>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.
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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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