
would
be
considered
to
no
longer
contain
hazardous
waste.
Since
this
determination
involves
development
of
site­
specific
health­
based
levels,
the
approval
of
EPA
or
an
authorized
state
is
required.

In
certain
circumstances
the,
RCRA
land
disposal
restrictions
will
continue
to
apply
to
contaminated
media
that
has
been
determined
not
to
contain
hazardous
waste.
This
is
the
case
when
contaminated
media
contain
hazardous
waste
when
they
are
first
generated
(i.
e.,
removed
from
the
land,
or
area
of
contamination)
and
are
subsequently
determined
to
no
longer
contain
hazardous
waste
(e.
g.,
after
treatment),
but
still
contain
hazardous
constituents
at
concentrations
above
land
disposal
restriction
treatment
standards.
It
is
also
the
case
when
media
are
contaminated
as
a
result
of
disposal
of
untreated
(or
insufficiently
treated)
listed
hazardous
waste
after
the
effective
date
of
an
applicable
LDR
treatment
requirement.
Of
course,
if
no
land
disposal
will
occur
(e.
g.,
the
media
will
be
legitimately
recycled)
the
LDR
treatment
standards
do
not
apply.
In
addition,
contaminated
environmental
media
determined
not
to
contain
any
waste
(i.
e.,
it
is
just
media,
it
does
not
contain
solid
or
hazardous
waste)
would
not
be
subject
to
any
RCRA
Subtitle
C
requirements,
including
the
LDRs,
regardless
of
the
time
of
the
"contained­
in"
determination.

The
contained­
in
policy
was
first
articulated
in
a
November
13,
1986
EPA
memorandum,
"RCRA
Regulatory
Status
of
Contaminated
Groundwater."
It
has
been
updated
many
times
in
Federal
Register
preambles,
EPA
memos
and
correspondence,
see,
e.
g.,
53
FR
31138,
31142,
31148
(Aug.
17,
1988),
57
FR
21450,
21453
(May
20,
1992),
and
detailed
discussion
in
HWIRMedia
proposal
preamble,
61
FR
18795
(April
29,
1996).
A
detailed
discussion
of
the
continuing
requirement
that
some
soils
which
have
been
determined
to
no
longer
contain
hazardous
waste
(but
still
contain
solid
waste)
comply
with
land
disposal
treatment
standards
can
be
found
in
the
3
This
rule,
which
also
addresses
a
number
of
non­
soil
issues,
has
been
challenged
by
a
number
of
parties.
To
date,
the
parties
have
filed
non­
binding
statements
of
issues
only;
however,
based
on
those
statements,
it
appears
that,
with
the
exception
of
the
requirement
that
PCBs
be
included
as
an
underlying
hazardous
constituent
which
has
been
challenged
for
both
soil
and
non­
soil
wastes,
the
soil
treatment
standards
are
not
included
in
the
challenges.

4
Except
fluoride,
selenium,
sulfides,
vanadium
and
zinc.

11
HWIR­
Media
proposal
preamble,
61
FR
18804;
the
September
15,
1996
letter
from
Michael
Shapiro
(EPA
OSW
Director)
to
Peter
C.
Wright
(Monsanto
Company);
and
the
preamble
to
the
LDR
Phase
IV
rule,
63
FR
28617
(May
26,
1998).

Note
that
the
contained­
in
policy
applies
only
to
environmental
media
(soil,
ground
water,
surface
water
and
sediments)
and
debris.
The
contained­
in
policy
for
environmental
media
has
not
been
codified.
As
discussed
below,
the
contained­
in
policy
for
hazardous
debris
was
codified
in
1992.

RCRA
Section
3020(
b)
Exemption
for
Reinjection
of
Contaminated
Ground
Water.
Under
RCRA
Section
3020(
a),
disposal
of
hazardous
waste
into
or
above
a
formation
that
contains
an
underground
source
of
drinking
water
is
generally
prohibited.
RCRA
Section
3020(
b)
provides
an
exception
for
underground
injection
carried
out
in
connection
with
certain
remediation
activities.
Under
RCRA
Section
3020(
b),
injection
of
contaminated
ground
water
back
into
the
aquifer
from
which
it
was
withdrawn
is
allowed
if:
(1)
such
injection
is
conducted
as
part
of
a
response
action
under
Section
104
or
106
of
CERCLA
or
a
RCRA
corrective
action
intended
to
clean
up
such
contamination;
(2)
the
contaminated
ground
water
is
treated
to
substantially
reduce
hazardous
constituents
prior
to
reinjection;
and,
(3)
the
response
action
or
corrective
action
will,
on
completion,
be
sufficient
to
protect
human
health
and
the
environment.
Approval
of
reinjection
under
RCRA
Section
3020(
b)
can
be
included
in
approval
of
other
cleanup
activities,
for
example,
as
part
of
approval
of
a
RCRA
Statement
of
Basis
or
CERCLA
Record
of
Decision.
See,
RCRA
Section
3020(
b),
established
as
part
of
the
1984
HSWA
amendments.
See
also,
OSWER
Directive
9234.1­
06,
"Applicable
of
Land
Disposal
Restrictions
to
RCRA
and
CERCLA
Ground
Water
Treatment
Reinjection
Superfund
Management
Review:
Recommendation
No.
26,"
November
27,
1989.

LDR
Treatment
Standards
for
Contaminated
Soils.
On
May
26,
1998,
EPA
promulgated
land
disposal
restriction
treatment
standards
specific
to
contaminated
soils.
3
These
treatment
standards
require
that
contaminated
soils
which
will
be
land
disposed
be
treated
to
reduce
concentrations
of
hazardous
constituents
by
90
percent
or
meet
hazardous
constituent
concentrations
that
are
ten
times
the
universal
treatment
standards
(UTS),
whichever
is
greater.
(This
is
typically
referred
to
as
90%
capped
by
10xUTS.)
For
contaminated
soil
that
exhibits
a
characteristic
of
ignitable,
reactive
or
corrosive
hazardous
waste,
treatment
must
also
eliminate
the
hazardous
characteristic.

The
soil
treatment
standards
apply
to
all
underlying
hazardous
constituents
4
reasonably
expected
to
be
present
in
any
given
volume
of
contaminated
soil
when
such
constituents
are
found
at
initial
concentrations
greater
than
ten
times
the
UTS.
For
soil
that
exhibits
a
characteristic
of
toxic,
ignitable,
reactive
or
corrosive
hazardous
waste,
treatment
is
also
required
for:
(1)
in
the
case
of
the
toxicity
characteristic,
the
characteristic
constituent;
and,
(2)
in
the
case
of
ignitability,
12
reactivity
or
corrosivity,
the
characteristic
property.
Although
treatment
is
required
for
each
underlying
hazardous
constituent,
it
is
not
necessary
to
monitor
soil
for
the
entire
list
of
underlying
hazardous
constituents.
Generators
of
contaminated
soil
can
reasonably
apply
knowledge
of
the
likely
contaminants
present
and
use
that
knowledge
to
select
appropriate
underlying
hazardous
constituents,
or
classes
of
constituents,
for
monitoring.
As
with
the
LDR
treatment
standards
for
hazardous
debris
(discussed
below),
generators
of
contaminated
soil
may
use
either
the
applicable
universal
treatment
standards
for
the
contaminating
hazardous
waste
or
the
soil
treatment
standards.

See,
soil
treatment
standard
regulations
at
40
CFR
268.49,
promulgated
May
26,
1998
and
associated
preamble
discussion
at
63
FR
28602­
28622.

Note
that
the
soil
treatment
standards
supersede
the
historic
presumption
that
an
LDR
treatment
variance
is
appropriate
for
contaminated
soil.
LDR
treatment
variances
are
still
available
for
contaminated
soil,
provided
the
generator
can
show
that
an
otherwise
applicable
treatment
standard
(i.
e.,
the
soil
treatment
standard)
is
unachieveable
or
inappropriate,
as
discussed
above,
or
can
show
that
a
site­
specific,
risk­
based
treatment
variance
is
proper,
as
discussed
below.

Site­
Specific,
Risk­
Based
LDR
Treatment
Variance
for
Contaminated
Soils.
On
May
26,
1998,
EPA
promulgated
a
new
land
disposal
restriction
treatment
variance
specific
to
contaminated
soil.
Under
40
CFR
268.44(
h)(
3),
variances
from
otherwise
applicable
LDR
treatment
standards
may
be
approved
if
it
is
determined
that
compliance
with
the
treatment
standards
would
result
in
treatment
beyond
the
point
at
which
short­
and
long­
term
threats
to
human
health
and
the
environment
are
minimized.
This
allows
a
site­
specific,
risk­
based
determination
to
supersede
the
technology­
based
LDR
treatment
standards
under
certain
circumstances.

Alternative
land
disposal
restriction
treatment
standards
established
through
site
specific,
risk­
based
minimize
threat
variances
should
be
within
the
range
of
values
the
Agency
generally
finds
acceptable
for
risk­
based
cleanup
levels.
That
is,
for
carcinogens,
alternative
treatment
standards
should
ensure
constituent
concentrations
that
result
in
the
total
excess
risk
to
an
individual
exposed
over
a
lifetime
generally
falling
within
a
range
from
10
­4
to
10
­6
,
using
10
­6
as
a
point
of
departure
and
with
a
preference
for
achieving
the
more
protective
end
of
the
risk
range.
For
non­
carcinogenic
effects,
alternative
treatment
standards
should
ensure
constituent
concentrations
that
an
individual
could
be
exposed
to
on
a
daily
basis
without
appreciable
risk
of
deleterious
effect
during
a
lifetime;
in
general,
the
hazard
index
should
not
exceed
one
(1).
Constituent
concentrations
that
achieve
these
levels
should
be
calculated
based
on
a
reasonable
maximum
exposure
scenario
­­
that
is,
based
on
an
analysis
of
both
the
current
and
reasonable
expected
future
land
uses,
with
exposure
parameters
chosen
based
on
a
reasonable
assessment
of
the
maximum
exposure
that
might
occur;
however,
alternative
LDR
treatment
standards
may
not
be
based
on
consideration
of
post­
land
disposal
controls
such
as
caps
or
other
barriers.

See,
regulations
at
40
CFR
268.44(
h)(
4),
promulgated
May
26,
1998
and
associated
preamble
discussion
at
63
FR
28606­
28608.

Regulations
and
Policies
that
Apply
Only
to
Debris
13
LDR
Treatment
Standards
for
Contaminated
Debris.
In
1992,
EPA
established
land
disposal
restriction
treatment
standards
specific
to
hazardous
contaminated
debris.
The
debrisspecific
treatment
standards
established
by
these
regulations
are
based
on
application
of
common
extraction,
destruction,
and
containment
debris
treatment
technologies
and
are
expressed
as
specific
technologies
rather
than
numeric
criteria.
As
with
the
contaminated
soil
treatment
standards
discussed
earlier,
generators
of
hazardous
contaminated
debris
may
choose
between
meeting
either
the
debris
treatment
standards
or
the
numerical
treatment
standard
promulgated
for
the
contaminating
hazardous
waste.
See,
regulations
at
40
CFR
268.45,
promulgated
August
18,
1992,
and
associated
preamble
discussion
at
57
FR
37194
and
27221.

Interpretation
that
Debris
Treated
to
the
LDR
Debris
Treatment
Standards
Using
Extraction
or
Destruction
Technologies
no
Longer
Contain
Hazardous
Waste.
With
the
land
disposal
restriction
treatment
standards
for
hazardous
contaminated
debris,
in
1992,
EPA
determined
that
hazardous
debris
treated
to
comply
with
the
debris
treatment
standards
using
one
of
the
identified
extraction
or
destruction
technologies
would
be
considered
no
longer
to
contain
hazardous
waste
and
would,
therefore,
no
longer
be
subject
to
regulation
under
RCRA,
provided
the
debris
do
not
exhibit
any
of
the
hazardous
waste
characteristics.
This
"contained­
in
determination"
is
automatic;
no
agency
action
is
needed.
Note
that
this
automatic
contained­
in
determination
does
not
apply
to
debris
treated
to
the
debris
treatment
standards
using
one
of
the
identified
immobilization
technologies.
See,
regulations
at
40
CFR
261.3(
f)
and
treatment
standards
at
Table
1
of
40
CFR
268.45,
promulgated
August
18,
1992,
and
associated
preamble
discussion
at
51
FR
37225.

cc:
Barbara
Simcoe,
Association
of
State
and
Territorial
Solid
Waste
Management
Officials
APPENDIX
B:
STATISTICAL
TABLES
Table
B­
1:
10%
Values
For
The
Nonparametric
Test
of
Location
nU
(
nT
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
1
9
10
11
12
13
14
15
16
17
18
19
19
20
21
22
23
24
25
26
27
28
28
29
30
31
32
33
34
35
36
37
37
38
39
40
41
42
43
44
45
46
46
2
3
4
5
6
6
7
8
8
9
10
10
11
12
12
13
14
15
15
16
17
17
18
19
19
20
21
21
22
23
23
24
25
25
26
27
28
28
29
30
30
31
32
32
33
34
34
35
36
3
2
3
4
4
5
5
6
6
7
7
8
9
9
10
10
11
11
12
12
13
13
14
14
15
15
16
17
17
18
18
19
19
20
20
21
21
22
22
23
24
24
25
25
26
26
27
27
28
28
4
2
3
3
4
4
5
5
5
6
6
7
7
8
8
9
9
9
10
10
11
11
12
12
13
13
13
14
14
15
15
16
16
16
17
17
18
18
19
19
20
20
20
21
21
22
22
23
23
23
5
2
3
3
3
4
4
4
5
5
6
6
6
7
7
7
8
8
9
9
9
10
10
10
11
11
12
12
12
13
13
13
14
14
14
15
15
16
16
16
17
17
17
18
18
19
19
19
20
20
6
2
2
3
3
3
4
4
4
5
5
5
6
6
6
7
7
7
8
8
8
9
9
9
10
10
10
11
11
11
11
12
12
12
13
13
13
14
14
14
15
15
15
16
16
16
17
17
17
18
7
2
2
3
3
3
3
4
4
4
5
5
5
5
6
6
6
7
7
7
7
8
8
8
9
9
9
9
10
10
10
11
11
11
11
12
12
12
13
13
13
13
14
14
14
14
15
15
15
16
8
2
2
2
3
3
3
4
4
4
4
5
5
5
5
6
6
6
6
7
7
7
7
8
8
8
8
9
9
9
9
10
10
10
10
11
11
11
11
12
12
12
12
13
13
13
13
14
14
14
9
1
2
2
2
3
3
3
3
4
4
4
4
4
5
5
5
5
6
6
6
6
7
7
7
7
7
8
8
8
8
9
9
9
9
9
10
10
10
10
11
11
11
11
12
12
12
12
12
13
13
10
1
2
2
2
2
3
3
3
3
4
4
4
4
4
5
5
5
5
5
6
6
6
6
7
7
7
7
7
8
8
8
8
8
9
9
9
9
9
10
10
10
10
10
11
11
11
11
11
12
12
11
1
2
2
2
2
3
3
3
3
3
4
4
4
4
4
5
5
5
5
5
6
6
6
6
6
6
7
7
7
7
7
8
8
8
8
8
9
9
9
9
9
10
10
10
10
10
10
11
11
11
12
1
2
2
2
2
2
3
3
3
3
3
4
4
4
4
4
5
5
5
5
5
5
6
6
6
6
6
6
7
7
7
7
7
8
8
8
8
8
8
9
9
9
9
9
9
10
10
10
10
10
13
1
2
2
2
2
2
3
3
3
3
3
3
4
4
4
4
4
4
5
5
5
5
5
5
6
6
6
6
6
6
7
7
7
7
7
7
8
8
8
8
8
8
9
9
9
9
9
9
10
10
14
1
2
2
2
2
2
3
3
3
3
3
3
3
4
4
4
4
4
4
5
5
5
5
5
5
5
6
6
6
6
6
6
7
7
7
7
7
7
7
8
8
8
8
8
8
9
9
9
9
9
15
1
2
2
2
2
2
2
3
3
3
3
3
3
3
4
4
4
4
4
4
5
5
5
5
5
5
5
6
6
6
6
6
6
6
7
7
7
7
7
7
7
8
8
8
8
8
8
8
9
9
16
1
2
2
2
2
2
2
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
5
5
5
5
5
5
5
6
6
6
6
6
6
6
7
7
7
7
7
7
7
7
8
8
8
8
8
8
17
1
2
2
2
2
2
2
2
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
5
5
5
5
5
5
5
5
6
6
6
6
6
6
6
7
7
7
7
7
7
7
7
8
8
8
8
18
1
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
5
5
5
5
5
5
5
5
6
6
6
6
6
6
6
6
6
7
7
7
7
7
7
7
7
8
19
1
1
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
5
5
5
5
5
5
5
5
5
6
6
6
6
6
6
6
6
6
7
7
7
7
7
7
7
20
1
1
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
4
5
5
5
5
5
5
5
5
5
6
6
6
6
6
6
6
6
6
7
7
7
7
7
21
1
1
2
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
4
5
5
5
5
5
5
5
5
5
6
6
6
6
6
6
6
6
6
6
7
7
7
22
1
1
2
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
4
5
5
5
5
5
5
5
5
5
5
6
6
6
6
6
6
6
6
6
6
7
23
1
1
2
2
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
4
4
4
5
5
5
5
5
5
5
5
5
5
6
6
6
6
6
6
6
6
6
24
1
1
2
2
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
4
4
4
5
5
5
5
5
5
5
5
5
5
5
6
6
6
6
6
6
6
25
1
1
2
2
2
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
4
4
4
5
5
5
5
5
5
5
5
5
5
5
6
6
6
6
6
6
26
1
1
2
2
2
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
4
4
4
5
5
5
5
5
5
5
5
5
5
5
5
6
6
6
6
27
1
1
2
2
2
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
4
4
4
4
5
5
5
5
5
5
5
5
5
5
5
5
6
6
28
1
1
2
2
2
2
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
4
4
4
4
5
5
5
5
5
5
5
5
5
5
5
5
6
29
1
1
2
2
2
2
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
4
4
4
4
5
5
5
5
5
5
5
5
5
5
5
5
30
1
1
2
2
2
2
2
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
4
4
4
4
4
5
5
5
5
5
5
5
5
5
5
31
1
1
2
2
2
2
2
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
4
4
4
4
4
4
5
5
5
5
5
5
5
5
5
32
1
1
2
2
2
2
2
2
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
4
4
4
4
4
4
5
5
5
5
5
5
5
5
33
1
1
2
2
2
2
2
2
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
4
4
4
4
4
4
5
5
5
5
5
5
5
34
1
1
2
2
2
2
2
2
2
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
5
5
5
5
5
35
1
1
2
2
2
2
2
2
2
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
5
5
5
5
36
1
1
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
5
5
5
37
1
1
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
5
38
1
1
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
39
1
1
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
40
1
1
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
41
1
1
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
4
4
4
4
4
4
42
1
1
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
4
4
4
4
4
43
1
1
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
4
4
4
4
44
1
1
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
4
4
4
45
1
1
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
4
4
4
46
1
1
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
4
4
47
1
1
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
4
48
1
1
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
49
1
1
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
50
1
1
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
Table
B­
2:
5%
Values
For
The
Nonparametric
Test
of
Location
nU
(
nT
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
1
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
39
40
41
42
43
44
45
46
47
48
49
2
5
6
7
8
9
9
10
11
12
13
13
14
15
16
16
17
18
19
20
20
21
22
23
23
24
25
26
26
27
28
29
30
30
31
32
33
33
34
35
36
37
37
38
39
40
40
3
3
4
5
5
6
7
7
8
9
9
10
11
11
12
12
13
14
14
15
16
16
17
18
18
19
19
20
21
21
22
23
23
24
24
25
26
26
27
28
28
29
30
30
31
31
32
33
33
4
3
4
4
5
5
6
6
7
8
8
9
9
10
10
11
11
12
12
13
13
14
14
15
15
16
17
17
18
18
19
19
20
20
21
21
22
22
23
23
24
24
25
26
26
27
27
28
28
5
2
3
3
4
4
5
5
6
6
7
7
8
8
9
9
9
10
10
11
11
12
12
13
13
14
14
14
15
15
16
16
17
17
18
18
18
19
19
20
20
21
21
22
22
23
23
23
24
24
6
2
3
3
4
4
4
5
5
6
6
6
7
7
8
8
8
9
9
10
10
10
11
11
12
12
12
13
13
14
14
14
15
15
16
16
16
17
17
18
18
18
19
19
20
20
20
21
21
21
7
2
3
3
3
4
4
5
5
5
6
6
6
7
7
7
8
8
8
9
9
9
10
10
11
11
11
12
12
12
13
13
13
14
14
14
15
15
15
16
16
16
17
17
18
18
18
19
19
19
8
2
3
3
3
4
4
4
5
5
5
6
6
6
6
7
7
7
8
8
8
9
9
9
10
10
10
11
11
11
12
12
12
12
13
13
13
14
14
14
15
15
15
16
16
16
17
17
17
17
9
2
2
3
3
3
4
4
4
5
5
5
5
6
6
6
7
7
7
7
8
8
8
9
9
9
9
10
10
10
11
11
11
11
12
12
12
13
13
13
13
14
14
14
15
15
15
15
16
16
10
2
2
3
3
3
4
4
4
4
5
5
5
5
6
6
6
6
7
7
7
8
8
8
8
9
9
9
9
10
10
10
10
11
11
11
11
12
12
12
12
13
13
13
14
14
14
14
15
15
11
2
2
3
3
3
3
4
4
4
4
5
5
5
5
6
6
6
6
7
7
7
7
8
8
8
8
9
9
9
9
9
10
10
10
10
11
11
11
11
12
12
12
12
13
13
13
13
14
14
12
2
2
3
3
3
3
3
4
4
4
4
5
5
5
5
6
6
6
6
6
7
7
7
7
8
8
8
8
8
9
9
9
9
10
10
10
10
10
11
11
11
11
12
12
12
12
12
13
13
13
2
2
2
3
3
3
3
4
4
4
4
4
5
5
5
5
6
6
6
6
6
7
7
7
7
7
8
8
8
8
8
9
9
9
9
9
10
10
10
10
11
11
11
11
11
12
12
12
12
14
2
2
2
3
3
3
3
3
4
4
4
4
4
5
5
5
5
5
6
6
6
6
6
7
7
7
7
7
8
8
8
8
8
9
9
9
9
9
10
10
10
10
10
11
11
11
11
11
12
15
2
2
2
3
3
3
3
3
4
4
4
4
4
4
5
5
5
5
5
6
6
6
6
6
7
7
7
7
7
7
8
8
8
8
8
9
9
9
9
9
9
10
10
10
10
10
11
11
11
16
2
2
2
2
3
3
3
3
3
4
4
4
4
4
5
5
5
5
5
5
6
6
6
6
6
6
7
7
7
7
7
7
8
8
8
8
8
9
9
9
9
9
9
10
10
10
10
10
10
17
2
2
2
2
3
3
3
3
3
4
4
4
4
4
4
5
5
5
5
5
5
6
6
6
6
6
6
7
7
7
7
7
7
8
8
8
8
8
8
8
9
9
9
9
9
9
10
10
10
18
2
2
2
2
3
3
3
3
3
3
4
4
4
4
4
4
5
5
5
5
5
5
5
6
6
6
6
6
6
7
7
7
7
7
7
8
8
8
8
8
8
8
9
9
9
9
9
9
10
19
1
2
2
2
2
3
3
3
3
3
3
3
4
4
4
4
4
4
5
5
5
5
5
5
5
6
6
6
6
6
6
7
7
7
7
7
7
7
8
8
8
8
8
8
8
9
9
9
9
9
20
1
2
2
2
2
2
3
3
3
3
3
3
4
4
4
4
4
4
4
5
5
5
5
5
5
5
6
6
6
6
6
6
6
7
7
7
7
7
7
7
8
8
8
8
8
8
8
9
9
9
21
1
2
2
2
2
2
3
3
3
3
3
3
3
4
4
4
4
4
4
4
5
5
5
5
5
5
5
6
6
6
6
6
6
6
6
7
7
7
7
7
7
7
8
8
8
8
8
8
8
9
22
1
2
2
2
2
2
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
5
5
5
5
5
5
5
6
6
6
6
6
6
6
6
7
7
7
7
7
7
7
7
8
8
8
8
8
8
23
1
2
2
2
2
2
2
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
5
5
5
5
5
5
5
5
6
6
6
6
6
6
6
6
7
7
7
7
7
7
7
7
8
8
8
8
24
1
2
2
2
2
2
2
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
5
5
5
5
5
5
5
5
6
6
6
6
6
6
6
6
7
7
7
7
7
7
7
7
7
8
8
25
1
2
2
2
2
2
2
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
5
5
5
5
5
5
5
5
5
6
6
6
6
6
6
6
6
6
7
7
7
7
7
7
7
7
8
26
1
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
5
5
5
5
5
5
5
5
5
6
6
6
6
6
6
6
6
6
7
7
7
7
7
7
7
7
27
1
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
4
5
5
5
5
5
5
5
5
5
6
6
6
6
6
6
6
6
6
6
7
7
7
7
7
7
28
1
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
4
5
5
5
5
5
5
5
5
5
5
6
6
6
6
6
6
6
6
6
7
7
7
7
7
29
1
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
4
4
5
5
5
5
5
5
5
5
5
5
6
6
6
6
6
6
6
6
6
6
7
7
7
30
1
2
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
4
4
5
5
5
5
5
5
5
5
5
5
6
6
6
6
6
6
6
6
6
6
7
7
31
1
2
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
4
4
5
5
5
5
5
5
5
5
5
5
6
6
6
6
6
6
6
6
6
6
6
32
1
2
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
4
4
4
5
5
5
5
5
5
5
5
5
5
5
6
6
6
6
6
6
6
6
6
33
1
2
2
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
4
4
4
5
5
5
5
5
5
5
5
5
5
5
6
6
6
6
6
6
6
6
34
1
2
2
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
4
4
4
4
5
5
5
5
5
5
5
5
5
5
5
6
6
6
6
6
6
6
35
1
2
2
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
4
4
4
5
5
5
5
5
5
5
5
5
5
5
5
6
6
6
6
6
6
36
1
2
2
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
4
4
4
5
5
5
5
5
5
5
5
5
5
5
5
6
6
6
6
6
37
1
2
2
2
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
4
4
4
4
5
5
5
5
5
5
5
5
5
5
5
5
5
6
6
6
38
1
2
2
2
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
4
4
4
4
5
5
5
5
5
5
5
5
5
5
5
5
5
6
6
39
1
1
2
2
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
4
4
4
4
4
5
5
5
5
5
5
5
5
5
5
5
5
5
6
40
1
1
2
2
2
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
4
4
4
4
4
5
5
5
5
5
5
5
5
5
5
5
5
5
41
1
1
2
2
2
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
4
4
4
4
4
4
5
5
5
5
5
5
5
5
5
5
5
5
42
1
1
2
2
2
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
4
4
4
4
4
4
5
5
5
5
5
5
5
5
5
5
5
43
1
1
2
2
2
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
4
4
4
4
4
4
5
5
5
5
5
5
5
5
5
5
44
1
1
2
2
2
2
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
4
4
4
4
4
4
5
5
5
5
5
5
5
5
5
5
45
1
1
2
2
2
2
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
4
4
4
4
4
4
5
5
5
5
5
5
5
5
5
46
1
1
2
2
2
2
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
5
5
5
5
5
5
5
5
47
1
1
2
2
2
2
2
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
5
5
5
5
5
5
5
48
1
1
2
2
2
2
2
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
5
5
5
5
5
5
49
1
1
2
2
2
2
2
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
5
5
5
5
5
50
1
1
2
2
2
2
2
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
5
5
5
5
Table
B­
3.
Critical
Values
of
Student's
t
Distribution
(One­
Tailed)

Degrees
of
Freedom
1­
"
0.80
0.85
0.90
0.95
0.99
1
1.376
1.963
3.078
6.314
31.821
2
1.061
1.386
1.886
2.920
6.965
3
0.978
1.250
1.638
2.353
4.541
4
0.941
1.190
1.533
2.132
3.747
5
0.920
1.156
1.476
2.015
3.365
6
0.906
1.134
1.440
1.943
3.143
7
0.896
1.119
1.415
1.895
2.998
8
0.889
1.108
1.397
1.860
2.896
9
0.883
1.100
1.383
1.833
2.821
10
0.879
1.093
1.372
1.812
2.764
11
0.876
1.088
1.363
1.796
2.718
12
0.873
1.083
1.356
1.782
2.681
13
0.870
1.079
1.350
1.771
2.650
14
0.868
1.076
1.345
1.761
2.624
15
0.866
1.074
1.340
1.753
2.602
16
0.865
1.071
1.337
1.746
2.583
17
0.863
1.069
1.333
1.740
2.567
18
0.862
1.067
1.330
1.734
2.552
19
0.861
1.066
1.328
1.729
2.539
20
0.860
1.064
1.325
1.725
2.528
21
0.859
1.063
1.323
1.721
2.518
22
0.858
1.061
1.321
1.717
2.508
23
0.858
1.060
1.319
1.714
2.500
24
0.857
1.059
1.318
1.711
2.492
25
0.856
1.058
1.316
1.708
2.485
26
0.856
1.058
1.315
1.706
2.479
27
0.855
1.057
1.314
1.703
2.473
28
0.855
1.056
1.313
1.701
2.467
29
0.854
1.055
1.311
1.699
2.462
30
0.854
1.055
1.310
1.697
2.457
40
0.851
1.050
1.303
1.684
2.423
60
0.848
1.046
1.296
1.671
2.390
120
0.845
1.041
1.289
1.658
2.358
¥
0.842
1.036
1.282
1.645
2.326
Table
B­
4.
Critical
Values
For
the
Wilcoxon
Rank
Sum
Test
nT
a
nref
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
2
0.05
0.10
0
0
0
1
0
1
1
2
1
2
1
2
2
3
2
3
2
4
2
4
3
5
3
5
4
5
4
6
4
6
4
7
5
7
5
8
5
8
3
0.05
0.10
0
1
1
2
2
2
2
3
3
4
3
5
4
6
5
6
5
7
6
8
6
9
7
10
8
11
8
11
9
12
10
13
10
14
11
15
12
16
4
0.05
0.10
0
1
1
2
2
4
3
5
4
6
5
7
6
8
7
10
8
11
9
12
10
13
11
14
12
16
13
17
15
18
16
19
17
21
18
22
19
23
5
0.05
0.10
1
2
2
3
3
5
5
6
6
8
7
9
9
11
10
13
12
14
13
16
14
18
16
19
17
21
19
23
20
24
21
26
23
28
24
29
26
31
6
0.05
0.10
1
2
3
4
4
6
6
8
8
10
9
12
11
14
13
16
15
18
17
20
18
22
20
24
22
26
24
28
26
30
27
32
29
35
31
37
33
39
7
0.05
0.10
1
2
3
5
5
7
7
9
9
12
12
14
14
17
16
19
18
22
20
24
22
27
25
29
27
32
29
34
31
37
34
39
36
42
38
44
40
47
8
0.05
0.10
2
3
4
6
6
8
9
11
11
14
14
17
16
20
19
23
21
25
24
28
27
31
29
34
32
37
34
40
37
43
40
46
42
49
45
52
48
55
9
0.05
0.10
2
3
5
6
7
10
10
13
13
16
16
19
19
23
22
26
25
29
28
32
31
36
34
39
37
42
40
46
43
49
46
53
49
56
52
59
55
63
10
0.05
0.10
2
4
5
7
8
11
12
14
15
18
18
22
21
25
25
29
28
33
32
37
35
40
38
44
42
48
45
52
49
55
52
59
56
63
59
67
63
71
11
0.05
0.10
2
4
6
8
9
12
13
16
17
20
20
24
24
28
28
32
32
37
35
41
39
45
43
49
47
53
51
58
55
62
58
66
62
70
66
74
70
79
12
0.05
0.10
3
5
6
9
10
13
14
18
18
22
22
27
27
31
31
36
35
40
39
45
43
50
48
54
52
59
56
64
61
68
65
73
69
78
73
82
78
87
13
0.05
0.10
3
5
7
10
11
14
16
19
20
24
25
29
29
34
34
39
38
44
43
49
48
54
52
59
57
64
62
69
66
75
71
80
76
85
81
90
85
95
14
0.05
0.10
4
5
8
11
12
16
17
21
22
26
27
32
32
37
37
42
42
48
47
53
52
59
57
64
62
70
67
75
72
81
78
86
83
92
88
98
93
103
15
0.05
0.10
4
6
8
11
13
17
19
23
24
28
29
34
34
40
40
46
45
52
51
58
56
64
62
69
67
75
73
81
78
87
84
93
89
99
95
105
101
111
Table
B­
4.
Critical
Values
For
the
Wilcoxon
Rank
Sum
Test
(continued)

nT
a
nref
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
16
0.05
0.10
4
6
9
12
15
18
20
24
26
30
31
37
37
43
43
49
49
55
55
62
61
68
66
75
72
81
78
87
84
94
90
100
96
107
102
113
108
120
17
0.05
0.10
4
7
10
13
16
19
21
26
27
32
34
39
40
46
46
53
52
59
58
66
65
73
71
80
78
86
84
93
90
100
97
107
103
114
110
121
116
128
18
0.05
0.10
5
7
10
14
17
21
23
28
29
35
36
42
42
49
49
56
56
63
62
70
69
78
76
85
83
92
89
99
96
107
103
114
110
121
117
129
124
136
19
0.05
0.10
5
8
11
15
18
22
24
29
31
37
38
44
45
52
52
59
59
67
66
74
73
82
81
90
88
98
95
105
102
113
110
121
117
129
124
136
131
144
20
0.05
0.10
5
8
12
16
19
23
26
31
33
39
40
47
48
55
55
63
63
71
70
79
78
87
85
95
93
103
101
111
108
120
116
128
124
136
131
144
139
152
