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. ------- -2- 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 ------- -3- 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 ------- OSWER DIRECTIV£ 9902.4 RCRA §3008(h) CORRECTIVE ACTION INTERIM MEASURES GUIDANCE (Interim Final) ------- 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 ------- -2- 9902.4 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 ------- -3- 9902.4 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. ------- -4- 9902.4 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. ------- -5- 9902.4 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 ------- -6- 9902.4 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 ------- -7- 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) ------- -8- 9902.4 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. ------- 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. ------- -10- 9902.4 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 ------- -12- 9902.4 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 ------- -11- 9902.4 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 ------- -12- 9902.4 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 ------- -13- 9902.4 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 ------- -14- 9902.4 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]. ------- -15- 9902.4 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 ------- _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]. ------- -17- 9902.4 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. ------- -18- 9902.4 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 ------- -19- 9902.4 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) ------- -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. ------- -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. ------- -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 ------- -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 ------- -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 ------- -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 ------- -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) ------- -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 ------- -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 ------- -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. ------- -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 ------- -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. ------- -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. ------- -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]. ------- -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 ------- -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. ------- -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- ------- -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. ------- -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 ------- -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. ------- -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. ------- -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. ------- -47- 9902.4 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. ------- -48- 9902.4 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. ------- -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. ------- -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 ------- -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. ------- 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 ------- 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. ------- 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; ------- 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. ------- 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; ------- 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 ------- 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: ------- 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; ------- 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. ------- 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. ------- 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 ------- 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. ------- 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. ------- 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: ------- 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 ------- 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. ------- 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 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 ------- 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. ------- 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; ------- 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 ------- 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. ------- 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. ------- 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. ------- |