Historical Perspective of Performance-Based Measurement Systems (PBMS)
at Rocky Mountain Arsenal (RMA)
Mary K. Wolf, Chemist
Lockheed Martin Systems Support & Training Services, Rocky Mountain Arsenal Bldg. 130,
72nd and Quebec, Commerce City, CO 80022
Paper published in the Proceedings of WTQA '99
(15th Annual Waste Testing & Quality Assurance Symposium), pp. 3-8.
Compliance monitoring under a performance-based measurement systems (PBMS) is an on-going process at the Rocky Mountain Arsenal (RMA) in Commerce City, CO. RMA is a Superfund site where disposal of industrial and military chemical wastes in unlined basins over a period of approximately 10 years during and following World War II resulted in widespread contamination of soil and both surface and ground waters. The United States Army, along with Shell Oil Company and the U.S. Fish and Wildlife Service, are in the process of remediating RMA. The remediation effort involves the analysis of various matrices for a wide variety of analytes, some of which are unique to RMA, and standard analytical methodologies are either not available or are not adequate to fulfill regulatory requirements in certain instances. Hence the requirement to develop methods which are specific to the RMA and are performance-based.
In response to these site specific requirements and utilizing the Army Environmental Agency Guidelines, RMA developed the RMA Chemical Quality Assurance Plan (CQAP), which addresses all activities from planning to data verification related to the remediation of RMA. Compliance with the CQAP ensures that data produced are legally defensible, cost effective, and scientifically sound. A strict proficiency demonstration process for methods is prescribed by the CQAP to validate both standard and new or unproven methods.
Recently the Environmental Laboratory Advisory Board (ELAB) defined five critical elements for PBMS implementation. As recommended by ELAB, the data produced by laboratories should be legally defensible, cost effective, scientifically sound, demonstrate good performance criteria, and achieve regulatory compliance monitoring requirements. Historically, analogous criteria have been applied to the analytical work performed by laboratories supporting the RMA remediation effort. ELAB has also recommended essential elements for PBMS implementation. This presentation discusses the analytical program at RMA, under the Comprehensive Analytical Laboratory Services (CALS) contract (CALS contractor URS Greiner Woodward Clyde), in the context of these elements. Utilizing the performance criteria, regulatory development, and analytical methods specific to RMA, the remediation of RMA has progressed at an accelerated rate.
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