SEPA
United States
Environmental Protection
Agency
Office uf So'-'J Waste and
Emergency Response
Washington DC 20460
EPA 530-SW-88 028 (/
OSWER Directive 9902 3
June 1 988
RCRA Corrective
Action Plan
Interim Final
-------
EPA/530-SW-88-028
OSWER Directive 9902.3
June 1988
RCRA CORRECTIVE ACTION PLAN
(Interim Final)
Office of Solid Waste
Office of Waste Programs Enforcement
U.S. Environmental Protects
Region 5, Library (n.-P.!)
77 West Jackson Ban1' , ',
Chicago, IL 60604-0'.,
-------
NOTICE
This document has been reviewed in accordance with
U.S. Environmental Protection Agency policy and
approved for publication. Mention of trade names
or commercial products does not constitute endorse-
ment or recommendation for use.
11
-------
Table of Contents
Page
Foreword v
Acknowledgments vii
Introduction 1
RCRA Facility Investigation 4
Task I: Description of Current Conditions 4
Task II: Pre-lnvestigation Evaluation of Corrective
Measure Technologies 6
Task III: RFI Workplan Requirements 6
Task IV: Facility Investigation 10
Task V: Investigation Analysis 14
Task VI: Laboratory and Bench-Scale Studies 15
Task VII- Reports 15
Corrective Measure Study 17
Task VIII: Identification and Development of the Corrective
Measure Alternative or Alternatives 17
Task IX: Evaluation of the Corrective Measure
Alternative or Alternatives ... 18
Task X: Justification and Recommendation of the
Corrective Measure or Measures 21
Task XI: Reports 21
Corrective Measure Implementation 23
Task XII: Corrective Measure Implementation Program Plan 23
Task XIII: Corrective Measure Design 24
Task XIV: Corrective Measure Construction 26
Task XV: Reports 27
-------
Foreword
This document was issued by Gene A. Lucero, Director, Office of Waste Programs Enforcement,
and Marcia Williams, Director, Office of Solid Waste, on November 14, 1986, as the RCRA
Corrective Action Plan Guidance (Interim Final), OSWER Directive 9902.3.
The RCRA Corrective Action Plan (CAP) will assist you in development of Corrective Action
Orders (§3008(h)) and corrective action requirements in permit applications and permits
(§3004(u)&(v)). The purpose of the CAP is to aid Regions and States in determining and directing
the specific work the owner/operator or respondent must perform, as part of a complete corrective
action program. The CAP should be used as a technical framework during the development of
Corrective Action Orders and corrective action permit requirements.
The CAP provides a framework for the development of a site-specific schedule of compliance to
be included in a permit or a compliance schedule in a Corrective Action Order. It does so by
laying out scopes of work for the three essential phases of a complete corrective action program.
These three phases and their objectives are as follows.
Phase I- RCRA Facility Investigation (RFI) - to evaluate thoroughly the nature and extent
of the release of hazardous waste and hazardous constituents and to gather
necessary data to support the Corrective Measure Study.
Phase II- Corrective Measures Study (CMS) - to develop and evaluate a corrective
measure alternative or alternatives and to recommend the final corrective
measure or measures.
Phase III- Corrective Measures Implementation (CMI) - to design, construct, operate,
maintain and monitor the performance of the corrective measure or measures
selected.
The CAP provides an overall model for a corrective action compliance schedule. The scopes of
work contained in the CAP should not be considered "boilerplate," but rather as a "menu" of
possible activities to be required on a site-specific basis. Only those tasks and reports necessary
and appropriate to the specific situation should be required of the Owner/Operator [Respondent].
We also encourage the Regions to make available to the Owner/Operator [Respondent] existing
model plans that are relevant to RCRA activities. For example, the "Occupational Safety and
Health Guidance Manual for Hazardous Waste Site Activities Operating Safety Guidelines"
contains a model that can be used for the Health and Safety Plan outlined in the CAP.
A RCRA Facility Assessment (RFA) will have been conducted at the facilities that are to receive
permits, and for some facilities which are issued §3008(h) Orders. The results of the RFA should
be used as the basis for focusing the RCRA Facility Investigation (RFI) compliance schedules for
individual sites, and should provide the necessary data for completion of the "background
information" components of the CAP
Finally, we feel it is necessary to stress the importance of site-specific technical detail in the
development of Corrective Action orders and corrective action permit requirements. Each facility
has unique characteristics and circumstances affecting it that need to be incorporated into any
requirements for corrective action. Without this up-front detail, many owner/operators or
respondent will provide us with submittals which lack the technical detail necessary to perform a
thorough corrective measure program. In addition to providing a detailed scope of work, the
Agency should also propose a site-specific time-frame for completion of the work. Enforcement
of permit conditions or requests for relief in an Order is always easier when very specific detail is
-------
included. Without a detailed schedule of compliance in a permit or a compliance schedule in a
Corrective Action Order, we can expect untimeliness in submittals and actions.
It was also intended that the model scopes of work in the CAP foster timely, concise submissions
by Owner/Operators. Therefore, when modifying these scopes Of work with site-specific
information, the scopes of work should only require that information which is necessary for the
subject facility, thereby minimizing the number and length of Owner/Operator submissions and our
review time.
VI
-------
Acknowledgments
This document was prepared by Mark Gilbertson, Anna Duncan and Peter Ornstein of the RCRA
Enforcement Division in the Office of Waste Programs Enforcement. A special thanks to Tony
Baney and Lloyd Guerci for their management support and the Office of Solid Waste and various
regional staff for their technical review and comments.
VII
-------
Introduction
The objective of a Corrective Action Program at a
hazardous waste management facility is to evaluate the
nature and extent of the release of hazardous waste or
constituents; to evaluate facility characteristics; and to
identify, develop, and implement the appropriate
corrective measure or measures adequate to protect
human health and the environment The following bullets
identify components necessary to assure a complete
corrective action program. It should be recognized that
the detail required in each of these steps will vary
depending on the facilty and its complexity.
• Locate the source(s) of the release(s) of
contaminants (e g. regulated units, solid waste
management units, and other source areas)
• Characterize the nature and extent of contamination
both within the facility boundaries and migrating from
the facility This would include defining the pathways
and methods of migration of the hazardous waste or
constituents, including the media, extent, direction,
speed, complicating factors influencing movement,
concentration profiles, etc.
• Identify areas and populations threatened by
releases from the facility
• Determine short and long term, present and potential
threats of releases from the facility on human health
and/or the environment
• Identify and implement a interim measure or
measures to abate the further spread of
contaminants, control the source of contamination, or
otherwise control the releases themselves
• Evaluate the overall integrity of containment structure
and activities at the site intended for long-term
containment
• Identify, develop, and implement a corrective
measure or measures to prevent and remediate
releases of hazardous waste or constituents from the
facility
• Design a program to monitor the implementation,
maintenance and performance of any interim or final
corrective measure(s) to ensure that human health
and the environment are being protected
The purpose of the Corrective Action Plan (CAP)is to aid
Regions and States in determining and directing the
specific work the owner/operator or respondent must
perform, as part of a complete corrective action program.
The Corrective Action Plan is a document specifically
intended to assist Regions and States in the development
of Corrective Action Orders (§3008(h)) and corrective
action requirements in permit applications and permits
(§3004(u)&(v)). It does so by laying out scopes of work for
the three essential phases of a complete corrective action
program which can be used to formulate facility-specific
scopes of work for an order or permit These three
phases and their objectives are as follows
Phase I- RCRA Facility Investigation (RFI) - to
evaluate thoroughly the nature and
extent of the release of hazardous waste
and hazardous constituents and to
gather necessary data to support the
Corrective Measure Study
Phase II- Corrective Measures Study (CMS) - to
develop and evaluate a corrective
measure alternative or alternatives and
to recommend the final corrective
measure or measures.
Phase III- Corrective Measures Implementation
(CMI) - to design, construct, operate,
maintain and monitor the performance
of the corrective measure or measures
selected.
Users of the CAP should understand that it is designed to
identify actions that facility owner/operator or respondent
must take as part of a corrective action program. It does
not identify the steps that remain the responsibility of the
regulatory agency. To clarify this interaction between the
facility owner/operator or respondent, Figure 1 represents
the flowchart of owner'operator or respondent submittals
and Agency actions for the three phases of the CAP
The CAP scopes of work should not be considered
"boilerplate." The scopes of work in the CAP are models
and must be modified, enhanced or sections deleted
based on site-specific situations. Information generated
from investigations such as RCRA Facility Assessments
(RFAs) should be used to tailor the scope of work to
address facility-specific situations.The following are
some examples where site-specifics require
modification to the CAP model scopes of work.
• If the contamination problem at a facility is merely a
small soil contamination problem, then the CAP
should be scaled down accordingly
• In complicated contamination situations, the Health
and Safety Plan and Community Relations Plans may
need to be comprehensive However, in simple
contamination situations, these plans may be very
brief
• If site-specifics conditions require more detail than
what has been scoped out in any particular section of
the CAP, then the CAP should be enhanced
accordingly.
• If there is sufficient information on a site to preclude
an air release, then it would not be necessary to
require the owner/operator or respondent to perform
an air contamination characterization. The air
-------
Figure 1. RCRA Corrective Action Plan.
Owner/Operator
Respondent
— o
o *-
CD CD
LL O)
< £
CC 0>
Permit
3008(h)
Order
^
RFI Workplan
•*r \
-~^__^
"*
Approval &
Oversight
f
RFI Report
I
Approval &
Cleanup
Requirements
Established
J
Corrective Measure
Study
Oversight
> £
-
o|M
0 «=
I
CMS Report
\
Approval &
Select
Corrective
Measure(s)
Public
Participation
1 EDO! or
Permit
Modification
D C
CO O
to z,
^ C
OJ d
t E
o —
CJ
3008{h)
Order
Permit
(Modified)
X
CMI Workplan
^
V
Design &
Construction
Maintenance
Monitoring
' ^
-* -—
Approval &
Oversight
Approval &
Oversight
contamination characterization work under the RFI
(Task IV, C, 4) should be deleted.
If interim measures are underway, scheduled or
contemplated at a facility, then the Interim Measures
section under the RFI (Task I, C) should be modified
to specifically reference the interim measures.
If possible, the CAP should focus the owner/operator
or respondent on specific solid waste management
units and other areas of interest, as well as known
waste management activity areas (i.e., waste
recycling units, wastewater treatment tanks).
If only one corrective measure alternative is
appropriate for a given situation, and it would not be
-------
necessary to require the owner/operator or respond-
ent to further investigate the possibility of other
corrective measure alternatives, then the scopes of
work (citations) would be modified to reflect this
situation.
Finally, it is necessary to stress the importance of site-
specific technical detail in the development of Corrective
Action Orders and corrective action permit requirements.
When the scope of work is specific to the facility, it is
easier to enforce. Each facility has unique characteristics
and circumstances affecting it that need to be
incorporated into any requirements for corrective action.
Without this many owner/operators or respondents will
provide us with submittals which lack the necessary
information to perform a corrective measure program. In
addition to providing an adequate scope of work, the
Agency should also propose a site-specific time-frame
for completion of the work.
-------
Scope of Work for a RCRA Facility Investigation (RFI)
at
[Specify Facility Name]
Purpose
The purpose of this RCRA Facility Investigation is to
determine the nature and extent of releases of hazardous
waste or constituents from regulated units, solid waste
management units, and other source areas at the facility
and to gather all necessary data to support the Corrective
Measures Study. The Owner/Operator [Respondent] shall
furnish all personnel, materials, and services necessary
for, or incidental to, performing the RCRA remedial
investigation at [specify facility name].
[NOTE: This scope of work is intended to foster timely,
concise submissions by Owner/Operators To achieve
this goal, it is important when using the model scope of
work to consider facility specific conditions. This scope of
work should be modified as necessary to require only that
information necessary to complete the RCRA Facility
Investigation.]
Scope
The RCRA Facility Investigation consists of seven tasks:
Task I: Description of Current Conditions
A. Facility Background
B. Nature and Extent of Contamination
C. Implementation of Interim Measures
Task II: Pre-lnvestigation Evaluation of Corrective
Measure Technologies
Task III: RFI Workplan Requirements
A. Project Management Plan
B. Data Collection Quality Assurance Plan
C. Data Management Plan
D. Health and Safety Plan
E. Community Relations Plan
Task IV: Facility Investigation
A. Environmental Setting
B. Source Characterization
C. Contamination Characterization
D. Potential Receptor Identification
Task V: Investigation Analysis
A. Data Analysis
B. Protection Standards
Task VI: Laboratory and Bench-Scale Studies
Task VII: Reports
A. Preliminary and Workplan
B. Progress
C. Draft and Final
Task I: Description of Current Conditions
The Owner/Operator [Respondent] shall submit for U.S.
EPA approval a report providing the background
information pertinent to the facility, contamination and
interim measures as set forth below. The data gathered
during any previous investigations or inspections and
other relevant data shall be included.
A. Facility Background
The Owner/Operator's [Respondent's] report shall
summarize the regional location, pertinent boundary
features, general facility physiography,
hydrogeology, and historical use of the facility for the
treatment, storage or disposal of solid and hazardous
waste. The Owner/Operator's [Respondent's] report
shall include:
1. Map(s) depicting the following:
a. General geographic location;
b. Property lines, with the owners of all
adjacent property clearly indicated;
c. Topography and surface drainage (with a
contour interval of [number] feet and a scale
of 1 inch = 100 feet) depicting all water-
ways, wetlands, floodplains, water features,
drainage patterns, and surface-water
containment areas;
-------
d. All tanks, buildings, utilities, paved areas,
easements, rights-of-way, and other
features;
e. All solid or hazardous waste treatment,
storage or disposal areas active after
November 19, 1980;
f. All known past solid or hazardous waste
treatment, storage or disposal areas
regardless of whether they were active on
November 19, 1980;
g. All known past and present product and
waste underground tanks or piping;
h. Surrounding land uses (residential,
commercial, agricultural, recreational); and
i. The location of all production and ground-
water monitoring wells. These wells shall be
clearly labeled and ground and top of casing
elevations and construction details included
(these elevations and details may be
included as an attachment).
All maps shall be consistent with the requirements
set forth in 40 CFR §270.14 and be of sufficient detail
and accuracy to locate and report all current and
future work performed at the site;
2. A history and description of ownership and
operation, solid and hazardous waste generation,
treatment, storage and disposal activities at the
facility;
3. Approximate dates or periods of past product
and waste spills, identification of the materials
spilled, the amount spilled, the location where
spilled, and a description of the response actions
conducted (local, state, or federal response units
or private parties), including any inspection
reports or technical reports generated as a result
of the response; and
4. A summary of past permits requested and/or
received, any enforcement actions and their
subsequent responses and a list of documents
and studies prepared for the facility.
8. Nature and Extent of Contamination
The Owner/Operator [Respondent] shall prepare and
submit for U.S. EPA approval a preliminary report
describing the existing information on the nature and
extent of contamination.
1. The Owner/Operator's [Respondent's] report
shall summarize all possible source areas of
contamination. This, at a minimum, should
include all regulated units, solid waste
management units, spill areas, and other
suspected source areas of contamination. For
each area, the Owner/Operator [Respondent]
shall identify the following:
a. Location of unit/area (which shall be
depicted on a facility map);
b. Quantities of solid and hazardous wastes;
c. Hazardous waste or constituents, to the
extent known; and
d. Identification of areas where additional
information is necessary.
2. The Owner/Operator [Respondent] shall prepare
an assessment and description of the existing
degree and extent of contamination. This should
include:
a. Available monitoring data and qualitative
information on locations and levels of
contamination at the facility;
b. All potential migration pathways including
information on geology, pedology,
hydrogeology, physiography, hydrology,
water quality, meterology, and air quality;
and
c. The potential impact(s) on human health and
the environment, including demography,
ground-water and surface-water use, and
land use.
C. Implementation of Interim Measures
The Owner/Operator [Respondent's] report shall
document interim measures which were or are being
undertaken at the facility. This shall include:
1. Objectives of the interim measures: how the
measure is mitigating a potential threat to human
health and the environment and/or is consistent
with and integrated into any long term solution at
the facility;
2. Design, construction, operation, and main-
tenance requirements;
3. Schedules for design, construction and
monitoring; and
-------
4. Schedule for progress reports.
Task II: Pre-lnvestigation Evaluation of
Corrective Measure Technologies
Prior to starting the facility investigation, the
Owner/Operator [Respondent] shall submit to EPA a
report that identifies the potential corrective measure
technologies that may be used on-site or off-site for
the containment, treatment, remediation, and/or disposal
of contamination. This report shall also identify any field
data that needs to be collected in the facility investigation
to facilitate the evaluation and selection of the final
corrective measure or measures (e.g., compatibility of
waste and construction materials, information to evaluate
effectiveness, treatability of wastes, etc.).
Task III: RFI Workplan Requirements
The Owner/Operator [Respondent] shall prepare a RCRA
Facility Investigation (RFI) Workplan. This RFI Workplan
shall include the development of several plans, which
shall be prepared concurrently. During the RCRA Facility
Investigation, it may be necessary to revise the RFI
Workplan to increase or decrease the detail of information
collected to accommodate the facility specific situation.
The RFI Workplan includes the following:
A. Project Management Plan
The Owner/Operator [Respondent] shall prepare a
Project Management Plan which will include a
discussion of the technical approach, schedules,
budget, and personnel. The Project Management
Plan will also include a description of qualifications of
personnel performing or directing the RFI, including
contractor personnel. This plan shall also document
the overall management approach to the RCRA
Facility Investigation.
B. Data Collection Quality Assurance Plan
The Owner/Operator [Respondent] shall prepare a
plan to document all monitoring procedures:
sampling, field measurements and sample analysis
performed during the investigation to characterize the
environmental setting, source, and contamination, so
as to ensure that all information, data and resulting
decisions are technically sound, statistically valid,
and properly documented.
1. Data Collection Strategy
The strategy section of the Data Collection
Quality Assurance Plan shall include but not be
limited to the following:
a. Description of the intended uses for the
data, and the necessary level of precision
and accuracy for these intended uses;
b. Description of methods and procedures to
be used to assess the precision, accuracy
and completeness of the measurement data;
c. Description of the rationale used to assure
that the data accurately and precisely
represent a characteristic of a population,
parameter variations at a sampling point, a
process condition or an environmental
condition. Examples of factors which shall
be considered and discussed include:
i) Environmental conditions at the time of
sampling;
Number of sampling points;
Representativeness of selected media;
and
iv) Representativeness of selected analyt-
ical parameters.
d. Description of the measures to be taken to
assure that the following data sets can be
compared to each other:
i) RFI data generated by the
Owner/Operator over some time period,
ii) RFI data generated by an outside
laboratory or consultant versus data
generated by the Owner/Operator;
iii) Data generated by separate consultants
or laboratories; and
iv) Data generated by an outside consultant
or laboratory over some time period.
e. Details relating to the schedule and
information to be provided in quality
assurance reports. The reports should
include but not be limited to:
i) Periodic assessment of measurement
data accuracy, precision, and
completeness;
ii)
iii)
iv)
Results of performance audits;
Results of system audits;
Significant quality assurance problems
and recommended solutions; and
2.
v)
Sampling
Resolutions of previously stated
problems.
-------
The Sampling section of the Data Collection
Quality Assurance Plan shall discuss:
a. Selecting appropriate sampling locations,
depths, etc.;
b. Providing a statistically sufficient number of
sampling sites;
c. Measuring all necessary ancillary data;
d. Determining conditions under which
sampling should be conducted;
e. Determining which media are to be sampled
(e.g., ground water, air, soil, sediment, etc.);
f. Determining which parameters are to be
measured and where;
g. Selecting the frequency of sampling and
length of sampling period;
h. Selecting the types of sample (e.g.,
composites vs. grabs) and number of
samples to be collected;
i. Measures to be taken to prevent
contamination if the sampling equipment
and cross contamination between sampling
points;
j. Documenting field sampling operations and
procedures, including:
i) Documentation of procedures for
preparation of reagents or supplies
which become an integral part of the
sample (e.g., filters, and adsorbing
reagents);
ii) Procedures and forms for recording the
exact location and specific
considerations associated with sample
acquisition;
iii) Documentation of specific sample
preservation method;
iv) Calibration of field devices;
v) Collection of replicate samples;
vi) Submission of field-biased blanks,
where appropriate;
vii) Potential interferences present at the
facility;
viii) Construction materials and techniques,
associated with monitoring wells and
piezometers;
ix) Field equipment listing and sample
containers;
x) Sampling order; and
xi) Decontamination procedures.
k. Selecting appropriate sample containers;
I. Sample preservation; and
m. Chain-of-custody, including:
i) Standardized field tracking reporting
forms to establish sample custody in the
field prior to and during shipment; and
ii) Pre-prepared sample labels containing
all information necessary for effective
sample tracking.
3. Field Measurements
The Field Measurements section of the Data
Collection Quality Assurance Plan shall discuss:
a. Selecting appropriate field measurement
locations, depths, etc.;
b. Providing a statistically sufficient number of
field measurements;
c. Measuring all necessary ancillary data;
d. Determining conditions under which field
measurements should be conducted;
e. Determining which media are to be
addresssed by appropriate field
measurements (e.g., ground water, air, soil,
sediment, etc.);
f. Determining which parameters are to be
measured and where;
g. Selecting the frequency of field
measurements and length of field
measurements period; and
h. Documenting field measurement operations
and procedures, including:
i) Procedures and forms for recording raw
data and the exact location, time, and
facility-specific considerations
associated with the data acquisition;
ii) Calibration of field devices;
iii) Collection of replicate measurements;
iv) Submission of field-biased blanks,
where appropriate;
-------
v) Potential interferences present at the
facility;
vi) Construction materials and techniques
associated with monitoring wells and
piezometers use to collect field data;
vii) Field equipment listing;
viii) Order in which field measurements were
made; and
ix) Decontamination procedures.
4. Sample Analysis
The Sample Analysis section of the Data
Collection Quality Assurance Plan shall specify
the following:
a. Chain-of-custody procedures, including:
i) dentification of a responsible party to
act as sample custodian at the
laboratory facility authorized to sign for
incoming field samples, obtain
documents of shipment, and verify the
data entered onto the sample custody
records;
ii) Provision for a laboratory sample
custody log consisting of serially
numbered standard lab-tracking report
sheets; and
iii) Specification of laboratory sample
custody procedures for sample
handling, storage, and dispersement for
analysis.
b. Sample storage procedures and storage
times;
c. Sample preparation methods;
d. Analytical procedures, including:
i) Scope and application of the procedure;
ii) Sample matrix;
iii) Potential interferences;
iv) Precision and accuracy of the
methodology; and
v) Method detection limits.
e. Calibration procedures and frequency;
f Data reduction, validation and reporting;
g. Internal quality control checks, laboratory
performance and systems audits and
frequency, including:
i) Method blank(s);
ii) Laboratory control sample(s),
iii) Calibration check sample(s);
iv) Replicate sample(s);
v) Matrix-spiked sample(s);
vi) "Blind" quality control sample(s);
vii) Control charts;
viii) Surrogate samples;
ix) Zero and span gases; and
x) Reagent quality control checks.
[A performance audit will be conducted by
U.S. EPA on the laboratories selected by the
Owner/Operator [Respondent]. This audit
must be completed and approved prior to
the facility investigation.]
h. Preventive maintenance procedures and
schedules;
i. Corrective action (for laboratory problems);
and
j. Turnaround time.
C. Data Management Plan
The Owner/Operator [Respondent] shall develop and
initiate a Data Management Plan to document and
track investigation data and results. This plan shall
identify and set up data documentation materials and
procedures, project file requirements, and project-
related progress reporting procedures and
documents. The plan shall also provide the format to
be used to present the raw data and conclusions of
the investigation.
1. Data Record
The data record shall include the following:
a. Unique sample or field measurement code;
b. Sampling or field measurement location and
sample or measurement type;
c. Sampling or field measurement raw data;
d. Laboratory analysis ID number;
-------
e. Property or component measured; and
f. Result of analysis (e.g., concentration).
2. Tabular Displays
The following data shall be presented in tabular
displays:
a. Unsorted (raw) data;
b. Results for each medium, or for each con-
stituent monitored;
c. Data reduction for statistical analysis;
d. Sorting of data by potential stratification
factors (e.g., location, soil layer, topog-
raphy); and
e. Summary data.
3. Graphical Displays
The following data shall be presented in
graphical formats (e.g., bar graphs, line graphs,
area or plan maps, isopleth plots, cross-
sectional plots or transects, three dimensional
graphs, etc.):
a. Display sampling location and sampling grid;
b. Indicate boundaries of sampling area, and
areas where more data are required;
c. Displays levels of contamination at each
sampling location;
d. Display geographical extent of contam-
ination;
e. Display contamination levels, averages, and
maxima;
f. Illustrate changes in concentration in relation
to distance from the source, time, depth or
other parameters; and
g. Indicate features affecting intramedia
transport and show potential receptors.
D. Health and Safety Plan
The Owner/Operator [Respondent] shall prepare a
facility Health and Safety Plan.
1. Major elements of the Health and Safety Plan
shall include:
a. Facility description including availability of
resources such as roads, water supply,
electricity and telephone service;
b. Description of the known hazards and
evaluate the risks associated with the
incident and with each activity conducted;
c. A Listing of key personnel and alternates
responsible for site safety, responses
operations, and for protection of public
health;
d. Delineation of work area;
e. Description of levels of protection to be worn
by personnel in work area;
f. Establishment of procedures to control site
access;
g. Description of decontamination procedures
for personnel and equipment;
h. Establishment of site emergency pro-
cedures;
i. Emergency medical care for injuries and
toxicological problems;
j. Description of requirements for an
environmental surveillance program;
k. Routine and special training required for
responders; and
I. Establishment of procedures for protecting
workers from weather-related problems.
2. The Facility Health and Safety Plan shall be
consistent with:
a. NIOSH Occupational Safety and Health
Guidance Manual for Hazardous Waste Site
Activities (1985);
b. EPA Order 1440.1 - Respiratory Protection;
c. EPA Order 1440.3 - Health and Safety
Requirements for Employees engaged in
Field Activities;
d. Facility Contingency Plan;
e. EPA Standard Operating Safety Guide
(1984);
f. OSHA regulations particularly in 29 CFR
1910 and 1926;
g. State and local regulations; and
h. Other EPA guidance as provided.
-------
£. Community Relations Plan
The Owner/Operator [Respondent] shall prepare a
plan, for the dissemination of information to the
public regarding investigation activities and results.
Task IV: Facility Investigation
The Owner/Operator [Respondent] shall conduct those
investigations necessary to: characterize the facility
(Environmental Setting); define the source (Source
Characterization); define the degree and extent of
contamination (Contamination Characterization); and
identify actual or potential receptors.
The investigations should result in data of adequate
technical quality to support the development and
evaluation of the corrective measure alternative or
alternatives during the Corrective Measures Study.
The site investigation activities shall follow the plans set
forth in Task III. All sampling and analyses shall be
conducted in accordance with the Data Collection Quality
Assurance Plan. All sampling locations shall be
documented in a log and identified on a detailed site
map.
A. Environmental Setting
The Owner/Operator [Respondent] shall collect
information to supplement and verify existing
information on the environmental setting at the
facility. The Owner/Operator [Respondent] shall
characterize the following:
1. Hydrogeology
The Owner/Operator [Respondent] shall conduct
a program to evaluate hydrogeologic conditions
at the facility. This program shall provide the
following information:
a. A description of the regional and facility
specific geologic and hydrogeologic
characteristics affecting ground-water flow
beneath the facility, including:
i) Regional and facility specific
stratigraphy: description of strata
including strike and dip, identification of
stratigraphic contacts;
ii) Structural geology: description of local
and regional structural features (e.g.,
folding, faulting, tilting, jointing, etc.);
iii) Depositional history;
iv) Identification and characterization of
areas and amounts of recharge and
discharge;
v) Regional and facility specific ground-
water flow patterns; and
vi) Characterize seasonal variations in the
ground-water flow regime.
b. An analysis of any topographic features that
might influence the ground-water flow
system. (Note: Stereographic analysis of
aerial photographs may aid in this analysis).
c. Based on field data, test, and cores, a
representative and accurate classification
and description of the hydrogeologic units
which may be part of the migration
pathways at the facility (i.e., the aquifers and
any intervening saturated and unsaturated
units), including:
i) Hydraulic conductivity and porosity
(total and effective);
ii) Lithology, grain size, sorting, degree of
cementation;
iii) An interpretation of hydraulic
interconnections between saturated
zones; and
iv) The attenuation capacity and
mechanisms of the natural earth
materials (e.g., ion exchange capacity,
organic carbon content, mineral content
etc.).
d. Based on field studies and cores, structural
geology and hydrogeologic cross sections
showing the extent (depth, thickness, lateral
extent) of hydrogeologic units which may be
part of the migration pathways identifying:
i) Sand and gravel deposits in
unconsolidated deposits;
ii) Zones of fracturing or channeling in
consolidated or unconsolidated
deposits;
iii) Zones of higher permeability or low
permeability that might direct and
restrict the flow of contaminants;
iv) The uppermost aquifer: geologic
formation, group of formations, or part of
a formation capable of yielding a
significant amount of ground water to
wells or springs; and
v) Water-bearing zones above the first
confining layer that may serve as a
pathway for contaminant migration
including perched zones of saturation.
e. Based on data obtained from ground-water
monitoring wells and piezometers installed
10
-------
upgradient and downgradient of the potential
contaminant source, a representative
description of water level or fluid pressure
monitoring including:
i) water level contour and/or poten-
tiometric maps;
ii) Hydrologic cross sections showing
vertical gradients;
iii) The flow system, including the vertical
and horizontal components of flow; and
iv) Any temporal changes in hydraulic
gradients, for example, due to tidal or
seasonal influences.
f. A description of man-made influences that
may affect the hydrogeology of the site,
identifying:
i) Active and inactive local water-supply
and production wells with an
approximate schedule of pumping; and
ii) Man-made hydraulic structures
(pipelines, french drains, ditches,
unlined ponds, septic tanks, NPDES
outfalls, retention areas, etc.).
2. Soils
The Owner/Operator [Respondent] shall conduct
a program to characterize the soil and rock units
above the water table in the vicinity of the
contaminant release(s). Such characterization
shall include but not be limited to, the following
information:
a. SCS soil classification;
b. Surface soil distribution;
c. Soil profile, including ASTM classification of
soils;
d. Transects of soil stratigraphy;
e. Hydraulic conductivity (saturated and
unsaturated);
f. Relative permeability;
g. Bulk density;
h. Porosity;
i. Soil sorptive capacity;
j. Cation exchange capacity (CEC);
k. Soil organic content;
I. Soil pH;
m. Particle size distribution;
n. Depth of water table;
o. Moisture content;
p. Effect of stratification on unsaturated flow;
q. Infiltration
r. Evapotranspiration;
s. Storage capacity;
t. Vertical flow rate; and
u. Mineral content.
3. Surface Water and Sediment
The Owner/Operator [Respondent] shall conduct a
program to characterize the surface-water bodies in
the vicinity of the facility. Such characterization shall
include, but not be limited to, the following activities
and information:
a. Description of the temporal and permanent
surface-water bodies including:
i) For lakes and estuaries: location,
elevation, surface area, inflow, outflow,
depth, temperature stratification, and
volume;
ii) For impoundments: location, elevation,
surface area, depth, volume, freeboard,
and purpose of impoundment;
iii) For streams, ditches, drains, swamps
and channels: location, elevation, flow,
velocity, depth, width, seasonal
fluctuations, and flooding tendencies
(i.e., 100 year event);
iv) Drainage patterns; and
v) Evapotranspiration.
b. Description of the chemistry of the natural
surface water and sediments. This includes
determining the pH, total dissolved solids,
total suspended solids, biological oxygen
demand, alkalinity, conductivity, dissolved
oxygen profiles, nutrients (NHs, NO$~
/NO2~, PC>4'3), chemical oxygen
demand, total organic carbon, specific
contaminant concentrations, etc.
c. Description of sediment characteristics in-
cluding:
i) Deposition area;
ii) Thickness profile; and
11
-------
iii) Physical and chemical parameters (e.g.,
grain size, density, organic carbon
content, ion exchange capacity, pH,
etc.).
4. Air
The Owner/Operator [Respondent] shall provide
information characterizing the climate in the
vicinity of the facility. Such information shall
include, but not be limited to:
a. A description of the following parameters:
i) Annual and monthly rainfall averages;
ii) Monthly temperature averages and
extremes;
iii) Wind speed and direction;
iv) Relative humidity/dew point;
v) Atmospheric pressure;
vi) Evaporation data;
vii) Development of inversions; and
viii) Climate extremes that have been known
to occur in the vicinity of the facility,
including frequency of occurrence.
b. A description of topographic and manmade
features which affect air flow and emission
patterns, including:
i) Ridges, hills or mountain areas;
ii) Canyons or valleys;
iii) Surface water bodies (e.g., rivers, lakes,
bays, etc.);
iv) Wind breaks and forests; and
v) Buildings.
B. Source Characterization
The Owner/Operator [Respondent] shall collect
analytical data to completely characterize the wastes
and the areas where wastes have been placed,
collected or removed including: type; quantity;
physical form; disposition (containment or nature of
deposits); and facility characteristics affecting release
(e.g., facility security, and engineered barriers). This
shall include quantification of the following specific
characteristics, at each source area:
1. Unit/Disposal Area Characteristics:
a. Location of unit/disposal area;
b. Type of unit/disposal area;
c. Design features;
d. Operating practices (past and present);
e. Period of operation;
f. Age of unit/disposal area;
g. General physical conditions; and
h. Method used to close the unit/disposal area.
2. Waste Characteristics:
a. Type of waste placed in the unit;
i) Hazardous classification (e.g., flam-
mable, reactive, corrosive, oxidizing or
reducing agent);
ii) Quantity; and
iii) Chemical composition.
b. Physical and chemical characteristics;
i) Physical form (solid, liquid, gas);
ii) Physical description (e.g., powder, oily
sludge);
iii) Temperature;
iv) pH;
v) General chemical class (e.g., acid, base,
solvent);
vi) Molecular weight
vii) Density;
viii) Boiling point;
ix) Viscosity;
x) Solubility in water;
xi) Cohesiveness of the waste;
xii) Vapor pressure; and
xiii) Flash point.
c. Migration and dispersal characteristics of the
waste;
i) Sorption;
ii) Biodegradability, bioconcentration bio-
transformation;
iii) Photodegradation rates;
iv) Hydrolysis rates; and
v) Chemical transformations.
12
-------
The Owner/Operator [Respondent] shall document
the procedures used in making the above
determinations.
C. Contamination Characterization
The Owner/Operator [Respondent] shall collect
analytical data on ground-water, soils, surface
water, sediment, and subsurface gas contamination
in the vicinity of the facility. This data shall be
sufficient to define the extent, origin, direction, and
rate of movement of contaminant plumes. Data shall
include time and location of sampling, media
sampled, concentrations found, and conditions during
sampling, and the identity of the individuals
performing the sampling and analysis. The
Owner/Operator [Respondent] shall address the
following types of contamination at the facility:
1. Ground-water Contamination
The Owner/Operator [Respondent] shall conduct a
Ground-water Investigation to characterize any
plumes of contamination at the facility. This
investigation shall at a minimum provide the following
information:
a. A description of the horizontal and vertical
extent of any immiscible or dissolved
plume(s) originating from the facility;
b. The horizontal and vertical direction of
contamination movement;
c. The velocity of contaminant movement;
d. The horizontal and vertical concentration
profiles of Appendix VIII constituents in the
plume(s);
e. An evaluation of factors influencing the
plume movement, and
f. An extrapolation of future contaminant
movement.
The Owner/Operator [Respondent] shall
document the procedures used in making the
above determinations (e.g., well design, well
construction, geophysics, modeling, etc.).
2. Soil Contamination
The Owner/Operator [Respondent] shall conduct
an investigation to characterize the
contamination of the soil and rock units above
the water table in the vicinity of the contaminant
release. The investigation shall include the
following information:
a. A description of the vertical and horizontal
extent of contamination.
b. A description of contaminant and soil
chemical properties within the contaminant
source area and plume. This includes
contaminant solubility, speciation,
adsorption, leachability, exchange capacity,
biodegradability, hydrolysis, photolysis,
oxidation and other factors that might affect
contaminant migration and transformation.
c. Specific contaminant concentrations.
d. The velocity and direction of contaminant
movement.
e. An extrapolation of future contaminant
movement.
The Owner/Operator [Respondent] shall
document the procedures used in making the
above determinations.
3. Surface-Water and Sediment Contamination
The Owner/Operator [Respondent] shall conduct
a surface-water investigation to characterize
contamination in surface-water bodies resulting
from contaminant releases at the facility.
The investigation shall include, but not be limited
to, the following information:
a. A description of the horizontal and vertical
extent of any immisicible or dissolved
plume(s) originating from the facility, and the
extent of contamination in underlying
sediments;
b. The horizontal and vertical direction of
contaminant movement;
c. The contaminant velocity;
d. An evaluation of the physical, biological and
chemical factors influencing contaminant
movement;
e. An extrapolation of future contaminant
movement; and
f. A description of the chemistry of the
contaminated surface waters and sediments.
This includes determining the pH, total
dissolved solids, specific contaminant
concentrations, etc.
The Owner/Operator [Respondent] shall
document the procedures used in making the
above determinations.
13
-------
4. Air Contamination
The Owner/Operator [Respondent] shall conduct
an investigation to characterize the particulate
and gaseous contaminants released into the
atmosphere. This investigation shall provide the
following information:
a. A description of the horizontal and vertical
direction and velocity of contaminant
movement;
b. The rate and amount of the release; and
c. The chemical and physical composition of
the contaminants(s) released, including
horizontal and vertical concentration profiles.
The Owner/Operator [Respondent] shall
document the procedures used in making the
above determinations.
5. Subsurface Gas Contamination
The Owner/Operator [Respondent] shall conduct
an investigation to characterize subsurface gases
emitted from buried hazardous waste and
hazardous constituents in the ground water. This
investigation shall include the following
information:
a. A description of the horizontal and vertical
extent of subsurface gases mitigation;
b. The chemical composition of the gases
being emitted;
c. The rate, amount, and density of the gases
being emitted; and
d. Horizontal and vertical concentration profiles
of the subsurface gases emitted.
The Owner/Operator [Respondent] shall
document the procedures used in making the
above determinations.
D. Potential Receptors
The Owner/Operator [Respondent] shall collect data
describing the human populations and environmental
systems that are susceptible to contaminant
exposure from the facility. Chemical analysis of
biological samples may be needed. Data on
observable effects in ecosystems may also be
obtained. The following characteristics shall be
identified:
1. Local uses and possible future uses of ground
water:
a. Type of use (e.g., drinking water source:
municipal or residential, agricultural,
domestic/non-potable, and industrial); and
b. Location of groundwater users including
wells and discharge areas.
2. Local uses and possible future uses of surface
waters draining the facility:
a. Domestic and municipal (e.g., potable and
lawn/gardening watering);
b. Recreational (e.g., swimming, fishing);
c. Agricultural;
d. Industrial; and
e. Environmental (e.g., fish and wildlife
propagation).
3. Human use of or access to the facility and
adjacent lands, including but not limited to:
a. Recreation;
b. Hunting;
c. Residential;
d. Commercial;
e. Zoning; and
f. Relationship between population locations
and prevailing wind direction.
4. A description of the biota in surface water bodies
on, adjacent to, or affected by the facility.
5. A description of the ecology overlying and
adjacent to the facility.
6. A demographic profile of the people who use or
have access to the facility and adjacent land,
including, but not limited to: age; sex; and
sensitive subgroups.
7. A description of any endangered or threatened
species near the facility.
Task V: Investigation Analysis
The Owner/Operator [Respondent] shall prepare an
analysis and summary of all facility investigations and
their results. The objective of this task shall be to ensure
that the investigation data are sufficient in quality (e.g.,
quality assurance procedures have been followed) and
quantity to describe the nature and extent of
contamination, potential threat to human health and/or the
environment, and to support the Corrective Measures
Study.
14
-------
A. Data Analysis
The Owner/Operator [Respondent] shall analyze all
facility investigation data outlined in Task IV and
prepare a report on the type and extent of
contamination at the facility including sources and
migration pathways. The report shall describe the
extent of contamination (qualitative/quantitative) in
relation to background levels indicative for the area.
B. Protection Standards [where applicable]
1. Ground-water Protection Standards
For regulated units the Owner/Operator
[Respondent] shall provide information to
support the Agency's selection/development of
Ground-water Protection Standards for all of the
Appendix VIII constituents found in the ground-
water during the Facility Investigation (Task IV).
The Groundwater Protection Standards shall
consist of:
i) For any constituents listed in Table 1 of
40 CFR 264.94, the respective value
given in that table (MCL) if the
background level of the constituent is
below the given in Table 1; or
ii) The background level of that constituent
in the groundwater; or
a.
iii) A U.S. EPA approved
Concentration Limit (ACL).
Alternate
b. Information to support the Agency's
subsequent selection of Alternate
Concentration Limits (ACLs) shall be
developed by the Owner/Operator
[Respondent] in accordance with U.S. EPA
guidance. For any proposed ACLs the
Owner/Operator [Respondent] shall include
a justification based upon the criteria set
forth in 40 CFR 264.94(b).
c. Within [insert number] days of receipt of any
proposed ACLs, the U.S. EPA shall notify
the Owner/Operator [Respondent] in writing
of approval, disapproval or modifications, the
U.S. EPA shall specify in writing the
reason(s) for any disapproval or
modification.
d. Within [insert number] days of receipt of the
U.S. EPA's notification or disapproval of any
proposed ACL, the Owner/Operator
[Respondent] shall amend and submit
revisions to the U.S. EPA.
2. Other Relevant Protection Standards
The Owner/Operator [Respondent] shall identify
all relevant and applicable standards for the
protection of human health and the environment
(e.g., National Ambient Air Quality Standards,
Federally-approved state water quality
standards, etc.).
Task VI: Laboratory and Bench-Scale Studies
The Owner/Operator [Respondent] shall conduct
laboratory and/or bench scale studies to determine the
applicability of a corrective measure technology or
technologies to facility conditions. The Owner/Operator
[Respondent] shall analyze the technologies, based on
literature review, vendor contracts, and past experience to
determine the testing requirements.
The Owner/Operator [Respondent] shall develop a testing
plan identifying the type(s) and goal(s) of the study(ies),
the level of effort needed, and the procedures to be used
for data management and interpretation.
Upon completion of the testing, the Owner/Operator
[Respondent] shall evaluate the testing results to assess
the technology or technologies with respect to the site-
specific questions identified in the test plan.
The Owner/Operator [Respondent] shall prepare a report
summarizing the testing program and its results, both
positive and negative.
Task VII: Reports
A. Preliminary and Workplan
The Owner/Operator [Respondent] shall submit to the
EPA reports on Tasks I and II when it submits the
RCRA Facility Investigation Workplan (Task III).
B. Progress
The Owner/Operator [Respondent] shall at a
minimum provide the EPA with signed, [monthly,
bimonthly] progress reports containing:
15
-------
1. A description and estimate of the percentage of
the RFI completed;
2. Summaries of all findings;
3. Summaries of all changes made in the RFI
during the reporting period;
4. Summaries of all contacts with representative of
the local community, public interest groups or
State government during the reporting period;
5. Summaries of all problems or potential problems
encountered during the reporting period;
6. Actions being taken to rectify problems;
7. Changes in personnel during the reporting
period;
8. Projected work for the next reporting period; and
9. Copies of daily reports, inspection reports,
laboratory/monitoring data, etc.
C. Draft and Final
Upon EPA approval, the Owner/Operator
[Respondent] shall prepare a RCRA Facility
Investigation Report to present Tasks IV-V. The
RCRA Facility Investigation Report shall be
developed in draft form for U.S. EPA review. The
RCRA Facility Investigation Report shall be
developed in final format incorporating comments
received on the Draft RCRA Facility Investigation
Report. Task VI shall be submitted as a separate
report when the Final RCRA Facility Investigation
Report is submitted.
[Number] copies of all reports, including the Task I
report, Task II report, Task III workplan, Task VI
report and both the Draft and Final RCRA Facility
Investigation Reports (Task IV-V) shall be provided
by the Owner/Operator [Respondent] to U.S. EPA.
[THE FOLLOWING FACILITY SUBMISSION SUMMARY
MAY BE PLACED IN THE BODY OF THE ORDER OR
PERMIT AND REMOVED FROM THE SCOPE OF
WORK. NOT ALL OF THE ITEMS LISTED BELOW MAY
BE REQUIRED AT EACH FACILITY.]
Facility Submission Summary
A summary of the information reporting requirements
contained in the RCRA Facility Investigation Scope of
Work is presented below:
Facility Submission
Description of Current
Situation
(Task I)
Pre-lnvestigation
Evaluation of
Corrective Measure
Technologies
(Task II)
RFI Workplan
(Task III)
Draft RFI Report
(Tasks IV and V)
Final RFI Report
(Tasks IV and V)
Laboratory and Bench-
Scale Studies
(Task VI)
Progress Reports on
Tasks I through VI
Due Date
[ DATE ]
DATE]
[ DATE]
[ NUMBER ] days after
RFI Workplan Approval
[ NUMBER ] days after
EPA comment on Draft
RFI Report
Concurrent with Final RFI
Report
[ MONTHLY, BI-
MONTHLY ]
16
-------
Scope of Work for a Corrective Measure Study
at
[Specify Facility Name]
Purpose
The purpose of this Corrective Measure Study (CMS) is
to develop and evaluate the corrective action alternative
or alternatives and to recommend the corrective measure
or measures to be taken at [specify facility name]. The
Owner/Operator [Respondent] will furnish the personnel,
materials, and services necessary to prepare the
corrective measure study, except as otherwise specified.
[Note. This scope of work is intended to foster timely,
concise submissions by Owner/Operators. To achieve
this goal, it is important when using the model scope of
work to consider facility specific conditions. This scope
should be modified as necessary to require only that
information necessary to complete the Corrective Mea-
sure Study.]
Scope
The Corrective Measure Study consists of four tasks:
Task VIII Identification and Development of the
Corrective Measure Alternative or
Alternatives
A. Description of Current Situation
B. Establishment of Corrective Action
Objectives
C. Screening of Corrective Measures
Technologies
D. Identification of the Corrective
Measure Alternative or Alternatives
Task IX: Evaluation of the Corrective Measure
Alternative or Alternatives
A. Techmcal/Environmental/Human
Health/Institutional
B. Cost Estimate
Task X: Justification and Recommendation of
the Corrective Measure or Measures
A. Technical
B. Environmental
C. Human Health
Task XI: Reports
A. Progress
B. Draft
C. Final
TASK VIM: Identification and Development of the
Corrective Measure Alternative or Alternatives
Based on the results of the RCRA Facility Investigation
and consideration of the identified Preliminary Corrective
Measure Technologies (Task II), the Owner/Operator
[Respondent] shall identify, screen and develop the
alternative or alternatives for removal, containment,
treatment and/or other remediation of the contamination
based on the objectives established for the corrective
action.
A. Description of Current Situation
The Owner/Operator [Respondent] shall submit an
update to the information describing the current
situation at the facility and the known nature and
extent of the contamination as documented by the
RCRA Facility Investigation Report. The
Owner/Operator [Respondent] shall provide an
update to information presented in Task I of the RFI
to the Agency regarding previous response activities
and any interim measures which have or are being
implemented at the facility. The Owner/Operator
[Respondent] shall also make a facility-specific
statement of the purpose for the response, based on
the results of the RCRA Facility Investigation. The
statement of purpose should identify the actual or
potential exposure pathways that should be
addressed by corrective measures.
B. Establishment of Corrective Action Objectives
The Owner/Operator [Respondent], in conjunction
with the U.S. EPA, shall establish site specific
objectives for the corrective action. These objectives
shall be based on public health and environmental
criteria, information gathered during the RCRA
Facility Investigation, EPA guidance, and the
requirements of any applicable Federal statutes. At a
minimum, all corrective actions concerning ground-
water releases from regulated units must be
17
-------
consistent with, and as stringent as, those required
under 40 CFR 264.100
C. Screening of Corrective Measure
Technologies
The Owner/Operator [Respondent] shall review the
results of the RCRA Facility Investigation and
reassess the technologies specified in the Task II
report as approved by EPA and identify additional
technologies which are applicable at the facility. The
Owner/Operator [Respondent] shall screen the
preliminary corrective measure technologies
identified in Task II of the RCRA Facility Investigation
and any supplemental technologies to eliminate
those that may prove infeasible to implement, that
rely on technologies unlikely to perform satisfactorily
or reliably, or that do not achieve the corrective
measure objective within a reasonable time period.
This screening process focuses on eliminating those
technologies which have severe limitations for a
given set of waste and site-specific conditions The
screening step may also eliminate technologies
based on inherent technology limitations Site, waste,
and technology characteristics which are used to
screen inapplicable technologies are described in
more detail below
1. Site Characteristics
Site data should be reviewed to identify
conditions that may limit or promote the use of
certain technologies. Technologies whose use is
clearly precluded by site characteristics should
be eliminated from further consideration,
2 Waste Characteristics
Identification of waste characteristics that limit
the effectiveness or feasibility of technologies is
an important part of the screening process.
Technologies clearly limited by these waste
characteristics should be eliminated from
consideration Waste characteristics particularly
affect the feasibility of m-situ methods, direct
treatment methods, and land disposal (on/off-
site); and
3. Technology Limitations
During the screening process, the level of
technology development, performance record,
and inherent construction, operation, and
maintenance problems should be identified for
each technology considered. Technologies that
are unreliable, perform poorly, or are not fully
demonstrated may be eliminated in the
screening process For example, certain
treatment methods have been developed to a
point where they can be implemented in the field
without extensive technology transfer or
development.
D. Identification of the Corrective Measure
Alternative or Alternatives
The Owner/Operator [Respondent] shall develop the
corrective measure alternative or alternatives based
on the corrective action objectives and analysis of
Preliminary Corrective Measure Technologies, as
presented in Task II of the RCRA Facility
Investigation and as supplemented following the
preparation of the RFI Report The Owner/Operator
[Respondent] shall rely on engineering practice to
determine which of the previously identified
technologies appear most suitable for the site.
Technologies can be combined to form the overall
corrective action alternative or alternatives. The
alternative or alternatives developed should represent
a workable number of option(s) that each appear to
adequately address all site problems and corrective
action objectives. Each alternative may consist of an
individual technology or a combination of
technologies. The Owner/Operator [Respondent]
shall document the reasons for excluding
technologies, identified in Task II, as supplemented
in the development of the alternative or alternatives.
Task IX: Evaluation of the Corrective Measure
Alternative or Alternatives
The Owner/Operator [Respondent] shall describe each
corrective measure alternative that passes through the
Initial Screening in Task VIII and evaluate each corrective
measure alternative and it's components The evaluation
shall be based on technical, environmental, human health
and institutional concerns. The Owner/Operator
[Respondent] shall also develop cost estimates of each
corrective measure.
A. Technical/Environmental/Human
Health/Institutional
The Owner/Operator [Respondent] shall provide a
description of each corrective measure alternative
which includes but is not limited to the following:
preliminary process flow sheets; preliminary sizing
and type of construction for buildings and structures;
and rough quantities of utilities required. The
Owner/Operator [Respondent] shall evaluate each
alternative in the four following areas:
1. Technical;
The Owner/Operator [Respondent] shall evaluate
each corrective measure alternative based on
performance, reliability, implementability and
safety.
a. The Owner/Operator [Respondent] shall
evaluate performance based on the
effectiveness and useful life of the corrective
measure:
i) Effectiveness shall be evaluated in
terms of the ability to perform intended
18
-------
functions, such as containment,
diversion, removal, destruction, or
treatment. The effectiveness of each
corrective measure shall be determined
either through design specifications or
by performance evaluation. Any specific
waste or site characteristics which could
potentially impede effectiveness shall
be considered. The evaluation should
also consider the effectiveness of
combinations of technologies; and
ii) Useful life is defined as the length of
time the level of effectiveness can be
maintained. Most corrective measure
technologies, with the exception of
destruction, deteriorate with time. Often,
deterioration can be slowed through
proper system operation and
maintenance, but the technology
eventually may require replacement.
Each corrective measure shall be
evaluated in terms of the projected
service lives of its component
technologies. Resource availability in
the future life of the technology, as well
as appropriateness of the technologies,
must be considered in estimating the
useful life of the project.
b. The Owner/Operator [Respondent] shall
provide information on the reliability of each
corrective measure including their operation
and maintenance requirements and their
demonstrated reliability:
i) Operation and maintenance
requirements include the frequency and
complexity of necessary operation and
maintenance. Technologies requiring
frequent or complex operation and
maintenance activities should be
regarded as less reliable than
technologies requiring little or
straightforward operation and main-
tenance. The availability of labor and
materials to meet these requirements
shall also be considered; and
ii) Demonstrated and expected reliability is
a way of measuring the risk and effect
of failure. The Owner/Operator
[Respondent] should evaluate whether
the technologies have been used
effectively under analogous conditions;
whether the combination of technologies
have been used together effectively;
whether failure of any one technology
has an immediate impact on receptors;
and whether the corrective measure has
the flexibility to deal with uncontrollable
changes at the site.
c. The Owner/Operator [Respondent] shall
describe the implementability of each
corrective measure including the relative
ease of installation (constructability) and the
time required to achieve a given level of
response:
i) Constructability is determined by
conditions both internal and external to
the facility conditions and include such
items as location of underground
utilities, depth to water table,
heterogeneity of subsurface materials,
and location of the facility (i.e., remote
location vs. a congested urban area).
The Owner/Operator [Respondent] shall
evaluate what measures can be taken to
facilitate construction under these
conditions. External factors which affect
implementation include the need for
special permits or agreements,
equipment availability, and the location
of suitable off-site treatment or
disposal facilities; and
ii) Time has two components that shall be
addressed: the time it takes to
implement a corrective measure and the
time it takes to actually see beneficial
results. Beneficial results are defined as
the reduction of contaminants to some
acceptable, pre-established level.
d. The Owner/Operator [Respondent] shall
evaluate each corrective measure alternative
with regard to safety. This evaluation shall
include threats to the safety of nearby
communities and environments as well as
those to workers during implementation.
Factors to consider are fire, explosion, and
exposure to hazardous substances.
2. Environmental;
The Owner/Operator [Respondent] shall perform
an Environmental Assessment for each
alternative. The Environmental Assessment shall
focus on the facility conditions and pathways of
contamination actually addressed by each
alternative. The Environmental Assessment for
each alternative will include, at a minimum, an
evaluation of: the short- and long-term
beneficial and adverse effects of the response
alternative; any adverse effects on
environmentally sensitive areas; and an analysis
of measures to mitigate adverse effects.
19
-------
3. Human Health; and
The Owner/Operator [Respondent] shall assess
each alternative in terms of the extent of which it
mitigates short- and long-term potential
exposure to any residual contamination and
protects human health both during and after
implementation of the corrective measure. The
assessment will describe the levels and
characterizations of contaminants on-site,
potential exposure routes, and potentially
affected population. Each alternative will be
evaluated to determine the level of exposure to
contaminants and the reduction over time. For
management of mitigation measures, the relative
reduction of impact will be determined by
comparing residual levels of each alternative with
existing criteria, standards, or guidelines
acceptable to EPA.
4. Institutional;
The Owner/Operator [Respondent] shall assess
relevant institutional needs for each alternative.
Specifically, the effects of Federal, state and
local environmental and public health standards,
regulations, guidance, advisories, ordinances, or
community relations on the design, operation,
and timing of each alternative
B. Cost Estimate
The Owner/Operator [Respondent] shall develop an
estimate of the cost of each corrective measure
alternative (and for each phase or segment of the
alternative). The cost estimate shall include both
capital and operation and maintenance costs.
1. Capital costs consist of direct (construction) and
indirect (nonconstruction and overhead) costs.
a. Direct capital costs include:
i) Construction costs: Costs of materials,
labor (including fringe benefits and
worker's compensation), and equipment
required to install the corrective
measure;
ii) Equipment costs: Costs of treatment,
containment, disposal and/or service
equipment necessary to implement the
action; these materials remain until the
corrective action is complete;
iii) Land and site-development costs:
Expenses associated with purchase of
land and development of existing
property; and
iv) Buildings and services costs: Costs of
process and nonprocess buildings,
utility connections, purchased services,
and disposal costs.
b. Indirect capital costs include:
i) Engineering expenses: Costs of
administration, design, construction
supervision, drafting, and testing of
corrective measure alternatives;
ii) Legal fees and license or permit costs:
Administrative and technical costs
necessary to obtain licenses and
permits for installation and operation;
iii) Startup and shakedown costs: Costs
incurred during corrective measure
startup; and
iv) Contingency allowances: Funds to cover
costs resulting from unforeseen
circumstances, such as adverse weather
conditions, strikes, and inadequate
facility characterization.
2. Operation and maintenance costs are post-
construction costs necessary to ensure
continued effectiveness of a corrective measure.
The Owner/Operator [Respondent] shall consider
the following operation and maintenance cost
components:
a. Operating labor costs: Wages, salaries,
training, overhead, and fringe benefits
associated with the labor needed for post-
construction operations;
b. Maintenance materials and labor costs:
Costs for labor, parts, and other resources
required for routine maintenance of facilities
and equipment;
c. Auxiliary materials and energy: Costs of
such items as chemicals and electricity for
treatment plant operations, water and sewer
service, and fuel;
d. Purchased services: Sampling costs,
laboratory fees, and professional fees for
which the need can be predicted;
e. Disposal and treatment costs: Costs of
transporting, treating, and disposing of waste
materials, such as treatment plant residues,
generated during operations;
f. Administrative costs: Costs associated with
administration of corrective measure
operation and maintenance not included
under other categories;
g. Insurance, taxes, and licensing costs: Costs
of such items as liability and sudden
accidental insurance; real estate taxes on
20
-------
purchased land or rights-of-way; licensing
fees for certain technologies, and permit
renewal and reporting costs;
h. Maintenance reserve and contingency funds:
Annual payments into escrow funds to cover
(1) costs of anticipated replacement or
rebuilding of equipment and (2) any large
unanticipated operation and maintenance
costs; and
i. Other costs: Items that do not fit any of the
above categories.
Task X: Justification and Recommendation of
the Corrective Measure or Measures
The Owner/Operator [Respondent] shall justify and
recommend a corrective measure alternative using
technical, human health, and environmental criteria. This
recommendation shall include summary tables which
allow the alternative or alternatives to be understood
easily. Tradeoffs among health risks, environmental
effects, and other pertinent factors shall be highlighted.
The U.S. EPA will select the corrective measure
alternative or alternatives to be implemented based on
the results of Tasks IX and X. At a minimum, the
following criteria will be used to justify the final corrective
measure or measures.
A. Technical
1. Performance - corrective measure or measures
which are most effective at performing their
intended functions and maintaining the
performance over extended periods of time will
be given preference;
2. Reliability - corrective measure or measures
which do not require frequent or complex
operation and maintenance activities and that
have proven effective under waste and facility
conditions similar to those anticipated will be
given preference;
3. Implementability - corrective measure or
measures which can be constructed and
operating to reduce levels of contamination to
attain or exceed applicable standards in the
shortest period of time will be preferred; and
4. Safety - corrective measure or measures which
pose the least threat to the safety of nearby
residents and environments as well as workers
during implementation will be preferred.
B. Human Health
The corrective measure or measures must comply
with existing U.S. EPA criteria, standards, or
guidelines for the protection of human health.
Corrective measures which provide the minimum
level of exposure to contaminants and the maximum
reduction in exposure with time are preferred.
C. Environmental
The corrective measure or measures posing the least
adverse impact (or greatest improvement) over the
shortest period of time on the environment will be
favored.
Task XI: Reports
The Owner/Operator [Respondent] shall prepare a
Corrective Measure Study Report presenting the results
of Task VIII through X and recommending a corrective
measure alternative, [number] copies of the preliminary
report shall be provided by the Owner/Operator
[Respondent].
A. Progress
The Owner/Operator [Respondent] shall at a
minimum provide the EPA with signed, [monthly,
bimonthly] progress reports containing:
1. A description and estimate of the percentage of
the CMS completed;
2. Summaries of all findings;
3. Summaries of all changes made in the CMS
during the reporting period;
4. Summaries of all contacts with representative of
the local community, public interest groups or
State government during the reporting period;
5. Summaries of all problems or potential problems
encountered during the reporting period;
6. Actions being taken to rectify problems;
7. Changes in personnel during reporting period;
8. Projected work for the next reporting period; and
9. Copies of daily reports, inspection reports,
laboratory/ monitoring data, etc.
B. Draft
The Report shall at a minimum include:
1. A description of the facility;
a. Site topographic map and preliminary
layouts.
2. A summary of the corrective measure or
measures;
a. Description of the corrective measure or
measures and rationale for selection;
b. Performance expectations;
21
-------
c. Preliminary design criteria and rationale;
d. General operation and maintenance re-
quirements; and
e. Long-term monitoring requirements.
3. A summary of the RCRA Facility Investigation
and impact on the selected corrective measure
or measures;
a. Field studies (ground-water, surface water,
soil, air); and
b. Laboratory studies (bench scale, pilot scale).
4. Design and Implementation Precautions;
a. Special technical problems;
b. Additional engineering data required;
c. Permits and regulatory requirements;
d. Access, easements, right-of-way;
e. Health and safety requirements; and
f. Community relations activities.
5. Cost Estimates and Schedules;
a. Capital cost estimate;
b. Operation and maintenance cost estimate;
and
c. Project schedule (design, construction,
operation).
[Number] copies of the draft shall be provided by the
Owner/Operator [Respondent] to U.S. EPA.
C. Final
The Owner/Operator [Respondent] shall finalize the
Corrective Measure Study Report incorporating
comments received from EPA on the Draft Corrective
Measure Study Report
[THE FOLLOWING FACILITY SUBMISSION SUMMARY
MAY BE PLACED IN THE BODY OF THE ORDER OR
PERMIT AND REMOVED FROM THE SCOPE OF
WORK. NOT ALL OF THE ITEMS LISTED BELOW MAY
BE REQUIRED AT EACH FACILITY.]
Facility Submission Summary
A summary of the information reporting requirements
contained in the Corrective Measure Study Scope of
Work is presented below:
Facility Submission
Draft CMS Report
(Tasks VIII, IX, and X)
Final CMS Report
(Tasks VIII, IX, and X)
Progress Reports on
Tasks VIII, IX, and X
Due Date
[ NUMBER ] days
after submittal of the
final RFI
[ NUMBER] days
after Public and EPA
comment on the Draft
CMS
[ MONTHLY.BI-
MONTHLY ]
22
-------
Scope of Work for the Corrective Measure Implementation
at
[Specify Facility Name]
Purpose
The purpose of this Corrective Measure Implementation
(CMI) program is to design, construct, operate, maintain,
and monitor the performance of the corrective measure
or measures selected to protect human health and the
environment. The Owner/Operator [Respondent] will
furnish all personnel, materials and services necessary
for the implementation of the corrective measure or
measures.
[Note This scope of work is intended to foster timely,
concise submissions by Owner/Operators. To achieve
this goal, it is important when using the model scope of
work to consider facility specific conditions This scope
should be modified as necessary to require only that
information necessary to complete the Corrective
Measure Implementation ]
Scope
The Corrective Measure Implementation program
consists of four tasks;
Task XII:
Task XIII:
Task XIV:
Corrective Measure Implementation
Program Plan
A. Program Management Plan
B. Community Relations Plan
Corrective Measure Design
A. Design Plans and Specifications
B. Operation and Maintenance Plan
C. Cost Estimate
D. Project Schedule
E.
Construction Quality Assurance
Objectives
F.
Health and Safety Plan
G. Design Phases
Corrective Measure Construction
A. Responsibility and Authority
B. Construction Quality Assurance
Personnel Qualifications
C. Inspection Activities
D. Sampling Requirements
E. Documentation
Task XV- Reports
A. Progress
B. Draft
C. Final
Task XII: Corrective Measure Implementation
Program Plan
The Owner/Operator [Respondent] shall prepare a
Corrective Measure Implementation Program Plan. This
program will include the development and implementation
of several plans, which require concurrent preparation. It
may be necessary to revise plans as the work is
performed to focus efforts on a particular problem. The
Program Plan includes the following:
A. Program Management Plan
The Owner/Operator [Respondent] shall prepare a
Program Management Plan which will document the
overall management strategy for performing the
design, construction, operation, maintenance and
monitoring of corrective measure(s). The plan shall
document the responsibility and authority of all
organizations and key personnel involved with the
implementation. The Program Management Plan will
also include a description of qualifications of key
personnel directing the Corrective Measure
Implementation Program, including contractor
personnel.
B. Community Relations Plan
The Owner/Operator [Respondent] shall revise the
Community Relations Plan to include any changes in
the level of concern of information needs to the
community during design and construction activities.
1. Specific activities which must be conducted
during the design stage are the following:
23
-------
a. Revise the facility Community Relations
Plan to reflect knowledge of citizen concerns
and involvement at this stage of the process;
and
b. Prepare and distribute a public notice and
an updated fact sheet at the completion of
engineering design.
2. Specific activities to be conducted during the
construction stage could be the following:
Depending on citizen interest at a facility at this
point in the corrective action process,
community relations activities could range from
group meetings to fact sheets on the technical
status.
Task XIII: Corrective Measure Design
The Owner/Operator [Respondent] shall prepare final
construction plans and specifications to implement the
corrective measure(s) at the facility as defined in the
Corrective Measure Study.
A. Design Plans and Specifications
The Owner/Operator [Respondent] shall develop
clear and comprehensive design plans and
specifications which include but are not limited to the
following:
1. Discussion of the design strategy and the design
basis, including:
a. Compliance with all applicable or relevant
environmental and public health standards;
and
b. Minimization of environmental and public
impacts.
2. Discussion of the technical factors of importance
including:
a. Use of currently accepted environmental
control measures and technology;
b. The constructability of the design; and
c. Use of currently acceptable construction
practices and techniques.
3. Description of assumptions made and detailed
justification of these assumptions;
4. Discussion of the possible sources of error and
references to possible operation and
maintenance problems;
5. Detailed drawings of the proposed design
including:
a. Qualitative flow sheets; and
b. Quantitative flow sheets.
6. Tables listing equipment and specifications;
7. Tables giving material and energy balances;
8. Appendices including:
a. Sample calculations (one example
presented and explained clearly for
significant or unique design calculations);
b. Derivation of equations essential to
understanding the report; and
c. Results of laboratory or field tests
B. Operation and Maintenance Plan
The Owner/Operator [Respondent] shall prepare an
Operation and Maintenance Plan to cover both
implementation and long-term maintenance of the
corrective measure. The plan shall be composed of
the following elements:
1. Description of normal operation and maintenance
(O&M);
a. Description of tasks for operation;
b. Description of tasks for maintenance;
c. Description of prescribed treatment or
operation conditions; and
d. Schedule showing frequency of each O&M
task.
2. Description of potential operating problems;
a. Description and analysis of potential
operation problems;
b. Sources of information regarding problems;
and
c. Common and/or anticipated remedies.
3. Description of routine monitoring and laboratory
testing;
a. Description of monitoring tasks;
b. Description of required laboratory tests and
their interpretation;
c. Required QA/QC; and
d. Schedule of monitoring frequency and date,
if appropriate, when monitoring may cease.
4. Description of alternate O&M;
a. Should systems fail, alternate procedures to
prevent undue hazard; and
24
-------
b. Analysis of vulnerability and additional
resource requirements should a failure
occur.
5. Safety plan;
a. Description of precautions, of necessary
equipment, etc., for site personnel; and
b. Safety tasks required in event of systems
failure.
6. Description of equipment; and
a. Equipment identification;
b. Installation of monitoring components;
c. Maintenance of site equipment; and
d. Replacement schedule for equipment and
installed components.
7. Records and reporting mechanisms required.
a. Daily operating logs;
b. Laboratory records;
c. Records for operating costs;
d. Mechanism for reporting emergencies;
e. Personnel and maintenance records; and
f
Monthly/annual reports to State agencies
An initial Draft Operation and Maintenance Plan
shall be submitted simultaneously with the
Prefinal Design Document submission and the
Final Operation and Maintenance Plan with the
Final Design Documents.
C. Cost Estimate
The Owner/Operator [Respondent] shall develop cost
estimates for the purpose of assuring that the facility
has the financial resources necessary to construct
and implement the corrective measure. The cost
estimate developed in the Corrective Measure Study
shall be refined to reflect the more detailed/accurate
design plans and specifications being developed.
The cost estimate shall include both capital and
operation and maintenance costs. An Initial Cost
Estimate shall be submitted simultaneously with the
Prefinal Design submission and the Final Cost
Estimate with the Final Design Document.
D. Project Schedule
The Owner/Operator [Respondent] shall develop a
Project Schedule for construction and
implementation of the corrective measure or
measures which identifies timing for initiation and
completion of all critical path tasks. Owner/Operator
[Respondent] shall specifically identify dates for
completion of the project and major interim
milestones. An Initial Project Schedule shall be
submitted simultaneously with the Prefinal Design
Document submission and the Final Project
Schedule with the Final Design Document.
E. Construction Quality Assurance Objectives
The Owner/Operator [Respondent] shall identify and
document the objectives and framework for the
development of a construction quality assurance
program including, but not limited to the following:
responsibility and authority; personnel qualifications;
inspection activities; sampling requirements; and
documentation.
F. Health and Safety Plan
The Owner/Operator [Respondent] shall modify the
Health Safety Plan developed for the RCRA Facility
Investigation to address the activities to be
performed at the facility to implement the corrective
measure(s).
G. Design Phases
The design of the corrective measure(s) should
include the phases outlined below.
1. Preliminary design
The Owner/Operator [Respondent] shall submit
the Preliminary design when the design effort is
approximately 30% complete. At this stage the
Owner/Operator [Respondent] shall have field
verified the existing conditions of the facility. The
preliminary design shall reflect a level of effort
such that the technical requirements of the
project have been addressed and outlined so
that they may be reviewed to determine if the
final design will provide an operable and usable
corrective measure. Supporting data and
documentation shall be provided with the design
documents defining the functional aspects of the
program. The preliminary construction drawings
by the Owner/Operator [Respondent] shall reflect
organization and clarity. The scope of the
technical specifications shall be outlined in a
manner reflecting the final specifications The
Owner/Operator [Respondent] shall include with
the preliminary submission design calculations
reflecting the same percentage of completion as
the designs they support.
2. Intermediate design
Complex project design may necessitate review
of the design documents between the
preliminary and the prefinal/final design. At the
discretion of the Agency, a design review may
be required at 60% completion of the project.
25
-------
The intermediate design submittal should include
the same elements as the prefinal design.
3. Correlating plans and specifications
General correlation between drawings and
technical specifications, is a basic requirement of
any set of working construction plans and
specifications. Before submitting the project
specifications, the Owner/Operator [Respondent]
shall:
a. Coordinate and cross-check the
specifications and drawings; and
b. Complete the proofing of the edited
specifications and required cross-checking
of all drawings and specifications.
These activities shall be completed prior to the
95% prefinal submittal to the Agency.
4. Equipment startup and operator training
The Owner/Operator [Respondent] shall prepare,
and include in the technical specifications
governing treatment systems, contractor
requirements for providing: appropriate service
visits by experienced personnel to supervise the
installation, adjustment, startup and operation of
the treatment systems, and training covering
appropriate operational procedures once the
startup has been successfully accomplished.
5. Additional studies
Corrective Measure Implementation may require
additional studies to supplement the available
technical data At the direction of the Agency for
any such studies required, the Owner/Operator
[Respondent] shall furnish all services, including
field work as required, materials, supplies, plant,
labor, equipment, investigations, studies and
superintendence. Sufficient sampling, testing and
analysis shall be performed to optimize the
required treatment and/or disposal operations
and systems. There shall be an initial meeting of
all principal personnel involved in the
development of the program. The purpose will
be to discuss objectives, resources,
communication channels, role of personnel
involved and orientation of the site, etc. The
interim report shall present the results of the
testing with the recommended treatment or
disposal system (including options). A review
conference shall be scheduled after the interim
report has been reviewed by all interested
parties. The final report of the testing shall
include all data taken during the testing and a
summary of the results of the studies.
6. Prefinal and final design
The Owner/Operator [Respondent] shall submit
the prefinal/Final design documents in two parts.
The first submission shall be at 95% completion
of design (i e., prefinal). After approval of the
prefinal submission, the Owner/Operator
[Respondent] shall execute the required
revisions and submit the final documents 100%
complete with reproducible drawings and
specifications.
The prefinal design submittal shall consist of the
Design Plans and Specifications, Operation and
Maintenance Plan, Capital and Operating and
Maintenance Cost Estimate, Project Schedule,
Quality Assurance Plan and Specifications for
the Health and Safety Plan
The final design submittal consists of the Final
Design Plans and Specifications (100%
complete), the Owner/Operator's [Respondent's]
Final Construction Cost Estimate, the Final
Operation and Maintenance Plan, Final Quality
Assurance Plan, Final Project Schedule and Final
Health and Safety Plan specifications. The
quality of the design documents should be such
that the Owner/Operator [Respondent] would be
able to include them in a bid package and invite
contractors to submit bids for the construction
project.
Task XIV: Corrective Measure Construction
Following EPA approval of the final design, the
Owner/Operator [Respondent] shall develop and
implement a construction quality assurance (CQA)
program to ensure, with a reasonable degree of certainty,
that a completed corrective measure(s) meets or exceeds
all design criteria, plans and specifications. The CQA plan
is a facility specific document which must be submitted
to the Agency for approval prior to the start of
construction. At a minimum, the CQA plan should include
the elements, which are summarized below. Upon EPA
approval of the CQA plan the Owner/Operator
[Respondent] shall construct and implement the
corrective measures in accordance with the approved
design, schedule and the CQA plan. The Owner/Operator
[Respondent] shall also implement the elements of the
approved Operation and Maintenance plan.
A. Responsibility and Authority
The responsibility and authority of all organizations
(i.e., technical consultants, construction firms, etc.)
and key personnel involved in the construction of the
corrective measure shall be described fully in the
CQA plan. The Owner/Operator [Respondent] must
identify a CQA officer and the necessary supporting
inspection staff.
26
-------
B. Construction Quality Assurance Personnel
Qualifications
The qualifications of the CQA officer and supporting
inspection personnel shall be presented in the CQA
plan to demonstrate that they possess the training
and experience necessay to fulfill their identified
responsibilities.
C. Inspection Activities
The observations and tests that will be used to
monitor the construction and/or installation of the
components of the corrective measure(s) shall be
summarized in the CQA plan. The plan shall include
the scope and frequency of each type of inspection.
Inspections shall verify compliance with all
environmental requirements and include, but not be
limited to air quality and emissions monitoring
records, waste disposal records (e.g., RCRA
transportation manifests), etc. The inspection should
also ensure compliance with all health and safety
procedures. In addition to oversight inspections, the
Owner/Operator [Respondent] shall conduct the
following activities:
1. Preconstruction inspection and meeting
The Owner/Operator [Respondent] shall conduct
a preconstruction inspection and meeting to:
a. Review methods for documenting and re-
porting inspection data;
b. Review methods for distributing and storing
documents and reports;
c. Review work area security and safety
protocol;
d. Discuss any appropriate modifications of the
construction quality assurance plan to
ensure that site-specific considerations are
addressed; and
e. Conduct a site walk-around to verify that
the design criteria, plans, and specifications
are understood and to review material and
equipment storage locations.
The preconstruction inspection and meeting shall be
documented by a designated person and minutes
should be transmitted to all parties.
2. Prefinal inspection
Upon preliminary project completion
Owner/Operator [Respondent]shall notify EPA for
the purposes of conducting a prefinal inspection.
The prefinal inspection will consist of a walk-
through inspection of the entire project site. The
inspection is to determine whether the project is
complete and consistent with the contract
documents and the EPA approved corrective
measure. Any outstanding construction items
discovered during the inspection will be
identified and noted. Additionally, treatment
equipment will be operationally tested by the
Owner/Operator [Respondent]. The
Owner/Operator [Respondent] will certify that the
equipment has performed to meet the purpose
and intent of the specifications. Retestmg will be
completed where deficiencies are revealed The
prefinal inspection report should outline the
outstanding construction items, actions required
to resolve items, completion date for these
items, and date for final inspection.
3. Final inspection
Upon completion of any outstanding construction
items, the Owner/ Operator [Respondent] shall
notify EPA for the purposes of conducting a final
inspection. The final inspection will consist of a
walk-through inspection of the project site. The
prefinal inspection report will be used as a
checklist with the final inspection focusing on the
outstanding construction items identified in the
prefinal inspection. Confirmation shall be made
that outstanding items have been resolved.
D. Sampling Requirements
The sampling activities, sample size, sample
locations, frequency of testing, acceptance and
rejection criteria, and plans for correcting problems
as addressed in the project specifications should be
presented in the CQA plan.
£. Documentation
Reporting requirements for CQA activities shall be
described in detail in the CQA plan. This should
include such items as daily summary reports,
inspection data sheets, problem identification and
corrective measures reports, design acceptance
reports, and final documentation. Provisions for the
final storage of all records also should be presented
in the CQA plan.
Task XV: Reports
The Owner/Operator [Respondent] shall prepare plans,
specifications, and reports as set forth in Tasks XII
through Task XV to document the design, construction,
operation, maintenance, and monitoring of the corrective
measure. The documentation shall include, but not be
limited to the following:
A. Progress
The Owner/Operator [Respondent] shall at a
minimum provide the EPA with signed, [monthly,
bimonthly] progress reports during the design and
construction phases and [semi-annual] progress
27
-------
reports for operation and maintenance activities
containing:
1. A description and estimate of the percentage of
the CM I completed;
2. Summaries of all findings;
3. Summaries of all changes made in the CMI
during the reporting period;
4. Summaries of all contacts with representative of
the local community, public interest groups or
State government during the reporting period;
5. Summaries of all problems or potential problems
encountered during the reporting period;
6. Actions being taken to rectify problems;
7. Changes in personnel during the reporting
period;
8. Projected work for the next reporting period; and
9. Copies of daily reports, inspection reports,
laboratory/ monitoring data, etc.
B. Draft
1. The Owner/Operator [Respondent] shall submit a
draft Corrective Measure Implementation
Program Plan as outlined in Task XII;
2. The Owner/Operator [Respondent] shall submit
draft Construction Plans and Specifications,
Design Reports, Cost Estimates, Schedules,
Operation and Maintenance Plans, and Study
Reports as outlined in Task XIII;
3. The Owner/Operator [Respondent] shall submit a
draft Construction Quality Assurance Program
Plan and Documentation as outlined in Task XIV;
and
4. At the "completion" of the construction of the
project, the Owner/Operator [Respondent] shall
submit a Corrective Measure Implementation
Report to the Agency. The Report shall
document that the project is consistent with the
design specifications, and that the corrective
measure is performing adequately. The Report
shall include, but not be limited to the following
elements:
a. Synopsis of the corrective measure and
certification of the design and construction;
b. Explanation of any modifications to the plans
and why these were necessary for the
project;
c Listing of the criteria, established before the
corrective measure was initiated, for judging
the functioning of the corrective measure
and also explaining any modification to
these criteria;
d. Results of facility monitoring, indicating that
the corrective measure will meet or exceed
the performance criteria; and
e. Explanation of the operation and
maintenance (including monitoring) to be
undertaken at the facility.
This report should include all of the daily inspection
summary reports, inspection summary reports,
inspection data sheets, problem identification and
corrective measure reports, block evaluation reports,
photographic reporting data sheets, design
engineers' acceptance reports, deviations from
design and material specifications (with justifying
documentation) and as-built drawings.
C. Final
The Owner/Operator [Respondent] shall finalize the
Corrective Measure Implementation Program Plan,
Construction Plans and Specifications, Design
Reports, Cost Estimates, Project Schedule, Operation
and Maintenance Plan, Study Reports, Construction
Quality Assurance Program Plan/Documentation and
the Corrective Measure Implementation Report
incorporating comments received on draft
submissions.
[THE FOLLOWING FACILITY SUBMISSION SUMMARY
MAY BE PLACED IN THE BODY OF THE ORDER OR
PERMIT AND REMOVED FROM THE SCOPE OF
WORK. NOT ALL OF THE ITEMS LISTED BELOW MAY
BE REQUIRED AT EACH FACILITY].
Submission Summary
A summary of the information reporting requirements
contained in the Corrective Measure Implementation
Scope of Work is present below:
28
-------
Facility Submission
Draft Program Plans (Task XII)
Final Program Plans (Task XII)
Design Phases (Task XIII A)
- Preliminary Design (30% completion)
- Intermediate Design (60% completion)
- Prefinal Design (95% completion)
- Final Design (100% completion)
(Tasks XIII B through G)
- Draft Submittals
-Final Submittals
Additional Studies: InterimReport (Task XIII F)
Additional Studies: Final Report (Task XIII F)
Draft Construction Quality Assurance Plan (Task XIV)
Final Construction Quality Assurance Plan (Task XIV)
Construction of Corrective Measure(s)
Prefinal Inspection Report (Task XIV)
Draft CMI Report (Task XV)
Completion of Construction
Final CMI Report (Task XV)
Progress Reports for Tasks XII through XIV
Progress Reports During Operation and Maintenance
Due Date
[DATE ]
[ NUMBER ] days after EPA comment on Draft Program
Plans
[ NUMBER ] days after submittal of Final Program Plan
[ NUMBER ] days after submittal of Final Program Plan
[ NUMBER ] days after submittal of Final Program Plan
[ NUMBER ] days after submittal of Prefinal Design
Concurrent with Prefinal Design
Concurrent with Final Design
[ DATE ESTABLISHED PRIOR TO FINAL DESIGN ]
[ NUMBER ] days after EPA comment on Interim Report
Prior to construction
[ NUMBER ] days after EPA comment on Draft
Construction Quality Assurance Plan
As approved in Final Design
[ NUMBER ] days after Prefinal Inspection
Upon completion of construction phase
As approved by EPA in the Corrective Measure Design
[ NUMBER ] days after EPA comment on Draft CMI
Report
[ MONTHLY.BI-MONTHLY ]
[ SEMI-ANNUAL]
29
-------
Annotated Bibliography
for the
Corrective Action Plan**
Guidance on Remedial Investigations Under CERCLA;
May 1985
Provides detailed guidance on the information that
should be collected in performing a CERCLA
Remedial Investigation This document should be
consulted in performing the investigation portion of
the RFI/CMS since most of the RCRA Facility
Investigation data needs are identical to these in
CERCLA.
Guidance on Feasibility Studies Under CERCLA; April
1985.
- Provides a framework for developing, screening, and
selecting a remedial action under CERCLA. Most of
the techniques described are appropriate for the
developing, screening, and selection of the RCRA
Corrective Measures. However, the management and
policy objectives presented in the document (i.e.;
fulfilling the requirements of the CERCLA National
Contingency Plan) are not appropriate to RCRA and
should be omitted from the Corrective Measure
decisionmakmg framework.
Chemical, Physical and Biological Properties of
Compounds Present at Hazardous Waste Sites;
EPA/OWPE, September 1985.
Provides detailed technical information of the
physical and toxicological properties of a wide range
of chemicals. Such information should be included in
the RCRA Facility Investigation and should be used
in developing Corrective Measures.
Endangerment Assessment Handbook; EPA/OWPE;
August 1985.
Provides guidance on developing a CERCLA (or
RCRA 7003) Endangerment Assessment. The
information presented might be useful in assessing
health and environmental effects in the RFI/CMS.
Methods for Chemical Analysis of Water and Waste;
EPA-600/4-79-020; March 1979.
Provides test procedures for monitoring waste
discharge water supplies, and ambient waters.
Toxicology Handbook - Principles Related to
Hazardous Waste Site Investigations; EPA/OWPE;
August 1985.
Discusses toxicological principles. Intended as an aid
for non-toxicologists.
Remedial Action at Waste Disposal Sites (Revised);
EPA/625/6-85/006; 1985.
- Provides basic reference material on the design and
implementation of remedial action. Although the
document is geared towards the CERCLA RI/FS
process, most of the material presented is directly
applicable to the RCRA Corrective Action Plan.
7esf Methods for Evaluating Solid Waste,
Physical/Chemical Methods; SW-846; July 1982.
Provides procedures that should be used to
determine whether a waste is a hazardous waste as
defined by 40 CFR Part 261.
Superfund Remedial Design and Remedial Action
Guidance; February 1985.
Provides guidance on developing remedial design
and remedial actions at Superfund sites. Although
procedurally focused on satisfying the NCP, the
document provides useful managerial information for
implementing RCRA Corrective Meaures.
Guidance on Remedial Actions for Contaminated Ground
Water at Superfund Sites; Draft; May 1986.
Provides technical discussions of CERCLA remedial
alternative screening and case studies which are
largely applicable to the RFI/CMS. The guidance is
intended to be consistent with EPA's Ground Water
Protection Strategy and with RCRA.
Construction Quality Assurance for Hazardous Waste
Land Disposal Facilities; EPA/530-SW-85-031; July
1986.
Public guidance on construction quality assurance for
hazardous waste landfills, surface impoundments,
and wastepiles.
RCRA Ground-Water Monitoring Technical Enforcement
Guidance Document; Final; EPA/OWPE; September
1986.
Provides guidance on data collection and well
spacing and design for detection and assessment
monitoring of Interim Status facilities. This guidance
should be consulted in both the RCRA Facility
Investigation and Corrective Measure stages of the
RFI/CMS.
"NOTE This is not a complete listing of the Agency guidance which
may be relevant to the corrective action process A number of
documents are presently under development and have not
been included
30
&U. S. GOVERNMENT PRINTING OFFICE: 1S88/548-158/67132
------- |