905F87101
          UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                      WASHINGTON, D.C. 20460
                          JUN  I 0 I937
                                                      OFFICE OF
                                             SOLID WASTE AND EMERGENCY RESPONSE
                                               OSWER DIRECTIVE 9902.4

MEMORANDUM

SUBJECT:  Interim Final RCRA §3008(h) Corrective Action
          Interim Measures        />       _

FROM:     Gene A Lucero, Director \O^-\L  ^' '  ^^^
          Office of Waste Programs Enforcement

          Marcia Williams, Director
          Office of Solid Waste

TO:       Addressees


     Attached is the interim final guidance document entitled
RCRA §3008(h) Corrective Action Interim Measures.  The Interim
Measures Guidance should be used in the development,  implementation
and coordination of corrective action orders (§3008(h)) and
corrective action programs carried out pursuant to a RCRA
permit (§3004(u) and (v)).  Its purpose is to assist the Regions
and states in deciding when to require an interim measure.  In
addition, it will also assist in identifying and communicating
to the owner/operator or respondent the specific work which
must be performed to mitigate or remove the threat presented
by releases.  This document should be used in conjunction with
two previously transmitted corrective action guidances, the
interim final Corrective Action Plan, November 1986 and the
draft RCRA §3008(h) Model Consent Order, February 1987.

     The document is designed to provide a review of corrective
actions available under §3008(h) as well as through RCRA permits
to quickly address problems while other detailed investigations
or analyses may be ongoing.  Interim measures can be designed
and implemented as an initial corrective action activity in a
multi-phased order or as the action in the first of a series of
orders which feed into an operating permit, post-closure permit
or supplement an interim status closure plan.

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                              -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

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                              -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

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                                         OSWER DIRECTIV£ 9902.4
RCRA  §3008(h)  CORRECTIVE  ACTION






              INTERIM  MEASURES






                     GUIDANCE






                     (Interim Final)

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                                                          9902.4
                           INDEX

                                                            Pages

INTERIM MEASURES IMPLEMENTATION STRATEGY 	 2-6

EXAMPLES OF INTERIM MEASURES 	 7-8

MODEL INTERIM MEASURES LANGUAGE 	 9-51

   Containers 	 10-14
   Tanks 	 15-16
   Surface Impoundments 	 17-23
   Landfills 	 24-28
   Waste Piles 	 29-31
   Soils 	 32-35
   Ground Water	 36-42
   Surface Water Release 	 43-46
   Gas Migration Control 	 47
   Particulate Emissions 	 48-49
   Other Types of Actions 	 50-51


APPENDICES
   APPENDIX A: Interim Measures Workplan 	 A-l - A-3
   APPENDIX B: Interim Measures Investigation Program .... B-l - B-5
   APPENDIX C: Interim Measures Design Program 	 C-l - C-4
   APPENDIX D: Interim Measures Construction
               Quality Assurance Plan 	 D-l - D-3
   APPENDIX E: Reports 	 E-l - E-3

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                             -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

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                             -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.

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                             -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.

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                             -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

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                             -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

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                             -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)

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                             -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.

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                                                           9902.4
               MODEL INTERIM MEASURES LANGUAGE

                             FOR

                   CORRECTIVE ACTION ORDERS
NOTE:  It should be noted that each  action  listed  under  a
       particular unit or media  is independent  of  each other
       unless otherwise specified.

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                             -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

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                             -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

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                             -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

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                             -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

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                        -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

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                             -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].

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                              -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

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                        _16-                         9902.4








substances from the tanks into other tanks and replace



the tanks if leaks or cracks cannot be effectively and




permanently repaired in situ.   The Respondent shall



initiate closure of the emptied tanks in accordance with




a RCRA Closure Plan approved by [specify date].

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                             -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

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                             -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)

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                             -20-                         9902.4




     of surface impoundment [insert unit number] and dike

     area as shown in the attached map.  - The workplan shall include

     and be supported by an engineering  analysis that includes:

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

     Within 	 days following EPA's transmission of comments,  the

     Respondent shall revise the workplan in accordance with EPA's

     comments.   Within 	 days following EPA approval  or

     modification of the workplan, the Respondent shall implement

     the revised workplan in accordance  with the schedule therein.


4.    Temporary Cover

     Within 	 days, the Respondent shall submit a workplan

     to EPA for review and comment to place a temporary

     floating cover of synthetic lining  over surface impoundment

     [specify impoundment], as shown on  attached map to

     reduce infiltration of precipitation and control air

     releases.   The workplan shall include the design and

     construction of a cover and method  of application  including

     proper anchoring at the edges and floats to prevent the

     lining from submerging so that precipitation falling on

     the impoundment area runs off and does not pond on the

     cover.  The workplan shall also provide for effective

     erosion control.  The cover must have a permeability no

     greater than [specify permeability] cm/sec, thickness of

     [specify thickness] mil,  and be compatible with the chemical

     and physical characteristics of the waste being covered,

     local  climate and the other design  characteristics of

     the unit including any berms, dikes or other appurtenances.

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                             -21-                         9902.4



     The plan shall also include:

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

     Within 	 days following EPA's transmission of comments,

     Respondent shall revise the workplan in accordance with

     EPA's comments.  Within 	 days following EPA approval

     or modification, the Respondent shall implement the

     revised workplan in accordance with the schedule therein.


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

     Within 	 days, the Respondent shall submit a workplan for

     EPA review and comment for the construction and

     installation of devices to control surface run-on  and

     run-off so that run-on and run-off do not enter or leave

     the impoundment area shown on the attached map.  The

     workplan shall include the design of diversion and collection

     devices to effect run-on/run-off control.  These devices

     can consist of but not limited to:  dikes and berms,

     ditches, diversions, waterways, bench terraces, chutes

     and downpipes.  Design criteria shall consider 100 year

     precipitation events and floods, volume, area and  flow

     rates.  The workplan shall include and be supported by an

     engineering analysis that includes:

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

     It shall include a schedule for completion of work.

     Within 	 days following EPA's transmission of comments

     on the proposed workplan, the Respondent shall revise

     the workplan in accordance with EPA's comments.

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                             -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).

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                             -23-                         9902.4



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

     [insert  additional components from Appendices A,

     B and E].

     Within 	 days following EPA's transmission of  comments

     on the workplan, the Respondent shall revise the workplan in

     accordance with EPA's comments.  Within 	 days

     following EPA approval or modification of the workplan, the

     Respondent shall implement the revised workplan  in accordance

     with the schedules therein.  Within 	 days after

     reciept  of lab results,  the Respondent shall prepare a

     report to present all the information collected  during

     the investigation.  The report shall include but is not

     limited  to {for each core and sample, with sample location):

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

     EPA reserves the right to require further action during

     the implementation of the final remedy and establish

     levels of clean up that are protective to human health

     and the  environment in the long term.


7.  Interim Ground-water Measures

    (See Ground-water Section)
   Ultimate levels for the protection of human health and the
   environment in the long term will be determined later in
   the corrective action process.

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                             -24-                         9902.4





                          LANDFILLS








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



     Within 	 days, the Respondent shall submit a workplan



     for EPA review and comment for the construction and



     installation of devices to control surface run-on and



     run-off so that run-on and run-off do not enter or leave



     the landfill area shown on attached map.  The workplan



     shall include the design of diversion and collection



     devices to effect run-on/run-off control.  These devices



     can consist of, but not limited to: dikes and berms,



     ditches, diversions,  waterways, bench terraces, chutes



     and downpipes.  Design criteria shall consider 100 year



     precipitation events and floods,  volume, area and flow



     rates.  The workplan shall include and be supported by




     an engineering analysis that includes:



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



     The workplan shall include a schedule for the completion



     of work.  Within 	 days following EPA's transmission



     of comments on the proposed workplan, the Respondent



     shall revise the workplan in accordance with EPA's



     comments.   Within 	 days following EPA approval  or



     modification of the workplan,  the Respondent shall imple-




     ment the revised workplan in accordance with the schedules



     therein.






2.  Reduce Head on Liner and/or Leachate Collection System



     Within 	 days,  the  Respondent shall reduce the head on

-------
                             -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.

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                             -34-                         9902.4










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



     Within 	 days, the Respondent shall submit a workplan for




     EPA review and comment for the construction and



     installation of devices to control surface run-on and




     run-off so that run-on and run-off do not enter or leave



     the contaminated area shown on the attached map.   The



     workplan shall provide for the design of diversion and



     collection devices to effect run-on and run-off control.



     These devices can consist of,  but not limited to: dikes



     and berms, ditches, diversions,  waterways, bench terraces,



     chutes and downpipes.  The workplan shall include and be



     supported by an engineering analysis that includes:



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



     It shall include a schedule for  the completion of the



     work.   Within 	 days following EPA's transmission of



     comments on the proposed workplan the Respondent shall



     revise the workplan in accordance with EPA's comments.



     Within 	 days following EPA approval or modification



     of the workplan, the Respondent  shall implement the



     revised workplan in accordance with the schedules therein.






3.   Temporary Cap/Cover



     Within 	 days, Respondent shall submit a workplan to EPA



     for review and comment to place  a cap (temporary) over



     the contaminated area shown on the attached map to



     prevent precipitation infiltration and ponding, control



     water  and wind erosion and dispersion, and isolate and

-------
                        -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].

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                             -39-                         9902.4


     Within 	  days following EPA's transmission of  comments,

     the Respondent shall revise the workplan in accordance with

     EPA's comments and following EPA approval shall  implement

     the revised workplan in accordance with the schedule therein.
             \

3.   Interceptor Trench/Sump/Subsurface Drains

     Within 	 days, the Respondent shall submit a workplan to

     EPA for review and comment for the the installation of

     [interceptor trench, sump or subsurface drains]  to contain

     and remove the plume and lower the ground-water  table to

     prevent contact of water with waste material. The workplan

     shall include and be supported by an engineering  analysis

     that includes:

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

     Within 	  days following EPA's transmission of  comments,

     the Respondent shall revise the workplan in accordance with

     EPA comments.  Within 	 days following EPA approval or

     modification of the workplan, the Respondent shall implement

     the revised workplan in accordance with the schedule

     therein.  The Respondent shall treat, store or dispose of

     contaminated ground water pumped out the [trench sump or

     subsurface drain] in a manner that complies with the

     substantive standards of RCRA or shall arrange for off-site

     treatment, storage or disposal in compliance with RCRA.

     Any discharges to navigable water shall comply with all

     relevant state and Federal requirements.


4.   Pump and Treat/In-situ Treatment

     Within 	 days, the Respondent shall submit  for  EPA

-------
                             -40-                         9902.4
     review and comment a workplan for the design and installation

     of injection wells that will allow water within the

     plume to be pumped and treated.^ The workplan shall include

     and be supported by an engineering analysis that includes:

For Example:

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

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

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

          b.   proposed interim levels of clean up and technical
              basis for such levels.

     [Insert  additional components from Appendices A, C,

     D and E],

     Within 	 days following EPA's  transmission of comments

     on proposed workplan, the Respondent shall revise the

     workplan in accordance with EPA's comments.  Within 	

     days following EPA approval or modification of the

     workplan,  the Respondent shall implement the revised

     workplan in accordance with the  schedules therein.


     Within 	 days after the installation of the pumping

     system outlined in the above paragraph and start up, the

     Respondent shall submit to EPA a report showing the
  /  Permit  may be required for surface discharge;  coordination
    with proper authorities is necessary.

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                             -41-                         9902.4







     effectiveness of the pumping,  the area of influence,




     draw down times and any changes in operation necessary



     to collect or contain the contaminated ground water.   If



     based on the report EPA determines that the wells are



     insufficient to adequately collect or contain the contam-



     inated ground water, additional wells shall be proposed



     by the Respondent.   Within 	 days following EPA's



     transmission of comments, on the report the Respondent



     shall provide a workplan for an upgraded system in accord-



     ance with EPA's comments.  Within 	 days following



     EPA approval or modification of the workplan, the Respondent



     shall implement changes in operation necessary to collect



     and contain effectively contaminated ground water including



     the installation of additional wells.  The Respondent



     shall treat, store  or dispose  of contaminated ground



     water pumped out the extraction wells or drains in a



     manner that complies with the  substantive standards of



     RCRA, or shall arrange for off-site treatment, storage



     or disposal in compliance with RCRA.  Any discharge to



     navigable waters shall comply with all relevant state



     and Federal regulations.






5.   Temporary Cap/Cover



     Within 	 days, the Respondent shall submit a workplan to



     EPA for review and  comment, for the design and installation



     of a cover system to minimize rainwater infiltration into



     the waste disposal  area and slow the migration of contami-

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                        -42-                         9902.4






nation.   The workplan shall include and be supported by



an engineering analysis that includes:



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



Within 	 days following EPA's transmission of comments



on the workplan, the Respondent shall revise the work-



plan in accordance with EPA's comments.  Within 	 days



following EPA approval or modification of the workplan,



the Respondent shall implement the revised workplan sub-




mitted pursuant to paragraph [specify paragraph] in



accordance with the schedules therein.

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                             -43-                         9902.4



                    SURFACE V?ATER RELEASE


1.   Overflow/Underflow Dams

     Within 	 days,  the Respondent shall submit a workplan to

     EPA for review and comment for the installation of

     [overflow or underflow] dams at [insert area].   The

     workplan shall include and be supported by and engineering

     analysis that includes:

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

     Within 	 days  following EPA's transmission of comments,

     the Respondent shall revise the worXplan in accordance

     with EPA's comments.  Within 	 days following EPA

     approval or modification of the workplan,  the Respondent

     shall implement the revised workplan in accordance with

     the schedule therein.


 2 .   Filter Fences

     Within 	 days,  Respondent shall install filter fences

     in [insert surface water name and location] in order to

     prevent further spread of contamination.


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

     Within 	 days,  the Respondent shall submit a workplan to

     EPA for review and comment for the construction and

     installation of surface-water diversion and collection

     devices.  These devices can consist of, but are not

     limited to: dikes and berms, ditches, diversions,  waterways,

     bench terraces,  chutes and downpipes.  The workplan shall

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                             -44-                         9902.4





     include and be supported by an engineering analysis that



     includes:




          a.  [insert components from Appendix A,  C,  D and ^].



     It shall include as-designed topographic maps and a



     schedule.   Within days following EPA's transmission of



     comments,  the Respondent shall revise  the workplan in



     accordance with EPA's comments.   Within 	 days following



     EPA approval or modification of  the workplan, the Respondent



     shall implement the revised workplan in accordance with the



     schedule therein.






4.   Regrading/Revegetation



     Within 	 days, the Respondent  shall  submit a workplan to



     EPA for review and comment for the grading of the capped



     area [specify area] as shown on  attached map.  The grading



     shall be conducted to [state objectives],  shall result



     in run-off away from the area without  ponding, no run-on



     to the area and, run-off away from water courses.  The



     workplan shall include and be supported by an engineering



     analysis that includes:



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



     Within 	 days following EPA's  transmission of comments on



     the proposed workplan, the Respondent  shall revise the workplan



     in accordance with EPA's comments.  Within 	 days



     following  EPA approval or modification of the workplan, the



     Respondent shall implement the revised workplan in accordance



     with the schedules therein.

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                             -45-                         9902.4




     Within  '  days,  the Respondent shall submit to EPA for

     review and comment a workplan to establish a vegetative

     cover to stabilize the surface of the hazardous disposal

     site.  The workplan will include and be supported by an

     engineering analysis that includes:

For Example:

          a.  discussion of the technical factors of importance
              including:

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

             ii.  selection of suitable plant species;

            iii.  use of currently acceptable construction
                  practices and techniques including description
                  of  seed bed preparation, seeding and planting;

          b.  tables  listing materials, equipment and specif-
              ications including types of mulching and/or
              chemical stabilizators; and

          c.  description of normal operation,  fertilization
              and maintenance.

     [Insert additional components from Appendices A,

     C, D and E].

     Within 	 days following EPA's transmission of comments on

     the workplan, the Respondent shall revise the workplan in

     accordance with EPA's comments.  Within 	 days following

     EPA approval or modification of the workplan, the Respondent

     shall  implement the revised workplan  in accordance with the

     schedule therein.

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                             -48-                         9902.4



6.   Sample and Analyze Surface Waters and Sediments or Point Sourc^
    Discharges

     Within 	 days, the Respondent shall submit a workplan

     to EPA for review and comment to sample and analyze

     surface water and sediments.  The plan shall include:

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

     The workplan shall provide for respondent to sample and

     analyze surface waters and/or sediments located at

     [insert locations upstream of adjoining and downstream

     of areas which have received (point source or non-point

     source) discharges from areas,  units of concern].

     Samples shall be analyzed for the following parameters

     [list Appendix VIII parameters].   Within 	 days following

     EPA's comments,  the Respondent shall revise the workplan  in

     accordance with EPA's comments.   Within 	 days following

     EPA approval or modification of  the workplan,  the Respondent

     shall implement the revised workplan in accordance with

     the schedule therein.  Respondent shall provide information

     on the sampling locations and the results of analysis

     within 	 days of receipt from  the laboratory.

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                             -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.

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                             -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.

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                             -49-                         9902.4







3.   Application of Dust Suppressant




     Within 	 days,  the Respondent shall spray uncontaminated



     water every [specify time frame] hours in areas [insert



     areas] to control dust emissions.   The Respondent shall



     not use collected leachate,  used oil or hazardous waste



     to control dust emissions.

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                             -50-                         9902.4








                        OTHER ACTIONS






1.  Fencing to Prevent Direct Contact



     Within 	 days the Respondent shall install security



     fencing [insert type of fence] of a minimum of [specify



     height] feet high around the perimeter of the [insert



     site/unit/work area],  warning signs and other measures to



     limit access to the facility.





2 .  Sampling Off-site Areas



     Within 	 days,  the Respondent shall submit a workplan to



     EPA for review and comment to collect and analyze samples




     from drinking water wells located within a [specify



     distance] mile radius  of the facility.   Samples shall be



     analyzed for the following parameters:   [insert parameters].



     The workplan shall include but not be limited to the



     following:



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



     In the event that said permission is not obtained,  the



     Respondent shall demonstrate to the satisfaction of EPA,



     that the Respondent was unable to obtain necessary  permission.






3.  Alternate Water Supply  to Replace Contaminated Drinking Water



     Within 	 days,  the Respondent shall provide an alternate



     water supply to the [insert area name of affected community].



     The alternate water supply shall consist of,  but is not



     limited to:



          a.  purchase of water from another supply; or

-------
                             -51-                         y902.4



          b.  provision of a new surface water intake(s); or

          c.  provision of a new ground-water well(s); or

          d.  provision of bottled and bulk water; or

          e.  provision of point-of-use wells; or

          f.  combination of the above as necessary

     Within 	 days, the Respondent shall submit a workplan

     to EPA for review and comment for the design and construc-

     tion of a system(s) for the treatment of contaminated

     water supplies.  The treatment shall consist of, but is

     not limited to:

          a.  treatment of contaminated central water supplies; or

          b.  point-of-use treatment; or

          c.  combination of the above as necessary

     The workplan shall include and be supported by an engineering

     analysis that includes:

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

     Within 	 days following EPA's transmission of comments,

     the Respondent shall revise the workplan in accordance

     with EPA's comments.  Within 	 days following EPA

     approval or modification of the workplan, the Respondent

     shall implement the revised workplan in accordance with the

     schedule therein.


*4.   Temporary Relocation of Exposed Population

*5.   Temporary or Permanent Injuction

*6.   Suspend or Revoke  Authorization to Operate Under Interim
     Status

        V

* Order language not included.

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                                                         9902.4
                       INTERIM MEASURES
                          APPENDICES
APPENDIX  A.   INTERIM MEASURES WORKPLAN

               1. Interim Measures Objectives
               2. Health and Safety Plan
               3. Community Relations Plan
APPENDIX  B,
INTERIM MEASURES INVESTIGATION PROGRAM

1. Data Collection Quality Assurance Plan
2. Data Management Plan
APPENDIX  C.
INTERIM MEASURES DESIGN PROGRAM

1. Design Plans and Specifications
2. Operations and Maintenance Plan
3. Project Schedule
4. Final Design Documents
APPENDIX  D,
APPENDIX  E,
INTERIM MEASURES CONSTRUCTION QUALITY ASSURANCE
PLAN

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

REPORTS

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

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                                                          9902.4


                              A-l


                           APPENDIX A
INTERIM MEASURES WORKPLAN

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


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

A.  Interim Measures Objectives

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

B.  Health and Safety Plan

    The Respondent shall prepare a facility Health and Safety
    Plan.

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                                                  9902.4
                      A-2
Major elements of the Health and Safety Plan shall
include:

a.  Facility description including availability of
    resources such as roads, water supply, electricity
    and telephone service;

b.  Describe the known hazards and evaluate the risks
    associated with the incident and with each activity
    conducted, including, but not limited to on and
    off-site exposure to contaminants during the
    implementation of interim measures at the facility.

c.  List key personnel and alternates responsible for
    site safety, responses operations, and for protection
    of public health;

d.  Delineate work area;

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

f.  Establish procedures to control site access;

g.  Describe decontamination procedures for personnel
    and equipment;

h.  Establish site emergency procedures;

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

j.  Describe requirements for an environmental
    surveillance program;

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

1.  Establish procedures for protecting workers from
    weather-related problems.

The Facility Health and Safety Plan shall be consistent
with:

a.  NIOSH Occupational Safety and Health Guidance
    Manual for Hazardous Waste Site Activities (1985);

b.  EPA Order 1440.1 - Respiratory Protection;

c.  EPA Order 1440.3 - Health and Safety Requirements
    for Employees engaged in Field Activities;

d.  Facility Contingency Plan;

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                                                          9902.4


                              A-3


        e.   EPA Standard Operating Safety Guide  (1984);

        f.   OSHA regulations particularly in 29  CFR 1910 and 1926;

        g.   State and local regulations;  and

        h.   Other EPA guidance as  provided.

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

C.  Community Relations Plan

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

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                                                          9902.4
                              B-l
                           APPENDIX B
INTERIM MEASURES INVESTIGATION PROGRAM

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


A.  Data Collection Quality Assurance Plan

    The Respondent shall prepare a plan to document all
    monitoring procedures: sampling, field measurements and
    sample analysis performed during the investigations to
    characterize the source and contamination, so as to
    ensure that all information, data and resulting decisions
    are technically sound, and properly documented.

    1.   Data Collection Strategy

        The strategy section of the Data Collection Quality
        Assurance Plan shall include but not be limited to the
        following:

        a.  Description of the intended uses for the data, and
            the necessary level of precision and accuracy for
            these intended uses;

        b.  Description of methods and procedures to be used
            to assess the precision, accuracy and completeness
            of the measurement data;

        c.  Description of the rationale used to assure that
            the data accurately and precisely represent
            parameter variations at a sampling point, a process
            condition or an environmental condition.  Examples
            of factors which shall be considered and discussed
            include:

    2.   Sampling and Field Measurements

        The Sampling and Field Measurements section of the Data
        Collection Quality Assurance Plan shall discuss:

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

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

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                                                  9902.4


                      B-2


c.  Measuring all necessary ancillary data;

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

e.  Determining which parameters are to be measured and
    where ,-

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

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

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

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

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

    iii)  Documentation of specific sample preservation
          method;

     iv)  Calibration of field devices;

      v)  Collection of replicate samples;

     vi)  Submission of field-biased blanks, where
          appropriate;

    vii)  Potential interferences present at the facility;

   viii)  Construction materials and techniques,
          associated with monitoring wells and piezometers;

     ix)  Field equipment listing and sample containers;

      x)  Sampling and field measurement order; and

     xi)  Decontamination procedures.

i.  Selecting appropriate sample containers;

j.  Sample preservation; and

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                                                      9902.4


                          B-3


    k.   Chain-of-custody,  including:

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

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

3.   Sample Analysis

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

    a.   Chain-of-custody procedures,  including:

          i)  Identification of a  responsible party to act
              as sample custodian at  the laboratory facility
              authorized to sign for  incoming field samples,
              obtain documents of  shipment,  and  verify the
              data entered onto the sample custody records;

         ii)  Provision for a laboratory sample  custody log
              consisting of serially  numbered standard
              lab-tracking report  sheets;  and

        iii)  Specification of laboratory  sample custody
              procedures for sample handling,  storage,  and
              dispersement for analysis.

    b.   Sample storage and holding times,-

    c.   Sample preparation methods;

    d.   Analytical procedures,  including:

          i)  Scope and application of the procedure;

         ii)  Sample matrix;

        iii)  Potential interferences;

         iv)  Precision and accuracy  of  the methodology;  and

          v)  Method detection limits.

    e.   Calibration procedures and frequency;

    f.   Data reduction,  validation and reporting;

    g.   Internal quality control checks,  laboratory performance
        and systems audits and frequency,  including:

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                                                          9902.4


                              B-4


             i)  Method blank(s);

            ii)  Laboratory control sample(s);

           iii)  Calibration check sample(s);

            iv)  Replicate sample(s);

             v)  Matrix-spiked sample(s);

             vi)  "Blind" quality control sample(s);

            vii)  Control charts;

           viii)  Surrogate samples;

             ix)  Zero and span gases; and

              x)  Reagent quality control checks.

        A performance audit may be conducted by U.S. EPA on
        the laboratories selected by the Respondent.

        h.  Preventive maintenance procedures and schedules;

        i.  Corrective action (for laboratory problems); and

        j.  Turnaround time.

B.   Data Management Plan

    The Respondent shall develop and initiate a Data Management
    Plan to document and track investigation data and results.
    This plan shall identify and set up data documentation
    materials and procedures, project file requirements, and
    project-related progress reporting procedures and documents.
    The plan shall also provide the format to be used to present
    the raw data and conclusions of the investigation.

    1.   Data Record

        The data record shall include the following:

        a.  Unique sample or field measurement code;

        b.  Sampling or field measurement location and sample
            or measurement type;

        c.  Sampling or field measurement raw data;

        d.  Laboratory analysis ID number;

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                                                      9902.4


                          B-5

    e.   Property or component measured; and

    f.   Result of analysis (e.g.,  concentration).

2.  Tabular Displays

    The following data shall be presented in tabular displays

    a.   Unsorted (raw) data;

    b.   Results for each medium,  or for each constituent
        monitored;

    c.   Data reduction for numerical analysis;

    d.   Sorting of  data by potential stratification factors
        (e.g., location, soil layer, topography);  and

    e.   Summary data.

3.  Graphical Displays

    The following data shall be presented in graphical
    formats (e.g.,  bar graphs,  line graphs,  area or plan
    maps,  isopleth  plots,  cross-sectional plots or transects,
    three  dimensional  graphs, etc.):

    a.   Display sampling location and sampling  grid;

    b.   Indicate boundaries of  sampling area, and  areas
        where more  data are required,

    c.   Displays levels of contamination at  each sampling
        location;

    d.   Display geographical extent of contamination;

    e.   Display contamination levels,  averages, and maxima;

    f.   Illustrate  changes in concentration in  relation
        to distance from the source, time,  depth or other
        parameters; and

    g.   Indicate features  affecting intramedia  transport
        and show potential receptors.

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                                                          9902.4
                              C-l
                           APPENDIX C
INTERIM MEASURES DESIGN PROGRAM

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


A.  Design Plans and Specifications

    The Respondent shall develop clear and comprehensive design
    plans and specifications which include but are not limited
    to the following:

    1. Discussion of the design strategy and the design basis,
       including:

        a.  Compliance with all applicable or relevant
            environmental and public health standards; and

        b.  Minimization of environmental and public impacts.

    2.  Discussion of the technical factors of importance
        including:

        a.  Use of currently accepted environmental control
            measures and technology;

        b.  The constructability of the design; and

        c.  Use of currently acceptable construction practices
            and tehcniques.

    3.  Description of assumptions made and detailed justification
        of these assumptions;

    4.  Discussion of the possible sources of error and references
        to possible operation and maintenance problems;

    5.  Detailed drawings of the proposed design  including;

        a.  Qualitative flow sheets; and

        b.  Quantitative flow sheets.

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                                                          9902.4


                              C-2

        c.  Facility Layout

        d.  Utility Locations

    6.  Tables listing materials, equipment and specifications;

    7.  Tables giving material balances;

    8.  Appendices including,

        a.  Sample calculations  (one example presented and
            explained clearly for significant or unique
            design calculations);

        b.  Derivation of equations essential to understanding
            the report; and

        c.  Results of laboratory or field tests.

    General correlation between drawings and technical
    specifications, is a basic requirement of any set of working
    construction plans and specifications.  Before submitting
    the project specifications,  the Respondent shall coordinate
    and cross-check the specifications and drawings and complete
    the proofing of the edited specifications and required
    cross-checking of all drawings and specifications.

B.   Operation and Maintenance Plan

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

    1.  Equipment start-up and operator training

        The Respondent shall prepare,  and include in the
        technical specifications governing treatment systems,
        contractor requirements for providing: appropriate
        service visits by experienced personnel to supervise
        the installation, adjustment,  startup and operation of
        the treatment systems, and training covering appropriate
        operational procedures once the startup has been
        successfully accomplished.

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

        a.  Description of tasks for operation;

        b.  Description of tasks for maintenance;

        c.  Description of prescribed treatment or operation
            conditions;  and

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                                                          9902.4


                              C-3

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

        c.  Common and/or anticipated remedies.

    3.  Description of routine monitoring and laboratory testing;

        a.  Description of monitoring tasks;

        b.  Description of required laboratory tests and their
            interpretation;

        c.  Required QA/QC; and

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

    4.  Description of equipment; and

        a.  Equipment identification;

        b.  Installation of monitoring components;

        c.  Maintenance of site equipment; and

        d.  Replacement schedule for equipment and installed components.

    5.  Records and reporting mechanisms required.

        a.  Daily operating logs,

        b.  Laboratory records;

        c.  Mechanism for reporting emergencies;

        d.  Personnel and maintenance records; and

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

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

C.  Project Schedule

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

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                                                          9902.4


                                  C-4
D.  Final Design Documents
    The Final Design Documents shall consist of the Final
    Design Plans and Specifications (100% complete), the Final
    Draft Operation and Maintenance Plan, and Project Schedule.
    The Respondent shall submit the final documents 100% complete
    with reproducible drawings and specifications.   The quality
    of the design documents should be such that the Respondent
    would be able to include them in a bid package  and invite
    contractors to submit bids for the construction project.

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                                                          9902.4


                              D-l
                          APPENDIX  D
INTERIM MEASURE CONSTRUCTION QUALITY ASSURANCE PLAN

[This appendix should be incorporated in the scope of work and
the interim measures workplan when the interim measure to be
implemented will require a construction quality assurance (CQA)
plan to ensure, with a reasonable degree of certainty, that a
completed interim measure(s) meets or exceeds all design
criteria, plans and specifications.  The CQA plan is a facility-
specific document which must be submitted to the Agency for
approval prior to the start of construction.  At a minimum, the
CQA plan should include the following elements: construction
quality assurance objectives, inspection activities, and
documentation.  This appendix should be modified to take into
account site-specific detail.  Upon EPA approval of the CQA
plan, the Respondent shall construct and implement the interim
measures in accordance with the approved design, schedule, CQA
plan, and operation and maintenance plan.]


A.  Construction Quality Assurance Objectives

    In the CQA plan, the Respondent shall identify and document
    the objectives and framework for the development of a
    construction quality assurance program including, but not
    limited to the following: responsibility and authority;
    personnel qualifications; inspection activities; sampling
    requirements; and documentation.  The responsibility and
    authority of all organizations (i.e.  technical consultants,
    construction firms, etc.) and key personnel involved in the
    construction of the interim measure shall be described
    fully in the CQA plan.  The Respondent must identify a CQA
    officer and the necessary supporting inspection staff.

B.  Inspection Activities

    The observations and tests that will be used to monitor the
    construction and/or installation of the components of the
    interim measure(s) shall be summarized in the CQA plan.
    The plan shall include the scope and frequency of each type
    of inspection.  Inspections shall verify compliance with
    all environmental requirements and include, but not be
    limited to air quality and emissions monitoring records,
    waste disposal records  (e.g., RCRA transportation manifests),
    etc.  The inspection should also ensure compliance with all
    health and safety procedures.  In addition to oversight
    inspections, the Respondent shall conduct the following
    act ivities:

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                                                      9902.4
                          D-2

1.  Preconstruction inspection and meeting

    The Respondent shall conduct a preconstruction inspection
    and meeting to:

    a.  Review methods for documenting and reporting inspection
        data;

    b.  Review methods for distributing and storing documents
        and reports;

    c.  Review work area security and safety protocol;

    d.  Discuss any appropriate modifications of the
        construction quality assurance plan to ensure that
        site-specific considerations are addressed; and

    e.  Conduct a site walk-around to verify that the
        design criteria,  plans, and specifications are
        understood and to review material and equipment
        storage locations.

    The preconstruction inspection and meeting shall be
    documented by a designated person and minutes should be
    transmitted to all parties.

2.  Prefinal inspection

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                                                          9902.4


                              D-3

        outstanding construction items identified in the prefinal
        inspection.  Confirmation shall be made that outstanding
        items have been resolved.

    4.  Sampling and Testing Requirements

        The sampling and testing activities,  sample size,
        sample and test locations,  frequency of testing,
        acceptance and rejection criteria, and plans for
        correcting problems should be presented in the CQA
        plan.

C.  Documentation

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

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                                                      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

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                                                          9902.4


                              D-3

        outstanding construction items identified in the prefinal
        inspection.  Confirmation shall be made that outstanding
        items have been resolved.

    4.  Sampling and Testing Requirements

        The sampling and testing activities,  sample size,
        sample and test locations,  frequency of testing,
        acceptance and rejection criteria, and plans for
        correcting problems should be presented in the CQA
        plan.

C.   Documentation

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

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                                                          9902.4
                              E-l

                           APPENDIX E
REPORTS

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

A.  Progress

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

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

        2.  Summaries of all findings;

        3.  Summaries of all changes made in the interim measures
            during the reporting period;

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                                                          9902.4
D.  Draft Interim Measures Report

    At the "completion" of the construction of the project
    (except for long term operation,  maintenance and monitoring),
    the Respondent shall submit a Interim Measures Implementation
    Report to the Agency.  The Report shall document that the
    project is consistent with the design specifications, and
    that the interim measures are performing adequately.  The
    Report shall include, but not be limited to the following
    elements:
    1.


    2.


    3.
Synopsis of the interim measures
the design and construction;
and certification of
Explanation of any modifications to the plans and why
these were necessary for the project;

Listing of the criteria, established before the interim
measures was initiated, for judging the functioning of
the interim measures and also explaining any modification
to these criteria;
    4,  Results of facility monitorinq  indicating that the

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                                                          9902.4
                              E-l

                           APPENDIX E
 REPORTS

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

 A.   Progress

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

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

        2.  Summaries of  all findings;

        3.  Summaries of  all changes made in the interim measures
            during the reporting period;

        4.  Summaries of  all contacts with representative of
            the local community, public interest groups or State
            government during the reporting period;

        5.  Summaries of  all problems or potential problems
            encountered during the reporting period;

        6.  Actions being taken to rectify problems;

        7.  Changes in personnel during the reporting period;

        8.  Projected work for the next reporting period; and

        9.  Copies of daily reports,  inspection reports,
            laboratory/monitoring data,  etc.

B.   Interim Measures Workplan

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

C.  Final Design Documents

    The Respondent shall submit the Final Design Documents as
    described in Appendix C.

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                                                          9902.4
                              E-2
D.  Draft Interim Measures Report

    At the "completion" of the construction of the project
    (except for long term operation, maintenance and monitoring),
    the Respondent shall submit a Interim Measures Implementation
    Report to the Agency.  The Report shall document that the
    project is consistent with the design specifications, and
    that the interim measures are performing adequately.  The
    Report shall include, but not be limited to the following
    elements:
                                                            - ' ,   '5
    1.  Synopsis of the interim measures and certification of
        the design and construction;

    2.  Explanation of any modifications to the plans and why
        these were necessary for the project;

    3.  Listing of the criteria, established before the  interim
        measures was initiated, for judging the functioning of
        the interim measures and also explaining any modification
        to these criteria;

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

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

    This report shall include of the inspection summary  reports,
    inspection data sheets, problem identification and corrective
    measure reports, block evaluation reports, photographic
    reporting data sheets, design engineers' acceptance  reports,
    deviations,from design and material, specificatipns  (with
    justifying documentation) and as-built drawi/ngs/   ' " -' : -    ':

E.  Final Interim Measures Report

    The Respondent shall finalize the Interim Measures Work
    Plan and the Interim Measures Implementation Report
    incorporating comments received on draft submissions.

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                                                          9902.4
                              E-3
Facility Submission Summary
A summary of the information reporting requirements contained
in the Interim Measures Scope of Work is present below:
FACILITY SUBMISSIONS	

INTERIM MEASURES WORKPLAN
 -Interim Measures Objectives
 -Health ans Safety Plan
 -Community Relations Plan
 -Data Collection QA Plan
 -Data Management Plan
 -Construction QA Plan

Final Design Documents
 -Design Plans and Specs
 -O&M Plan
 -Project Schedule

Draft Interim Measures Report

Final Interim Measures Report
Progress Reports
DUE DATE*
SPECIFY DATE
SPECIFY DATE
Upon completion of construction'

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

MONTHLY
*A11 dates are calculated from the effective date of this order
unless otherwise specified.

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