>EPA
United States
Environmental Protection
Agency   .
                      Office of Solid Waste and
                      Emergency Response
                      Washington DC 20460
EPA/530-SW-88-029
OSWER Directive 9902.4
June 1988
RCRA Corrective
Action Interim
Measures Guidance
           Interim Final

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                                 EPA/530-SW-88-029
                                 OSWER Directive 9902.4
                                        June 1988
  RCRA CORRECTIVE ACTION

INTERIM MEASURES GUIDANCE


           (Interim Final)
          Office of SoUd Waste
    Office of Waste Programs Enforcement

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                                     TABLE OF CONTENTS
FOREWORD	,	  v

ACKNOWLEDGMENTS	".	,	   vii

INTERIM MEASURES IMPLEMENTATION STRATEGY	,	  1

EXAMPLES OF INTERIM MEASURES  	.		  4

MODEL INTERIM MEASURES LANGUAGE	  5

  Containers	  5
  Tanks  		  6
  Surface Impoundments	  8
  Landfills 	.	  8
  Waste Pile					   10
  Soils	   10
  Ground Water	,. .   It
  Surface Water Release	   13
  Gas Migration Control	;	   14
  Particulate Emissions			 ,14
  Other Actions	   15

  APPENDICES	   16

  APPENDIX A; Interim Measures Workpfan	  A « 1
  APPENDIX'S: Interim Measures Investigation Program	  B • 1
  APPENDIX C: Interim Measures Design Program  	  C»1
  APPENDIX D; Interim Measures Construction Quality Assurance Plan	  D-1
  APPENDIX E: Reports	  E - 1
                                               in

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                                                                  FOREWORD
                            This document was issued by Gene A. Lucero, Director, Office of Waste Programs Enforcement,
                            and  Marcia Williams, Director,  Office of Solid Waste, on June 10, 1987, as the RCRA §3008(h)
                            Corrective Action Interim Measures Guidance (Interim Final), OSWER Directive 9902.4

                            The  Interim Measures Guidance should be used  in the development,  implementation and
                            coordination of corrective action orders (P008(h)) and corrective action programs carried  out
                            pursuant to a RCRA permit (P004(u) and (v)). Its purpose is to  assist the regions and states in
                            deciding when to require an interim measure. In addition, it will also assist in identifying and
                            communicating to the owner/operator or respondent the specific work which must be performed to
                            mitigate or remove the threat presented by releases. This document should be used in conjunction
                            with  two previously transmitted corrective action guidances,  the interim final  Corrective Action
                            Plan, November 1986 and the RCRA P008(h) Model Consent Order,. February 1987.

                            The  document is designed to provide  a review of corrective actions available under P008(h) as
                            well  as through RCRA permits to quickly address problems while other detailed investigations or
                            analyses may be ongoing. Interim  measures can be designed and  implemented as  an initial
                            corrective action activity in a multi-phased order or as the action  in the first of a series of orders
                            which feed into an operating permit, post-closure permit or supplement an interim status closure
                            plan.

                            The  Interim Measures guidance consists of:
    s                    «
 "".                        1.  Implementation Strategy •  which lays out the thought process  necessary to  determine  the
"*°*                             need for interim measures,

                            2.  Interim Measures  List -  which provides  examples of  interim measures  compiled from past
                                removal actions and Superfund remedial guidance,

                            3.  Model Language - which provides specific language as needed for each interim measure that
                                should be modified to address site-specific conditions.

                            4,  Interim Measures Appendices - which lay out the scope of work for the investigation, design
                                and implementation of the interim measures.

                            Regions should consider  the magnitude of potential threat to human health and the environment
                            during the selection of an interim measure. The Agency's authority to require an owner/operator to
                            perform specified  activities  is directly correlated to the protection of human health and  the
                            environment. Therefore, if the risk has yet to be determined, simple monitoring of ground water,
                            surface waste, soil or air may  be the types of actions ordered. As more information becomes
                            available through initial or additional sampling and analysis, more comprehensive actions should
                            be contemplated either by incorporating actions into a permit,  a single "phased" order  or by
                            issuing separate orders.

                            Please note that the model language provided in this document should be tailored to site-specific
                            technical details.  This is particularly  important when the Agency  compels the  respondent to
                            implement an  interim  measure  without a submission  of  a plan for EPA review  and approval.
                            Significant up-front  detail should be provided in the order or the permit so that the  measure
                            implemented  by the respondent is appropriate and  in accordance with EPA's requirements. In
                            addition, since the purpose of the interim measure is to expeditiously abate or remove the threat
                            presented by  releases,  specific  and  stringent  time frames  for  implementation should  be
                            incorporated into the order or permit.

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                              ACKNOWLEDGMENTS
This document was prepared by Mark Qilbertson, Anna Duncan and Jacqueline Moya of the RCRA
Enforcement Division in the Office of Waste Programs Enforcement. A special thanks  to Tony
ianey and Lloyd Ouercl for their management support and the Office of Solid Waste and various
regional staff for their technical review and comments.
                                         vli

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                            INTERIM MEASURES IMPLEMENTATION STRATEGY
Introduction


Regions should consider  interim measures for corrective
action in orders and permits and initiate them for facilities
where response is  appropriate prior to the completion of
the RCRA Facility Investigation/Corrective Measure Study.
Implementation of interim measures should be consistent
with agency priorities and must be related to protection of
human health or the environment,


Decision Criteria

Regional staff must review the pertinent facts about the
source  and nature of the release or potential threat of
release. To decide whether  an interim  measure is
appropriate, both technical engineering judgment and an
evaluation  of potential threat to  human  health or the
environment should be considered. The decision for an
interim  measure can be made, based on  the immediacy
and magnitude of the potential threat to human health or
environment, the nature of appropriate corrective action,
and the implications of deferring the corrective action until
the RCRA Facility Investigation/Corrective Measures Study
is completed. The EPA official initiating the action should
maintain a  file  containing reports and  internal  Agency
documents  used in generating  or  supporting the interim
measure.

Sources that may provide information on releases as welt
as environmental and health concerns include:

»   Inspection reports

*   RCRA Facility Assessment (RFA)

•   RCRA Facility Investigations (RFIs)

»   RCRA Part A and Part B permit applications

*   Notice of significant increase {265.93}

•   Responses to RCRA §3007 information requests

•   Information obtained through RCRA §3013 orders

•   Notifications required  by  CERCLA §103 or RCRA
    §3016 submittals

*   Information-gathering activities  conducted under
    CERCLA §104

»   Informants'  tips or citizens' complaints corroborated
    by  supporting information

In  considering a release and potential  threat to human
health or the environment, the enforcement official/permit
writer should consider factors  such as type of release, its
scope  and site  demographics. The following  questions
may help the Regional staff in evaluating these factors,*

A.  Release Characterization

    1.   What is the source(s)? (nature, number of drums,
        size (area, depth), amount, locations))

    2.   Regarding hazardous wastes  or  constituents  at
        the source(s):

        a.   What hazardous wastes (listed, characteristic)
            and hazardous constituents are present?

        b.   At what concentrations?

        c.   What is the background   level  of  each
            hazardous waste or constituent?

    3.   What are the known  pathways through which the
        contamination is migrating or may  migrate and the
        extent of contamination?

        a.   By  what media  is it spreading  or likely  to
            spread? In what direction?  At what rate?

        b,   How far have the contaminants migrated? At
            what concentrations?

        c.   How mobile is the constituent?

        d.   What  are  the estimated  quantities and/or
            volumes released?

    4;   What is the projected fate and transport  to the
        extent known?

S.  Potential Human Exposure

    1.   What is or will be the exposure pathway(s) (e.g.,
        air, fire/explosion, ground water,  surface  water,
        contact, ingestion)?

    2.   W.hat  are the  location  and  demographics  of
        populations potentially at risk from exposure (e.g.,
        residential area,  schools, drinking water supply,
        sole source aquifer near vital ecology or protected
        natural resource}?

    3.   What are the potential effects of human exposure
        (short-  and  long-term  effects)?"*
  This does not  imply  that either  a  risk  assessment or an
  endangerment assessment is necessary In part, these questions are
  designed to focus on high priority releases.
  "Hazardous constituent health effects data can be found  in
  "Chemical, Physical and Biological Properties of Compounds Present
  at Hazardous Waste Silas," September 1985. The draft "Superfund
  Exposure  Assessment  Manual," January 14, 1986,  th* draft
  "Suparfund Public Health Evaluation Manual," December 18, 1985
  and the RCRA §3001 data on identification and listing of hazardous
  wastes are also available as references on health effects

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    4  Has human exposure  actually  occurred?  When
       may human exposure occur?

       a.  What kind (e.g., inhalation, ingestion, skin
           contact)?

       b.  Are there reports-of Illness, injury, death?

       c.  May people be affected?

       d.  What are the characteristics of the  exposed
           population(s)  (how many, infants,  nursing
           home residents)?

    5.  If response is delayed,  how will the situation
       change?

C.  Potential Environmental  Exposure  and
    Threats

    !.  What media have been and may be contaminated
       (e.g., ground water, air, surface water)?

    2.  What  are  the  likely short-term  and long-term
       threats and effects  on the environment of the
       released waste or constituent?

    3.  What natural resource and environmental effects
       have occurred or are possible (terrestrial; aquatic
       organisms; aquifers whether  or not used  for
       drinking water purposes}?

    4.  What are the known or  projected  ecological
       effects?

    5.  When  Is this  threat likely to materialize  (days,
       weeks, months)?

    6.  What are the projected long term effects?

    7.   If response is delayed, how will the  situation
       change?

Selection of Interim Measure*

Once a decision can be made that interim measures  are
appropriate,  then the next question  is what  interim
measures (generally short term and  mid-term) might be
required  for this particular situation. Examples of interim
measures for various unit and release types an listed in
the next chapter of this guidance document on page 4,

Integration with Long Term Corrective Action

Interim   measures  may  be  separate   from  the
comprehensive corrective action plan but should anticipate
integration with any longer  term  corrective action {e.g.,
corrective measure through an order, an operating permit,
or  a post-closure permit  or interim  status closure
requirements).  To the extent-possible, interim measures
should not  seriously  complicate the ultimate  physical
management of hazardous  wastes or constituents and
should not present a substantial health or environmental
thread Interim measures may add additional costs or work
to  the  comprehensive corrective action. This does  not
preclude implementation of an interim measure.

Developing the talerlm Measure Language

A  scope, of  work for the implementation of  the  interim
measures should be laid out in the corrective action order
or permit Depending on  the immediacy of the problem
and the nature of the measure, an order may be written to
directly compel actions or may require submission of a
plan to  be  implemented  upon  EPA  approval or
modification. This scope of work could be laid out in the
body of the order/permit  or may be incorporated as" an
attachment to the order/permit.

Interim measures language to be included in a corrective
action order follows in the chapter entitled "Model  Interim
Measures  Language,"  on page 5. Language  included in
Ms guidance for various units and releases types  can be
combined  in either  an order/permit In general, the scope
of work for  interim measures  to  be implemented  at a
facility  may consist of all or some of the tasks, which have
been laid out in more detail in the model language and the
appendices of  this document.  Examples of how the
Appendices may, be expanded  and/or tailored to specific
units are provided on pages ?, 8,11,12,13 and 14.

Appendix A contains the recommended components (the
objectives,  a health and  safety plan and  a  community
relations plan) for an Interim measures workplan. When
interim measures are taking place at the same time as a
RCRA  Facility Investigation (RF1),  the RFI workplan may
already incorporate health and safety  and  community
relations plans sufficient for Hie interim measure activities.
Additional components  may  need  to be added  to  this
workplan. For  example, if  media investigations  are
necessary, see Appendix B  -  Interim Measures  Investi-
gation  Program, for details to be added to the  workplan. If
an interim measure design is  necessary,  see Appendix
C • Interim  Measures  Design Program, for details to be
added  to the workplan. If a construction  quality assurance
program is required, see Appendix D *  Interim Measures
Construction Quality Assurance Plan, for details to be
added  to the workplan. If progress, draft and final reporting
are required, see Appendix E - Reports, lor details to be
added  to the workplan. Language in the appendices should
be modified to take into account  site-specific technical
detail.

   APPENDIX A - INTERIM MEASURES WORKPLAN

    1.   Interim Measures Objectives
    2.   Health and Safety Plan
    3.   Community Relations Plan

   APPENDIX B - INTERIM MEASURES
   INVESTIGATION PROGRAM

    1,   Data Collection Quality Assurance Plan
    2.   Data Management Plan

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APPENDIX C - INTERIM MEASURES DESIGN
PROGRAM

  1.  Design Plans and Specifications
  2.  Operation and Maintenance Plan
  3.  Project Schedule
  4.  Final Design Documents

APPENDIX D - INTERIM MEASURES
CONSTRUCTION QUALITY ASSURANCE PLAN

  1.  Construction Quality Assurance Objectives
  2.  Inspection Activities
  3.  Sampling Requirements
  4.  Documentation

APPENDIX E - REPORTS

  1.  Progress
  2.  Interim Measures Workplan
  3,  Final Design Documents
  4,  Draft Interim Measures Report
  5.  Final Interim Measures Report

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                                   EXAMPLES OF INTERIM MEASURES
    The following is a list of possible interim measures for
various units and release types. This list is not considered
to be all inclusive,

Containers

    1.   Qverpack/Redrum
    2.   Construct Storage Area/Move to  New Storage
        Area
    3.   Segregation
    4.   Sampling and Analysis
    5.   Treatment, Storage and/or Disposal
    6.   Temporary Cover

Tanks

    1.   Overflow/Secondary Containment
    2.   Leak Detection/Repair/Partia! or  Complete Re-
        moval

Surface Impoundments

    1.   Reduce Head
    2.   Remove Free Liquids and Highly Mobile Wastes
    3.   Stabilize/Repair Side Wails, Dikes or Liner(s)
    4,   Temporary Cover
    5.   Run-off/Run-on Control  (Diversion or Collection
        Devices)
    6.   Sample  and  Analysts to Document  the
        Concentration of Constituents Left in Place When
        a Surface  Impoundment Handling  Characteristic
        Wastes is Clean Closed
    7,   Interim Ground-water  Measures (See  Ground-
        water Section)

Landfills

    1,   Run-off/Run-on Control  {Diversion or Collection
        Devices)
    2,   Reduce Head on Liner and/or  in  Leachate
        Collection System
    3.   Inspect Leachate  Collection/Removal System or
        French Drain
    4.   Repair Leachate  Collection/Removal  System or
        French Drain
    5,   Temporary Cap
    6.   Waste Removal (See Soils Section)
    7.  . Interim Ground-water  Measures (See  Ground-
        water Section)

Waste Pile

    1.   Runoff/Run-on Control  (Diversion  or Collection
        Devices)
    2.   Temporary Cover
    3.   Waste Removal (See Soils Section)
    4.   Interim Ground-water  Measures (See Ground-
        water Section)
Soils

    1.  Sampling/Analysis/Disposal
    2,  Run-off/Run-on  Control (Diversion or Collection
      • Devices)
    3.  Temporary Cap/Cover

Ground Water

    1,  Delineation/Verification of Gross Contamination
    2,  Sampling and Analysis
    3.  Interceptor Trench/Sump/Subsurface Drain
    4.  Pump and Treat/ln-situ Treatment
    5.  Temporary Cap/Cover

Surface  Water Release (Point and Non-point)

    1.  Overflow/Underflow Dams
    2.  Filter Fences  "
    3.  Run-off/Run-on  Control (Diversion or Collection
       Devices)
    4.  Regrading/Revegetation
    5.  Sample and  Analyze  Surface Waters and
       Sediments or Point Source Discharges

Gas Migration Control

    1.  Barriers/Collection/Treatment/Monitoring

Particulate Emissions

    1,  Truck Wash (Decontamination Unit)
    2.  Revegetation
    3.  Application of Dust Suppressant

Other Actions

    1.  Fencing to Prevent Direct Contact
    2.  Sampling Off-site  Areas
    3.  Alternate Water Supply to Replace Contaminated
       Drinking Water
    4.  Temporary Relocation of Exposed Population*
    5.  Temporary or Permanent Injunction*
    6.  Suspend  or Revoke Authorization to Operate
       Under Interim Status *
  . "Model language not included in Ma guidance

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             MODEL INTERIM MEASURES LANGUAGE FOR CORRECTIVE ACTION ORDERS*
                   CONTAINERS"

 1.   Overpack/Redrum
 Beginning immediately, the Respondent shall overpack or
 redrum each leaking, significantly corroded, damaged,
 uncovered and bulged container located in (insert location]
 that may  leak or burst, This action shall be completed by
 [insert date].  Within_  days  and  every  _ days
 thereafter until [insert date^T the Respondent shall examine
 every container located in [insert  location] to detect any
 leakage, significant corrosion or structural damage likely to
 lead to leakage. Each such leaking, significantly corroded,
 damaged uncovered or bulged container  that may leak or
 burst shall be overpacked or redrummed within 24 hours
 of  discovery. The Respondent shall  within	days of
 detection, report to EPA any leak or inadequate container
 which has  been identified  and the measures taken to
 correct the problem.

 2.   Construct Storage Area/Move  to New Storage
     Area
 Within	days, the Respondent shall designate to EPA or
 construct a storage area in [insert location] that meets the
 standards of 40 CFR §265 (or authorized state standards
 or standards consistent with draft permit conditions) and is
 large enough for all containers presently in areas [insert
 areas]  as Shawn in the attached map, stacked one  high
 with sufficient aisle space. The storage area must have an
 impervious base with side containment walls. The volume
 contained within the walls  shall be sufficient to contain
 10% of the volume  of containers or  the volume of the
 largest container, whichever is greater, The walls must be
 joined to  the base and scaled to prevent any  releases  from
 migrating between the base and  walls.  The Respondent
 shall also submit a schedule for placing  containers in the
 area.

" [If construction is required, within	days  Respondent
 shall submit to EPA for review and comment a  workplan
 and schedule for the construction of the storage area. The
 workplan shall include:

  a. [insert components from Appendices  A, C, D and E].

 Within	days following  EPA's  transmission of
 comments, the Respondent shall  modify the workplan in
   It should be noted that each action listed under a particular unit or
   madia is indapwtdant of «ach. other unless otherwise specified.
   "Set also "Guidance Document (or cleanup of Surface Tank and
   Drum Sites.* OSWER 0380.0-3. May 28. 1985.
accordance with  EPA's  comments.  Within	days
following  EPA's approval or modification, the Respondent
shall implement the  workplan in accordance  with  the
schedule therein.)
Following  approval  of  the storage area by  EPA,  the
Respondent shall consolidate and place containers that do
not require overpacking or redrumming in the storage area,
by [insert date]. Respondent shall overpack or redrum
each leaking, significantly corroded, damaged, uncovered
and bulged container located in  [insert location] area  that
may leak or burst and place the overpacked or redrummed
containers in the storage area by  [insert date].

3.  Segregation

Within	days, the  Respondent shall  segregate
hazardous waste in area [insert area] that is  incompatible
with any waste or other materials  stored in other containers
[or nearby piles, open tanks or surface impoundments in
the area shown in attached map]. Toward this end, within
days, the  Respondent shall submit a workplan  and
schedule  to  EPA for  review  and  comment  for  the
installation of devices and  movement of wastes that will
segregate incompatible  waste. The workplan  shall include
the design, construction and installation of dikes, berms,
walls  or  other devices in  accordance with  40 CFR
§265.177  and movement  of  wastes to  segregate
incompatible wastes. The  plan  shall  include but  is  not
limited to:

  a. [insert components from Appendices A, C, D and E],

Within	days  following  EPA's  transmission  of
comments, the Respondent shall modify the workplan in
accordance  with  EPA's  comments. Withm^__days
following EPA  approval or  modification of the aBove, the
Respondent shall implement the workplan in accordance
with the schedule therein,

4.  Sampling and Analysis

Within	days, the Respondent shall submit a workplan
to EPA for review and comment which details procedures
for sampling and analysis of wastes in [every container or
specify container or other unit] for the following parameters
[insert parameters]  or [Region develops  boiler plate
sampling  and  analysis  plan  and requires  Respondent to
implement it which is the preferred option where time is of
the essence or Respondent is unlikely to  produce an
acceptable workplan]. This  workplan shall include:

  a. [insert the components from  Appendices A, B and E].

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 Within	days  following  f.r>A s  ^arv.-v-Kinr,  .>}
 comments , the Respondent shall modify the v/orkpian in
 accordance with  EPA's  comments.  Within	days
 following EPA'S approval or modification of the workplan,
 the  Respondent  shall  implement  the  workplan  in
 accordance with  the  schedule  therein.  Within	days
 after receipt of lab results, the Respondent shall submit a
 report to EPA with all data generated from the sampling
 and analysis. The report shall include but is not limited to:

 a. [insert the components from  Appendix  B  "Data
    Management Plan" and Appendix E],

 5. Treatment,  Storage  and/or  Disposal  of
    Containers

 Within    days, the Respondent shall submit a workplan
 to EPA" for  review and  comment, for the treatment,
 storage and/or  disposal  of containers  [insert container
 description and  location].  Management of hazardous
 waste shall be conducted on-site in accordance with the
 substantive  requirements of RCRA  or off-site  in
 accordance with RCRA. The workplan shall include:

 a. [insert components from Appendices A and E].
 Within
_days,  following  EPA's  transmission  of
 comments, the Respondent shall modify the workplan in
 accordance with  EPA's  comments. Within	days,
 following EPA approval or modification of the above, the
 Respondent shall implement the workplan in accordance
 with the schedule therein.

 6. Temporary Cover

Within	days, the Respondent shall place a temporary
cover [specify material; e.g.,  synthetic material] over the
containers  in  the  areas [insert areas] to  prevent
precipitation  infiltration,  control water  running off  the
container  area,  prevent air emissions and isolate and
contain contaminated wastes and  volatiles. Respondent
shall inspect the cover on a [specify period] basis, and
shall maintain the cover until [insert  date].

                       TANKS*

1.  Overflow/Secondary Containment

Within	days, to prevent overflow, the Respondent shall
remove waste  from tank  [specify tank] as  shown on
attached map to ensure a freeboard of  at least  2  feet.
Withinj	days,  the  Respondent  shall  monitor on  a
{specify period] basis the liquid level  and maintain the  2
feet freeboard [or submit a workplan to EPA for review and
comment  for the; installation .of  an  impervious secondary
containment  structure with a  capacity  that equals  or
exceeds the volume  of the tank. The  workplan  shall
include but is not limited to:

 a, [insert components from Appendices A, C, D  and E],
v,''.:riir!	days of transmission or EH/- ;	TV,-- •
Respondent shall revise the workplan in accordance   . *
EPA comments. Within    days following Ef?A approve. .•<•
modification of the workplan, the Respondent shall imple-
ment the  workplan  in  accordance  with  the  schedule
therein.

2.  Leak Detection/Repair/Partial or Complete
    Removal

Beginning within	days and on a [specify period] basis
thereafter,  the Respondent shall inspect tanks [specify
tanks] as shown on the attached  map, including valves,
pumps and pipes  (especially joints and connectors)  to
detect leaks or cracks. The Respondent shall repair leaks
and tanks that present structural failure {e.g., cracks). The
Respondent shall immediately remove  the  substances
from the tanks into  other tanks and replace the  tanks if
leaks or cracks cannot be effectively  and permanently
repaired in  situ. The Respondent shall  initiate closure of
the emptied tanks in accordance with  a RCRA  Closure
Plan approved by [specify date],

            SURFACE IMPOUNDMENTS'

The  basic objective of this section is to  provide a concise
description  of the necessary steps to implement interim
measures  at surface  impoundments.  Prior  to the
order/permit issuance, an  initial scoping of the available
information  needs to be conducted. The  initial  scoping
should consist of a  review  of  the  existing information
regarding the hydrogeologic  conditions underlying  the
surface  impoundment, characteristics of the design and
construction of the surface impoundment,  estimated
quantities of wastes stored and  their characteristics. This
information  will be used to:

  » evaluate the type and magnitude of the problem
        dike stability
        freeboard conditions
        releases to ground water, air, surface water
  * identify  depth of subsurface sampling program and
    select appropriate sampling methods
        soil sampling
        ground-water sampling
    - .  waste sampling
  * evaluate and design  the interim measure based on
        site characteristics
        waste characteristics
        technology limitations
  • verification of effectiveness of the interim measure
        operation and maintenance

General language outlined below tailored  to  facility
specifics may be  used to compel  actions  such  as:
reduction of head, removal of wastes and minimization of
further migration of contaminants.
  "See also "Guidance Document lor Cleanup of Surface Tank and
  Drum Site*," OSWER 9380.0-3, May 28, 1986.
                                                There are scenarios where some types of interim measures may not
                                                be appropriate  These scenarios are discussed in the "Guidance.
                                                Document for Cleanup of Surface Impoundment Operable Units,"
                                                January 14, 1986, OSWER 9355.0-13.

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1,  Reduce head

Within	days, the Respondent shall reduce the head by
pumping in surface impoundment [specify Impoundment]
as shown on  the attached map, to a level of [insert leveij
inches below [specify  benchmark]  and thereafter shall
maintain the head at or below that level so as to prevent
overtopping and dike or side wail failure. The Respondent
shall store, treat or  dispose of the pumped materials on-
site in a manner that complies with substantive standards
of RCRA or shal! arrange for off-site storage, treatment or
disposal in accordance with  RCRA, Any  discharges to
navigable waters shall comply with all relevant state  and
Federal  requirements.

2.  Remove Free  Liquids and  Highly  Mobile
    Wastes

Within    days, the Respondent shall submit a  workplan
and schedule to  EPA for review and comment to remove
any  free liquids and  pumpable  materials  in  surface
impoundment [specify impoundment] as  shown on
attached  map. The workplan shall  also  provide  for
Respondent to effectuate  source control  by removing,
stabilizing, treating, and/or isolating (individually  or in
combination)  soils/ sludges down to levels [specify  levels
that would reduce contaminant migration and will protect
human health and  the  environment in the short term) or
[Respondent shall propose  levels  of  cleanup and
justification for such levels]" The workplan shall include:

For Example:

 a. a description of the sampling  and analysis  to be
    conducted to determine  the  characteristics of  the
    wastes to be stabilized, treated or isolated;

   i.   Impoundment  [specify impoundment} will be divided
      into a grid system using two orthogonal control lines,
      one parallel to the axis of  the impoundment,  the
      other positioned to produce a grid of  roughly  equal
      surface area.  Control stakes shall be placed at each
      of the control  lines.

   it.  [specify number of samples] samples shall be taken
      at  each quadrant defined  by  control lines with
      spacing of not less than [specify spacing! "set  and
      not greater than [specify spacing] feet.

   iii.  Samples shall be collected using [insert instrument
      to  be  used]  and analyze for the following  [insert
      Appendix VIII parameters].

 b, a description of all  steps to be taken to effectuate the
    removal,  stabilization, treatment or isolation; and

 c. a description   of  the  sampling and  analysis  to
    determine that the  removal, stabilization, treatment or

  This level may not be  to the extent thai is ultimately necessary to
  protect  the human health and the environment in the long farm.
  Further action may be necessary during implementation ot the final
  remedy after ultimate levels* of cleanup have been determined. This
  approach is generally not appropriate if capping or backfilling of  the
  residual is necessary.
    isolation has been fully undertaken. [Insert additional
    components from Appendices A. C! D and E],

Within	days  following  EPA's  transmission  of
comments, the Respondent shall  revise the  workplan in
accordance  with  EPA's  comments.  Witbin___days,
following EPA approval or modification of the workpian, the
Respondent  shall  implement  the revised workplan in
accordance  with  the  schedule  therein.  Long  term
remediation shall b© effectuated following completion of a
RCRA Facility  Investigation  and  Corrective Measures
Study.

3.  Stabilize/Repair Side Wails, Dikes, or Liner(s)

Within_	days, the Respondent shall submit a workplan
and schedule to EPA for review and comment to stabilize
and  repair and thereafter  maintain the  side walls and
liner(s) of surface impoundment [insert unit number] and
dike area as  shown in the attached map. The workplan
shall include and be supported by an engineering analysis
that includes:

  a. [insert components from Appendices A, C,  D,  E and
   the  "Technical  Guidance Document  on Construction
   Quality Assurance for Hazardous Waste Land Disposal
   Facilities," July 1986. OSWER Directive # 9472.00-3J.

Within_	_days  following  EPA's  transmission  of
comments, the Respondent shall  revise the  workplan in
accordance  with  EPA's  comments. Within_days
following EPA approval or modification of the workplan, the
Respondent  shall  implement  th$ revised workplan in"
accordance with the schedule therein.

4.  Temporary Cover

Within	days, the Respondent shall submit a workplan
to EPA  for review and  comment to  place a temporary
floating  cover of  synthetic  lining  over  surface
impoundment {specify  impoundment],  as  shown  on
attached map to  reduce infiltration of  precipitation and
control air releases. The workplan shall include the design
and  construction of a cover and  method  of application
including  proper anchoring at  the edges  and  floats  to
prevent  the lining from submerging so that precipitation
falling on the impoundment area  runs off  and  does not
pond on the  cover. The workplan  shall also  provide  for
effective  erosion  control.  The  cover  must  have  a
permeability no greater than [specify permeability] cm/sec,
thickness  of (specify thickness] mil,  and be compatible
with the chemical and physical characteristics of the waste
being covered,  local climate  and  the other design
characteristics of the unit including any berms, dikes or
other appurtenances. The plan shall also include:

  a. [Insert components from Appendices A, C, D,  6 and
   the  "Technical  Guidance Document on Construction
   Quality Assurance for Hazardous Waste Land Disposal
   Facilities," July 1986, OSWER  Directive # 9472.00-3].

Within	days  following EPA's  transmission  of
comments, Respondent  shall  revise the workplan  in
accordance  with  EPA's  comments.  Within     days

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following EPA approval  or  modification, the  Respondent
shall implement the revised workplan in accordance with
the schedule therein.

5.  Run-off/Run-on  Control  (Diversion  or
    Collection Devices)

Within	days, the Respondent shall submit a workplan
for  EPA review  and comment  for the  construction and
installation of devices to control surface run-on arid run-
off so that  run-on  and run-off do not enter or leave the
impoundment  area shown  on  the  attached  map.  The
workplan shall include the design of  diversion  and
collection devices  to effect run-on/run-off control. These
devices can consist of but not limited to: dikes and berms,
ditches, diversions, waterways, bench terraces, chutes and
downpipes.  Design  criteria shall  consider 100   year
precipitation events and floods, volume, area  and  flow
rates. The workplan shall include and be supported by an
engineering analysis that includes:

 a. [insert components from Appendices A, C, D and EJ.

It  shall include a schedule for completion  of work.
Within	days following EPA's transmission of comments
on the proposed workplan, the Respondent shall revise the
workplan  in  accordance with EPA's  comments.
Within	days following EPA approval  or modification of
the workplan, the Respondent shall  implement the
approved workplan  in  accordance  with  the  schedule
therein.

6.  Sampling and Analysis of Residuals

Within	days, the Respondent shall submit a workplan
to EPA~Tor review, and comment to sample and  analyze
surface  impoundment [specify  impoundment] shown on
the attached map  to document, the  levels  of the
concentrations of hazardous constituents left in place when
surface  impoundment [specify impoundment] was closed
by removal of wastes.* The workpian shall include but is
not limited to:

For Example:
                                 %
                                 \
 a, a grid system  using two orthogonal control lines one
    parallel to the  axis, the other positioned to produce a
    grid of roughly equal surface area, and control stakes
    at each end of  the control lines;

 b. a minimum of [insert number] boreholes taken at each
    quadrant defined by the control lines with spacing of
    not less than [insert spacing] feet and not greater than
    [insert spacing] feet as shown on attached map and
    extended to a depth of  [insert depth] feet or deeper if
    visual evidence of contaminants exists at each of the
    sampling locations;
 c. screening of cores using [insert method, e.g., HNU or
    OVA]; and

 d. This workplan  shall include the  procedures and
    methods to be followed for the removal and treatment,
    storage or disposal of  contaminated soil and
    groundwater to levels [insert interim levels that would
    reduce contaminant migration and will protect human
    health  and the  environment in  the short term] or
    {Respondent shall propose levels of clean  up and
    justification for  such  levels based  on  the soil and
    waste characteristics]."

 [Insert additional components from Appendices A, B and
 E].

 Within	days following EPA's  transmission  of
 comments on the workplan, the Respondent shall revise
 the workplan in  accordance with EPA's comments.
 Within	days following EPA  approval or modification of
 the workplan, the Respondent shall implement  the
 revised workplan  in accordance  with the  schedules
 therein. Within	days  after  receipt of lab results, the
 Respondent shall  prepare  a  report to present  all  the
 information collected during the investigation. The report
 shall  include  but  is not limited to (for each core  and
 sample, with sample location):

 a. {insert  components  from.  Appendix  8  "Data
 Management Plan" and Appendix EJ.

EPA reserves the right to require further action during the
implementation of the final remedy' and establish levels of
cleanup that  are protective to human  health and  the
environment in the long term.

7.   Interim Ground-water Measures
                                   (Diversion  or
(See Ground-water Section)

                    LANDFILLS

1.  Run-on/Run-off  Control
    Collection Devices)

Within	days, the Respondent shall submit a workplan
for  EPA  review and comment for the  construction  and
installation of devices to control surface run-on and  run-
off so that  run-on and  run-off do  not enter or  leave the
landfill area shown on attached map. The workplan shall
include the design of diversion and collection devices to
effect run-on/run-off  control. These devices  can  consist
of, but not limited to:  dikes and berms, ditches, diversions,
waterways, bench  terraces, chutes  and downpipes. Design
criteria shall consider 100 year precipitation events and
floods,  volume, area and flow rates. The workplan shall
include and be supported by an engineering analysis that
includes:

  a. [insert components  from Appendices A, C, D and E].
  •When this type of surface impoundment is closed by  removal,
  them may be constituents left in place. Some of these constituents
  may present a potential threat to human health or the environment
  (eg. corrosive waste may contain heavy metals}.
  •Ultimate levels for the protection of human health and  the
  environment in the long term will be determined later in  the
  corrective action process.

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The workplan shall include a schedule tor the completion
of work. Within	days following  EPA's transmission of
comments  on the proposed workplan,  the  Respondent
shall  revise  the workplan in  accordance  with EPA's
comments. Within	days following EPA  approval or
modification of the workplan, the Respondent shall imple-
ment the  revised  workplan in  accordance  with the
schedules therein.
2.  Reduce  Head  on  Liner  and/or  Leachate
    Collection System

Within	days,  the Respondent shall reduce the head on
the liner in landfili(s)  [specify  landfill(s)]  shown  on the
attached map  and/or in the leachate collection system  in
landfill(s) {specify  landfill(s)J to a level of [specify  level]
inches as  measured by  [specify  method]  at  [specify
location] and thereafter maintain the head at or below that
level. The  Respondent shall treat, store  or  dispose  of
removed leachate  on-site in a manner that complies with
substantive  standards of RCRA, or shall arrange for off-
site  treatment, storage or  disposal  in compliance  with
RCRA. Any discharges to navigable waters shall comply
with all relevant state and Federal requirements.
3.  Inspect Leachate Collection/Removal  System
    or French Drain

Within    days, the Respondent shall inspect the leachate
collection system in  landfill  [specify  fandfill]  shown on
attached rnap using indirect inspection  methods including
but not limited to monitoring of flow at outlets or access
points, monitoring of leachate  ievel, correlating  leachate
quality with  clogging indicators;  using direct inspection
methods including but not limited to video monitoring or
photographic inspection  of drainage pipes and checking
physical  continuity  of  the pipes  with  sewer  cleaning
equipment. The Respondent shall record all data collected
or observations   made  including  clean areas,  deposits,
obstructions, deterioration, collapse,  and  maintain this
record as  part of the  facility  operating record.  If the
observations or data  collected  demonstrate that leachate
collection system is not functioning to effectively  collect
leachate, or  effectively  transmit it to collection points or
sumps [or does  not  meet the standards consistent with
draft  permit conditions],  the Respondent shall submit the
inspection record to EPA Within	days for review, [See
#4 below}.
4.  Repair  Leachate  Collection/Removal  System
    or French Drain

Within	days, the Respondent  shall clean the leachate
collection system lines in landfill [specify landfill] as shown
on attached  map using  conventional  sewer  cleaning
techniques  to  eliminate  siltation and accumulation  of
chemical, biological and. other  deposits. The Respondent
shall  use [option: insert specific  equipment to be used,
e.g., power redding, balling, flushing, jetting, scooter, kites,
bags,  tires  and  poly  pigs for hydraulic cleaning; and
bucket machine for mechanical cleaning]. Within	days,
the Respondent shall replace sections; of  the  leachate
collection  system  that have been deteriorated  and/or
crushed. In the event that the landfill experiences recurring
leachate perching and poor drainage after the system has
been cleaned, Within	days, the Respondent  shall  drill
caissons to various depths within  the fill and construct a
gravel trench all the way to the bottom of the fill  along the
inside periphery of the unit to prevent leachate perching
and poor  drainage. The Respondent shall pump oul the
perched leachate on a [insert pumping frequency} basis to
maintain the  proper operation of  the  leachate collection
system. The  Respondent shall store, treat or dispose of
the removed  leachate on-site in a manner that  complies
with substantive standards of RCRA, or  shall arrange for
off-site treatment, storage  or disposal  in compliance with
RCRA. Any  discharges to navigable waters shall comply
with all relevant state and Federal requirements.
5.  Temporary Cap

Within	days, Respondent shall submit a workplan for
EPA review and comment to place a cap (temporary) over
the entire landfill [specify landfill] shown on attached map
to prevent precipitation infiltration including  preventing
ponding, control water and wind erosion  and dispersion,
and isolate and contain contaminated wastes and volatiles.
The workplan shall include the design and construction of
a  cover  and method  of application  that  assures that
precipitation is channelled away from the  landfill area and
assures that  precipitation falling on the  landfill runs off
without ponding.  The cap  shall have a  permeability no
greater than [specify permeabilityj cm/sec  as measured by
[specify  method]  and  a minimum thickness  of {specify
thickness] mil or {specify  thickness]  inches  if soil, be
compatible with the chemical and physical characteristics
of the waste being covered,  local climate, hydrogeology
and other design  characteristics of the unit including any
berms or other appurtenances. The workplan shall include
and be supported by an engineering analysis that includes:
     t *
  a. [insert components from Appendices  A, C, D, E and
    the  "Technical Guidance Document on Construction
    Quality Assurance for Hazardous Waste Land Disposal
    Facilities," July 1986, OSWER Directive *  9472.00-3].

Within	days following EPA's transmission of comments
on the proposed workplan the Respondent shall revise the
workplan  in accordance  with  EPA's  comments.
Within	days following EPA approval or modification of
the workplan, the  Respondent shall implement the revised
workplan in accordance with the schedule therein.
6.  Waste Removal

(See Soils Section)


7.  Interim Ground-water  Measures

(See  Ground-water Section)

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                     WASTE PILE

 1.   Run-on/Run-off  Control  (Diversion  or
     Collection Devices)

 Within    days, the Respondent shall submit a workplan
 for EPA review  and comment  for the construction and
 installation of devices to control  surface run-on and run-
 off so that run-on and run-off do not enter or leave the
 waste pile area  shown on  attached map. The workplan
 shall include  the design of diversion and collection devices
 to  effect run-on/rurt-off  control.  These devices can
 consist of, but not limited to; dikes and  berms.  ditches,
 diversions,  waterways, bench  terraces,  chutes and
 downpipes.  Design  criteria shall consider  100  year
 precipitation  events and floods,  volume,  area and flow
 rates. The workplan  shall include and be supported  by an
 engineering analysis that includes:

  a.  [insert components from Appendices A, C, D and E].

 The workplan shall include a schedule  for the completion
 of work. Within	days following EPA's  transmission  of
 comments on  the  proposed workplan,  the  Respondent
 shall revise  the  workplan in accordance with  EPA's
 comments. Within	days following  EPA  approval  or
 modification  of  the workplan,   the Respondent  shall
 implement the revised workplan in accordance with the
 schedules therein.

 2,   Temporary Cover

 Within	days, the  Respondent  shall  submit for  EPA
 review and  comment a  workplan  to  place  a  cap
 (temporary) over the entire waste pile [specify pile] shown
 in attached map to  prevent precipitation infiltration and
 ponding, control  water and  wind erosion  and  dispersion.
 and isolate and contain contaminated wastes and volatiles.
 The workplan shall include the design and construction  of
 a cover and  method of  application that assures that
.precipitation is channelled away  from the  waste pile area
 and assures that precipitation falling on the waste pile runs
 off without ponding. The cover shall have a permeability no
 greater than [specify permeability] cm/sec as measured by
 (specify  method] and a minimum thickness of [specify
 thickness] mil,  be compatible  with the  chemical and
 physical characteristics of the waste being covered, local
 climate, hydrogeology and other design characteristics  of
 the unit including any berms or other appurtenances. The
 workplan shall include and be supported by an engineering
 analysis that includes:

  a. [insert components from Appendices A,  C, D, E and
    the "Technical Guidance Document on  Construction
    Quality Assurance for Hazardous Waste Land Disposal
    Facilities,"  July 1986, OSWER Directive #9472.00-3].

 Within	days following EPA's transmission of comments
 on the proposed workplan the Respondent shall  revise the
 workplan  in  accordance  with  EPA's comments.
 Within	days following EPA .approval or modification of
 the workplan, the Respondent shall Implement the-revised
 workplan in accordance with the schedule therein.
 3.  Waste Removal

 (See Soils Section)                       ?

 4.  Interim Ground-water  Measures

 (See  Ground-water Section)


                       SOILS

    The basic  objective of this section  is to provide  a
 concise description of the necessary steps to implement
 interim measures when there is evidence that substantially
 contaminated soil  is present at the  facility. The  interim
 measures which may apply at the facility include removal
 of contaminated soil and capping to prevent the infiltration
 of contaminants. Prior to  the  order/permit issuance, an
 initial scoping needs to be conducted  to compile and have
 a better understanding of the information already available.
 The initial scoping should consist of the identification of
 the soil contaminated areas, a soil/geologic cross section,
 if  possible,  to  provide a three dimensional overview of
 soils/geology and  extent  of  soil contamination  at  the
 facility,  and hydrogeologic characteristics underlying  the
 facility. Evidence of past spills,  illegal  disposal and lack of
 run-off control  may help to identify contaminated areas.
 This information will be used to:

  » evaluate the type and magnitude of the problem
    -   amount of contaminated  soil

  • determine  the scope of the sampling program and
    select appropriate sampling methods
    -   ground-water  sampling
    •   soil sampling

  » evaluate and design the interim measure based on
    -   site characteristics
    -   waste characteristics
    -   technology limitations

  • verification of effectiveness of the interim measure
    -   operation'and maintenance

    General language outlined  below tailored  to  facility
specifics  may  be used to compel  actions  such  as:
sampling and disposal of contaminated soil and prevention
of further migration  by controlling run-off  and run-on
and infiltration using a cap or cover.
          1.  Sampling/Analysis/Disposal

Within	days, the Respondent  shall submit a workplan
for  EPA review  and comment  for  the sampling  and
analysis of  the soil  in following  areas [insert specific
areas}. Within	days following  EPA's  transmission of
comments on the workplan, the Respondent shall revise
the workplan in  accordance with EPA's comments  and
following EPA  approval  shall implement  the revised
workplan in  accordance with the schedules therein.  The
workplan shall include but is not limited to:
                                                      10

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For Example:

 a. a minimum of {insert number] boreholes at locations
    shown on attached  map and extended to a depth  of
    [specify depth] feet or deeper if visual  evidence  of
    contaminants exists  at each of the sampling locations;

 b, screening of cores using [insert method, e.g., HNU  or
    OVA]; and

 c. In addition, the workplan shall include the procedures
    and  methods to  be  followed for  the removal  and
    treatment, storage or disposal of contaminated soil  to
    [Interim  levels  of cleanup  that  would  reduce
    contaminant migration and will  protect human health
    and the environment in the short term or Respondent
    shall propose interim levels and justification included
    for  such  levels based  on  the  soil  and  waste
    characteristics.l*

[Insert additional  components  from  Appendices A, B and
Within _ days after receipt of lab results, the Respondent
shal!  prepare  a report for EPA review and comment  to
present all  the  information collected during the investi-
gation. The report shall include but is not limited to;

 a. [insert components  from Appendix B "Data  Man-
    agement Plan" and Appendix E],

Long term  remediation  shall  be  effectuated  following
completion of  a RCRA Facility Investigation  and Corrective
Measure Study.

2.  Run-off/Run-on   Control   (Diversion  or
    Collection .Devices)

Within _ days, the  Respondent shall  submit a  workplan
for EPA review and comment  for the construction and
installation of  devices  to control surface run-on  and run-
off so that run-on and run-off do  not  enter or  leave the
contaminated  area  shown on  the  attached map.  The
workplan  shall provide for the  design of  diversion and
collection devices to effect  run-on  and run-off control.
These devices can consist of, but not limited to:  dikes and
berms,  ditches, diversions, waterways, bench  terraces.
chutes and downpipes. The workplan shall include and be
supported by an engineering analysis that includes:

 a. [insert components from Appendices A, C, D and EJ.

It shall include a schedule  for the completion of the work.
Within _ days following EPA's transmission of comments
on the proposed workplan the Respondent shall  revise the
workplan  in  accordance  with  EPA's  comments.
Within _ days following EPA approval or modification  of
the workplan, the Respondent shal) implement the revised
workplan in accordance with the schedules therein.
3,  Temporary Cap/Cover

Within	days, Respondent shall sybmit  a workplan  to
EPA for review and comment to place a cap (temporary)
over the contaminated area shown on the attached map to
prevent precipitation infiltration and ponding, control water
and wind erosion and dispersion, and isolate and contain
contaminated  soils  and voiatiles.  The workplan shall
include the design and construction of a cover and method
of application that assures that precipitation is channelled
away from  the contaminated  area and  assures  that
precipitation falling on the area  runs off without ponding.
The workpfan shall  provide for the design and construction
of a cover that assures that the cap has a permeability no
greater than [specify permeability] cm/sec as measured by
[specify method], thickness of [specify thickness] mil  or
[specify thickness]  inches of clay or both, a minimum
slope of  [specify  slope] percent. The  cover  shall be
compatible  with the chemical and physical  characteristics
of the  waste being covered, local climate,  hydrogeology
and other design characteristics of the unit, including any
berms or other appurtenances. The workptan shall include
and be supported by an engineering analysis that includes:

  a. [insert components from Appendices A, C, D, E and
   the "Technical  Guidance Document  on Construction
   Quality Assurance for Hazardous  Waste Land Disposal
   Facilities," July 1986, OSWER Directive # 9472.00-3].

Within	days following EPA's transmission of comments
on the  proposed workplan the Respondent shall revise the
workplan  in  accordance  with  EPA's  comments.
Within	days following EPA approval or modification  of
the workplan, the Respondent shall implement the revised
workplan in accordance with the schedule therein.

                GROUND WATER*

    The basic objective of this  section  is to  provide a
concise description of the  necessary steps to implement
interim measures  when  there  is evidence that gross
contamination of ground water  has or is occurring at the
facility  and  that the  contamination is spreading.  The
interim measures which may apply at a facility Include
removal of  the gross contamination and capping of the
contaminated area to  minimize  the  spread of the
contamination. Prior to the order/permit issuance, an initial
scoping needs to be conducted  by  agency personnel  to
compile and review the information already available. The
initial scoping should include a review of the physical and
chemical  nature of  the wastes contaminating ground water
(e.g., solubility  in  water, chemical class, density) and a
review  of  the hydrogeologic conditions  at the facility
including: the characteristics of the subsurface geology;
depth to the aquifer; aquifer connections to surface water
and/or  deeper aquifers;  confining layers;  hydraulic
conductivity  of  the aquifer; and horizontal and  vertical
components of groundwater flow. This  information will be
used to:
  •Ultimate  levels tar the protection of human health and  the
  environment in the long term will be specified later in the corrective
  action process.
  *S@9 "L@9Ch$t@  Plume Management,"  November  163$.
  EPA/640/2-85/004,  guidance document for further inlormaiion.
                                                       11

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  » evaluate the type and magnitude of the problem
        amount of contaminated ground water
        identify the potential  pathways of  contaminant
        migration
        rate of contaminant movement

  • determine  the  scope  of  the  sampling program and
    select appropriate sampling methods
        ground-water sampling
        other  direct and indirect  methods (e.g.,  soil gas
        monitoring, geophysical techniques)

  » evaluate and design the interim measure based on
        site characteristics
        waste characteristics
        technology limitations

  » verification of effectiveness of the interim measure
    -operation  and maintenance

    The general language outline below when tailored to
facility specifics may be used to compel actions such as:
delineation/ verification of gross contamination,  sampling
and  analysis, the  installation  of  an  interceptor
trench/sump/subsurface drain system, implementation of a
pump and  treat or in-situ treatment program  and  the
installation  of a temporary cap or cover.


1.  Delineation/Verification of Gross
    Contamination

Within	days, the Respondent shall submit a workplan
to conduct a  groundwater investigation to verify  the
characterization of the gross contamination beneath [insert
unit or areaj. This investigation shall at a minimum provide
tha following information:

  a. A description  of the  horizontal and vertical  extent of
    any immiscible or dissolved contamination  beneath
    [insert unit or area];

  b. The horizontal and vertical direction of contaminant
    movement;

  c. The velocity of contaminant movement;

,  d. The measurement of the  following parameters {insert
    parameters] and  the  concentration  of the  following
    Appendix VIII constituents [insert constituents];

  e. An evaluation of factors  influencing contaminant
    movement; and

  f. An extrapolation of future contaminant movement.

  The workplan shall include the following components:

For Example:

  a, A narrative discussion of the hydrogeologic conditions
    at the facility;  identification of potential contaminant
    pathways;

  b. Description of the ground-water monitoring system;
 c. Description  of the investigatory approach to be used
    to delineate/verify the rate and extent of contaminant
    migration;

 d. Discussion of the number, location, and depth of wells
    to 6e installed  and information  on the design and
    construction of the wells; and

 e. A description of the sampling and analytical program
    to be used to  obtain ground-water monitoring  data.
    [Insert additional components from Appendices A, 8
    and E). Within	days following  EPA's transmission
    of  comments,   the  Respondent  shall  revise  the
    workplan in accordance  with  EPA's comments
    Within	days following EPA approval or modification
    of the workplan, the Respondent shall implement the
    workplan in accordance with the schedule therein.

2.   Sampling and Analysis

Within	days, the Respondent shall submit a workplan
to  EPA for review and comment which details procedures
for sampling and analysis of the ground-water monitoring
wells  [insert numbers].  The  workplan  shall  include
procedures for the:

For Example:

 a. Measurement of depth to fluid surface and/or standing
    water and depth to the bottom of the well;

 b. Detection and  sampling  of  light  and dense phase
    immiscible laye_rs;

 c. Evacuation of the well and withdrawal of the sample;

 d. Analysis of  in-situ/field measured  parameters;  and

 e. Preservation and handling of samples.

 [Insert additional components  from Appendices A, 8, E
 and  the "RCRA  Ground-water  Monitoring Technical
 Enforcement  Guidance Document,"  September 1986,
 OSWER Directive  # 9950.1].

Within	days  following  EPA's  transmission  of
comments, the  Respondent shall revise  the  workplan in
accordance with EPA's comments and  following EPA
approval  shall implement  the  revised workplan  in
accordance with the schedule therein.   .

3.   Interceptor Trench/Sump/Subsurface Drains

Within	days, the Respondent shall submit a workplan
to  EPA for review and comment for the the installation of
[interceptor trench,  sump or subsurface drains] to  contain
and remove the plume  and lower the ground-water table
to  prevent  contact  of  water with waste material. The
workplan  shall include and be supported by an engineering
analysis that includes.

 a. [insert components from Appendices A, C, D and EJ.

Within	days  following EPA's  transmission  of
comments, the  Respondent shall revise  the  workplan in
accordance with EPA comments. Within	days following
                                                      12

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EPA approval  or modification  of the  workplan, the
Respondent shall  implement  the revised  workplan  in
accordance  with the schedule therein. The  Respondent
shall treat, store or dispose of contaminated ground water
pumped  out the [trench sump or subsurface drain] in a
manner that complies with the substantive  standards  of
RCRA  or shall  arrange for off-site treatment, storage  or
disposal  in  compliance  with  RCRA.  Any discharges  to
navigable water shall  comply with all relevant  state and
Federal requirements,

4.  Pump and  Treat/ln-situ Treatment
Within
         days, the Respondent shad  submit for  EPA
review and comment  a workplan for the design  and
installation of injection wells that will allow water within the
plume to be pumped  and treated."  The workplan  shall
include and be  supported by an engineering analysis that
includes:

For Example:

  a. discussion  of the technical factors of importance for
    the installation of the wells including:

   i)  selection  of the number  of welts and  their location
      based on the hydrogeology of  the site, location of
      the plume and the type and amount of contaminants
      present in the ground water;

   ii)  well  design  and  construction equipment  and
      specifications  (i.e.  pumps, pipes, tanks, etc.),
      pumping  cycles and rates, and the area of influence
      for each withdrawal well;

  b. proposed interim levels of cleanup and technical basis
    for such levels.

  [Insert additional components from Appendices A, C, D
  and E].
EPA's comments. Within	days following  EPA approval
or modification  of  the  workplan, th^ Respondent shall
implement changes in operation necessary  to collect and
contain  effectively  contaminated ground water  including
the installation of additional wells.  The Respondent shall
treat,, store or dispose of contaminated ground  water
pumped out of the extraction wells or drains in a manner
that complies with the substantive standards of RCRA, or
shall arrange  for off-site treatment, storage  or disposal in
compliance with RCRA. Any discharge to navigable waters
shall comply with all relevant state and Federal regulations.

S.  Temporary Cap/Cover

Within	days, the Respondent shalt submit a workplan
to EPA for review and comment, for  the design and
installation  of a  cover system  to  minimize rainwater
infiltration  into the waste  disposal  area and slow  the
migration of contamination, The worNplan shall include  and
be supported by an engineering analysis  that includes:

  a. {insert components from Appendices A,  C, D and E].

Within	days following EPA's transmission of comments
on the workplan, the Respondent  shall  revise the work-
plan in accordance with EPA's comments. Within	days
following EPA approval or modification of the workplan, the
Respondent  shall  implement the  revised worNplan
submitted  pursuant to  paragraph  [specify  paragraph] in
accordance with the schedules therein,

            SURFACE WATER RELEASE

1.  Overflow/Underflow Dams

Within	days,  the Respondent shall submit a workplan
to EPA for review and comment for the  installation of
[overflow or underflow] dams at [insert area}. The workplan
shall include and be supported  by an engineering analysis
that includes:
 Within	days following EPA's transmission of comments      a.  [insert components from Appendices A, C, D and E].

                                                         Within  _days  following EPA's  transmission of
                                                         comme*rWs, the Respondent shall revise the workplan in
                                                         accordance with  EPA's  comments.  Within	days
                                                         following EPA approval or modification of the workplan, the
                                                         Respondent shall  implement the  revised  workplan in
                                                         accordance with the schedule therein.
on proposed workplan, the Respondent shall revise the
workplan  in  accordance with  EPA's  comments.
Within	days following EPA approval  or modification of
the workplan, the Respondent shall implement the revised
workplan in accordance with the schedules therein.

Within	days  after the  installation  of the  pumping
system outlined in the above paragraph and  start up, the
Respondent shall  submit to EPA a  report showing the
effectiveness of the pumping, the area of influence, draw
down times and any changes  in operation necessary to
collect or contain the contaminated ground water. If based
on the report EPA determines that the wells are insufficient
to adequately  collect or contain the contaminated ground
water, additional  wells  shall  be  proposed by the
Respondent. Within	days following EPA's  transmission
of comments, on the report the Respondent shall provide a
workplan for an upgraded  system  in  accordance with
   "Parmil may be required for surface discharge, coordination with
   proper authorities is necessary
 2.   Filter Fences

 Within	days,  Respondent  shall  install filter fences  in
 [insert surface water name  and  location]  in  order  to
 prevent further spread of contamination.

 3,   Run-off/Run-on   Control  (Diversion  or
     Collection  Devices)

 Within	days,  the Respondent shall submit a workplan
 to EPA for review and comment for the construction and
 installation  of surface-water  diversion  and collection
 devices. These devices can consist of, but are not limited
 to; dikes and berms, ditches, diversions, waterways, bench
 terraces, chutes  and downpipes. The workplan shall

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include and be supported by an engineering analysis that
includes:

 a, [insert components from Appendices A, C, D and EJ,

It  shall  include  as-designed  topographic maps and- a
schedule. Within	days following  EPA's transmission of
comments, the Respondent shall revise the  workplan in
accordance  with EPA's comments.  Within_	days
following EPA approval or modification of the workplan, the
Respondent shall implement  the  revised workplan in
accordance with the schedule therein.

4,   Regrading/Revegetation

Within_	days, the Respondent shall  submit a workplan
to  EPA  for review and comment for the grading of  the
capped  area  {specify area] as shown on attached  map.
The grading shall be  conducted to [state  objectives], shall
result in run-off away from the area without ponding, no
run-on to the area and, run-off away from water courses.
The  workplan shall  include and  be  supported by an
engineering analysis that includes;

a.   [insert components from Appendices A, C, D and E],

Within	days following EPA's transmission of comments
on the proposed workpian, the Respondent shall revise the
workplan  in  accordance  with  EPA's comments.
Within	days following EPA approval or modification of
the workplan, the  Respondent  shall implement the revised
workplan in accordance with the schedules therein.

Within	days, the Respondent shall  submit to EPA for
review and  comment a workplan to  establish a vegetative
cover to stabilize the surface  of the  hazardous  disposal
site.  The workplan will include and be supported by an
engineering analysis that includes:

For Example:

 a. discussion  of  the technical  factors  of  importance
    including:

    i)   description of soil characteristics including  grain
        size, organic content, nutrient and pH levels and
        water content;

   ii)   selection of suitable plant species;

   iti)   usa of currently acceptable  construction practices
        and techniques including description of seed bed
        preparation, seeding and planting;

 b. tables listing materials, equipment and specifications
   including  types of mulching  and/or  chemical
   stabilizers; and

 c. description of normal  operation,  fertilization   and
   maintenance.

 [Insert  additional components from Appendices A,  C, D
 and E].

 Within	days  following   EPA's  transmission  of
 comments on the workplan, the Respondent  shall revise
  the  workplan in  accordance  with  EPA's  comments.
  Within	days following EPA approval or modification of
  the  workplan,  the  Respondent shall Implement  the
  revised  workplan  in  accordance  with  the schedule
  therein.

S.  Sample  and  Analyze  Surface  Waters and
    Sediments or Point Source Discharges

Within	days, the  Respondent shall submit a workplan
to EPA for review and  comment to sample and analyze
surface water and sediments. The plan shall include:

  a. (insert components from Appendices A, B and E].

The workplan shall provide for respondent to sample and
analyze surface waters and/or sediments located at [insert
locations upstream of adjoining and downstream of areas
which  have  received (point source or  non-point source)
discharges from areas, units of concern]. Samples shall be
analyzed for  the following parameters  [list  Appendix  VIII
parameters!-  Within    days  following  EPA's comments,
the Respondent  shall revise the workplan in  accordance
with EPA's  comments.  Within	days following EPA
approval or modification of the workplan, the Respondent
shall implement the  revised workplan in accordance with
the schedule therein. Respondent shall provide information
on  the  sampling locations and  the  results of analysis
Within	days of receipt from the laboratory.

            GAS MIGRATION CONTROL

1.  Barriers/Collection/Treatment/Monitoring

Within	days, Respondent shall submit a workplan for
EPA review and comment for the design and installation of
a gas migration control system to  control  lateral and
vertical  migration of  gases  or vapors  from  the  landfill
{specify  landfill]. The  gas control  system  shall at a
minimum consist of;

  a. a  passive perimeter gas control system; or
  b. active perimeter gas control system; or
  c. active interior gas collection/recovery system; or
  d. a  combination of the above technologies.

The workplan shall  include  and be  supported  by  an
engineering analysis that includes:

  a. [insert components from  Appendices A, C, D and E
    which have been tailored for the facility specificsj,

Within	days  following  EPA's  transmission  of
comments, the Respondent shall revise the workplan in
accordance  with EPA's comments. Within	days
following EPA approval or modification of the workplan, the
Respondent shall implement the revised workplan  in
accordance with the schedule therein.

            PARTICULATE EMISSIONS

1.  Truck Wash (Decontamination  Unit)

Within_	days, the  Respondent shall submit to EPA for
review and comment a workplan to develop and install
                                                     14

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decontamination  units/procedures to provide  for  tne
effective  cleaning of  vehicles and  personnel entering
contaminated areas  in order to prevent further spread of
contamination. Within	days following EPA's comment,
the Respondent shall  revise the workplan in  accordance
with  EPA's  comments. Within	days following  EPA
approval  or modification of the worKplan, the Respondent
shall implement the revised workplan in accordance with
the schedule therein.

2.  Revegetation

Within    days, the Respondent shall  submit a workplan
to EPA for review and comment to establish a vegetative
cover to  stabilize  the  following contaminated surfaces
[insert areas}. The  workplan shall include  and  be
supported by an engineering analysis that includes:

  a. [insert components from Appendices A, C, D and E].

Within	days, the Respondent shall revise the workplan
in accordance with EPA's comments.  Within	days
following EPA approval or modification of the workplan, the
Respondent  shall  implement  the revised workplan to
establish a vegetative cover to stabilize the contaminated
surfaces  in accordance with the schedule therein.

3.  Application of Dust Suppressant

Within	days,  the Respondent  shall  spray
uncontaminated water every [specify  time frame] hours in
areas [insert areas]  to control  dust emissions. The
Respondent shall not use collected  leachate, used oil or
hazardous waste to control dust emissions.
                  OTHER ACTIONS

 1.   Fencing to Prevent Direct Contact

 Within	days the Respondent shall  install  security
 fencing [insert  type  of fence]  of a minimum of [specify
 height]  feet  high  around the perimeter of the [insert
 site/unit/work area), warning signs and other measures to
 limit access to the facility.

 2.   Sampling Off-site Areas

 Within	days, the  Respondent shall submit a  workplan
 to  EPA for review and comment to  collect and analyze
 samples from drinking water wells located within a [specify
 distance! mile  radius  of the facility.  Samples  shall  be
 analyzed for the following parameters: [insert parameters].
 The workplan  shall  include but not  be limited to the
 following:

  a. [Insert components from Appendices A, B and E].

 In  the  event that said permission is not obtained, the
 Respondent shall demonstrate to the satisfaction of EPA,
 that the Respondent  was  unable to obtain  necessary
 permission.
3.  Alternate  Water  Supply  to  Replace
    Contaminated Drinking Water

Withm	days, the Respondent shall provide an alternate
water supply  to  the  [insert area  name of affected
community]. The alternate water supply shall consist of,
but is not limited to:

 a. purchase of water from another supply; or
 b. provision of a new surface water intake(s); or
 c. provision of a new ground-water well{s); or
 d. provision of bottled and bulk water; or
 e. provision of point-of-use wells;  or
 f,  combination of the above as necessary.

Within	days, the  Respondent shall submit a workplan
to EPA for  review  and comment  for the  design  and
construction of  a  system(s)  for  the  treatment of
contaminated water supplies. The treatment shall consist
of, but is not limited to:

 a. treatment of contaminated central water supplies; or
 b. point-of-use treatment;  or
 c. combination of the above as necessary.

The  workplan  shall include and be supported by an
engineering analysis that includes:

 a. [insert components from  Appendices A, C, D and E].

Within	days  following EPA's transmission of
comments, the  Respondent  shall revise the workplan in
accordance  with  EPA's comments. Within  	days
following EPA approval or modification of the worEplan, the
Respondent shall implement the revised workplan in
accordance with the schedule therein.

4.  Temporary Relocation of Exposed Population*

5.  Temporary or Permanent Injunction*

6.  Si/Spend or Revoke  Authorization to Operate
    Under Interim Status*
  •Order language not included.
                                                      15

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APPENDIX A,
APPENDIX B.
APPENDIX C.
APPENDIX D,
                           INTERIM MEASURES APPENDICES
INTERIM MEASURES WORKPLAN
1. Interim Measures Objectives
2, Health and Safety Plan
3. Community Relations Plan

INTERIM MEASURES INVESTIGATION PROGRAM
1. Data Collection Quality Assurance Plan
2. Data Management Plan

INTERIM MEASURES DESIGN PROGRAM
1, Design Plans and Specifications
2. Operations and Maintenance Plan
3. Project Schedule
4, Final Design Documents

INTERIM MEASURES CONSTRUCTION QUALITY ASSURANCE PLAN
1. Construction Quality Assurance Objectives
2, Inspection Activities
3. Sampling Requirements
4. Documentation
APPENDIX E.    REPORTS
                1. Progress
                2, Interim Measures Workplan
                3. Final Design Documents
                4. Draft Interim Measures Report
                5. Final Interim Measures Report
                                           16

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                                                APPENDIX A
INTERIM MEASURES WORKPLAN
[This  appendix contains the  recommended  components
(the objectives, a health and safety plan and a community
relations plan) for  an interim measures workplan. When
interim measures are taking place at the same time  as a
RCRA Facility Investigation (RFI), the RFI workplan  may
incorporate health  and  safety and  community  relations
plans  sufficient for  the interim  measure activities.
Additional components  may  need to be added to this
workplan. For example,  if  media  investigations are
necessary,  see  Appendix  B  -  Interim  Measures
Investigation  Program, for details to be added  to the
workplan. If an interim  measure design is necessary, see
Appendix C  - Interim  Measures Design Program, for
details to be  added to the  workplan. If a  construction
quality assurance program is  required, see Appendix D -
Interim Measures Construction Quality  Assurance Plan, for
details to be added to the workplan. If progress, draft and
final reporting are required, see Appendix E - Reports, for
details to be  added to the  workplan. Language  in the
appendices should be modified to take into account site-
specific technical detail.]

The  Respondent  shall prepare  an  Interim Measures
Workplan. The Workplan shall include  the development of
several plans which shall be prepared concurrently.

A,  Interim Measures Objectives

The Workplan shall specify the objectives of the  interim
measures,  demonstrate how  the  interim measures will
abate releases .and threatened releases, and, to the extent
possible, be consistent and integrated with any long  term
solution at the facility. The Interim Measures Workplan will
include  a discussion  of   the  technical  approach,
engineering design, engineering plans, schedules, budget,
and  personnel.  The  Workplan  will  also  include  a
description of qualifications  of personnel  performing  or
directing the interim  measures,  including  contractor
personnel.  This  plan shall  also  document the  overall
management approach to the interim measures.

B.  Health and Safety Plan

The 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 Describe the  known hazards and evaluate the
         risks associated with the incident and with  each
         activity conducted,  including, but not limited  to
         on  and  off-site exposure  to  contaminants
         during the  implementation of interim measures
         at the facility.
      c  List key personnel and alternates responsible for
         site safety,  responses operations, and for
         protection of public health;

      d. Delineate work area;

      e. Describe levels of  protection to be worn by
         personnel in work area;

      f.  Establish procedures to control site access;

      g. Describe  decontamination  procedures for
         personnel and equipment;

      h. Establish site emergency procedures;

      i.  Address emergency medical care  for injuries
         and toxicofogical problems;

      j.  Describe  requirements  for an  environmental
         surveillance program;

      k. Specify any routine and  special training required
         for responders; and

      I,  Establish 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.

    3. The Health and Safety Plan shall be  revised to
      address the activities to be performed at the facility
      to implement  the interim measures.

C.  Community Relations Plan

The Respondent  shall prepare a plan, for  the
dissemination of information to  the public regarding interim
measure activities  and results.   These activities  shall
include the preparation and distribution  of fact sheets and
participation in public meetings.
                                                     A-1

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                                               APPENDIX B
INTERIM MEASURES INVESTIGATION PROGRAM
[This  appendix should  be incorporated in the  scope of
work  and the interim measures workplan when media
sampling wilt be undertaken, i.e., prior to source removal.
The components of this appendix are a Data Collection
Quality Assurance Plan and a Data Management Plan. This
appendix should be  modified to take  into account site-
specific technical detail.]

A.  Data Collection Quality Assurance Plan
    The Respondent  shall prepare a plan to document all
    monitoring procedures: sampling, field measurements
    and  sample  analysis  performed during  the
    investigations to  characterize  the  source  and
    contamination,  so as to ensure  that all  information,
    data  and  resulting  decisions are technically  sound,
    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 tor 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 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;

             ii)   Number of sampling points;

            iii)   Representativeness  of  selected
                 analytical parameters.
    2. Sampling and Field Measurements
       The Sampling and Field Measurements section of
       the  Data Collection  Quality Assurance Plan shall
       discuss:

       a.   Selecting appropriate  sampling  and field
            measurement locations, depths, etc.;

       b.   Providing a sufficient number of sampling  and
            field measurement sites;

       c.   Measuring all necessary ancillary data;

       d.   Determining which media are to be sampled
            (e.g., ground water, air, soil, sediment, etc,);
    e.  Determining  which parameters are to be
       measured and where;

    f..  Selecting the frequency of sampling and field
     •  measurement and length of sampling period;

    g.  Selecting the  types  of  sample  (e.g.,
       composites  vs.  grabs) and  number  of
       samples to be collected;

    h.  Documenting  field sampling  and  field
       measurement operations  and  procedures,
       including:

         i) Documentation of procedures  for
           preparation of reagents or supplies which
           become an integral part  of the sample
           (e.g.r filters, and adsorbing reagents);

         ii) Procedures and forms for recording the
           exact location and specific considerations
           associated  with  sample  and  field
           measurement data 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 and field measurement order;
           and

        xi) Decontamination procedures.

    i.  Selecting appropriate sample containers;

    j.  Sample preservation; and

    k.  Chain-of-custody,  including:

         i) Standardized  field  tracking  reporting
           forms to establish sample custody in the
           field prior to shipment; and

         ii) Pre-prepared  sample labels containing
           all information necessary for  effective
           sample tracking.
3. Sample Analysis

    The  Sample  Analysis  section of the  Data
    Collection Quality  Assurance Plan shall specify
    the following:
                                                     6-1

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3.  Sample Analysis
    The Sample Analysis  section of  the  Data
    Collection Quality  Assurance Plan shall  specify
    the following:
    a.   Chain-of-eustody  procedures, including:

         i)  Identification 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 dispersion for analysis.
    b.   Sample  storage and holding 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 samplQ(s);

        vii)  Control charts;

        viii) Surrogate  samples;

         ix)  Zero and span gases; and

         x)  Reagent quality control checks
    [Note; A performance audit may be conducted by
        g,S, EPA on the laboratories selected by the
        Respondent]
    h.   Preventive  maintenance procedures  and
        schedules;
        *,   Corrective  action (tor  laboratory  problems);
           and
        j.   Turnaround time.         "     •
B.  Data Management Plan
    The. 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  analysts ID number;
        e.  Property or component measured; and
        f.   Result of analysts (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
           constituent monitored;
        c.  Data reduction for numerical analysis;
        d.  Sorting  of data by  potential stratification
           factors (e.g., location, soil layer, topography);
           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,  isqpleth 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.  Display  levels of  contamination at each
           sampling location;

        d.  Display geographical extent of contamination;

        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.
                                                   B-2

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                                                 APPENDIX C
INTERIM MEASURES DESIGN PROGRAM

(This appendix should be incorporated  in the scope  of
work and  the interim  measures  workplan  when trie
Respondent will be required to prepare construction plans
and  specifications to implement the interim measure(s) at
the  facility.  The components  of this appendix include:
design plans and specifications, operations  and
maintenance plan,  project schedule, and final design
documents.  This appendix should be modified to take into
account site-specific detail.]

A.   Design Plans and Specifications

     The  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.

        c.  Facility Layout

        d.  Utility Locations

     6.  Tables  listing  materials,  equipment  and
        specifications;

     7.  Tables giving material 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.

    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 Respondent
    shall coordinate and cross-check the  specifications
    and drawings and complete the proofing of the edited
    specifications  and  required  cross-checking  of  all
    drawings and specifications.

B.  Operation and Maintenance Plan

    The  Respondent  shall prepare  an Operation and
    Maintenance Plan to cover both  implementation and
    long term maintenance of the  interim  measure. The
    plan shall be composed of the following  elements:

    1.   Equipment start-up and operator training

        The 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.

    2.   Description of normal operation and maintenance
        (O&M):

        a.  Description of tasks for operation;

       'to  Description of tasks for maintenance;

        c.  Description of  prescribed  treatment  or
           operation conditions;

        d.  Schedule showing frequency  of each  O&M
           task; and

        e.  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
                                                     C-1

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        d  Schedule of monitoring frequency and date, if
           appropriate, when monitoring may cease.

    4.   Description of equipment:

        a  Equipment identification;

        b.  Installation of monitoring components;

        c.  Maintenance of site equipment; and

        d.  Replacement  schedule for  equipment  and
           installed components.

    5.   Records and reporting mechanisms required:

        a.  Daily operating logs;

        b.  Laboratory records;

        c.  Mechanism for reporting emergencies;

        d.  Personnel and maintenance records; and

        e.  Monthly/annual  reports  to Federal/State
           agencies.

        The Operation and Maintenance Plan shall  be
        submitted with the Final Design Documents,

C.  Project Schedule

    The  Respondent shall develop a  detailed Project
    Schedule for construction and implementation of the
    interim measure(s) which identifies timing for initiation
    and completion of all critical  path tasks. Respondent
    shall specifically identify dates for completion of the
    project and  major interim  milestones which  are
    enforceable terms of this order. A  Project Schedule
    shall be  submitted simultaneously with  the  Final
    Design Documents.

D.  Final Design Documents

    The Final Design Documents  shall consist of the Final
    Design Plans and Specifications (100% complete), the
    Final Draft Operation and Maintenance  Plan, and
    Project Schedule. The  Respondent shall submit the
    final  documents  100% complete with  reproducible
    drawings and specifications. The quality of the design
    documents should be such that the Respondent would
    be able to include them in a bid package  and invite
    contractors to submit bids for the construction project.
                                                    C-2

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                                               APPENDIX D
INTERIM  MEASURES  CONSTRUCTION  QUALITY
ASSURANCE PLAN

{This  appendix should be incorporated in the scope of
work and the interim measures workplan when  the interim
measure to be implemented will  require a construction
quality assurance (CQA) pian to ensure, with a  reasonable
degree of certainty, that a completed  interim  measurers)
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  following  elements:
construction  quality assurance  objectives,  inspection
activities, and documentation.  This  appendix  should be
modified  to take  into account site-specific detail. Upon
EPA approval of  the  CQA  plan,  the  Respondent  shall
construct  and implement  the  interim  measures in
accordance  with the approved design,  schedule,  CQA
pian, and operation and maintenance plan.]

A.  Construction Quality  Assurance Objectives

    In  the CQA plan,  the  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. The responsibility and authority of all
    organizations  (i.e., technical consultants, construction
    firms,  etc.) 'and  key personnel involved  in  the
    construction of the interim measure shall be described
    fully in  the CQA plan. The Respondent must identify a
    CQA officer and the necessary supporting inspection
    staff.

B.  Inspection Activities

    The observations and tests that wilt be used to monitor
    the construction and/or installation of  the components
    of the interim  measure(s) shall be summarized in ihe
    CQA pian. 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  Respondent  shall  conduct  the
    following activities:

    1,   Reconstruction inspection  and  meeting

       The Respondent shall  conduct a  preconstruction
       inspection and meeting to:

       a.   Review  methods  for  documenting  and
            reporting 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  ad-
            dressed; 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  Respondent
        shall notify EPA for the purposes of conducting a
        prefinal inspection.  The  prefina! inspection  wilt
        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  interim  measure. Any outstanding
        construction  items  discovered during  the
        inspection will be   identified  and   noted
        Additionally,  treatment equipment will  be
        operationally tested by  the Respondent. The
        Respondent will certify that the equipment  has
        performed  to meet the  purpose and intent of the
        specifications. Retesting 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  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.

C.  Sampling Requirements

    The sampling  and  testing activities, sample size.
    sample  and test  locations,  frequency  of  testing,
    acceptance and rejection  criteria, and  plans  for
                                                    D-t

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    correcting problems should be presented in the CQA
    plan,

D.  Documentation

    Reporting requirements for CQA activities shall  be
    described in the CQA plan. This plan shall  include
    such items as daily summary reports, inspection data
    sheets, problem identification and  interim measures
    reports, design acceptance  reports,  and  final
    documentation.  Provisions for  final storage of  all
    records shall be presented in the CQA plan.
                                                   D-2

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                                                APPENDIX E
REPORTS
[This  appendix  should be incorporated in the scope  of
work  and the  interim  measures  workplan  when the
Respondent  prepares plans, specifications, and reports  to
document  the  design,  construction,   operation,
maintenance, and monitoring of the interim measures. The
documentation shall  include,  but not be  limited to the
following:  progress reports, interim  measures  workplan,
final design  documents, draft  and final interim measures
report.]

A.  Progress

    The Respondent  shall at a minimum provide the EPA
    with signed, monthly progress reports containing:

    1.  A description and estimate of the percentage  of
        the interim measures completed;

    2.  Summaries of all findings;

    3.  Summaries of all  changes made in the interim
        measures 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.  Interim Measures Workplan

    The  Respondent shall  Submit  an Interim  Measures
    Workplan as described in Appendices A, B, C, and D.

C.  Final Design Documents

    The Respondent  Shalt submit the Final  Design
    Documents as described in Appendix C,

D.  Draft Interim Measures Report

    At the "completion" of the construction of the project
    (except  for  long  term  operation, maintenance and
    monitoring),  the  Respondent shall submit an Interim
    Measures Implementation Report to the Agency. The
    Report shall document that the project is consistent
    with the design  specifications, and  that  the interim
    measures are performing adequately. The Report shall
    include, but not be limited to the following element?:

    1.  Synopsis of the interim measures and certification
        of the design and construction;

    2.  Explanation of any modifications to the plans and
        why these were necessary for the project;
    3.   Listing  of the  criteria,  established  before the
        interim  measures were  initiated, for  judging the
        functioning of the  interim measures  and also
        explaining any modification to these criteria;

    4.   Results of facility monitoring,  indicating that the
        interim measures  will  meet or exceed  the
        performance criteria; and

    5.   Explanation  of the  operation  and maintenance
        (including monitoring) to be  undertaken at the
        facility.

    This report  shall  include of  the 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.

E.  Final  Interim Measures Report

    The Respondent  shall finalize the Interim  Measures
    Workplan and the Interim Measures Implementation
    Report incorporating comments  received  on  draft
    submissions.
                                                     E-1

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Facility Submission Summary

A  summary of the information reporting  requirements
contained  in  the  Interim  Measures  Scope of Work  is
presented below:

                     FACILITY SUBMISSIONS
                                                                               DUE DATE-
       INTERIM MEASURES WORKPLAN

           -Interim Measures Objectives

           -Health and Safety Plan

           -Community Relations Plan

           -Data Collection QA Plan

           -Data Management Plan

           -Construction QA Plan

       Final Design Documents

           -Design Plans and Specs

           -O&M Plan

           -Project Schedule

       Draft Interim Measures Report

       Final Interim Measures Report

                      «
       Progress Reports
SPECIFY DATE
SPECIFY DATE
Upon completion of construction

15 days after receipt of EPA comments on Draft Interim
Measures Report

MONTHLY
      "All dates are calculated from the effective date of this order unless otherwise specified.
                                                       E-2
                                                                     •&U.S. GOVERNMENT PRINTING Of FICE: 1988/548-158/67133

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