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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 5
230 SOUTH DEARBORN ST.
CHICAGO, ILLINOIS 60604
REPLY TO THE ATTENTION OF:
1 6 JUN 1987
MEMORANDUM
RCRA Region V Policy on Ground Water Restoration at Solid
Waste Management Units
Basil G. Constantelos,
Waste Management Divisi
SUBJECT:
FROM:
TO: Waste Management Division Staff
This memorandum sets forth the Region V policy establishing ground water
protection standards for facilities seeking a permit having non-RCRA-
regulated Solid Waste Management Units (SWMUs), or facilities not seeking a
permit that have either RCRA-regulated or non-RCRA-regulated SWMUs.
As you are aware, 40 CFR 264.101 requires that owners or operators of
facilities seeking permits for the treatment, storage or disposal of
hazardous waste must institute corrective action as necessary to protect
human health and the environment for all releases of hazardous waste or
constituents from any SWMU, regardless of the time at which the waste was
placed in such unit. SWMUs that received hazardous waste after July 26,
1982 (regulated units), must comply with the Corrective Action
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merely because there are no current or projected plans or intentions to
use the aquifer as a source of drinking water. In addition, ground water
should not be considered "undrinkable" solely because of contamination
caused by the facility which is subject to corrective action. In this case,
cleanup targets should be set at the health-based standards described
above.
In general, the goal of corrective action should be to achieve cleanup levels
as soon as practicable. However, in determining the timing of cleanup, the
permit writer may consider such factors as the availability of treatment and
disposal capacity, the financial status of the facility owner/operator and his
ability to pay, and the imminence of threats to human health and the environ-
ment.
These standards should be employed in the following circumstances:
1) The Corrective Action part of the HSWA portion of the RCRA permit,
2) Requests for Applicable or Relevant and Appropriate requirements
(ARARs) from Superfund (CERCLA),
3) For standards that will be included in Section 3008(h) Corrective
Action Administrative Orders, and
4) Any other requests the U.S. EPA may respond to from other government
agencies.
If you have any questions regarding this matter, please contact Richard Rupert
or Carol Witt of my staff, at FTS 886-1960 or FTS 886-6146, for assistance in
implementing this policy.
cc: Frank Covington
Henry Longest, WH-543
Gene Lucero, WH-527
Marcia Williams, MH-562
William.Sanders, ESD
Robert Schaefer, ORC
Robert Springer, PMO
Charles Sutfin, WD
Roger Field, ORC
Liz Maxwell, ORC
State Division Directors
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CORRECTIVE ACTION ORDER WORKSHOP
Discussion of Regional Issues and Specific Cases
Information Sources:
a) IRIS - Integrated Risk Information System
Updated by U.S. EPA Reference Dose Work
Group and Carcinogen Review Group.
Accessible through E-Mail by typing >IRIS
with a personal computer with communications
software (Cross-Talk), word processors (Lexitron),
computer terminals.
Services: Chemical Files
List of 205 Chemicals
File Revision History
Background Information
Glossary
Users Guide
Report: Oral/Inhalation reference dose
Risk estimate for carcinogenicity
Drinking water health advisories
Risk management summaries
Supplemental data
Synonyms
Contact: EMail user support FTS 382-5639
IRIS coordinator FTS 382-7315
b) PHRED - Public Health Risk Evaluation Database
Chemical specific information.
Superfund Public Health Evaluation Manual
Available on personal computer hard drive,
or on disk.
Various Information on 364 chemicals, select 5 fields:
CAS Registry Number
Molecular Weight
Water Solubility
Vapor Pressure
Henrys Law
KOC
Log Kow
Fish BCF
Half Life-Soil
Half Life-Air
Half Life-Sur. Water
Oral MED
Oral RVe
Oral wTn
Inhalation MED
Inhalation aTn
Oral ED10
Oral wTc
Oral sTc
Inhalation ED10
Inhalation aTc
WQC Aqua, organisms + DW
WQC Drinking Water Only
Drinking Water MCL
Drinking Water MCLG
Clean Air Act NAAQS
DW HAs - One-day
DW HAs - Ten-day
HA Longer-term 10 kg
HA Longer-term 70 kg
HA Lifetime
Ref. Concentration-Pot. Carcin
Contact: Dr. Craig Zamuda FTS 382-2182
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-2-
c) Dialog - Dialog Information Retrieval Service.
On-Line database system, personal computer.
220 databases available, 110 million records
Located Palo Alto, CA
*Chemnane - 1,572,000 chemical substances, CAS
Registry Number, molecular formula,
synonyms, searchable by tradename.
*Chemical Exposure - 1974-present, 11,300 records,
comprehensive database of chemicals
that have been identified in both
humans and animals. Body burden infor-
mation, exposure, etc.
CA Search - 1967-present, 6,840,000 records, contains
bibliographic data, keyword phrases, and
index entries.
*Enviroline - 1971-present, 115,500 records, produced
by the Environment Information Center,
covers the world's environmental infor-
mation.
*Medline - 1966-present, 4,687,000 records, U.S.
National Library of Medicine, major
source of biomedical literature.
*Pollution Abstracts - 1970-present, leading resource
for references to environmentally related
literature on pollution, its source, and
its control.
SciSearch - 1974-present, multidisciplinary index
to the literature of science and tech-
nology.
Contact: U.S. EPA Library, Region V: 353-2022
Chicago Dialog Office contact: (312)726-9206
d) QSAR - Quantitative Structure Activity Relationships
A structure-activity based chemical modeling
and information system - Montana State University.
(406)994-4481
Accessible chemical name CAS number or Smiles string.
*Ecotox option generates a series of exposure assessment
and characteristic displays for the chemical specified
in the QSAR structure option:
Exposure Assessment
Biodegradation Half-Life
*Henry's Law Constant and Environmental Partitioning
Aquati c Toxicity
Phytotoxicity
*Genetic/Mutagenic Assessment
Aqui re
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INTEGRATED RISK INFORMATION SYSTEM: Chemical Files
Methylene Chloride; CAS No. 75-09-2 (Revised 11/16/1986)
USE AND INTERPRETATION OF THE DATA IN IRIS
Health risk assessment information on chemicals is included in IRIS only
after a comprehensive review of chronic toxicity data by work groups
composed of U.S. EPA scientists from several Agency Program Offices. The
summaries presented in Sections I and II represent a consensus reached in
those reviews. The conceptual bases of these risk assessments are described
in Appendices A & B in Service Code A. The other sections are supplementary
information which may be useful in particular risk management situations, but
have not yet undergone comprehensive U.S. EPA review. The risk management
numbers (Section V) may not be based on the most current risk assessment, or
may be based on a current, but unreviewed, risk assessment, and may take into
account factors other than health effects (e.g., treatment technology). When
considering the use of risk management numbers for a particular situation,
note the date of their development, the date of the most recent risk
assessment, and whether technological factors were considered. For a more
detailed description of procedures used in these assessments and the
development of risk management numbers, see Appendix E in Service Code 4.
STATUS OF DATA FOR Methylene Chloride
I. Chronic Systemic Toxicity: Noncarcinogenic Health Effects
A. Oral RfD: available
B. Inhalation RfD: none
II. Risk Estimates for Carcinogens: under review
III. Drinking Water Health Advisories: none
IV. Risk Management Summaries: available
V. Supplementary Data: none
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Methylene Chloride: page 2 of 6
I. CHRONIC SYSTEMIC TOXICITY: NONCARCINOGENIC HEALTH EFFECTS
INTERPRETATION OF CHRONIC SYSTEMIC TOXTCITY DATA
The Reference Dose (RfD) is based or. the assumption that thresholds may exist
for certain toxic effects such as cellular necrosis, but may not exist for
other toxic effects such as carcinogenicity. The RfD is considered to be the
level unlikely to cause significant adverse health effects associated with a
threshold mechanism of action in humans exposed for a lifetime. RfDs can
also be derived for the noncarcinogenic health effects of compounds which are
also carcinogens. Therefore, it is essential to refer to section II, and
other sources as well, for risk assessment information pertaining to the
carcinogenicity of this compound. Please refer to the Background Document on
the RfD (Appendix A) in Service Code 4 for an elaboration of these concepts.
A. REFERENCE DOSE (RfD) FOR ORAL EXPOSURE
Chemical: Methylene Chloride
CAS No.: 75-09-2
Preparation Date: 06/13/86
1. REFERENCE DOSE SUMMARY TABLE
Critical Effect
Experimental Doses *
UF
MF
RfD
Liver toxicity
2-year rat drinking
water bioassay
National Coffee
Association (1982)
NOAEL: 5.85 and 6.47
mg/kg/day for males
and females,
respectively
LOAEL: 52.58 and
58.32 mg/kg/day for
males and females,
respectively
100 1 6E-2
mg/kg/day
* Dose Conversion Factors & Assumptions: none
2. PRINCIPAL AND SUPPORTING STUDIES
National Coffee Association. 24-Month chronic toxicity and oncogenicity
study of methylene chloride in rats. Final Report. Prepared by Hazleton
Laboratories America, Inc., Vienna, VA, August 11, 1982.
The chosen study appears to have, been very well conducted, with 85 rats/
sex at each of four dose groups. A high-dose recovery group of 25 rats/sex,
as well as two control groups of 85 and 50 rats/sex, was also tested. Many
effects were monitored.
The supporting data base is limited. A NOAEL of 87 mg/cu. m was reported
in one inhalation study (Haun, et al., 1972). [The equivalent oral dose is
about 28 mg/kg bw/day (i.e., 87 mg/cu. m x 0.5 x 0.223 cu. m/day/0.35 kg;
these exposure values are for rats).]
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Methylene Chloride: page 3 of 6
3. UNCERTAINTY AND MODIFYING FACTORS
UF - 100. (lOa x lOh) The 100-fold factor accounts for both the expected
Intra- and interspecies variability to the toxlclty of this chemical In lieu
of specific data.
MF - 1
4. ADDITIONAL COMMENTS
None.
5. CONFIDENCE IN THE RfD
Study: High Data Base: Medium RfD: Medium
The study Is given a high confidence rating because a large number of
animals of both sexes were tested In four dose groups, with a large number of
controls. Many effects were monitored and a dose-related increase In severity
was observed. The data base is rated medium to low because only a few studies
support the NOAEL. Medium confidence in the RfD follows.
6. DOCUMENTATION AND REVIEW
U.S. EPA. Drinking Water Criteria Document for Methylene Chloride. Office
of Drinking Water, Washington, DC. (1985)(Draft)
The ADI has been reviewed by the U.S. EPA's ADI (RfD) Work Group.
Agency RfD Work Group Review: 06/24/85, 07/08/85, 11/06/85
Verification Date: 11/06/85
7. U.S. EPA CONTACTS
Primary: K. Khanna FTS/382-7588 or 202/382-7588
Office of Drinking Water
Secondary: M.L. Dourson FTS/684-7544 or 513/569-7544
Office of Research and Development
B. REFERENCE DOSE (RfD) FOR INHALATION EXPOSURE
Chemical: Methylene Chloride
CAS No.: 75-09-2
Information Is not available at this time.
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Methylene Chloride: page 4 of 6
II. RISK ESTIMATES FOR CARCINOGENS
Chemical: Methylene Chloride
CAS No.: 75-09-2
This chemical is among those substances evaluated by the U.S. EPA for
evidence of human carcinogenic potential. This does not imply that this
chemical is necessarily a carcinogen. The evaluation for this chemical is
under review by an inter-office Agency work group. A risk assessment summary
will be included on IRIS when the review has been completed.
III. DRINKING WATER HEALTH ADVISORIES
Chemical: Methylene Chloride
CAS No.: 75-09-2
Information is not available at this time.
IV. RISK MANAGEMENT SUMMARIES
Chemical: Methylene Chloride
CAS No.: 75-09-2 Preparation Date: 10/16/86
INTERPRETATION OF RISK MANAGEMENT DATA
EPA risk assessments may be continuously updated as new data are published
and as assessment methodologies evolve. Risk management (RM) decisions are
frequently not updated at the same time. Carefully read the dates for the
risk management actions (in this section) and the verification dates for the
risk assessments (in sections I & II), as this may explain apparent inconsis-
tencies. Also note that some risk management decisions consider factors not
related to health risk, such as technical or economic feasibility. Such
considerations are indicated in the table below (Considers Econ/Tech
Feasibility). Please direct any questions you may have concerning the use of
risk assessment information in making a risk management decision to the
contact listed in Part B of this section (Risk Management Rationale). Users
are strongly urged to read the background information on each RM action in
Appendix E in Service Code 4.
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Methylene Chloride: page 5 of 6
A. RISK MANAGEMENT ACTIONS
Risk
Management
Action
Reportable
Quantity (RQ)
Status
Date
Final
1985
Risk
Management
Value
1000 Ibs.
Considers
Econ/Tech
Feasibility
no
Reference
50 FR 13456
04/04/85
Water Quality
Criteria (WQC):
a. Human Health Final
1980
b. Aquatic Toxicity
1) Freshwater Final
1980
2) Marine
Final
1980
Clean Air Act (CAA)
Regulatory Decision:
Nat. Emissions Current
Standards for 1985
Hazardous Air
Pollutants (NESHAP)
Hazardous Waste Final
Constituent 1985
(App. VIII)
0.19 ppb no
Acute no
11,000 ug/1
Chronic
none
Acute no
12,000 ug/1
Chronic
6,400 ug/1
Under no
development
Listed no
45 FR 79318
11/13/80
ibid.
ibid.
FR
10/17/85
40 CFR Part 261
App. VIII
B. RISK MANAGEMENT RATIONALE
The final adjusted RQ of 1000 pounds is based upon a chronic toxicity
score of 10. This substance has recently been identified for assessment of
carcinogenicity, and the RQ will be reevaluated when that assessment is
completed.
Contact: RCRA/Superfund Hotline
800-424-9346 or 382-3000 (202 area/FTS)
WQC
Contact: Office of Water Regulations and Standards
202-382-5400 or FTS-382-5400
a. Human health: Methylene chloride is classified as a carcinogen, and under
the assumption of no threshold for a carcinogen, the recommended WQC is zero.
However, if zero cannot be obtained and exposure is via ingestion of water
and aquatic organisms, 0.19 ug/1 is associated with an upper-bound excess
lifetime risk of l.OE-6 [other risk levels to consider: l.OE-5 (1.9 ug/1) and
l.OE-7 (0.019 ug/1)]. If exposure is only via ingestion of aquatic
organisms, the WQC associated with an upper-bound excess lifetime risk of
l.OE-6 is 15.7 ug/1. The criteria are based on halomethanes as a class.
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Methylene Chloride: page 6 of 6
b. Aquatic toxicity: Water quality criteria for the protection of aquatic
life are derived from a minimum data base of acute and chronic tests on a
variety of aquatic organisms. The "(LEL)" after the value indicates that the
minimum data were not available and the concentration given is not a criteria
value but the lowest effect level found in the literature. The values are
based on halomethanes as a class - no specific chemicals are cited.
V. SUPPLEMENTARY DATA
Chemical: Methylene Chloride
CAS No.: 75-09-2
Information is not available at this time.
Synonyms: Methane, dichloro- (8CI9CI); Aerothene MM; Chlorure de methylene
(French); Dichlormethan, uvasol; Dichloromethane; DCM; Freon 30; Methane
dichloride; Methylene bichloride; Methylene chloride (ACN); Methylene
dichloride; Metylenu chlorek (Polish); Narkotil; NCI-C50102; R 30; Solaesthin;
Solmethine; WLN: GIG; 1,1-Dichloromethane.
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CAS !UQC Drinking Water Only !DW MCLs !DU MCL6 !Ref Dose
! ! (•?/!) ! (ag/l) KuD/1)
Acetone
&7641 : : : :
Benzene
71432 !0 (0.67 ug/1) ! 10 10.35
Benzo(a)pyrene
50328 10 (3.1 ng/1) ! ! !
Benzo(k)fluoranthene
207069 !0 (3.1 ng/1) 1 I !
Carbon Disulfide
75150 ! ! ! !
Chlorofom
67663 ! 10.1 h/ !
Chrysene
218019 ! ! ! !
Dibutyl Phthalate
64742 144 ag/1 1 ! i
1,3-Dichlorobenzene
541731 1470 ug/1 ! i !Nft
1,1-Dichloroethane
75343 {Insufficient data ! I !
Dichlorovethane
75092 Isee HaloKthanes ! 1 15
Fluorene
86737 i iii
Naohthalene
91203 !Insufficient data ! ! i
Phenanthrene
B501B
Pheriol
108952
Pyrene
129000
Toluene
108883
10 <3.1 ng/1)
13.5
i
i
115 i
•g/1
.g/1
1,1, l-Trichloroethane
71556 119 »g/l i ! 0.2 122000
Vinyl Chloride
75014 10 (2.0 ug/1) ! ! 0 10.015
Xylene (Bixed)
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CAS IUQC Drinking Water Only iDH MCLs IDH MCLS IRef Dose
! ! (»g/l) ! (ng/1) Mug/1)
Arsenic and Compounds
7440382 ',(25 ng/1) 10.05 1 10.0022
Barim and Compounds
7440393 ! !1.0 ! !Nft
Cadniuc and Compounds
7440439 110 ug/1 10.01 ! !Nft
2,4-Dichlorophenoxyacetic ftcid (2,4-D)
94757 : 10.1 : \m
Endrin
72208 11 ug/1 10.0002 ! INft
Fluorides
7782414 ! !1.4-2.4 ! !
gaua-HCCH (Lindane)
58899 10 (17.4 ng/1) !0.004 ! 10.0265
Lead and Coapounds (Inorganic)
7439921 150 ug/1 10.05 ! 10.031
Manganese and Compounds
7439965 110 ug/1 10.002 ! !
Mercury and Compounds (Alkyl)
20 110 ug/1 10.002 «g/l ! INfi
Mercury and Coapounds (Inorganic)
7439976 110 ug/1 10.002 «g/l ! INA
Methoxychlor
72435 ! 10.1 ! INfl
Nitrate
14797558 ! i ! INfl
Seleniui and Coipounds
7782492 110 ug/1 10.01 ! !
Silver and Compounds
7440224 150 ug/1 S0.05 ! !
Toxaphene
8001352 10 (26 ng/1) 10.005 ! 10.031
2,4,5-Trichlorophenoxyacetic ftcid
93765 ! ! i !
Tritium
57 ! 120,000 pCi/1 ! !
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CAS :
NAME :
SMILES:
•
1
2
3
4
5
4
7
8
9
10
••11
12
Property
k^
'Theni c 4 1 4 nd
'5-»9-
Propanoic 4C
Phyiic4l Properties
0
id , 2 . 2-dichloro-
1
Work ihee t
0-CIO)C(C1 KC1 'C
Property
Mol Wgt.
' P4r4chor
Mol Ref.
Hoi Vol. '
LogP
Melt Pt.
Boil Pt.
.V. Pren.
Ht. Vpr.
PK4
SOL. H20,
3. Are4
C >h4nged or
V»lue 4nd 'Jniti
142. 00 g/mol
248. 00
27. 30
1 1». 00 cm-3/j. «<
1.47
;98. 00 C t760mm
0. 44 nun. Hg
4103. 00 c»l/mol
I. 3« • 25 C.
13. 70 3m/ L
Source Method Error
C4lC.
C»lc. ""
C4lc. Av. 'i. Error » 5
C»lc. -"'
CLogP .
Ne4i
C*lc. Av. •/. Error » 3». 0
C»lc. Av. v. Error » 1. 85
C4lC.
C»lc. "•'•'
D>et4iled. Connectivity Iindicei or Qiuit:
J
a. Significance
These twelve chemical properties are helpful in assessing
the environmental fate and transport of a chemical. The defini-
tion of each property and its significance is given in Table 1.
TABLE 1
FHYSICOCHEMICAL PROPERTIES
Property
Significance
Mol.ecul.ar_wei.ght - The
sum of the atomic
weights of the atoms in
a molecule (Hawley.1981)
Factor in determining
diffusion and passage
through interstitial
space. Also a possible
factor in biological
transport (Oliver and
Nilmi, 1985).
17
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f
/
I CAS • : 7S-M-0
I Nave :Propanotc acid, 2.2-dlchloro-
I
I Smtle«:0-C(0>ClCl>C
I
Htnry« law Constant and Environment*I Partitioning
Log 10 (Henryt Conitant) • -5.21 atm-iMi»3/inole
Lynan tt al. l'B2. would conclude that a chemical
with th«*e properties will volatilise tlowly from
open water. See page 15-15.
NEELY 100 Day Partitioning Pattern
Kif
Water
Ground
Hydrotoi1
0. IS '/.
99. 20 •>.
0. 34 •/.
0. 32 •/.
a. Henry's Law Constant
as
This display gives an estimate of Henry's Law Constant given
the logarithm of Henry's Law Constant.
Definition: the ratio of a chemical's concentration in air
to its concentration in water. when those two phases are in
contact and at equilibrium (Lyman, 1985. p.17).
Significance: indicates the propensity of a chemical to
volatilize. Vaporization of organic chemicals form water bodies
is an important transfer mechanism form water to air. Volatilza-
tion rates are necessary to determine the amount of chemical that
enters the atmosphere and the change of chemical concentration
in water bodies. (Thomas, 198E, p.15-1).
Estimation model: see Thomas. 1982. p.15-11. equation 15-8.
b. Environmental Partitioning
This display uses an equilibrium model to estimate environ-
mental exposure of the chemical. Compartments of the environment
(air, water, ground and hydrosoil) are represented using a one
kilometer square unit world concept as described by Neely and
Mackey (198S). Relative concentrations of the chemical (indicated
as percentages) are given for each compartment.
Definition: the relative disposition of a chemical partioned
into various environmental compartments such as air, water,
soi1, etc.
53
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The structural evaluation to determine potential carcinogen-
ic functional groups (situation b above) is based on unpublished
work by C. V. Basa^ , U.S. Environmental Protection Agency,
Environmental Research Laboratory, Duluth, Minnesota.
r
I
I SnU*i:OC<0>ClCl>ICl>C
I
^
1
I
I
_ — +
Genetic/Mutagenic Atteitment
Thli Molecule hat triggered the carcinogen flag in th» QSAR D»ti Bts*.
It it tuip*ct*d to caul* C»nc»r. and it can b* found in :
"Suip«ct«d C»rcinog«n§, 2nd Edition". U.S. Department of H. E. W.
The following »v4lu»tion of thu ch«mic»l it bai»d on itructurt, only.
Thif if a POLYCHtORIN^TED Compound which may b* carcinogen
A rtvitw may bt found in P. D. Lawlay. 1974.
Thlt If Chlorinated, Brominated, or lodlnated.
Alkane or Alkene of moderate length ! I.e. up to
15 Carbons) and at tuch thould be contldered a
pottible Hutagen or Carcinogen. See Sax, N. Irving, IfBl.
Prett the RETURN kesi
57
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Species Summary display.
2. Select the endpoint/effeet of interest at the
Endpoint/effect Summary display.
3. Choose the desired test from the Tests Summary
display.
Now let's go through these steps using our example.
The Search option is invoked at the Chemical Summary.
o type S (return)
a. Species Summary
The Species Summary appears on the screen showing all the
test species for the identified chemical.
AQU1RE
C*S:
Lln«t
I
2
3
4
5
6
9
9
10
11
12
13
14
IS
Sp»ci«i
Ch«»ie»i: 2, 2-OICHLOROPROPlONtC KCID
- nMlCH I'M
Sptcitf* Lttin
2 UPOmS flACROCHIRUS
4 SM.nO 3AIRDNERI
5 OAPHN1A T1AGNA
8 DAPHNtA PULEX
11 CRKNGON CRKNGON
\2 CERASTOOERnA EOULE
14 RASBORK HETEROMORPHA
16 3AMBUSIA AFF1NIS
20 ICTALURUS PUNCTATUS
30 LEPOHIS CYANELLUS
54 SIHOCEPHALUS SERRULATUS
106 TUCROPTERUS OOLOMIEU!
211 ALBURNUS ALBURNUS
212 NtTOCRA SPINIPES
2»« DUNM.IELLA TERTIOLECTA
Common
B'.'JEGUI.
'MNBOW TROVJT.OONMOSON TROUT
• VTER FLEK
:onnow SHRIMP
HKRUEQUtNFISH. RED RKSBORK
HOSQU1TOFISH
CH^NNEL CKTFiSH
3REEN SUNFISH
VHTER FLEfc
SHKLLriOUTH BftSS
BLEAK
HfcRPKCTlCOID COPEPOO
GREEN KL3KE
Option*: Oontinu* S>»l»c« tptcitt Pirior icr««i\ Qluit RETURN to Ch«». SuMitk
The Menu options for the Species Summary are:
Continue - scrolls to the next
screen of the Species Summary if
over IS species are listed.
Select species - to select a
species.
Prior - scrolls back to the
previous screen if multiple species
screens exist.
37
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AGENDA
RCRA CORRECTIVE ACTION ORDER WORKSHOP
DAY 1
8:30 Introductory Remarks
9:00 Corrective Action Process
9:15 Overview of Administrative Options
0 Enforcement options (§3008(h), §3013, §7003, §3008(a))
0 Permitting options (§3004(u) and (v))
0 Interaction with other programs (CERCLA/TSCA/Cv^/GAA/State)
10:30 NPL Policy and Status of the Corrective Action Regulations
10:45 Applicability and Scope of §3008(h) Authorities
11:15 §3008(h) Order Procedures
12:00 Lunch
1:00 Summary of Authorities - Applications
1:30 Public Involvement
2:00 Development of a §3008(h) Corrective Action Order
0 Administrative Record
0 Model Order
-Strueture/Components
-Unilateral Order language
0 Negotiations
0 Heaiquarters Review Team Process
4:00 Adjourn
DAY 2
8:30 Development of a Facility Strategy
9:45 Interim Measures
10:15 Use of the Corrective Action Plan (CAP) to Develop the Scope of Work
8 RCRA Facility Investigation (RFI)
0 Corrective Measures Study (CMS)
0 Corrective Measures Implementation (CMI)
12:00 Lunch
1:00 Corrective Action Guidance Resources
1:30 Oversight During the Corrective Action Process
2:00 Discussion of Regional Issues and Specific Cases
4:00 Adjourn
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United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
&EPA
DIRECTIVE NUMBER: 9902.4
TITLE: CORRECTIVE ACTION INTERIM MEASURES
I
APPROVAL DATE: June 10, 1987
EFFECTIVE DATE: June 10, 1987
ORIGINATING OFFICE: Q^E
[3 FINAL
D DRAFT
LEVEL OF DRAFT
DA — Signed by AA or DAA
E B — Signed by Office Director
.. .DC — Review & Comment
REFERENCE (other documentsf?:' u
SWER OSWER OSW*=R
DIRECTIVE DIRECTIVE
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United States Envirc — -— -'o.-.; .,.-..
0 f-r*« w" — — -
V>trA OSWER Directive Initiation Reauest
1 Directive Number
9902.4
2. Originator Information
Name of Contact Person Meil Code
Mark Gilbertson & Anna Duncan WH-527
3 Title
ORA Corrective Action Interiin Measures
Office
CWPE/FCRA Enf . Div.
T3»m^r§82-4829
4 Summary of QnKiivm (Include brief statement of purpose) iji^e pcp^ Corrective Action Interim Measures
is intended to assist the Regions and States in determining the need for an interim
measure and directing the work which must be performed as part of the corrective
action program to mitigate or remove the exposure threat presented by releases.
5. Keywords
RCRA, corrective action, interim measures
6a. Does this Directive Supersede Previous Directives)? Q Yes Q No What directive (number, title)
b. Does It Supplement Previous Directives)? Q Yes 0 No What Directive (number, title)
7, Draft Level
LJ A — Signed by AA/DAA (U 8 — Signed by Office Director LJ C — For Review & Comment O In Development
This Request Meets OSWER Directives System Format
8. Signatute. of Lead Office Directives Coordinator _
9. Name and Title of Approving Official
Date
Date
PS WER OS WER OS WER
DIRECTIVE DIRECTIVE L
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