HomeMy WebLinkAboutMINUTES - 07091996 - D2 TO: BOARD OF SUPERVISORS
Contra
FROM. William B. Walker, M.D., Health Services Directov ,s Costa
v�q County
,.DATE: July 9, 1996 `'A........
SUBJECT: Keller Canyon Landfill and Change of Hazardous Waste Definition and Air
Quality Monitoring Program
SPECIFIC REQUEST(S)OR RECOMMENDATION(S)&BACKGROUND AND JUSTIFICATION
RECOMMENDED ACTION:
ACCEPT the Health Services Department staff reports on the DTSC hazardous waste
definition and the City of Pittsburg's proposed air quality monitoring program as it
relates to Keller Canyon Landfill.
BACKGROUND .INFORMATION:
The Board of Supervisors directed Health Services Department staff at the June 4,
1996 Board meeting to report on the change in hazardous waste definition and the
effects on types of wastes Keller Canyon Landfill would be able to accept. Health
Services Department staff was also directed to report on an air quality monitoring
program proposed by the City of Pittsburg.
CONTINUED ON ATTACHMENT: YES SIGNATURE:
RECOMMENDATION OF COUNTY ADMINISTRATOR RECOMMENDATION OF BOARD COMMITTEE
APPROVE OTHER
SIGNATURE(S):
ACTION OF BOARD ON ,7t i 1�z 90 1 9 9 h APPROVED AS RECOMMENDED X OTHER X
IT IS BY THE BOARD ORDERED that the above recommendation is APPROVED; and
the above -report is REFERRED to Browning Ferris Industries and the City of
Pittsburg for consideration as part of a good neighbor agreement.
VOTE OF SUPERVISORS
I HEREBY CERTIFY THAT THIS IS A TRUE
X UNANIMOUS(ABSENT AND CORRECT COPY OF AN ACTION TAKEN
AYES: NOES: AND ENTERED ON THE MINUTES OF THE BOARD
ABSENT: ABSTAIN: OF SUPERVISORS ON THE DATE SHOWN.
CC: County Administrator July 9 , 1996
Health Services Director ATTESTED
PHIL BATCHELOR,CLERK OF THE BOARD OF
Environmental Health (via HSD) SUPERV)SPRS AND COUNTY ADMINISTRATOR
City of Pittsburg
Browning Ferris Industries
v
M382 (10/88)
BY C,L I At i DEPUTY
Contra Costa County Item D-2.
The Board of Supervisors HEALTH SERVICES DEPARTMENT ENT OFFICE OF THE DIRECTOR
Jim Rogers, 1st District William B. Walker, M.D.
Jeff Smith,2nd District s Ec
Gayle Bishop,3rd District " o� Director& Health Officer
Mark DeSaulnier,4th District - -='' 20 Allen Street
Tom Torlakson,5th District f
.r�� Martinez,California 94553-3191
o: (510)370-5003
County Administrator x .off FAX(510)370-5099
Phil Batchelor
County Administrator coo'zz cP
July 3, 1996
To: Board of Supervisors
From: William Walker, MD, Director
Health Services Department
Re: Keller Canyon Landfill Hazardous Waste and Air Monitoring Issues
Attached are summary reports regarding Keller Canyon Landfill as requested by the
Board on June 4, 1996. The Health Services Department has been following both issues
for some time.
1. State Department of Toxic Substances Control (DTSQ proposal to change the way
hazardous waste is defined and classified:
As part of Governor Wilson's commitment to reduce and streamline regulation of
business and industry, DTSC initiated a large "regulatory structure update" project. One
part of it is focused on the issue of "California-only" hazardous wastes -- chemical wastes
that California regulates as hazardous, but the Federal government does not. The list of
"California-only" wastes was carefully developed. While this piece of the project is still
underway, the thrust of concept papers has been towards changing how wastes are
classified in a way that could allow the wastes California now considers hazardous to be
disposed of at a Class III waste site, i.e. at Keller. Now these wastes go primarily to
Class I (hazardous waste) sites.
I wrote a letter to DTSC Director Jesse Huff on April 1, 1996, advising him of our
concerns and our public health and oversight responsibilities regarding the landfill. I
urged that any changes in California's hazardous waste definitions, standards, and
regulations be made with protection of human health and the environment in the
forefront, and offered to provide the project with a local public health perspective. Mr.
Huff replied in a May 20, 1996 letter that the Advisory Group was filled, and that we
were invited to participate as a commentator, especially via the Internet.
2. Air Quality Monitoring Program at the landfill
In response to community concern, an air monitoring program has been designed for the
Merrithew Memorial Hospital&Health Centers - Public Health - Mental Health Substance Abuse - Environmental Health
Contra Costa Health Plan - Emergency Medical Services • Home Health Agency - Geriatrics
A-345 (1/96)
Board of Supervisors Page 2
July 3, 1996
landfill and reviewed by HSD staff. Last fall, we investigated community concerns about
lead exposure from landfill dust. Dr. Brunner offered our technical assistance for the air
monitoring project or related health issues to the City of Pittsburg at the last Healthy
Cities meeting, and reaffirmed the offer in a letter we received in April from David
Hobbs to Yolanda Lopez, Assistant City Manager, and reviewed the document on the
design of a Generic Ambient Air Monitoring Program.
The Health Services Department is committed to monitoring the Keller Landfill and
insuring that there is no adverse impact to public health from material disposed at that
site. We will certainly continue to monitor any change in the Department of Toxic
Substances Control (DTSC) regulations that may impact the kind of materials that may
be disposed of at Keller, and make any concerns we have about public health impacts
from regulation changes known to both DTSC and the city of Pittsburg. We believe also
that an appropriate ambient air monitoring program should be established at least to
determine baseline and periodic levels up and down wind from the site. Such an air
monitoring program would not need to be excessively expensive, but could either identify
public health problems or allay community concerns.
f t
Contra =s L'° Health Services Department
Costa _- ENVIRONMENTAL HEALTH DIVISION
IJI V �,11011 1111 Ward Street
County , �a __ 4° Martinez,California 94553-1352
J °os•• ~~ (510)646-2521
T'q cou'KT`;
DATE: June 21, 1996
TO; Board of Supervisors ,/� ,/�
FROM: William B. Walker, Health Services Director """ %1
By: Rebecca Ng, Senior Environmental Health Specialist
SUBJECT: Keller Canyon Landfill and the Hazardous Waste Definition
The Board of Supervisors directed Health Services staff at the June 4, 1996 Board meeting, to
report on issues raised by recent legislation regarding Keller Canyon Landfill. Assemblyman
Robert Campbell had authored a bill, AB 3329 prohibiting Keller Canyon Landfill (KCLF) from
accepting any hazardous waste. Apparently, the bill was written to prohibit KCLF from
accepting waste other than what they are now accepting since the Department of Toxic
Substances Control (DTSC) is contemplating a regulatory structure update which may include
a change to the waste classification,system. The following is a summary of the DTSC concept
on the waste classification system change as derived from the DTSC scoping paper and
conversations with Jim Carlisle, a member of the Waste Classification Team.
WASTE CLASSIFICATION SYSTEM
Currently, a waste classified as "hazardous" in California may not be hazardous under the
Federal Resources Conservation and Recovery Act (RCRA). One task under the proposed
Department of Toxic Substances regulatory structure update is to determine if the federal system
for identifying hazardous wastes under RCRA adequately protects public health or is a regulatory
program above and beyond the RCRA system needed to protect public health and the
environment in California. In order to make this determination, it is necessary to evaluate the
risks associated with wastes that escape the RCRA system. Another issue that parallels this
determination is that any system of hazardous waste identification that goes beyond federal
RCRA regulation must be justified on the basis of significant added environmental protection.
Towards this goal the Waste Classification Team has found it necessary to take a closer look at
California's regulatory system and the wastes that escape the RCRA systema Only after looking
at California's hazardous waste regulatory system, can a determination on the adequacy of
RCRA be made.
The Team will look at the present standards and their basis. Are the standards based scientificly
on risk? Is the risk adequately expressed in the soluble threshold limit concentrations (STLC)?
In the total threshold limit concentrations (TTLC)?
A373A (10/92)
Page 2 of 2
Board of Supervisors
KCLF, Hazardous Waste Definition
June 21, 1996
Team Consensus
The Waste Classification Team consensus seems to be that the present standards are not based
on scientific levels associated with risk and that the regulations should be changed to a risk based
system. The present system results in some materials being over-regulated and some under-
regulated. If risk-based calculations are applied, some materials will drop out of the hazardous
waste definition and some will be added. A more uniform approach would be taken related to
the risk imposed. In theory, regulation of hazardous waste could be more uniform if it were
based on the risk imposed by a material. A system may develop that would allow a closer
matching of the management of a material to the level of hazard of the material.
Changes
Upon completion of their study, DTSC may choose to retain a regulatory program above and
beyond the RCRA system and make changes to the regulations regarding waste classification.
DTSC could also determine that a regulatory program beyond RCRA is unnecessary. Any
changes to the regulations and waste classifications could change the management of some
materials and the volume of hazardous wastes in California. Changes would also affect the
volume of wastes that could be disposed of in non-hazardous landfills.
Time Line
DTSC has proposed a target date of November 1996 for a final concept paper on this issue.
Proposed regulations would follow shortly after in Spring 1997. The projected effective date
for revised regulations is 1998.
Effects on Keller Canyon Landfill
If DTSC finds that regulatory changes on waste classifications are necessary, the types of
materials classified as hazardous wastes as well as the volumes of wastes could change. The
changes would effect Keller Canyon Landfill in the same way.
Since the DTSC study has not yet been conducted, it is unknown what types of materials, if any,
would drop out or be added into the definition of hazardous waste. Therefore, it is unknown
if and how the composition of waste would change at Keller Canyon Landfill.
BNI:boshaz
Contra ="s L ° Health Services Department
Costa = - ENVIRONMENTAL HEALTH DIVISION
J o .r h„m 1111 Ward Street
County x� a--�'- a Martinez,California 94553-1352
—'66—K`� �~ (510)646-2521
DATE: June 21, 1996
TO: Board of Supervisors
FROM: William B. Walker, Health Services Director
By: Rebecca Ng, Senior Environmental Health Specialist
SUBJECT: Status of Air Quality Monitoring Program at Keller Canyon Landfill
The Board of Supervisors directed Health Services staff at the June 4, 1996 Board meeting, to report on the
establishment of an air quality monitoring program at Keller Canyon Landfill. The following are the staff
findings.
It is our understanding that the City of Pittsburg, Keller Canyon Landfill, Inc. and the County Growth
Management and Development Agency have discussed various issues including air quality monitoring at Keller
Canyon Landfill. Whether preemptive or in response to the discussions, the City of Pittsburg had Radian
Corporation prepare "Design of a Generic Ambient Air Monitoring Program". "Design" was prepared to
address Pittsburg's concern of air emissions from Keller Canyon Landfill. A copy of "Design of a Generic
Ambient Air Monitoring Program" is attached for your review.
"Design" has been reviewed by Health Services staff. It is a sound air monitoring program. However,
implementation of such a program at Keller Canyon Landfill (KCLF) would strictly be voluntary unless the
Bay Area Air Quality Management District (BAAQMD) chose to require implementation. The County
Environmental Health Division as the Local Enforcement Agency (LEA) for solid waste has no jurisdiction over
air emissions at landfills. Jurisdiction over air emissions at Keller Canyon Landfill lies strictly with the
BAAQMD. To our knowledge KCLF has been in substantial compliance with their BAAQMD operating
permits and the air quality regulations, therefore, BAAQMD has no intention of requiring implementation of
additional monitoring.
The division of jurisdiction is confirmed by Assembly Bill 1220 which the California Legislature passed in
1993. The intent of the Bill is to reduce or eliminate overlap, duplication and conflict among the California
Integrated Waste Management Board (CIWMB), the State Water Resources control Board (SWRCB), the Local
Enforcement Agencies (LEAs), and other agencies (such as the Air Board and Districts). AB 1220 was enacted
to avoid overregulation by the various agencies by streamlining the regulations.
Should a decision be made for implementation of Radian Corporation's recommended air quality monitoring
program at Keller Canyon Landfill, the LEA would be willing to provide further input.
BNLBOSair
A373A (10/92)
DESIGN OF A GENERIC
AMBIENT AIR MONITORING PROGRAM
BFI owns and operates the Keller Canyon Landfill (KCL), which is a Class 2 landfill that has
been in operation since 1992. The landfill is located adjacent to the city of Pittsburg, CA and
the nearest residences are approximately 2500 ft. downwind of the landfill boundary. There is
concern among the citizens and elected officials of the city that air emissions from the landfill
may adversely affect human health and the environment in the local area. The landfill accepts
a variety of waste materials, including soils contaminated with lead, chromium, and volatile
organic compounds (VOCs). There also is concern that additional types of contaminants, such
as asbestos, may be disposed of in the landfill at some future date. The landfill is projected to
have a 40-year operational lifetime.
A variety of monitoring and modeling approaches can be used to evaluate the impact of air
emissions on the local air quality. In general, monitoring approaches are preferred over
modeling approaches because the results of monitoring studies typically have better accuracy
and less uncertainty.
The evaluation of human exposure (due to inhalation) using a monitoring approach generally
involves measuring the concentrations of target analytes at the fenceline of the facility for
ground-level emission sources such as landfills. Additional ambient air monitoring (AAM)
may be conducted at selected receptor locations in the surrounding community (e.g., at nearby
schools) or on site, if there is public access. Data are collected at locations upwind and
downwind of the site. The difference in the concentrations measured downwind and upwind
of the site represent the contribution of the site emissions to the local air quality. The data are
compared with health-based action levels to determine if there is cause for concern at
downwind locations. If downwind concentrations exceed levels of concern, actions may need
to be taken to reduce pollutant emissions.
This paper identifies the key issues to be considered when designing an ambient air monitoring
network and provides some preliminary recommendations for the AAM network being
considered for the Keller Canyon Landfill.
There is no universal approach to conducting an AAM program that will satisfy the needs of
every situation. Instead, each study should be designed to match the specific program needs
and available resources. The design of an effective ambient air monitoring (AAM) program
generally consists of eight basic steps as shown in Table 1. The table also summarizes the
recommendations for an AAM study to be performed for the Keller Canyon Landfill.
Each of these design elements are described below.
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Define Program Goals - A set of clearly-defined goals should be established that meet with
consensus approval by the site operator, the applicable regulatory agencies, the surrounding
community, and any other interested parties. These goals must be able to be reasonably
accomplished within the limitations of available technical and financial resources.
For the KCL study, possible goals might include determining the long-term impacts on human
health and the environment from releases of particulate matter, heavy metals, and VOCs.
Target Compounds - After the goals of the air pathway assessment have been defined, a list
of analytes should be determined. Landfill sites often contain a complex mixture of
contaminants, and not every contaminant will pose a significant risk via the air pathway.
Factors that affect the magnitude of any risk posed by a particular contaminant include the
concentration of the compound in the waste or soil material, the compound's volatility or the
rate at which the compound is emitted to the air, and the toxicity or unit risk factor of the
particular compound. It often is not practical to monitor for every compound present in the
soil or ambient air, because of the limitations of available technical or financial resources. In
these cases, potential target compounds must be ranked in terms of predicted concentration
levels and applicable health-based action levels. The most significant compounds at the site
from a health risk standpoint might not necessarily be those present in the highest
concentrations in the soil or waste.
For the KCL study, possible target compounds might include particulate matter of less than 10
microns in diameter (PM10); total suspended particulates (TSP); heavy metals such as lead,
arsenic, chromium, cadmium, nickel, and zinc; and benzene and other representative VOCs.
Particles with an aerodynamic diameter of more than 10 microns generally cannot enter the
human body because they are filtered out by the body's defense mechanism. Therefore PM,o
provides a measure of human health exposure due to inhalation, whereas TSP provides a
measure of total environmental exposure. Also, TSP monitoring provides information about
the potential deposition of large particles that can ultimately enter human exposure pathways
such as ingestion.
Define Data Quality Objectives (DQOs) - These are statements of the level of uncertainty a
decision maker is willing to accept where making decisions based on the air monitoring data.
DQOs differ from data quality indicators such as measurement precision and accuracy in that
they express the limits of the overall uncertainty of a project's results in terms of the
probability and consequences of making a wrong decision (rather than as the limits of certainty
about specific measurements). The DQOs that are established influence the choice of sampling
and analytical methods selected for performing the measurements. Data quality objectives are
expressed in terms of acceptable probabilities that the measurement results will lead to
incorrect decisions. Two general types of incorrect decisions can occur: false positive errors
and false negative errors. False positive errors result in decisions to take action to reduce
pollutant exposures when the true concentrations are actually below levels of concern. False
negative errors result in not taking action when, in fact, concentration levels are above those
thought to pose a serious risk. While false negative errors are usually more detrimental
because of the health risks that might unknowingly be imposed on the public, false positive
4
errors are also counterproductive because of the money and time wasted taking unnecessary
action. Data quality objectives, therefore, place limits on the acceptable probabilities that
either a false positive or false negative error will be made. The acceptable probability that a
measurement result will lead to an incorrect decision should depend on the seriousness of the
consequences of the incorrect decision. In addition to quantitative limits of data quality, data
quality objectives must also be defined qualitatively in terms of representativeness and
comparability.
For the KCL study, data quality objectives should be established that minimize the likelihood
of false positive and false negative errors without unduly raising the cost of the study. This
can be accomplished by using standard sampling approaches that have been validated and
optimized in previous studies.
Sampling Periods and Frequencies - The temporal resolution of the measurement domain is
defined by the sampling period and frequency. Sampling period refers to the length of time to
which each measurement value is performed (e.g., 8-hours, 24-hours, etc.). The sampling
frequency is the number of sampling periods conducted within a given time interval (e.g.,
daily, one every third day, etc.). Longer sampling periods are usually performed using
integrated methods. Integrated sampling may be performed continuously (i.e., back-to-back
sample collection), or at intermittent, discrete intervals.
Sampling periods must be chosen for comparability with relevant action levels or standards.
For example, if the measurement data are to be compared with a 8-hour health standard, a 8-hr
sampling period is normally required. Compliance with long-term action levels usually is
determined using a series of 24-hour sampling periods. In some cases, sampling periods also
may depend on the amount of sample volume needed to achieve acceptable detection limits.
For instance, a one-hour sampling period will yield a detection limit twice as low as the same
technique operating with the same flow rate for 30 minutes.
The required frequency of sample collection depends primarily on: (1) the temporal variability
of emission rates with respect to the temporal scale of the action level, (2) the variability of
meteorological and other factors that might affect pollutant dispersion, (3) the level of
confidence needed for determining mean or maximum downwind concentrations, and (4) the
level of available funding. For determining compliance with long-term action levels, a
minimum sampling frequency of once every sixth or twelfth day is normally required.
However, if the measured concentration levels are near levels of concern, a greater frequency
of collection, perhaps daily, will be required.
For the KCL study, it is recommended that PM10 and TSP be monitored every 6th day. Over
the course of a year, this provides about 60 sampling episodes, which is an adequately-sized
data set to evaluate the air quality. Sampling every 6th day results in samples being collected
during every day of the week, so any bias is avoided due to differences in weekday versus
weekend activities in and around the facility. The filters should be analyzed for heavy metals.
To minimize analytical costs, portions of the filters can be composited and a quarterly average
value determined. If this average approaches or exceeds the action levels, the individual filters
5
can be analyzed to determine the day to day variability in contaminant levels. For VOCs,
sampling should be performed every 6th or every 12th day, depending on the budget available
for VOC.analysis. The overall duration of the monitoring program should be at least one to
two years, and the need for subsequent monitoring can be determined based on the initial
results of the study.
Number and Location of Sampling Sites - The spatial resolution of the measurement domain
is defined by the number and locations of the sampling sites. Factors that influence the
required number and locations of monitoring sites are: (1) the locations of potential on-site
emission sources; (2) the locations of topographic features that affect the dispersion and
transport of site emissions; (3) the variability of local wind patterns; (4) the locations of
sensitive receptors such as schools, hospitals, and concerned citizens; (5) the level of
confidence needed to ensure that the maximum concentration levels are observed; and (4) the
level of available funding.
Typically, programs designed for determining long-term concentration levels (e.g., annual or
lifetime exposures) will require relatively few monitoring locations because the long-term
prevailing wind directions are usually more predictable, and sampling sites therefore can be
more accurately situated for measuring significant long-term effects. For example, the
dispersion modeling of source emissions, using climatological wind data as input, can be
performed to determine the most appropriate sampling locations (i.e., areas of maximum or
significant effects). In many cases, constraints on placing samplers can be encountered
because of wind flow obstructions caused by nearby buildings, trees, hills, or other obstacles.
Other constraints might be related to security, the accessibility of electrical power, as well as
the proximity to roadways or other pollution sources that might affect the representativeness of
the sample for measuring the waste site's effects on air quality.
For the KCL study, a minimum of 1 upwind and 3 downwind monitoring locations is
recommended to ensure that sufficient data are collected to determine the maximum, or worst-
case, impacts on local air quality.
Selecting Appropriate Monitoring Methods - There is no single monitoring method that
applies equally to every situation. Factors that might influence the selection of appropriate
monitoring methods to suit particular data needs are: (1) target compounds, (2) data
turnaround time, (3) detection limits, (4) data quality, (5) temporal resolution, (6) spatial
resolution, and (7) cost. Standard EPA sampling approaches exist for most target analytes.
Standard high-volume air sampling methods are widely used for PM10 and TSP sampling and it
is recommended that these methods be employed in the KCL study. Large volumes of air are
drawn though a filter for a set time period and the mass of the captured particles is measured.
The PM,o samplers have a selection device that allows only a certain size fraction of particles
to pass through the collection filter. For both PM,o and TSP sampling, the filters can be sent
to an off-site laboratory to determine the concentration of heavy metals on the filters. The
metals typically are analyzed by atomic absorption spectroscopy (AAS) or inductively coupled
6
plasma atomic emission spectroscopy (ICP-AES). Lead and arsenic typically are analyzed by
graphite furnace atomic absorption spectroscopy (GFAAS).
A variety of methods exist for sampling and analyzing benzene and other VOCs. It is
recommended that sample collection be performed using evacuated stainless steel canisters or
sorbent tubes containing charcoal or Tenax. Analysis is performed using gas chromatography
(GC) or gas chromatography with mass spectroscopy (GC/MS).
For the KCL study, it is recommended that standard high-volume sampling methods be used
for PM10 and TSP, as specified in Guidance for Ambient Air Monitoringat t Superfund Sites,
EPA-451/R-93-007, May 1993. Any of the analytical methods outlined above could be used
for analysis of the heavy metals on the filter catches. VOCs should be collected in canisters or
sorbents and analyzed by GC or GC/MS. The best choice for collection method will depend
on the number and type of VOCs on the target analyte list.
Meteorological Monitoring - Meteorological (met) measurements will often be required along
with ambient air quality data when assessing the risks associated with waste site air pathway
emissions. At a minimum, wind direction and wind speed should be measured so that the
direction of air pathway migration from the site can be assessed during all times that ambient
air quality data are collected. Other meteorological parameters that are relevant to the air
pathway assessment because of their effects on emission rates or dispersion of pollutants are:
temperature, precipitation, relative humidity, barometric pressure, and sigma theta (standard
deviation of the wind direction).
Meteorological measurements must be representative of the conditions at the source and at the
locations of the sampling stations. In areas of uniform terrain, one meteorological monitoring
station may be sufficient to represent the entire source and sampling domain. In some cases,
meteorological data from an existing, off-site monitoring station (e.g., at a local airport) may
serve this purpose. However, off-site data from other sources may not always be obtained
with the same concerns for quality control and data management as data collected on-site.
The accuracies of meteorological sensors should be checked periodically during the course of a
long-term measurement program (e.g., every three months or every six months) as part of the
quality assurance audit program.
Quality Assurance (QA) and Quality Control (QC) - A comprehensive QA/QC program is
needed to ensure that the AAM data are sufficient to meet the overall goals of the measurement
program. The cornerstone of any QA/QC program are preparation and adherence to a quality
assurance project plan (QAPP), also referred to as a test plant. This provides detailed
information and instructions on how the monitoring is to be performed.
It is recommended that the AAM program include preparation of a QAPP prior to the start of
any monitoring. Also, as part of the QA program, performance and system audits should be
performed periodically to determine if the QA goals and objectives are being met.
Performance audits are used to quantitatively evaluate the accuracy of the data being
7
e 3 .
generated. System audits address the capabilities of the measurement system for generating
data that are representative and comparable.
Data Management - The goal of ambient air monitoring (AAM) programs at Superfund sites
is to generate accurate,,verifiable reports on ambient concentrations of air pollutants in the area
of concern. These data are usually applied to evaluations of the risk to on-site personnel and
the surrounding community. The data used in these evaluations must be defensible and must
meet the criteria established in the,Quality Assurance Project Plan (QAPP) or Test Plan for
accuracy, precision, completeness, and representativeness. Therefore, establishing sound data
management procedures and objectives early in the program can be critical to its
success.
Long-term AAM programs may generate tremendous amounts of data. In most cases, AAM
data are reviewed regularly (e.g., daily) and compared with action levels to see if any
exceedances have occurred. The AAM data are then stored in hard-copy form, entered into
databases, or summarized in word processing software. Frequently, problems arise when, at
some future date, someone needs to review or use the data. In too many cases, the data record
is incomplete, the data are stored in a variety of formats, or they have not been consistently
validated. It may then be expensive or impossible to reconstruct a complete set of validated
data; therefore, a data management program should be established before any long-term AAM
program begins.
The key elements of data management for AAM programs include: data management
planning, data acquisition, data reduction, data validation, and data reporting.
Data summaries should be prepared monthly or quarterly to document the on-going study.
More detailed, interpretive reports should be prepared annually to present and analyze the data
trends and the overall findings of the AAM program.
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