905F87101
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
JUN I 0 I937
OFFICE OF
SOLID WASTE AND EMERGENCY RESPONSE
OSWER DIRECTIVE 9902.4
MEMORANDUM
SUBJECT: Interim Final RCRA §3008(h) Corrective Action
Interim Measures /> _
FROM: Gene A Lucero, Director \O^-\L ^' ' ^^^
Office of Waste Programs Enforcement
Marcia Williams, Director
Office of Solid Waste
TO: Addressees
Attached is the interim final guidance document entitled
RCRA §3008(h) Corrective Action Interim Measures. The Interim
Measures Guidance should be used in the development, implementation
and coordination of corrective action orders (§3008(h)) and
corrective action programs carried out pursuant to a RCRA
permit (§3004(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
draft RCRA §3008(h) Model Consent Order, February 1987.
The document is designed to provide a review of corrective
actions available under §3008(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.
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The Interim Measures guidance consists of:
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 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
timeframes for implementation should be incorporated into the
order or permit.
Comments submitted by the Regions on the draft of this
document have been incorporated. This guidance is being released
as an interim final document. Due to the evolving nature of
the corrective action program, an updated version of this
guidance may be issued. We would appreciate comments based
upon your experience using this guidance. If you have any
questions or comments, please direct them to Mark Gilbertson
(FTS 382-4849) or Anna Duncan (FTS 382-4829).
Attachment
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Addressees:
Waste Management Division Directors - Regions I-X
Hazardous Waste Branch Chiefs - Regions I-X
Enforcement Section Chiefs - Regions I-X
Permit Section Chiefs - Regions I-X
Regional Counsels - Regions I-X
Peter Cook, OWPE
Elaine Stanley, OWPE
Lloyd Guerci, OWPE
Steve Heare, OWPE
Bruce Weddle, OSW
Matthew Hale, OSW
Dave Pagan, OSW
Terry Grogan, OSW
Art Day, OSW
Mike Kilpatrick, OWPE
Hans Crump, OERR
Phil Jalbert, OERR
Bill Hansen, OERR
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OSWER DIRECTIV£ 9902.4
RCRA §3008(h) CORRECTIVE ACTION
INTERIM MEASURES
GUIDANCE
(Interim Final)
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9902.4
INDEX
Pages
INTERIM MEASURES IMPLEMENTATION STRATEGY 2-6
EXAMPLES OF INTERIM MEASURES 7-8
MODEL INTERIM MEASURES LANGUAGE 9-51
Containers 10-14
Tanks 15-16
Surface Impoundments 17-23
Landfills 24-28
Waste Piles 29-31
Soils 32-35
Ground Water 36-42
Surface Water Release 43-46
Gas Migration Control 47
Particulate Emissions 48-49
Other Types of Actions 50-51
APPENDICES
APPENDIX A: Interim Measures Workplan A-l - A-3
APPENDIX B: Interim Measures Investigation Program .... B-l - B-5
APPENDIX C: Interim Measures Design Program C-l - C-4
APPENDIX D: Interim Measures Construction
Quality Assurance Plan D-l - D-3
APPENDIX E: Reports E-l - E-3
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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 measures 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 well
as environmental and health concerns include:
0 inspection reports
0 RCRA Facility Assessment (RFA)
8 RCRA Facility Investigations (RFIs)
0 RCRA Part A and Part B permit applications
0 Notice of significant increase (265.93)
0 responses to RCRA §3007 information requests
0 information obtained through RCRA §3013 orders
0 notifications required by CERCLA §103 or RCRA §3016
submittals
0 information-gathering activities conducted
under CERCLA §104
0 informants' tips or citizens' complaints
corroborated by supporting information
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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, location(s))
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?
B. 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. What 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)?
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.
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3. What are the potential effects of human exposure (short-
and long-term effects)?2
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
populations) (how many, infants, nursing home
residents)?
5. If response is delayed, how will the situation change?
C. Potential Environmental Exposure and Threats
1. 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?
Hazardous constituent health effects data can be found in
"Chemical, Physical and Biological Properties of Compounds
Present at Hazardous Waste Sites", September 1985. The
draft "Superfund Exposure Assessment Manual", January 14,
1986 , the draft "Superfund 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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Selection of Interim Measures
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 are listed in the next chapter
of this guidance document on pages 7-8.
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 threat. Interim measures may add additional
costs or work to the comprehensive corrective action. This
does not preclude implementation of an interim measure.
Developing the Interim 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 9. Language included in this
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 19,
22, 33, 37, 38, 40 and 45.
Appendix A contains the recommended components (the objec-
tives, a health and safety plan and a community relations plan)
for a interim measures workplan. When interim measures are
taking place at the same time as a RCRA Facility Investigation
(RFI), the RFI workplan may already 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
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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.
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
APPENDIX C - INTERIM MEASURES DESIGN PROGRAM
1. Design Plans and Specifications
2. Operations 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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9902.4
EXAMPLES OF INTERIM MEASURES
The following is a list of possible interim measure for
various units and release types. This list is not considered
to be all inclusive.
Containers
1. Overpack/Re-drum
2. Construct Storage Area/Move to 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/Partial
or Complete Removal
Surface Impoundments
1. Reduce Head
2. Remove Free Liquids and Highly Mobile Wastes
3. Stabilize/Repair Side Walls, Dikes or Liner(s)
4. Temporary Cover
5. Run-off/Run-on Control (Diversion or Collection Devices)
6. Sample and Analysis 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)
Landfill
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. Run-off/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)
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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/In-situ Treatment
5. Temporary Cap/Cover
Surface Water Release (Point ann 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. Re-vegetation
3. Application of Dust Supressent
Other Types of Actions
1. Fencing to Prevent Direct Contact
2. Extend Contamination Studies to Off-site Areas
if Permission is Obtained as Required Under Section
§3004(v)
3. Alternate Water Supply to Replace Contaminated
Drinking Water
* 4. Temporary Relocation of Exposed Population
* 5. Temporary or Permanent Injuction
* 6. Suspend or Revoke Authorization to Operate Under
Interim Status
* Model language not included in this guidance.
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9902.4
MODEL INTERIM MEASURES LANGUAGE
FOR
CORRECTIVE ACTION ORDERS
NOTE: It should be noted that each action listed under a
particular unit or media is independent of each other
unless otherwise specified.
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CONTAINERS 4
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], 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 redrumed 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 it 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 shown 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
4/ See also "Guidance Document for Cleanup of Surface Tank
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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 the 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. Within 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
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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
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 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 redrura
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
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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 the 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. Within 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
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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].
Within days following EPA's transmission of comments,
the Respondent shall modify the workplan 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 fro_m
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].
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
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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 emisions 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].
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TANKS 5
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.
Within 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 imprevious 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].
Within days of transmission of EPA's comments, the
Respondent shall revise the workplan in accordance with
EPA comments. Within days following EPA approval or
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
JV See also "Guidance Document for Cleanup of Surface Tank
-" ^->^>/-><-\i »j_.,io i a a R
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_16- 9902.4
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].
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SURFACE IMPOUNDMENTS 6
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,
estimate'd quantities of wastes stored and their characteristics.
This information will be used to:
0 evaluate the type and magnitude of the problem
dike stability
freeboard conditions
releases to ground water, air, surface water
0 identify depth of subsurface sampling program and select
appropriate sampling methods
- soil sampling
- ground-water sampling
- waste sampling
0 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.
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 level]
inches below [specify benchmark] and thereafter shall
maintain the head at or below that level so as to prevent
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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overtopping and dike or side wall failure. The Respondent
shall store, treat or dispose of the pumped materials
onsite in a manner that complies with substantive standards
of RCRA or shall 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;
_2_l This levels may not be to the extent that is ultimately
necessary to protect the human health and the environment
in the long term. Further action may be necessary during
implementation of the final remedy after ultimate levels
of cleanup have been determined. This approach is generally
not appropriate if capping or backfilling of the residual
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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.
ii. [specify number of samples] samples shall be
taken at each quadrant defined by control
lines with spacing of not less than [specify
spacing] feet 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 ef_fectuate
the removal, stabilization, treatment or isolation;
and
c. a description of the sampling and analysis to
determine that the removal, stabilization, treat-
ment or 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. Within days, following EPA approval
or modification of the workplan, the Respondent shall im-
plement the revised workplan in accordance with the schedule
therein. Long term remediation shall be effectuated
following completion of a RCRA Facility Investigation and
Corrective Measures Study.
3. Stabilize/Repair Side Walls, Dikes, or Liner(s)
Within days, the Respondent shall submit a workplan and
and schedule to EPA for review and comment to stabilize
and repair and thereafter maintain the side walls and liner(s)
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-20- 9902.4
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 * 9472.00-3]
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. 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.
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-21- 9902.4
The plan shall also include:
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,
Respondent shall revise the workplan in accordance with
EPA's comments. Within days 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 and
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 E].
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.
-------
-22- 9902.4
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 for 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 workplan 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
£/ When this type of surface impoundment is closed by removal,
there may be constituents left in place. Some of these
constituents may present a potential threat to human
health or the environment (e.g., corrosive waste may
contain heavy metals).
-------
-23- 9902.4
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
reciept 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 B "Data Management
Plan" and Appendix E].
EPA reserves the right to require further action during
the implementation of the final remedy and establish
levels of clean up that are protective to human health
and the environment in the long term.
7. Interim Ground-water Measures
(See Ground-water Section)
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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-24- 9902.4
LANDFILLS
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 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].
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 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
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-25- 9902.4
the liner in landfill(s) [specify landfill(s)] shown on
the attached map and/or in the leachate collection
system in landfill(s) [specify landfill(s)] 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
requi rements.
3. Inspect Leachate Collection/Removal System or French Drain
Within days, the Respondent shall inspect the leachate
collection system in landfill [specify landfill] shown on
attached map using indirect inspection methods including
but not limited to monitoring of flow at outlets or
access points, monitoring of leachate level, 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
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-26- 9902.4
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 rodding, 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 out the perched leachate on a [insert pumping
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-27-
9902.4
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 ani 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 permeability] 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
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-28- 9902.4
any berms or other appurtances. 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 revisa 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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-29- 9902.4
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/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 Appendix 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
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-33- 9902.4
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
appurtances. The workplan shall include and be supported
by an engineering analysis that includes:
a. [insert components from Appendix 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)
-------
-31- 9902.4
4. Interim Ground-water Measures
(See Ground-water Section)
-------
-32- 9902.4
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 substatially contaminated soil is
present at the facility. The interim measures which may apply
at the facility include removal of contaminanted 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:
c evaluate the type and magnitude of the problem
amount of contaminated soil
0 determine the scope of the sampling program and
select appropriate sampling methods
ground-water sampling
soil sampling
0 evaluate and design the interim measure based on
site characteristics
waste characteristics
technology limitations
e 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
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-33-
9902.4
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:
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 proposed interim levels and
justification included for such levels based on
the soil and waste characterics.]^^
[insert additional components from Appendices A, B
and E].
Within days after reciept of lab results, the Respondent
shall 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 Management
Plan" and Appendix E].
Long term remediation shall be effectuated following
completion of a RCRA Facility Investigation and Corrective
Measure Study.
10/ Ultimate levels for the protection of human health and
the environment in the long term will be specified later
in the corrective action process.
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-34- 9902.4
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 E].
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 shall implement the
revised workplan in accordance with the schedules therein.
3. Temporary Cap/Cover
Within days, Respondent shall submit 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
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-35- 9902.4
contain contaminated soils 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 contaminated area and assures
that precipitation falling on the area runs off without
ponding. The workplan 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 appurtances.
The workplan shall include and be supported by an engineering
analysis that includes:
a. [insert components from appendix 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.
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-36- 9902.4
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 ground-
water flow. This information will be used to:
e evaluate the type and magnitude of the problem
amount of contaminated ground water
identify the potential pathways of contaminant
migration
rate of contaminant movement
0 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)
8 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.
11/ See "Leachate Plume Management", November 1985,
EPA/540/2-85/004, guidance document for futher information.
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-37- 9902.4
1. Delineation/Verification of Gross Contamination
Within days, the Respondent shall submit a workplan to
conduct a groundwater investigation to verify the charact-
erization of the gross contamination beneath [insert unit
or area]. This investigation shall at a minimum provide
the 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 contam-
inant 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 be installed and information on the
-------
-38- 9902.4
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,
B 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 im-
plement 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 layers;
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, B,
E and the "RCRA Ground-water Monitoring Technical
Enforcement Guidance Document", September 1986,
OSWER Directive # 9950.1].
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-39- 9902.4
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 E].
Within days following EPA's transmission of comments,
the Respondent shall revise the workplan in accordance with
EPA comments. Within days following 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/In-situ Treatment
Within days, the Respondent shall submit for EPA
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-40- 9902.4
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 wells 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 withdrawl well;
b. proposed interim levels of clean up and technical
basis for such levels.
[Insert additional components from Appendices A, C,
D and E],
Within days following EPA's transmission of comments
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
/ Permit may be required for surface discharge; coordination
with proper authorities is necessary.
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-41- 9902.4
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 contam-
inated 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 accord-
ance with EPA's comments. Within days following
EPA approval or modification of the workplan, the 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 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.
5. Temporary Cap/Cover
Within days, the Respondent shall 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 contami-
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-42- 9902.4
nation. 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 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 workplan sub-
mitted pursuant to paragraph [specify paragraph] in
accordance with the schedules therein.
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-43- 9902.4
SURFACE V?ATER 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 and 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 worXplan 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 . 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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-44- 9902.4
include and be supported by an engineering analysis that
includes:
a. [insert components from Appendix A, C, D and ^].
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 Appendix A, C, D and E].
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.
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-45- 9902.4
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;
iii. use of currently acceptable construction
practices and techniques including description
of seed bed preparation, seeding and planting;
b. tables listing materials, equipment and specif-
ications including types of mulching and/or
chemical stabilizators; 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.
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-48- 9902.4
6. Sample and Analyze Surface Waters and Sediments or Point Sourc^
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.
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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 Appendix A, C, D and
E which have been tailored for the facility
speci fics].
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.
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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
decontamination units/procedures to provide for the 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 Appendix 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.
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-49- 9902.4
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.
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-50- 9902.4
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
Within 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
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-51- y902.4
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 construc-
tion 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 Appendix 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 workplan, the Respondent
shall implement the revised workplan in accordance with the
schedule therein.
*4. Temporary Relocation of Exposed Population
*5. Temporary or Permanent Injuction
*6. Suspend or Revoke Authorization to Operate Under Interim
Status
V
* Order language not included.
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9902.4
INTERIM MEASURES
APPENDICES
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
APPENDIX C.
INTERIM MEASURES DESIGN PROGRAM
1. Design Plans and Specifications
2. Operations and Maintenance Plan
3. Project Schedule
4. Final Design Documents
APPENDIX D,
APPENDIX E,
INTERIM MEASURES CONSTRUCTION QUALITY ASSURANCE
PLAN
1. Construction Quality Assurance Objectives
2. Inspection Activities
3. Sampling Requirements
4. Documentation
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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9902.4
A-l
APPENDIX A
INTERIM MEASURES WORKPLAN
[This appendix contains the recommended components (the objec-
tives, a health and safety plan and a community relations plan)
for a 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 progess, 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 sevaral 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.
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9902.4
A-2
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
toxicological problems;
j. Describe requirements for an environmental
surveillance program;
k. Specify any routine and special training required
for responders; and
1. Establish procedures for protecting workers from
weather-related problems.
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;
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9902.4
A-3
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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9902.4
B-l
APPENDIX B
INTERIM MEASURES INVESTIGATION PROGRAM
[This appendix should be incorporated in the scope of work and
the interim measures workplan when media sampling will 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 for
these intended uses;
b. Description of methods and procedures to be used
to assess the precision, accuracy and completeness
of the measurement data;
c. Description of the rationale used to assure that
the data accurately and precisely represent
parameter variations at a sampling point, a process
condition or an environmental condition. Examples
of factors which shall be considered and discussed
include:
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;
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9902.4
B-2
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., 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
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9902.4
B-3
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:
a. Chain-of-custody 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
dispersement 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:
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9902.4
B-4
i) Method blank(s);
ii) Laboratory control sample(s);
iii) Calibration check sample(s);
iv) Replicate sample(s);
v) Matrix-spiked sample(s);
vi) "Blind" quality control sample(s);
vii) Control charts;
viii) Surrogate samples;
ix) Zero and span gases; and
x) Reagent quality control checks.
A performance audit may be conducted by U.S. EPA on
the laboratories selected by the Respondent.
h. Preventive maintenance procedures and schedules;
i. Corrective action (for 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 analysis ID number;
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9902.4
B-5
e. Property or component measured; and
f. Result of analysis (e.g., concentration).
2. Tabular Displays
The following data shall be presented in tabular displays
a. Unsorted (raw) data;
b. Results for each medium, or for each 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, isopleth plots, cross-sectional plots or transects,
three dimensional graphs, etc.):
a. Display sampling location and sampling grid;
b. Indicate boundaries of sampling area, and areas
where more data are required,
c. Displays levels of contamination at each sampling
location;
d. Display geographical extent of 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.
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9902.4
C-l
APPENDIX C
INTERIM MEASURES DESIGN PROGRAM
[This appendix should be incorporated in the scope of work and
the interim measures workplan when the Respondent will be
required to prepare construction plans and specifications to
implement the interim measursCs) 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 tehcniques.
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.
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9902.4
C-2
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;
b. Description of tasks for maintenance;
c. Description of prescribed treatment or operation
conditions; and
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9902.4
C-3
d. Schedule showing frequency of each O&M task.
c. Common and/or anticipated remedies.
3. Description of routine monitoring and laboratory testing;
a. Description of monitoring tasks;
b. Description of required laboratory tests and their
interpretation;
c. Required QA/QC; and
d. Schedule of monitoring frequency and date, if
appropriate, when monitoring may cease.
4. Description of equipment; and
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 terras of this
order. A Project Schedule shall be submitted simultaneously
with the Final Design Documents.
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9902.4
C-4
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.
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9902.4
D-l
APPENDIX D
INTERIM MEASURE 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)
plan to ensure, with a reasonable degree of certainty, that a
completed interim measure(s) meets or exceeds all design
criteria, plans and specifications. The CQA plan is a facility-
specific document which must be submitted to the Agency for
approval prior to the start of construction. At a minimum, the
CQA plan should include the 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
plan, 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 will be used to monitor the
construction and/or installation of the components of the
interim measure(s) shall be summarized in the CQA plan.
The plan shall include the scope and frequency of each type
of inspection. Inspections shall verify compliance with
all environmental requirements and include, but not be
limited to air quality and emissions monitoring records,
waste disposal records (e.g., RCRA transportation manifests),
etc. The inspection should also ensure compliance with all
health and safety procedures. In addition to oversight
inspections, the Respondent shall conduct the following
act ivities:
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9902.4
D-2
1. Preconstruction 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 addressed; and
e. Conduct a site walk-around to verify that the
design criteria, plans, and specifications are
understood and to review material and equipment
storage locations.
The preconstruction inspection and meeting shall be
documented by a designated person and minutes should be
transmitted to all parties.
2. Prefinal inspection
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9902.4
D-3
outstanding construction items identified in the prefinal
inspection. Confirmation shall be made that outstanding
items have been resolved.
4. Sampling and Testing Requirements
The sampling and testing activities, sample size,
sample and test locations, frequency of testing,
acceptance and rejection criteria, and plans for
correcting problems should be presented in the CQA
plan.
C. Documentation
Reporting requirements for CQA. activities shall be described
in detail 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 the final
storage of all records snail be presented in the CQA plan.
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D-2
1. Preconstruction 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 addressed; and
e. Conduct a site walk-around to verify that the
design criteria, plans, and specifications are
understood and to review material and equipment
storage locations.
The preconstruction inspection and meeting shall be
documented by a designated person and minutes should be
transmitted to all parties.
2. Prefinal inspection
Upon preliminary project completion Respondent
shall notify EPA for the purposes of conducting an
prefinal inspection. The prefinal inspection will
consist of a walk-through inspection of the entire
project site. The inspection is to determine whether
the project is complete and consistent with the contract
documents and the EPA approved 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
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9902.4
D-3
outstanding construction items identified in the prefinal
inspection. Confirmation shall be made that outstanding
items have been resolved.
4. Sampling and Testing Requirements
The sampling and testing activities, sample size,
sample and test locations, frequency of testing,
acceptance and rejection criteria, and plans for
correcting problems should be presented in the CQA
plan.
C. Documentation
Reporting requirements for CQA activities shall be described
in detail 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 the final
storage of all records snail be presented in the CQA plan.
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9902.4
E-l
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;
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9902.4
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 a 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
elements:
1.
2.
3.
Synopsis of the interim measures
the design and construction;
and certification of
Explanation of any modifications to the plans and why
these were necessary for the project;
Listing of the criteria, established before the interim
measures was initiated, for judging the functioning of
the interim measures and also explaining any modification
to these criteria;
4, Results of facility monitorinq indicating that the
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9902.4
E-l
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 Appendix A, B, C, and D.
C. Final Design Documents
The Respondent shall submit the Final Design Documents as
described in Appendix C.
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9902.4
E-2
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 a 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
elements:
- ' , '5
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 was 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, specificatipns (with
justifying documentation) and as-built drawi/ngs/ ' " -' : - ':
E. Final Interim Measures Report
The Respondent shall finalize the Interim Measures Work
Plan and the Interim Measures Implementation Report
incorporating comments received on draft submissions.
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9902.4
E-3
Facility Submission Summary
A summary of the information reporting requirements contained
in the Interim Measures Scope of Work is present below:
FACILITY SUBMISSIONS
INTERIM MEASURES WORKPLAN
-Interim Measures Objectives
-Health ans 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
DUE DATE*
SPECIFY DATE
SPECIFY DATE
Upon completion of construction'
15 days after receipt of EPA
comments on Draft Interim Measures
Report
MONTHLY
*A11 dates are calculated from the effective date of this order
unless otherwise specified.
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