6.2.1 INITIAL DATA AND STANDARDS COMPILATION
The PjM or designated Task Manager will assign a Preparer. The Preparer will complete initial sections of the Backfill Review and Approval Form by compiling the following applicable information:
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Specifying the relevant source sample numbers Identifying the planned use of the backfill
Identifying the relevant sections from applicable work plan and SAP The Preparer will then attach copies of the applicable reference sections and data including:
Sampling and Analysis Plan (SAP) sections/tables for chemistry SAP sections/tables/ for radiological constituents
Work plan sections for geotechnical analysis
Reports for relevant chemical, radiological, and/or geotechnical analyses
6.2.1 DATA EVALUATION
When initial section and the attachments are completed, the Preparer will provide the Backfill Review and Approval Form (with attachments) to the Project Chemist, RSO and Project Engineer for review (as applicable).
Each reviewer will review the data relevant to their area of expertise. Data will be strictly reviewed against the established criteria. For chemical data, analytes without
established criteria may be detected.
The purpose of these evaluations is to review the data and determine if any exceedance of the established acceptance criteria exists and/or identify and evaluate other detected analytes without established acceptance criteria.
In cases where a detected result was identified and an established acceptance criterion does not exist, the result will be provided to the RS for review and a determination of the significance of the result. The RS will specify the conclusion of their determination on the Backfill Review and Acceptance Form.
6.2.2 RESULTS DESIGNATION
There are three possible evaluation designations that can result from the evaluation of the data. They are:
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Class 1(1) Class 2(1) Class 3(2)
Chemical data evaluation
Analytes are below established criteria
AND
Analytes without established standards are not detected
Non-metal analytes are below established criteria
AND
Metal analytes are below HPAL(3)
AND
Detected analytes without established criteria are deemed “acceptable” by the RS
One or more non-metal analytes exceeds established criteria
OR
One or more metal analytes exceeds HPAL(3)
OR
Detected analytes without established criteria are deemed “unacceptable” by the RS
Radiological data evaluation
Results are below
established standards N/A One or more results exceeded established standards
Geotechnical data evaluation
Results are below
established standards N/A One or more results exceeded established standards (1) All chemical, data must meet the specified criteria in Class 1 or 2 for that class to apply
(2) Class 3 will apply if any one (or more) of the Class 3 criteria are met. (3) HPAL (Hunters Point Ambient Level)
Each reviewer will mark the appropriate evaluation designation box (“Class 1,” Class 2,” or “Class 3”) on the Backfill Review and Approval Form and sign and date the form. The basis for a proposed Class 2 or Class 3 designation will be documented in writing by the reviewer. Any additionally required information will be either attached or noted on the form.
6.2.3 REGULATORY SPECIALIST REVIEW
After the Project Chemist, RSO and Project Engineer have completed their evaluation, the RS will review the conclusions. The RS will concur in writing with any Class 2 designation and will explain the basis for concluding that a detected result for an analyte without established acceptance criterion should not be the cause to reject the backfill source.
The RS will also review the established acceptance criteria against which the data were evaluated to assess if any applicable standards changed after the work plan documents were prepared.
Any backfill source that is designated as Class 3 after this step will be rejected without further evaluation. This will be reported to the PjM (and designated Task Manager, if applicable), and the Backfill Review and Approval Form (including attachments) will be filed.
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6.2.4 QUALITY CONTROL REVIEW
Backfill source that is designated as Class 1 or 2 after the technical and RS reviews are completed and the findings are reported/documented, the PQCM will perform the
following:
Confirm that the correct acceptance criteria in the work plan(s) and SAP(s) were provided to the reviewers
Verify that frequency of samples collected and analysis performed are in accordance with the work plan(s) and SAP(s)
Perform a 10% random spot check of analytical data against the acceptance standards
Verify that all applicable reviews were completed and that the reviewers have signed off on the Backfill Review and Approval Form.
Any deviations or errors identified in this step will be reported to the PjM (and
designated Task Manager, if applicable). No backfill source will be approved until such time as identified deviations or errors are corrected.
6.2.5 APPROVAL
The PjM, or designated Task Manager has approval authority for backfill materials. At no time will the PjM approve import of material that is designated as Class 3. The approval/rejection for Class 1 and Class 2 materials will be designated on the form and will meet the following requirements:
1. For backfill sources that are designated as Class 1, the PjM may approve import of the material without further consultation. The PjM will sign the form and notify the CM to proceed with importing the backfill.
2. For backfill sources that are designated as Class 2, the PjM may recommend approval to the Department of the Navy (DON). PjM approval of these materials may only be done with the concurrence of the DON, as documented by a DON representative’s signature for acceptance on the Backfill Review and Approval Form, or in writing by e-mail or other acceptable means. Any DON approval aside from signing the form will be attached to the form. The PjM will notify the CM of the determination and acceptance or rejection of the materials.
6.2.6 SITE ACKNOWLEDGEMENT
The PjM, or designated Task Manager, will provide a copy of the signed Backfill Review and Approval Form to the CM. Prior importing the material, the CM will review the form and sign it to acknowledge that the material has been approved for the specific use identified on the form. Prior to using the material for any other application, the CM must
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inform the PjM, or designated Task Manager. The PjM or Task Manager, will be responsible for ensuring that the material is “re-approved” for the proposed application in accordance with this procedure prior to allowing the new use.