905R01015
-------
-------
-------
United States Environmental Protection Agency, Region 5
Corrective Action Conference
January 17 and 18, 2001
Chicago, Illinois
Section I - Presentation Summaries
Section II - Action Items from Meeting
Appendix 1 - Presentation Slides
Appendix 2 - Meeting Handouts
.«t.,t
U.S. Environmental
-------
-------
-1-
Section I - Presentation Summaries
Day 1 - January 17, 2001
Welcome and Introductory Remarks - Robert Springer, Director,
Waste, Pesticides and Toxics Division, United States
Environmental Protection Agency (U.S. EPA), Region 5
We have made much progress in the RCRA program during the past
two years. Achieving Environmental Indicator determinations (Els)
has been our main priority. For the State programs: Illinois -
has been the standard bearer for Region 5 States; Indiana - Our
Memorandum of Agreement (MOA) for their voluntary program is
almost final, it may be a model for the country to follow;
Michigan - Region 5 recently signed a MOA with the State;
Minnesota - Has only two CA 725 (human health) and only three CA
750 (groundwater) determinations left to complete. They also
have only two facilities that have CA 999 determinations
(termination of Corrective Action process) left to complete;
Ohio - Has a large number of facilities in their universe to
address.
Projections - Our goal is to keep pace while working on our
streamlining.
Streamlining - Fewer deliverables required; New Orders will be
performance-based; and our goal will be to streamline existing
orders.
Region 5 RCRA corrective action strategy: Where we were, are, and
where we are going. Future goals will be to get voluntary
agreements with all of the states, meet Government Performance
and Results Act (GPRA) goals for Environmental Indicators and
complete the Corrective Action process (CA 999) .
National Perspective - Michael Shapiro, Deputy Assistant
Administrator, Office of Solid Waste and Emergency Response,
U.S. EPA
Region 5 is leading the country. Region 5 entered into the first
Memorandum of Understanding to recognize a State voluntary
program (Illinois in July 1997). The Region has also issued five
streamlined Corrective Action Orders that implement cleanup with
a minimum of process. They have also reached voluntary
agreements with six facilities.
This meeting is an invaluable opportunity for dialog and is a
-------
-2-
model for other Regions to follow. This is the second such
meeting here in Region 5 and we are urging other Regions and
States to have similar stakeholder meetings. The States are the
key to reaching GPRA goals as 38 states have authorized
Corrective Action Programs in place. Also key to meeting GPRA
goals is cooperation between U.S. EPA, the States and facilities
(private-sector). Other key components are to continue the
momentum of Reforms II, site reuse and redevelopment.
The first set of RCRA Corrective Action reforms (July 1999)
focused on environmental results over process, enhanced public
participation and flexibility. These reforms led to a
significant increase in program accomplishments. Nationally,
facilities meeting El determinations increased tenfold since
1997. Last month, in Pontiac, Michigan, General Motors
Corporation and EPA celebrated the 500th facility to meet both
Environmental Indicator Measures.
In the future cleanups will be more challenging. Last August
Assistant Administrator Tim Fields announced that EPA needed to
renew our commitment under Corrective Action to achieving our
cleanup goals be developing a second round of RCRA Cleanup
Reforms that would build upon the 1999 Cleanup Reforms and that
would ensure all stakeholders had a voice. Last week at the
BP Amoco facility in Wood River, Illinois, U.S. EPA announced the
RCRA Cleanup Reforms II.
The 2001 Cleanup Reforms focus on several themes. These include:
Pilots to ground-test innovative and protective approaches to
cleanup; Cultural change, Changing the way people interact and
implement the program in the field; Information, Effective access
to timely information to increase public awareness and
opportunity for involvement at Corrective Action sites; and
Redevelopment and reuse of sites. Capitalizing on redevelopment
potential at sites can motivate interested parties in expediting
cleanup and help to revitalize communities.
Some of the highlights of the 2001 RCRA Cleanup Reforms include:
At least 25 innovation pilots, at least one in each Region for
2001. The new pilot program will support State and Regional
offices in their efforts to use innovative, results-oriented and
protective approaches to speed up El determinations and final
cleanups; U.S. EPA will take actions to accelerate culture change
in implementing the program including hosting a stakeholder
meeting, provide the public with more access to information (El
forms and site summaries on-line) and encourage stakeholders top
to capitalize on brownfields reuse.
-------
-3-
Industrv Perspective, John Quarles, Esq., Counsel, RCRA
Corrective Action Project
Key to program success is the application of concepts and
spending funds OR cleanups versus studies. In April 1997, the
RCRA Corrective Action Program was in need of reform. There were
too many sites stuck in the study phase. There was a need to
communicate recommendations to U.S. EPA for program changes and
both U.S. EPA and industry were in agreement that reforms to the
RCRA Corrective Program should be made. There were two
categories of reforms in 1999, change in process and change in
approach. The original Corrective Action process was very rigid.
The reforms were implemented to change the program to a results-
based approach. Oversight was tailored to speedup the process.
A holistic approach was used to look at the entire facility (not
one solid waste management unit at a time). Procedural
flexibility was stressed. U.S. EPA was to set performance
standards (define objective) and leave it up to industry how to
get there. Data collection was targeted to that which the agency
felt was really needed and only go back if more data were
required.
The government should address the issue, "how clean is clean." A
relationship between cost and benefits must be considered. The
cost effectiveness of the cleanup must take into account future
land use (industrial standards versus residential). Use of
Institutional controls at sites. Groundwater standards need to
be reevaluated.
State Perspective. William Child, Chief Bureau of Land, Illinois
Environmental Protection Agency
In the State of Illinois, Corrective Action is a subset of the
Illinois Cleanup Program. Illinois goals are to properly
remediate Solid Waste Management Units. Illinois has a flexible
process for cleanups. We negotiate with industry to reach
mutually acceptable goals. Illinois expects to meet the GPRA
goals for 2005.
Illinois uses a tiered approach to Corrective Action referred to
as "TACO" (Tiered Approach to Cleanup Objectives). It is a risk
based standard (10 -6) and used in all our cleanup programs.
There are three tiers (I - Residential, II - Site Specific
Calculations and III - Risk Modeling).
Another component of the Illinois cleanup program is the
groundwater management zone. This consists of source removal and
managing remaining waste in a defined zone.
-------
-4-
Corrective Action Management Units - there are three facilities
in Illinois that have consolidated wastes into one unit.
Remedial Action Plan Permit - To date Illinois has issued three
final and five draft permits. Illinois was able to issue the
draft permits within 90 days. This approach allows for faster
and more cost effective cleanups.
Illinois has learned the following lessons from our past
experiences. First, the command and control that we had used in
the past were not the best option. We will accomplish more by
offering cleanup incentives to facilities. We need to tie our
other cleanup programs to the RCRA Corrective Action Program.
Illinois is currently working on an Ecological TACO. We should
have this finished by the end of the year. We also plan on
continued teamwork and open communication with the stakeholders.
We also want to continue looking for new and innovative ways to
manage the program. We are open to new ideas from industry.
Voluntary Efforts by the Private Sector, Robert Johnson,
Executive Vice President, Wildlife Habitat Council
The Wildlife habitat Council (WHC) was established in 1988. Our
main objective is to work with companies and Federal and State
agencies to increase wildlife habitat through improvement of
marginal or unused portions of property. To date, WHC has
assisted its members to plan wildlife enhancement opportunities
at more than 750 facilities. These programs encompass more than
1.5 million acres. The WHC works with and encourages industry to
work with WHC on sites involving RCRA and Superfund program
cleanups. WHC believes it is possible to achieve acceptable risk
levels. WHC focuses on results and innovation. Two cleanup
sites that WHC has provided assistance to were the
Bridgestone/Firestone Woodlawn Landfill in Cecil County, Maryland
and the Lime Lakes project at PPG in Barberton, Ohio. The PPG
Barberton site consisted of six above ground waste impoundments
containing more than 33 million metric tons of lime wastes.
Initial cost estimates indicated remediation would take more than
fifty years to complete at a cost of more than $100 million. The
final decision was to use land treatment and ecological
enhancements where sewerage sludge was used to amend the lime
wastes to produce a soil that sustained a vegetative cover
stimulating wildlife habitation.
Benefits to industry include enhanced wildlife habitat, increased
employee morale and productivity, better community relations,
maintenance cost savings and improved relationships with
governmental agencies.
-------
-5-
WHC will be holding a sequel conference to our June 2000
conference. It will be held on July 10 and 11, 2001 in
Washington, D.C.
Performance-Based Orders, Jean Caufield, Remediation Group,
General Motors Corporation and Gerald Phillips, Corrective Action
Process Manager, Region 5
Drawbacks of the traditional order were that it had an unlimited
scope of work, negotiation was a lengthy process delaying
cleanups, the work was too detailed and focused on minutiae and
generated ill-will between the facility and government.
U.S. EPA's objectives to streamlining include less oversight and
more owner/operator response. Achieving Environmental
Indicators are still a priority.
The positive features of the new streamlined order include:
• Enforceable deadlines, recourse for disputes and penalties
stop accruing until U.S. EPA notifies.
• The facility has more responsibility.
• Innovative technologies are welcomed.
• It features a risk basis for remediation.
• Reduced time in completing the cleanup is achieved due to
less review time.
The streamlined order has the following key legal provisions:
• Delay of one year for dispute resolution proceedings to
allow for negotiation between the project managers.
• Feature the same work products but the process is different:
There is a team approach, steps are eliminated, the team
meets in lieu of approvals.
• The order requires two meetings per year.
Results:
• The facility and the Agency are working more informally
(team approach to work product review). It has eliminated
detailed review of planning documents.
• The facility seeks EPA approval even when not required by
the order for comfort.
• EPA has been responsive to requests for meetings which has
helped with coordination with TSCA.
• The speed of the process has increased dramatically.
• All of General Motors Corporation's facilities are on
schedule.
-------
-6-
Voluntary Agreements, Hak Cho, Chief, Corrective Action Section,
Waste Management Branch, U.S. EPA, Region 5 and Monica Satrape,
Environmental Action Manager, Hoover Company
Hak Cho:
A voluntary agreement is performance-based. There is a minimized
oversight involvement by U.S. EPA. The owner/operator does not
have to wait for formal U.S. EPA approval to begin the cleanup.
Key points that are noted in the agreement are Environmental
Indicators (CA725 - human health and CA750 - groundwater) and the
final remedy. The voluntary agreement is a non-enforceable
document, there are no penalties and either party can terminate
the agreement with or without cause. The goal is to achieve
Environmental Indicator determinations and to achieve final site-
wide cleanup. Enhanced public participation is required and is
critical to the process. The facility must submit and maintain
all documentation required. The facility is required to act in a
timely manner. There are currently six voluntary agreements
signed in Region 5.
Monica Satrape:
The facility (Hoover Company) is in the middle of a small town
(North Canton, Ohio). Closure issues were addressed by the Ohio
Environmental Protection Agency (OEPA). OEPA did not have the
resources to address corrective action issues. Hoover Company
chose a voluntary agreement because there was trust and a sense
of partnership and the company is concerned with the people and
the community. Hoover Company wanted a shorter process than with
the traditional Corrective Action Order. Hoover Company received
support from OEPA with an extension for their closure plan
execution. The agreement required commitment from both U.S. EPA
and Hoover Company. U.S. EPA increased the facility from a
medium priority to a high priority facility and Hoover Company
committed to the agreement. Hoover Company plans to achieve
their El determinations by August 2001, which is 22 months after
the agreement was signed. The final remedy is planned to be
finished by December of 2003. The agreement features focused
deliverables. Implementing the plan included starting at the
perimeter of the facility to address community concerns. Hoover
Company has completed interim measures. The on-site
investigation is currently ongoing. Achieving El determinations
may be challenging because Hoover Company has only two
construction seasons. This requires a constant strategy and
focus on the Els. The voluntary agreement is more efficient
because it is less prescriptive and it has a maximum term of five
years. Hoover Company is saving money with this process. The
community is being supportive, and Hoover Company gained the
-------
-7-
support of a previously skeptical environmental group.
Streamlining Under Existing Instruments. Tammy Ohl, Corrective
Action Project Manager, Region 5; Roger Schumer, Project Manager.
International Paper; Richard Menozzi, Director of Environmental
Remediation, U.S. Steel; Gale Hruska, Corrective Action Project
Manager, Region 5; and Douglas Bley, Senior Projects Coordinator,
Bethlehem Steel Company
Tammy Ohl and Roger Schumer:
U.S. EPA negotiated a new order for the remedy implementation.
The impetus for streamlining came from International Paper's
upper management. They separated the Solid Waste Management
Units by priority and set time goals. They then planned what
work they could achieve in that time span. The preset schedule
made the process less formal. All decision-makers were present
at all meetings to prevent delays needed for consulting.
They completed the remedies on time. The motivation for adhering
to this process was that it is more efficient and it saves money.
Fewer documents were necessary to prepare formally. Documents
were conditionally approved rather than going through a round of
revisions. The catalyst for action was schedule constraints, the
aggressive schedule meant that there wasn't time to argue, the
atmosphere encouraged problem solving. In return, there was
quick turnaround for reply.
Tammy Qhl and Richard Menozzi. U.S. Steel Streamlining:
Previous negotiations were "stop and go." There was an attempt
to develop a MOA and then to modify the existing order. Neither
option was achieved. US Steel agreed to set a schedule to
expedite work at the site.
Pitfalls of the negotiations: The current order may have already
had the flexibility required, if both parties agreed on the
goals, the order can be amended. If the parties disagree, no
progress will be made regardless of the type of order. If we
intend to renegotiate an order, go on a parallel track with the
old order to maintain progress. The negotiations can be used to
establish trust. Both parties should align their objectives and
understanding each other's goals is important. Both parties
should identify their "must haves." Setting a schedule was also
important. Key decision-makers should be at all meetings so a
steering committee was established to include project managers
and management.
-------
-8-
Gale Hruska and Douglas Bley, Bethlehem Steel streamlining:
The facility had a permit for underground injection which
included corrective action. The permit was not specific about
work to be performed. It required development of a corrective
action plan, and implementation of that plan. The permit is
about to expire. The new permit will include the specifics and
flexibility that were missing. Partnership is important to speed
up communications. There must be a smooth transition from the
expiring permit with incorporation of past work, such as the
Quality Assurance Project Plan. The new instrument must
incorporate flexibility and be less process oriented. There is a
citizen's advisory committee that is interested in the South
Landfill Area at the site. The interest in this area makes it a
high priority and the facility wants to remediate it quickly.
The South Area will be addressed first. The rest of the facility
will then be addressed to expedite the cleanup.
Property Reuse, David Kalet, Environmental Business Manager, BP
Amoco, Whiting Refinery and Keith West, Remediation Group,
General Motors Corporation
David Kalet:
Establish a vision for the future use of the property. The
future use of the property will be market driven. Identifying
the stakeholders (community and external market) is important.
Identify the positive and negative attributes of the site. What
aspects of the site will be attractive to outside sources and
investors. Investors will be concerned about risks of
environmental liability. Stakeholders (users, community and
investors) will be more involved than the regulator agencies or
property owners. Relevant user needs such as access, community
concerns such as creation of jobs, taxbase and additional
greenspace. The Brownfield's equivalent of a RCRA Conceptual
Site Model is the site master plan.
Keith West:
In smaller towns, the facility may be the major employer.
Assessment of impact to communities must be considered.
Redevelopment of the facility should be included in corrective
action to create jobs after the facility is gone. The Corrective
Action process should mirror the business process. The approach
was to create a redevelopment strategy. This included discussing
future plans for the site with stakeholder including
decommissioning the buildings, performing the environmental site
assessment and, and prioritizing the environmental issues (do the
interim measures first, and then address the larger problems at
-------
-9-
the site) .
From the beginning the development of a current conditions report
that identifies environmental concerns at the site and sets the
tone of the remediation. For example: Centerpoint Business
Campus which was formerly a General Motors Corporation truck
plant. One production building was decommissioned and scaled
down to an office building. U.S. EPA had identified 28 SWMUs, GM
found 43 more. Interim measures were used extensively to get the
work started. The new uses for the plant are: GM offices, GM
plant, hotels, restaurants and commercial businesses.
Keys for success are the facility must be proactive and trust
EPA. Address immediate issues with interim measures and finally,
be flexible. Realize that the requirements of the developer may
be more stringent than EPA's requirements.
Alternative Remedy (Phvtocover), Martin Hamper, Principal
Scientist:, Arcadis, Geraghty and Miller and Dr. David Tsao,
Environmental Research Engineer, BP Amoco
Martin Hamper:
Phytoremediation provides containment and removal of water
content from a site through evapotranspiration and degradation of
the hazardous waste constituents. A 25-year-old tree can
transpire 5 gallons per day. The system needs to be designed to
meet RCRA regulations. A conservative design concept was
developed. Water balance analysis is crucial for success. The
benefits are that the regulatory requirements can be met in a
cost-effect manner. The phytocover provides greenspace.
Operation and maintenance costs decrease over time.
David Tsao:
During the mid-1990's, properties adjacent to the Mississippi
River such as BP Amoco's Closed Disposal Facility (CDF) in Wood
River, Illinois, were subjected to inundation as the river
reached 500-year flood stages. As the waters eventually receded,
the potentiometric gradient between the inside and outside of the
CDF began to build. Concerns were raised that this gradient
could potentially push the contained hydrocarbons (petroleum
wastes in the form of hydrocarbon sludge) through the containment
wall surrounding the CDF. In order to remedy this situation, BP
Amoco, in cooperation with Illinois EPA, investigated the use of
phytoremediation for its abilities to evapotranspire significant
volumes of water from the subsurface. Initially, plant screening
experiments were conducted in the greenhouse using hydrocarbon
material acquired from the CDF. These experiments provided
valuable insights into the potential species that could be used
-------
-10-
to send their roots into the subsurface of the CDF, possibly
encounter hydrocarbons, survive, and transpire out the contained
moisture. Both groundcover species as well as trees were tested.
Once a list of candidate species was developed, three-year field
trials were initiated which included planting several plots of
groundcover plants as well as stands of different tree species.
The groundcover plots were designed to intercept incoming
rainfall and prevent further infiltration into the subsurface
while the trees were designed to provide a slow pressure release
of the existing subsurface moisture. When used in conjunction
with one another, the combined vegetative cover should lead to a
reduction in liquid levels v/ithin the CDF. The site had ponding
due to flooding of the Mississippi River which was contained in
the site by a previously-installed slurry wall. The pump and
treat option was not feasible due to the lack of an electric
utility. Water would have to be collected and trucked away. The
cost was estimated at around two million dollars. The second
option was phytocover which would not require utility
connections. The estimated cost was $250,000 to $500,000.
Day 2 - January 18, 2001
Opening Remarks, David Ullrich, Deputy Regional Administrator,
U.S. EPA, Region 5
This year and the next several years will continue our efforts to
improve the effectiveness of RCRA Corrective Action. Yesterday
you heard about some new initiatives and some successful new
tools for program implementation. Today we will have a chance to
get State perspectives on Corrective Action in their Breakout
sessions. I support the streamlining efforts that have been
implemented and I encourage continued efforts to reform RCRA.
I want to stress that the Corrective Action program is key to
achieving both agency and regional priorities. These include
reducing toxics, Brownfield redevelopment, protecting people at
risk, especially children and environmental justice communities
and protecting and restoring ecosystems.
I want to encourage you to provide your suggestions, insights and
experience today during this afternoon's open discussion.
I believe that it is through effective communication that
improvements in the way we all work together can be achieved.
We look forward to working with you and thank you for coming to
our second conference on RCRA Corrective Action.
-------
-11-
State Breakout Sessions - Individual States with Industry
Illinois
Joe Zlogar, URS Corporation - Industry will encourage
streamlining in Illinois. Creative ideas, trust, and
communication are needed. Innovative programs such as RAPs and
CAMU are also needed. Perceived barriers include failed
promises, lack of progress, site specifics in discussions and
State interpretation of U.S. EPA guidance.
Indiana
Tom Linson, Indiana Department of Environmental Management -
Indiana's Risk Integrated System of Closure(RISC) (consistent
clean up standards) was adopted last Wednesday. It allows for
more flexibility in their cleanup program. RCRA reforms when
permits and orders appropriate (site specific issues were
discussed). Other discussion topics during their break out
session were the Corrective Action Program organizational
structure, Groundwater Rule (currently under development), land
use restrictions especially industrial closure scenarios' (more
agency authority to enforce and transition)(implementation of
RCRA reforms).
Michigan
De Montgomery, Michigan Department of Environmental Quality
(MDEQ) - Michigan's cleanup criteria is land use risk based
(1995), their Part 201 cleanup program. In November 2000, U.S.
EPA recognized Michigan's cleanup standards and they now have a
recognized Voluntary Action Program with U.S. EPA. MDEQ will be
training their personnel on the Part 201 cleanup standards.
Project managers will also adopt streamlining. MDEQ has
formulated a strategy to complete Corrective Action in Michigan.
Michigan identified "pilot" issues - waste identification (listed
waste classification versus risk-based cleanup criteria),
bioavailability determination (as opposed to more traditional
analytical procedures for identification of risk-based pathways),
and PCB Federal process (Michigan wants to pursue site specific
standards). Waste classification listed vs. risk based clean or
still listed. On May 1, 2001, MDEQ will host a Corrective Action
conference in Troy, Michigan with Michigan facilities.
Minnesota
Bruce Brott, Minnesota Pollution Control Agency - There were no
facilities attending the conference from Minnesota. Minnesota is
just about through with GPRA Corrective Action work. GPRA
-------
-12-
necessitated the issuance of a few additional permits with CA
agreements to address all sites.
Ohio
Dave Sholtis, Ohio Environmental Protection Agency - Overview of
Corrective Action is at 85 GPRA baseline facilities, almost an
even split between U.S. EPA versus State lead (work sharing is
ongoing). Concerns are that there is a smooth transition from
U.S. EPA to State lead. A lot of coordination will be required
as well as work sharing and getting the State involved early in
the transition process. Perceived barriers to streamlining
include getting ideas across and focusing on new methods, putting
things in writing at State level. Facilities with units subject
to closure rules sometimes want to be more flexible and move
ahead with site-wide cleanups, but run into authorization
problems. Closure requirements can get in the way of site-wide
cleanup (e.g., groundwater monitoring in cleanup areas to comply
with closure regulations). State requirements' conflict with
Federal requirements. Need to engage U.S. EPA on how to deal
with these types of scenarios.
Wisconsin
Mark Gordon, Wisconsin Department of Natural Resources - Pilot
projects expand liability exemption for government and lenders.
It expands EPA's area of contamination policy. Also, request an
MOU with Region 5 to recognize Wisconsin's voluntary program.
Federal
Cultural changes are needed to convert from process-based to
performance-based Corrective Action Program. October 13, 2000,
Region 5 Guidance on performance-based Corrective Action is key
to implementation of these changes. The Corrective Action
Program is in transition and we need to maintain the momentum of
the past few years. We need to concentrate on useful data
collection at sites (only collect data that is needed). Use an
iterative nature to collect data. Paula Williams, Region 5 is
working on risk-based guide (clean facility to risk point then
manage risk on a site specific basis). For all programs in
Waste, Pesticides and Toxics Division, involvement with all
stakeholders (community, citizens and local officials) as well as
facility. It is important to identify stakeholders at the
beginning of the process. Owner/operator cooperation and
communication (need a level of cooperation to develop a
partnership). A strong partnership with the States is also
critical. Make the process transparent. Encourage innovation and
skip steps as appropriate. Working on exit process and how clean
-------
-13-
is clean. The El determinations are a key step in the process,
but we need to finish the cleanups and terminate the process
before we are really finished at a site. We are currently
revising the Exit strategy. We still need to finish 162 GPRA
facilities and 1,600 sites that haven't been started yet (non-
GPRA facilities). U.S. EPA role in permit-driven Corrective
Action will be replaced by States over time as we transition from
Federal to State lead.
Superfund's sharing of information (set up exchange of ideas and
informal communication between project managers). Waste,
Pesticides and Toxics Division wants to incorporate that among
RCRA Corrective Action Project Managers.
U.S. EPA needs to mirror the performance-based approach to
encourage States to embrace RCRA reforms as well. Headquarters
assistance and support will help dealing with non-cooperative
sites.
Corrective Action Awards, Presented by Robert: Springer and
Karl Bremer, Chief, Waste Management Branch, Region 5
Leadership Award - Hoover Company, accepted by Monica Satrape,
Environmental Action Manager. Recognized for outstanding
facility leadership in the Corrective Action Program and the
development and implementation of a model Voluntary Agreement.
Progress Award - Argonne National Laboratory East, accepted by
Greg Borland and Angela Harvey, United States Department of
Energy. Recognized for outstanding facility progress in the
Corrective Action Program in streamlining and completing work at
its facility.
Special State Commendation - State of Illinois, Environmental
Protection Agency, accepted by William Child, Chief, Bureau of
Land. Recognized for outstanding leadership and support of
streamlining the Corrective Action Program and efforts in
completing Environmental Indicator determinations.
Honorable Mentions - Industry: Safety-Kleen and State: Michigan
Department of Environmental Quality.
The New RCRA Reforms, Steve Heare, Director, Permits and State
Programs Division, Office of Solid Waste, U.S. EPA
U.S. EPA Headquarters wants to thank the Region, States and
facilities for the progress achieved in the Corrective Action
program. Review of past reforms HPV to GPRA, stabilization to El
determinations. Environmental Indicator determinations are our
-------
-14-
top priority. 2005 is the deadline imposed by GPRA. We have
tools in place, regulations and policy to allow programs to take
off and meet these challenges. The RCRA Corrective Program will
be different in the future. It will be results not process that
will be stressed. Creativity and innovation by the Regions,
States and facilities will be key. RCRA Cleanup Reforms II
center around making cultural changes on how to do business.
Pilot innovative approaches. Twenty-five pilot projects for 2001
is our goal. We need to accelerate changes in culture in all
Regions. It is important to have these kind of conferences
where the stakeholders are present. Training, Corrective Action
workshops and partnering with industry to assist with training
are things we would like to see. Internet web-based
communication also linked to State sites to foster information
exchange. A summary pamphlet to summarize web information for
the public is another. Indoor air issues and such related to El
determinations, connecting communities to clean ups (TOSC grants
to help communities understand problems and options for cleanup).
Brownfields and TSE targeted sites are issues that could hold
things up (chance to work thru barriers). Outreach and training
(success of cleanup stories) should be communicated to
stakeholders. Also, comf6rt letters to keep U.S. EPA out of the
loop. Guidance and letter drafted and coming out soon.
The latest round of guidance coming out will be groundwater and
exit strategy. Most likely no new national policy but clarity is
needed. There are no current plans to issue perspective
purchaser policy/guidance. The Region plans to pursuing
voluntary program MOUs to recognize State programs rather than
issuing "comfort letters" on a case by case basis.
Open Issues Discussion. Steve Heare, John Quarles and Gerald
Phillips (moderated by Robert Springer)
Ground rules for pilots have not yet been published. The way
U.S. EPA currently envisions the process is to register them with
U.S. EPA Headquarters for information purposes (what it is, what
will it achieve and what we learned from the pilot). No formal
approval will be required from Headquarters. The pilot project
should demonstrate streamlining. We are looking at one per State
as a good idea. Headquarters would encourage the pursuit of a
pilot if it is something that makes sense and the company, State
and Region agree on it. Wisconsin is looking-at some sort of
lender liability protection pilot. We need to use pilots to test
new concepts to see if something will really work. The RCRA
Corrective Action Program is run on the basis of existing
guidance. The challenge is to find flexibility that currently
exists and to take the general framework of the guidance and
successfully applying it in practice, achieving results and
reporting out on successes.
-------
-15-
Brownfields are part of managing property. Reuse is part of the
decision making process for an owner. What is it about
Brownfields that RCRA Corrective Action project managers should
be paying attention to? The business process is the leading
issue. When is the corrective action process done at a site?
Property developers and managers want the corrective action
process to be out of their way. Does the absence of a proactive
Brownfields program in the RCRA arena restrict business activity?
The answer is yes. Companies will warehouse contaminated
property and not use it or sell it due to the liability risks.
It is a manageable burden for the company, but a devastating
burden to society because it is keeping that property out of
active use. U.S. EPA needs better tools and training to deal
with this problem.
Headquarters as part of Reforms I committed to do a handbook of
groundwater policies. What was envisioned was a compilation of
existing policies. Into the process it was found that it was
contrary to the kind of things they were trying to promote with
the reforms. It has since been significantly rewritten and has
been distributed for comment. Some of the comments dealt with
cleaning up a site to drinking water standards where the' existing
use is industrial. There needs to be some interim steps. For
example, the cleanup level for a facility that is operating may
not be the same once it closes. There needs to be continuing
dialogue, perhaps in some sort of setting. The current draft
will be out in a couple of weeks for Region and State review.
Exit Strategy. George Hamper, Corrective Action Section,
Enforcement and Compliance Assurance Branch, U.S. EPA, Region 5
Region 5 is developing a Corrective Action Completion Guide to
help Region 5 staff recognize the successful completion of RCRA
corrective action work at any individual facility, and describe
the situation accurately in the Agency's information database,
RCRAInfo. A draft is available for review and comment. It
explains that the "Statement of Basis" and the "Final Decision
and Response to Comments" are the key documents for public
participation and remedy selection. The "Final Decision and
Response to Comments" for each corrective action project should
explain what needs to be done to complete the corrective action
work for that facility. Recently, a workgroup has been formed to
try to adapt the Corrective Action Completion Guide for use by a
wider audience, including industry representatives and the staff
of state agencies. The goal is to have the document finalized by
about the end of April 2001.
-------
-16-
Risk Management Strategy, Paula Williams, Toxicologist,
Corrective Action Section, Enforcement and Compliance Assurance
Branch, U.S. EPA, Region 5
Corrective action decisions are largely based on risk. This
strategy is designed to unify risk managers' professional
judgement and to take a holistic approach to the process. The
strategy includes considerations of the big picture (i.e.,
wetlands, public interest, El determinations), data quality,
ecological concerns, and groundwater use concerns. Using this
guidance, project managers will make site specific, risk-based
decisions that are consistent with other decisions made in the
Region.
Persistent Bioaccumulative and Toxic Chemical Reduction Strategy,
Greg Rudloff, Corrective Action Project Manager, Corrective
Action Section, Waste Management Branch, U.S. EPA, Region 5
My discussion will be about PBT pollutants and what they are.
They are bioaccumulate in the food chain. They are toxic and
pose risks to human health and ecosystems. Examples include the
following chemicals: cadmium, lead, mercury, PAHs,
dioxins/furans, pentachlorophenol, heptachlor, chlorobenzene.
The GPRA goal is by 2005 to reduce by 50% of PBT chemicals as
compared with a baseline year of 1991. Recovering PBT chemicals
that have been released into environment is a key component of
the strategy. The RCRA program plans to track and document
these chemicals at ten U.S. EPA lead sites.
Performance Based Guide, Gerald Phillips
The Region's Performance-based Corrective Action Guide became
effective in October 2000. The purpose of the Guide is to
provide a summary of the philosophy behind the Region's efforts
to streamline RCRA Corrective Action. The focus of the Guide is
on the use of flexibility and prioritized decision making to
ensure that the cleanup efforts take precedence over
administrative steps. The Guide discusses the use of risk
management tools, iterative data collection and decision making
as well as the role of the interested stakeholders. The Guide is
intended to summarize the cultural changes being implemented by
the RCRA Corrective Action program in Region 5.
-------
-1-
Section II - Action Items
1. Illinois Environmental Protection Agency will develop
Ecosystems-Tiered Approach to Cleanup Objectives (ECO-TACO)
guidance.
2. Michigan Department of Environmental Quality will hold a
Corrective Action Conference in May 2001. They have offered
to share their efforts with the other States.
3. Indiana Department of Environmental Management will finalize
its State Risk Guidance (RISC).
4. Region 5 will send some staff to Indianapolis, Indiana for
RISC training.
5. Region 5 will send some staff to Lansing, Michigan for State
Cleanup Standards "Part 201" training.
6. Region 5 will work with the States to coordinate transition
of permitted sites from Federal lead to State lead.
7. Indiana Department of Environmental Management and Wisconsin
Department of Natural Resources will request Memoranda of
Understanding with Region 5 for acknowledgment of State
Voluntary Cleanup Programs.
8. Region 5 will further test streamlining pilot projects with
States using approaches such as:
a. Achieving cleanup goals more effectively;
b. Improving stakeholder involvement; and
c. Enhancing the use of accountable State non-RCRA cleanup
programs.
Region 5 will develop as many as six pilots under RCRA
Reforms II, through collaboration with each State.
9. Region 5 will provide more public access to information by
publishing Environmental Indicator forms and site summaries
on-line.
10. Region 5 will examine common approaches for industry
sectors.
11. Stakeholders will resolve property reuse issues.
-------
-2-
12. U.S. Environmental Protection Agency Headquarters will issue
revised draft groundwater policy (further dialogue with
stakeholders will be provided).
13. Region 5 will begin to make property re-use, such as
Brownfields, part of the CA approach used by the Region.
Links between the two efforts will include how Els fit,
release of property, timing, exit.
14. Region 5 has a workgroup developing a RCRA Corrective Action
completion and exit plan. Tied to this, is consideration of
alternative institutional controls, available at various
levels of government.
15. Region 5 is working to develop consistent risk guidance.
16. Region 5 will pilot test measuring Persistent
Bioaccumulative and Toxic chemical reductions at Federal
lead sites.
-------
Appendix 1 - Presentation Slides
Robert Springer - Welcome and Introductory Remarks
(13 slides)
William Child - RCRA Corrective Action, A State's
Perspective (10 slides)
Robert Johnson - Voluntary Efforts by the Private Sector
(39 slides)
Jean Caufield - Streamlined Corrective Action Order (12
slides
Hak Cho - Voluntary Agreements (4 slides)
Monica Satrape - Voluntary Agreements (22 slides)
Richard Menozzi - Streamlining (U.S. Steel)(1 slide)
Douglas Bley - Streamlining (Bethlehem Steel)(8 slides)
David Kalet - Property Reuse (19 Slides)
Keith West - Property Reuse (47 slides)
Martin Hamper - Phyto-Cover at a RCRA Site (23 slides)
David Tsao - Phytoremediation at Wood River (25 slides)
George Hamper - Exit Strategy (2 slides)
Paula Williams - Risk Management Strategy (2 slides)
Gregory Rudloff - PBT Strategy (7 Slides)
-------
Welcome and Introductory Remarks
presentation by
Robert Springer, Director
Waste, Pesticides and Toxics Division
U.S. EPA, Region 5
-------
-------
o
v^3
O
^y
^s
^
'"tj
a
^^^^j
A
G ..I
F"l
O
E
c
ir
r
4-4-
3 C
5 C
si r
Hit
i i i i
3 C
5 If
J T-
3 C
3 C
T-
1
|- 1
i j
— Z3
- .J
ii i
\ t f t
i_i i i
3 C
3 If
E
i ( i 1
j
!
„. ^r..., ,
i i
i
!...„ ,
i 1 1
T 1
1
i ) ( )
i i i i
) C
3
CD ™
CO H
~ % & Q
^
- *\ rjT ^^J DS &CU
S R 2 w ^
o Sg 0 H^l Q
m H ^> PH ^! O W
N* ^H i* *i S*"1 ^/ ^j r ,
£? < O ^N ^ ftj H
^ ^|fil|l
m S^^RLjO1^
0
o T~
O
5 i
HH
S R
o « U
CN R S
•J! ^J 'fm*
«i| z«
X Q W 3 ^ O W
O w kT H^ A w k~]
T- W ^ (sj O £ p>
< «) O t/3 U HO
0 O tf >, >H S ^
PH OH X X N Qj
^ fiw W H ^ Cu
§ 5i i i =p
HM *-^ ^5 iC [jj QQ rAi
O O
o o
o o
o »r>
o
o
U U U U U U
-------
WD
IT)
= PH
O
OX)
0)
U>
CD
_CU
CD
01
|
"0
C
3
2
O
\
?
Q. CD
E E
O CD
o a:
o
0)
o
O
H—
O
o
'•(-<
03
C
CD
O)
C
'c
'ro
0)
a>
-<—'
J!
o.
o
O
0)
D)
_C
'c
"co
E
0)
_
a.
E
o
O
-------
(D
"o
O>
O
O
>4—
o
c
o
"ro
c
E
0)
O)
c
'c
'«
E
(D
o:
_
Q.
I
-------
c
2
Q. (D
E oL
o c
o B
c O
.2 CD
ffS
QL
-------
I
CO
2
15
CO
o
Q.
X
LU
C
to
13
X
I
Q. §
E Q.
O C
o §
c O
O oj
o) *;
3 -2
C£ C/D
D>
0)
si *
D)
C
'c
'ro
0)
o:
o
O
w. „
CL ^)
E Q.
o p o)
O g .E
c O .E
o
-------
3
-2> 3
Q. jjj
E "5.
0 E
O g
c O
.2 a)
CD
c.
(C
* E
S S
co a:
(U
!S .a
a. 0
E Q.
O C
O §
c O
.2 a)
CD +i
CD JS
CC CO
c
g
I
I
"G
2
o
O
o
"-P
(0
c
a>
CO
c
'c
'ro
E
a>
01
0)
-*—'
JD
a.
E
o
O
CD
.
«
E
a)
-------
I
o
3
O
Q. j)
E Q.
O C CD
O § .|
c O .£
.205
co -£ E
0) B Q)
a: co a:
c
o
tj
(U
"o
o
O
"5
c
g
"re
c
E
0>
O)
_C
'c
ro
E
0)
a.
E
o
O
Q. _0)
£ "o.
o c co
O § .E
c O .E
.2 a) g
S5 3 I
DC: co DC:
snr
-------
1
o
(D
Q.
E
o
0
c
o
'en
.2
"S
Q.
E
o
O
£
en
'c
'CD
E
o:
'
o
O
M —
O
c
o
'-*-<
CO
c
CD
D)
c
'c
'co
(D
a:
.22
^
Q.
E
o
O
-------
t/3
l=
PH
pletions
ndicators Co
Corrective Ac
o
o
CO
O
O
o
CM
CM
SUOI)9|dUIOQ
O
10
O
o
O
m
ater
Ground
CO
CD
C
C3
E
OAijeinuino
-------
_c/>
CO
CO
C
i
,0
t
O
Q.
CD
K
]• CO
»s
•0.2
oi
•o c:
CD o
CO
C£ c
(/) O
o = S
I
o
a
CO
c
Q)
CO
M-
liSog
•£ p
O
a.
CD
co
co
£
0)
£
a.
CD
O U
O p
•— *- 2 M
L. v- £i CO
O O CD 3
oGfcO
-------
o
'-.
W)
<^
i
u
m
=
5/j
&
GO
H
^ a
«*-( o
0 S *
««
«*j
S
CJD
2
PH
US
ments
te Vol
e
p d n C c»
|| 11S
'5 & "2 l^ "ri
00
E
2
W)
2
o
bJO
CD
te£
a
• PM
review
TS
"3
C5
scision (
IX
PH
E
a
o
a
s
g
a
a>
U
S"
^
"E
S
o
U
<
U
•a 9
Ot)
ts «
& I
W OH
0) ..
03 H
f *
U ^
P^ co
H o P5
-------
o
!M
*3
o
u
f 1
U
OS —i
f* 2
O
U
*•<
u
<« ca
£5
a o
T3 T3
a> a>
1 §
*i 05
o £
O Q.
C 0)
D Ct
OS
i
o
fl
a
o
U
U
at
PH
V3
53 'o •£
5 fl
o
o
U fe
»5 JN *2
U
O
4) O
o *w
U^
o
o
• ^<
O
_
1
(U
(/>
2
Q.
(U
a:
I
2
§
cj >—N
I I
a 'S
h o
SU
*5 .
o J*
1—4 <1>
T>
I
(!)
(0
£
a.
0)
O
c
o
o
c
-------
-------
State Perspective
presentation by
William Child, Chief
Bureau of Land
Illinois Environmental Protection Agency
-------
^ CQ
-------
-------
-------
-------
-
lj;Pil*S'>:'••"-'I^Jgf'i- •- ' --.' ' .'
-------
-------
m H
Q ,ctf
O CD
-------
-------
-------
ft*
-------
Voluntary Efforts in the Private Sector
presentation by
Robert Johnson
Executive Vice President
Wildlife Habitat Council
-------
a
© 1988 WHC
o
o
u
PH
-------
o
• P-N
+n) C\
08 M
£ .9 «
« C oj
^^ P*^ ^ ^^ 5.- 1988 WHC
s« » ^ 1^2=,
a (/) ±j P-S-'
s fe I Ri
^ ^ S I**"
* rT! O ^^
o M 2 B_s
ft oo -a % j rj
fl 00 73 o « ^|
52 - sfl c3
e- .2 .S
W
111 a .s
a a 'S »N M
§D S g S «
UT O ^ O SI
o tu pq u. vi
-------
SJ
o
s
00
2
"I
!M
§ S3
O
H
'- •!-<
O
a
-------
B
S
o
u
=
• X O
DX)
S «
a
N
0>
e
o
U
-d
=
Q
r>
=
O
o
fl
^ ^ .fa *-C2 "-H
W ^
09 fl ^S
fl '3 «
o ^s ^^
u a
OJD o
M
E
-------
s
e*
wo
o
O
•ft
^
A
^
^
-------
fl
CQ
D
^Q
A^ 'H-H
W o
a
o
CD
o
o
o
fi
t. I»Httl WHC
F5
G
G
u
X
S
O
U
H
15
>—•
K
<
ffi
«
b
i—<
^
Q
^
-------
03
s^
o
a
CD
a
3
o
O
T3
CD
ts
oS
§
S3 »
TH
a
rH
03
^S «>
9 "^
03 «
PH -^
C CO
4^ _Q
^ ^
rH
& O
2 5
a bp
& a
03 M3
o3
a
o>
rH
0)
-------
-------
I
2
O
-------
a
-------
-------
8
Q
-------
Cfl
I
>•*'
s
(D
(D
rH
O
§
GO
^
• rH
^
t:
o
GO
O
o
O
GO
rH
CD
O
0)
o
§
O
• rH
PQ
C4H
O
fl
o
• i-H
ts
^H
O
-M
GO
I
o
O
§
CD
GO
O
O
0>
PQ O
o
^H
PH
1988 WHC
-------
u
§
O
GO
-------
CJ
o
§
O
-------
ffi
O
d
o
-e
0)
PQ
I
CO
b
CO
O
PH
f
o
U
o
U
CO
CO
ffl
-------
r—I
ts
o
o
o
CO
a
o
s
CO
CD
3
CO
0>
CO
o3
u
CJ
o
• 1—I
60
O
o
o
a
co
03
a
o
O
o
o
co (D
tJ O
a °
o
PH
o
s -a
-------
Jk
-------
fc:
CO
O
en
O
g
CO
a
CD
O
fl
O
O
PH
O
CO
fl
O
O
CO
fl
O
bD co
CO
PH .2
-------
O
w
o
1 1
X)
PH
GO
O
1 1
-------
T3
ts
a
O
GO
GO
2 8.3
O o(
-------
o
•^
o
p s
O
O
W)
OH
03
O
PH
co
T-H
•T-H
a
3
Co
o
o
o
. . H
^ $
rH rH
(D 0>
"d >
•rH
GO
a
o
o
CO
0)
V-i
o
PH
PH
0.
X< co
CD 4->
rH
•s
ons
a de
CD
GO
U 1/3
PH
0)
ts
-1— >
00
CO
ctf
CO
CO
a
o
o
-2
5^
a
o
CQ
-------
Q
a
-------
-------
-------
K
o
o
-------
a
o
o
g
(D
O
§
CO
CO
CD
I
CO
O
O
(D
S
O
CO
53
O
O
O
(D
-------
0>
-
§
CO
a
O CD
o
g
o-S
Develop the scienc
°5 d
o g
FH O
*"•«
§ g
o> ^
a
Cj
o B
w ts
a
a
s
o
•a
GO
•§
e
d .^
*-i ^ fl
> ^ ^
^ ^ °
«S 'C
!•£
fi §
s a
nstrate
to promote
s
OH
0)
a
(D
O
§
ij-a
*H 0>
<-> ^-H
Cd g
r ^ • • i _ t
O ^H O s-*1
a B a s
d) CJ (D rj
Q ^ Q
o
CD
-------
-------
-------
O
o ^ Q
5bS O
CO
ON
OS
O
o
0)
^H
(D
CO
a>
&
D
« ^
S2 C
i 1
i-s
4)
o
o
< 1
O °
CO
CD
^
H
GO
0
O
o
o
CO
-------
0>
« a
o
o
(D
O
CO
GO
a
o
i-H
I
CO
fl
O
a
Q
-------
mmmmm mm mm mm mm
-------
Q
K
S
1 ^^
a
-------
-------
-------
GO
PH
(D
GO
+-»
• rH
s
^
o
o
a>
rCj
GO
a
o
a
rH
r^»
GO
ise
Build
pro
GO
W
a
ffl
cd
4a
GO
I a
GO
CD
cd
>
ctf
<& (D
JP
fl g
a
o o
.a 43
• rH
XI
S iS
Si
a
o
rH
3
>
O
§
£ §
^ -a
a «
CO O
-------
GO
^^
T£>
T3
CD
T-H
o
GO
a
o
PH
GO
GO
CD
• T-H
T-H
CD
GO
o3
Vw
a
_ ^^^
• ^™ 1
CD
O
conferen
TJ
a
o
CD
00
ncemei
03
•s
CD
^
o3
O
•T-H
fcO
Q
0
CD
CD
"S
a
o
T-H
PH
O
GO
•§
€g
(U
J3
GO
TH
o
GO
a
o
PH
GO
H-j
CD
^Ji^f
r^^x
rj
^^
a
o
•T-H
-JL^
O
03
CD
>
• T-H
+->
o
CD
Z
O
O
T-H
cS
^^^^^1
^^^1
^^^J
r^^i
^^^\
i ^i
PL,
PQ
r\
O
PLH
PH
r i
-§
vironmei
c
W
O
h— 1
<:
en
O
i^^
o
GO
tone/Fire
GO
CD
W)
T3
•T-H
T-H
PQ
CD
Ovi
S
• T-H
^TlJ
CD
• T-H
Oo
CD
O
r^
•T-H
^
icements
§
o
-------
O
CO
a
GO
O
O
O
o
O
cd
KH
HH
o
o
(D
a
g>*
(X)
PH '
^§§
O -VH O
GO CO
bD
^^^j
1^" i
q
o
a
o
GO
a
•rH
a3
0)
O
cj
r T
'O
GO
•Hmmmmmmmmm
-------
Streamlined RCRA Corrective Action Order
presentation by
Jean Caufield
Remediation Group
General Motors Corporation
-------
-% >
/v. I
'* <<
$"
gj
CO
-------
O
Q
LU
Z
2
LU
(Y
h-
CO
Q.
o
WHY DEVEl
ORDER?
Q
LU
z
LU
h-
co
^
^*
01
o
u_
CO
OBJECTIVE
ORDER
o:
LU
Q
O
LU
LU
X
H
RESULTS
= >
-------
CO
**»>*
a:
UJ
a
01
O
o
HI
a:
UJ
o
a:
o
UJ
a
O
CO
•N
a.
UJ
a
UJ
UJ
03
"o
o
0
CO
CO
a:
o
<
£
UJ
a.
O
OWNER/
O
Z
•^
— •
^k_^
O
M—
O
0
CL
O
O
CO
-o
-2
1ZZ
C
D
CO
"c
E
CO
c
o
'•5
0
-4— •
O
Q.
"co
V W
0)
0
o
-z.
CO
.0
"co
c
0
Q.
J2
"co
13
Q.
55
-------
0"
Qi
III
Q
O
Q
UJ
UJ
£
fc-
Q.
q
LU
UJ
i
CO
IT
<
UJ
o
o
o
o
LJJ
z
LJJ
Q
£
O
CO
Q.
13
C
CO
_§.
o
"O
0
CD
0
CO
O
13
O
CO
0
0
03
_D
CO
•O
0
E
13
CO
C
o
Q O
o
13
E
T3
jD
"oo
0
c
0
O
-------
_ED PROCESS
•MM
^^r
H
LU
Q
^^
CO
i
-J
CO
LLI
^ ^
CO
Q.
_0
"co
.2
•E?
^^
0
C
2
CO
C
o
O
0
Q.
CO
Q.
C
O
0
CO
zs
o
o
Vi^
LJL
0
E
>-,,
0
^
>^
T5
0
03
0
Q
03
ii_i
ZJ
C
E
*-^
>>
JD
0
E
ZJ
CO
C
o
0
-------
ce
a:
UJ
a
CO
O
a
O
CO
CO
0
o
o
Q.
'o
c
».
o
c:
e based on performa
00
CO
0
i5
ave enforceable dea
X
_0
"3
Q.
_co
O
"oT
03
<_
m
rovide some recoursi
a.
JD
'co
c
0
CL
CO
0
CD
C
03
E
c
g
'o
0
•a
-2
"03
CD
o
o
|
<£
tals and approva
E
DMW
_J
CO
0
iizu
r*
CD
"2
0
o
CL
LJJ
CO
CO
_0
0
0
CL
C
g
i i
03
"E
^™*
1LULUOO
8>
13
CO
c
0
rovide milestones to
QL
CO
-H- •
c
'o
CL
~03
g
b
~03
•*-»
o
"5
03
CD
C
y
03
£
etain EPA decision -
a:
0
0
"ro
c:
03
^
_o
"03
0
T3
C
"as
-•--- •
ocus on Environmeni
LL
e innovative
-4— •
03
"co
C
O
E
0
•o
2
>>
"E
•i
o
CL
CL
O
0
O
0
0
O
CL
imedial measures
0
-------
-------
ee
"O
CO
H=
0
-4— •
03
"•+-*
0
D)
0
C
O
•+-»
CO CO
0 ^1
0) •£
a 1
CD C
T f
o
0
•2 additional orders signed in 20
ROVISIONS
Q.
INCORPORATES KEY LEGAL
dtam
'o
Q.
"03
0
b
"03
0
XI
•Gives EPA decision making aul
non-performance
s—
•Contains stipulated penalties fo
disputes:
c
•Provides O/O some protection i
o
c
O
O
"c
CO
03
O
CO
0
03
0
CO
03
Q.
CO
.0
~03
0
Q.
CO
LJJ
03
0
0
03
0
T3
CO
0
"03
C
0
Q_
0
E
0
"of
CO
0
03
Q.
•*— •
O
"o
"03
CO
0
0
CO
0
¥
•Requires public participation
QQ
-------
>,4
O
LJJ
cal conditions
o
-t— •
CO
!c
•a
c
03
-»— «
C
»
-Review curi
extent of releases
U)
"D
nature an
0
f—
-Delineate t\
-•—•
0
E
CO
LU
0
-Demonstral
easures
E
corrective
03
C
M—
0
CO
o
CL
O
ol
1
medy(ies)
0
-Implement i
o#
-Conduct O
anning and implementatio
Q_
O
"b
.0
CL
LU
T3
_0
'as
"0
Q
•
iminated
0
0
0
CL
LLJ
C
o
Q.
13
O)
C
"c
o
0
C
03
0
-*— »
03
*—
03
03
03
CO
3
Q
•
-------
o
UJ
Z
HI
X
urren
0
CO
SK-BASED
(O
*
Q
lacceptable risk
v_
3
c
03
0
CO
CL
g
Jc
^
CO
0
CO
w ^
03
0
CD
0
-»— •
03
0
C
"0
Q
<-»
"03
2
M—
>+— •
c:
0
E
c
0
>
c
0
0
Jd
C
03
£
0
c~
C
03
E
13
13
B
'o
ol
releases....
o
«4— •
0
13
CO
CO
0
_Q
03
4—1
CL
0
future unac
c
03
03
"5H
-2
'd
O
O)
c
'c
0
0
o
CO
conservate
0
CO
D
^^^
c:
_03
M—
"0
0
•5
0
CL
X
0
.^
jQ
03
C
O
ti\
CO
03
0
-Q
03
| ___,-•
1
O
o
0
CO
03
CD
CO
g
03
f—
0
O
CO
-------
CO
ts
13
"D
2
Q.
nated
o
0
CO
CO
0
£1
• -•
:f ssentially 1
c«
"C
CO
d.
2
, CL
,0
"S
, is.
O
^
1
T3
CO
CO
0
O
O
Q_
0
' x:
o
CO
f"«\
2
a.
Q.
CO
E
CO
0
IT
i
eliminated
CO
Q.
-S
"co
C
CO
IE
I
0
>>
"co
tr
'>
.0
jm \
2
Q.
LLJ
0
E
**•«
0
CO
Q.
CO
LLJ
1
CO
Q_
0
-»— •
CO
"co
0
b
"co
for reviews
45
"0
0
E
E
CO
0
-4— •
0
H
0
">
0
&_
lo
g
2
to
I
1
c
CO
Q_
^
s__
o
^
nvestigation
• ^™~
MM.
0
CO
c
"o.
o
o
CO
1
c
CO
CL
L_
O
"O
_0
"co
-1— »
0
«4—
O
£
.0
0
1
CO
•4— •
13
CO
0
ivestigation i
s_
M—
0
<:
0
'>
0
1
CO
CO
c
'c
c
CO
CL
1
-------
4'
//
'/„
'\*
*<
v^
w
:
3
m
LU
&
>
m incorporated the same as those
CO
"ba( comrtients
0
CO
T*
ZE
LU
jam members.
.E
s_
0
JZ
HM
O
M—
O
cf
o
>>
L_
CO
0
-1— »
13
Q.
_c
<
CL
LJJ
_*
0
0
CO
O
hly motivated t
CD
In
.to
S
O
or EPA comments.
M— .
_im-_j«
"co
^
o
*-•
•a
0
._
cr
E
•*-•
o
~2L
\
nsive to requests for meetings and
o
Q.
CO
2
^
0
c
0
0
_Q
CO
CO
-C
t
LLJ
eviews.
s_
"co
E
|
c
T3
_0
3
Q.
CD
C
"0
JD
CO
0
0
it
o
<
o
c/)
1
nications have increased significan
13
informal comrr
-i— •
c
0
13
O"
0
ts increased dramatically:
TO
CO
Q.
C
CO
0
0
M —
o
•a
0
0
a.
CO
0
x:
H
0
c
CD
C
ft
"co
1
CO
JZ
"c
0
E
CN
CN
'o
X
0
0"
o
c
CO
"0
Q
o
LL.
CO
1
CD
C
"o
c
tr\
Determinations
LU
"co
CO
0
CD
CD
CO
r»
-------
Voluntary Agreements
presentation by
Hak Cho, Chief
Corrective Action Section
Waste Management Branch
U.S. EPA, Region 5
-------
-------
-------
-------
-------
Voluntary Agreements
presentation by
Monica Satrape
Environmental Action Manager
Hoover Company
-------
£
O
o
to
0)
3
O
3
IL
o
0 o £
c
3
"o
c
o
UJ >
0 (5 S
« c §•
2- § E
2 E °
•• •• / \
w c
co 2 o
g«-
Q)
§j
l
a.
UJ
CM
O
-------
c
o
o
fl
o
£
o
o
a.
LU
0)
X
CM
X
o
-------
-------
-------
-------
0)
o
00
I
o
00
en
CL)
01
fD
o
-4—'
CO
E
Q
en
fD
1
jm -\
CD
'In
O
ro E
*- E
o o
>~
-r-t aj
E
O)
O
,i= (U
CL)
U
CL)
c/) ±3
€.£
fD
Q.
o
o> •_
> io
Q^
Q.
LLJ
X
CM
X
O
.A
-------
-------
c
o
o
(0
0)
o
0)
CO
Z3
U
>
i
CD
-u>
'co
^*\
£
E
CO
"c
fU
r"
U
CD
fU
CO
CD
T3
O
CL
0
E
••••i
Tl
i **^
1 CD
C CO
o ro
"or?
ni si/
\U —ju
Qi CO
J=;"s-
•M C
'^w
>sd>
1**^* f 1
•=^
O_J
_ o
£ Ui
= E!
< >-
^E
l«8
ui ¥-£=•
*— CJ
E.^ro
•T- 1— O
in CD i-
S Q.CL
^X CL
HH CD CD
CD
4_J
"O
fD
CO
CD
CD
^•»
O
Q.
E
CD
CO
4-J
_i i
-I—*
O
&
03
CO
2 25-
fD-J-1
U c
gi
o E
OQ
X u
CD
CO
c
CD
CO
CO
CO
(D
C
"co
u
jQ
T3
O
0
CO
£
fD
0.
LJJ
<*
»:*
*
.J
X
S
CM
Z
O
-------
c
0)
eem
b
O
(Q
^.
CU
CO
o
_g
0
_i i
i f
u
13
E
Q.
J=
artners
Q.
T3
fD
• «
4-J
C^
ru
4-»
c
CU
4-»
o
Q.
CU
U
Z5
"O —
V V
s- C
^ r^
fl
c
3
O
0)
ro
cn
O
-i_j
-i—»
O
o
4->
fO
•O
C
3
o
(U
X
(U
U)
CU
^ 13 M-
^ CQ O
£8
j_j ru
CO CO
CU CU
SI
Q.
LU
_J
_J
X
CM
X
(W
-------
0)
o
o
o c
o
o
-------
Agreement
^,
^^
0)
O)
^5
^^
c
o
"en
4-J
,g
CO
— • ^(
_J
u
CO
•4-J
CO
o
CL
^ff^
CL
CO
a.
LLJ
_g
O
"O
CL)
C
"03
r •••
en
en
i-H
cD
JD
o
tj
JC
c
o
E
rx
T3
CL)
en
"co
4->
a;
CL)
CL)
en
"L-.
4^1
u
c
^^•Ml
O
'"8
"cD
CO
^
a.
LLJ
en
c
C/)
CO
03
cD
•a
o
T3
CL)
BC
1
03
O)
-*— '
CO
CL)
^-»
i_
jj
^^^
f^5
T3
O)
CL)
T~5
>«/
o
^_
en
CD
en
fD
Q.
•rH
CL
w
X
CM
X
o
-------
CM
rsi
in'frj
4-»
CO
13
L-.
4-J
fD
4-»
13
E
^_
c
o
13
CU
fD
Q
?
fD
4-»
c
13
o
>
*T—f
*3
CU
CO
(D
.0
CU
U
c
fD
E
i
cu
Q_
i i
^H^
cz
cu
4-»
"E
E
o
u
¥
cu
o
o
4— »
c
cu
E
4-J
comm
v<"
£
LLJ
CO
ID
en
CU
C
o
4-^
CT)
_gj
Z
icators August :
)osal December
"^ 5=J
c P
~ Ql
fD >
C ^
5 «
if
0 ^
IS
LLJ U.
^^
LU
*>
*:*
<*
_j
x
S
(M
Z
O
-------
0)
o
0..*
o
to
0)
n
to
(/)
cu
o
Q.
CU
Z Cf
u
CU
T3
CL)
D
TO
O
CU
2
cu
O)
U
O
UL
CO
in ro
cu y
*- c
-o ^
J!
•5 °
roucu
^ -t;.o
cu
£
SQE
Q.
UJ
2MH
&
-------
c
o
c
0)
0)
a
E
Q.
UJ
I
s
M
X
o
-------
o
fl
o
a
a
a;
.1
a;
Q.
a>
fD
fD
CO
ZJ
E
E
o
u
a>
a;
fD
u
a;
^
fD
a)
a;
ZJ
tn
fD
a;
E
C1J
to
fD
E
TD
O>
01 = -77?
C/)
o
a;
o
E
WJ
Q
O
-------
-------
-------
o
c o
c
0)
£
• •••^
c
rsj
o
cu
Q
*
OT .2
CU
CO
cro
O (U
^ 5
u ^
13 CU
CU
CO
O f\lT5
4-»
fU
O
E OTCU
fM^
CM
C/)
fU
CO
13
U
en
C/)
fU:=
Q
X
O
UQZ
O
Q.
tD
o;
cu
en
c
'o.
cu
cu
cu
Q.
cu
D
U 13
fU U
a.
LJJ
s
N
X
o
-------
-------
(0
0)
• ^^^^H
O
o
"o
• ••
^•i
|^H
UJ
o
l^H
*rf
o
N
IH^I
"55
0)
D£
fD
BU
_l 1
1 *
u
03
a.
^i ^
n )
VL/
b
"O
c
ru
^M v
CU
^>
"413
b
G^
i_
Q.
i^^M^HB
CO
^
CT3
13 -R
•••^ • •
^^^^\ ft ^^j
T5 2
. Q.
CO Q.
> ru
Ttf-
-rH
C
03
4-»
L.
CL)
4-J
fU
}_
4-J
1
CU
en
ru
cu
LO
E
•i«
E
'x
tu
z
>^
C/)
C/)
CU
u
o
Q.
CU
C
mm^mm
>* Stream
j£
I w
O
CL
CL
fD
C
f f\
CO
ro
£
£
_Q
Z3
CO
fD
CO
C/)
CL)
u
cu
c
c
"o
c
,g
"fD
I
CL)
.
Q.
CO
(L)
[ i
CO
"o
"fD
O
Q.
CL
fD
CL)
U
C
fD
"D
fD
"D
fD
4_> CO
CHMM
CD
P i
CL— J
^J L. -|
"^ B
CL) fD
"D I-
CL
m
CM
X
o
-------
"O
8
fU
j-»
CO
c
o
2
Q.
co to
CD .2
Q.
i!
u c
01
o =
jQ
'X
cu
Q
cu
"O
cu
T3
C
03
CU
U
CU
CL
X
cu
E E
ru
— JQ fO
CO r=
CO .Q
< 03
Q.
JZ
CO
cu
c
03
CL
-------
4JI
I/I
c
'5
"o
c
o
o
-1— '
CD
E
en
"CD
^•v
_LJ
CU
03
c/)
CD
"u
-CD*
o
^•^^
C/)
<
CD
O
O
^^M^^H
"CD
en
c
"CD
cu
L_
fD
f f\
CD
"u
O
CD
"u
c
CD
OT
CD
^
>-
ti
i__
-i— »
CO
>/ j
O)
CL
'CD
a;
^w
fD
i *
^^^^
CD
E
CD
"5
cr
CD -
^ O
4— »
fD -«
.y ^
C i—
^1 CD
U ^1
.CD -a
03
u
M—
"c
.i^
C/)
en
c
^••IH
03
CO
.£
C^
CO
CD
u
0
Q.
T3
_CD
fD
a;
CD
U
U
fD
(— CO
^^^^^^ ^^ ^
*^^
^
03
CD
fD
t
CD
C7
CD
t
fD
o
MHtB
CT
O
•
H
*
u
a.
LLJ
*
*
i
01
o
-------
Streamlining Under Existing Instruments
presentation by
. Richard Menozzi
Director of Environmental Remediation
U.S. Steel
-------
CORRECTIVE ACTION - U.S.STEEL GARY WORKS
OVERVIEW
• 3008 (h) Order: signed May 1998
• Current Conditions Report: Submitted January 1997
Revised February 1999
• Facility Wide RFI Workplan: Submitted July 1999
Response to Comments December 2000
• Environmental Setting:
• 4000 acre site
• 7 miles long x Imile wide
• Operational for nearly 100 years
• RFA identified nearly 500 SWMU's
• CCR identified 251 SWMU's and 42 AOC's
• 3 Interim Status Hazardous Waste Units
• RFI identified 10 SWMA's & 3 Facility Wide Investigations
• Completed 2nd round of Groundwater sampling and analysis
at 55 perimeter groundwater wells
-------
Streamlining at Bethlehem Steel
presentation by
Douglas Bley
Senior Projects Coordinator
Bethlehem Steel Corporation
-------
-------
J z
I;
cu
-
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGIONS
230 SOUTH DEARBORN ST.
CHICAGO, ILLINOIS 60604
REPLY TO ATTENTION OF:
UTC3EKGROUND INJECTION CONTROL PERMIT
CLASS I HAZARDOUS PERMIT MODIFICATION
X
Permit Number: IN-127-1W-0003 x EPA ID Number: IND0039113423
Pursuant to the Underground Injection Control regulations of the
United States Environmental Protection Agency codified at Title 40 of the
Code of Federal Regulations, Parts 124, 144, 146, 147, and 148, Bethlehem
Steel Corporation, Burns Harbor Plant, of Chesterton, Indiana is hereby
authorized to operate a Class I injection well located at Indiana, Porter
County, T37N, R6W, Section 30, SE Quarter Section.
The injection zone, or zone which will contain the hazardous
constituents, for this well is the lower Eau Claire Formation and the Mt.
Simon Sandstone. Injection is permitted only into the lower Mt. Simon
Sandstone between the depths of 2730 and 4298 feet, upon the express condition
that the permittee meet the restrictions set forth herein. The designated
confining zone for this injection well is the upper Eau Claire Formation.
All references to Title 40 of the Code for Federal Regulations are to all
regulations that are in effect on the date that this permit is effective. The
following attachments are incorporated into this permit: A, B, C, D, E,
and F.
This permit is a modification of an existing permit which has an
expiration date of nddnifgHt-, October 30, 1990. This modified permit shall
become effective on U U I _ f> (8JtJ and shall supersede the existing
permit upon issuance. This permit shall remain in full force and effect
during the life of the permit, unless: 1) the statutory provisions of Section
3004 (f), (g) or (m) of the Resource Conservation and Recovery Act ban or
otherwise condition the authorizations in this permit; 2) the Agency
promulgates rules pursuant to these Sections which withdraw or otherwise
condition the authorization in this permit; or 3) this permit is otherwise
revoked, terminated, modified or reissued pursuant to 40 CFR 144.39 or 144.40.
This permit and the authorization to inject shall expire at midnight,
October 30, 1990, unless terminated.
-*i
Signed this O day of far^^ , 1990.
Dale S. Bryson
Director, Water Division
Printed on Racyded Paoer
-------
56
SWMU - resource recovery or conservation of any solid waste (as
defined in 40 CFR §261.2). It includes any uni.t a£ the
facility from which hazardous, constituents might migrate,
irrespective of whether the units were intended for the
management of solid and/or hazardous wastes.
B. Implementation of Corrective Action
The process of implementing Section 300.4(u) will take place in three
stages,'with each stage consisting of several specific steps, as follows:
1. Preliminary Assessment. Assessment of confirming re-leases is required
for all permits issued after November 8, 1984. If any of the requested
information has been previously submitted to the Director, include
the original source as a reference on the copy provided in the required
report. The permittee is required to submit the following information
45 -(forty-five) days from the effective date of the permit. Failure
to submit the required information or falsification!-of. arty submitted
information is grounds for the termination of this permit (40 CFR
§144.40). All information submitted trust be certified as required
"by 40 CFR §144.32.
a. Topographic Maps - Provide niap(s) showing the facility and a
distance of 1,000 feet around the property line at a scale of
one inch equal to not more than 200 feet. In addition to
showing the location of the permitted hazardous waste
facility and management unit;., the permittee must locate on
the map each existing and former soltd waste management
unit (SWMU), regardless of its permitting status.
b. Description of Units - For ;ach SWMU, provide a history of
construction, including engileering drawings, foundations,
materials of construction, dimensions, capacity and ancillary
systems. Include location, design» construction,, and description
Of all monitoring systems (air, surface water, ground water,
etc.). If the SWMU is not in use, describe' the methods
utilized to close the facility and all construction related
to closure.
c. Description of Operation - For each SWMll, provide a history
of the unit s function and all of the wastes processed or
-------
disposed of at the unit. Include the hazardous waste,
processed or disposed of, the time frames of operation, and
quantities handled during those time frames.
d. Description of Releases - For each SMW, describe an>y,_ .
or potential release originating at each SW4U. IncTjwte the
suspected date of release, the type o-f haziardouts vtasjte or
hazardous waste constituent, the quantity released-., the
environmental media affected, the nature of- the release and
present migration, arvd the circumstances and- cause af the release.
Provide any available data which would quant-tfy the nature and
extent of any environmental contamination including the
results of air, soil, surface and. ground, water samp:ling; and
analysis. Provide any available data; which wou.ld. indicate that
no releases are present, if applicable.
2. Remedial Investigations and Corrective Action Plan Development. If
hazardous wastes or constituents have been released, no later than six
(6) months after the effective date of this permit, the permittee shall
conduct remedial Investigations, develop a proposed corrective action
plan, and submit a report on the investigations to the Director
as follows:
(a) Site investigation, including but not limited to,
hydrological data, both surface and sub-surface sampling,
and identification of background prior to cantami nati on ;
(b) Remedial investigations by owner/operator to
identify /characterize releases;
(c) Develop an appropriate proposed corrective .action plan
and cost estimate; and
(d) Provide a financial assurance mechanism to cover the cost of
implementing the corrective action plan.
-------
5 8 ' A '•• " WL-^^ rlO Q'!>3
3. Corrective Action Plan Implementation. Within thirty-six (36) months
after the Director's approval, the permittee sha)l iiapTefaeifrt th
*•»
action plan as follows:
*
(a) 6 months after approval - Complete eng-ineering design;
(b) 6 months after approval - Prepare contract documents and
award construction bids or equivalent in-hou.s.e, action.
(c) 18 months after approval- Complete corrective, act-ton p.lan
C. Permit Modification
The Director may modify this permit to include additonal requirements or
modify the Schedule of Compliance as appropriate in accordance with 40 CR?
§270.41 and Section 212 of HSW. If major,permit modification fs receded,
USEPA will publish a public notice and allow for pubTfc review and comment.
-------
Table 2
Summary of Phase 2
Bethlehem Steel Corporation, Burns Harbor Division
Investigation Area
Phase 2 Activities
IA 1
Wastewater pump station
No. 2 surface impoundment
(1) Collect 2 upgradient hydropunch samples to confirm that there are no
upgradient sources of benzene
(2) Install downgradient monitoring well and sample for benzene quarterly for
one year
(3) Sample storm ditch and Outfall quarterly for benzene to verify no off-site
discharge.
(4) Perform a risk analysis using data obtained in Phases 1 and 2 to document
no risk to human health or the environment based on site-specific industrial
exposures and potential for off-site migration.
IA3
Rectangular and circular tar
impoundments
(1) Perform voluntary corrective measure
(2) Install 3 new groundwater monitoring wells
(3) Perform quarterly groundwater monitoring for one year to show
effectiveness of corrective measure.
(4) Perform a risk analysis as described for IA 1, above.
\ -_/_ ______ _ ~ "* _ — ~._—~------- -~_.._ —
(1) Re-sample existing wells 5-OW-3 and 5-P-2 quarterly for one year for
benzene
(2) Perform a risk analysis as described for IA 1, above.
IA5/7
Cokemaking by-products
recovery area
IA12
COG collection container
(1) Install one monitoring well immediately downgradient
(2) Perform quarterly groundwater monitoring for benzene for one year.
(3) Perform a risk analysis as described for IA 1, above.
IA15
COG collection container
(1) Install one monitoring well immediately downgradient
(2) Perform quarterly groundwater monitoring for benzene for one year.
(3) Perform a risk analysis as described for IA 1, above.
IA27
COG collection container
(1) Install one monitoring well immediately downgradient
(2) Perform quarterly groundwater monitoring for benzene and
benzo(a)pyrene for one year.
(3) Perform a risk analysis as described for IA 1, above.
IA30
COG collection container
(1) Install one monitoring well immediately downgradient
(2) Perform quarterly groundwater monitoring for benzene and toluene for
one year.
(3) Perform a risk analysis as described for IA 1, above.
(I) Perform quarterly sampling for one year in each area of potential off-site
migration (discharge channel, 001 outfall, and harbor)
(2) Perform a risk analysis as described for IA 1, above.
Dibenz[a,h]anthracene Study
-------
-------
Property Reuse
presentation by
David Kalet
Environmental Business Manager
BP Amoco, Whiting Refinery
-------
o
3
0)
Of
0)
Q.
O
0 o
E ™
CL<
O ^
0 o
"D (I)
~O
= O
o I
CD
0 8
-------
0
CO
05
0
0
E
^^•^
0
O
E
o
o
D)
O
03
o o
D) 0
0
c
o
0
ID
•D
O
03
CO
0.
ID
O
h- CD
A I
0
0)
o
_c
o
o
"D
A
03
-------
o
CO
>
^^^
03
D)
C
C"
tt>
CD
O
P
CO
c
J§
~x
CO
0
•o
O
0
03
CO
jD
/i/S
CO
-2
rs
CO
T3
0
xf ^
0
rs
(Q
"c
CO
s_
CO
o
.^
_0
"o
CD
CD
O
"CD
0)
T"
CO
0
.>
15
c
/IN
CO
15
-5
"oo
LU
0
0
0
i o
2 g
CO 0)
0
CO
03 —
0
•«
I
0
Q.
CD
CO
C
0
C
"D
C
03
CO
c
o
o
I
-------
C/)
0
0
03
E
CO
0
E
0
0
CO
CD
E
E
o
O
CO
0
-------
03
0)
CD
CD
CD
0
03
0
CO
o
o S.
o
Q.
CO
c
CD
CO
S o
= -^
±± 03
I I I
-------
-------
0)
CO
V)
0)
CD
^>
3
E
£
o
O
_c
1 '
"co
0
•o
C
03
£; <»
CD r^
,p*/ -LJ
03 .2,
" ?
~ 0
.J2 Z
1 1
0
D
c
0
0
i—
x
r ^
03
H— »
1 1
*l
O
0
O
13
O
CO
0
Z
1
"O
o
o
o
/-N
-LJ
O)
"0
C
0
0)
03
E
0
1
lal developmen
s^.
15
0
o
0
"D
c
03
0
O
03
Q.
CO
C
0
0
0
1
-------
-------
-------
-------
-------
-------
e
TO
e
o>
CD
s
o
S3
E
O i=
S
to
•o
oi
i
CN.
2,
-------
o«
to
O
73
to
to
CD
e
CD
*
CO
I I
-------
0
2 Miles
9 3 M Cottage Grove
j _ ] Census Blockgroup Boundaries
Percentage of Low Income Population
D o
H|j 0-6266
|U 6266-10169
91 10 165-15513
H 15513-32819
r
** PDA United States
Environmental Protection Agency
Total Population of 2 Mile Buffer Area 6397
Percentage of Population that is Minority 4.49%
Percentage of Population that is Low Income 10.16%
Source
1990 Bureau of Census
-------
LLCLLJ
JHK
,22:2 sssjgggss sgssas aeeeseeeee®
Hiilllliiiiiliiiillllflill
-------
CD
f
DL
S2
o>
«9
? fi
i
to
c
8
.5
1
CO
CO
CO
s
fl
o
CO
-------
o
=8
5
Q.
o
s
o
a
to
-------
-------
Property Reuse
presentation by
Keith West
Remediation Group
General Motors Corporation
-------
GO
GO
O
O
c/>
I
GO
n
-------
03
C
0
G)
< -o
CO
c
"o
0
tj
0
^.
o
o
o
•
0
E
QL
0
0
>
0
0
cr:
"O
0
• MMM
^^^^^
O
co
o
03
o
Q.
QL
C
'co
.N
i *
0
JCO
CD
•
CD
t Business
~^^
C
"o
Q.
"c
0
O
• •
0 (0
Q. ^
X CD
LLI O
CJ
"CD
CD
CO
CD
O
* •
CN
0
Q.
E
03
X
LLJ
Q
CO
CL
^^\
O)
o
0
o
0
•o
0
C
CO
0
^•^
CO
c
o
CO
CO
0
•
LU
-------
& Brownfield
development
offers
0— CO
— 0
•^ -^_> .—
.2*5
"£"< Q.
O
<
(D
+5
o
w^
O
O
o
•
^,
2
Q.
0
CO
0
r-
•4— «
U—
nup and utilization o
03
0
0
CO
.0
"•+— •
"c
1 commu
<*j
c
03
CO
.0
"-4— «
'o
a
£
H^
0
C
0
_Q
C
03
£
ith current
CO
o
£
E
03
0)
O
Q_
A Corrective Action
tr
O
or
o
-t— •
0
Q.
O
C
03
0
C
O
-e
0
Q.
o
IBMM
Q.
0
'•§
u_
O
0
o:
MBBBM
O
01
CO
/IN
cu
D)
C
03
0
O)
C
03
E
a.
LJJ
^ XN
CO
Z)
c
T3
'03
_O
E
03
O)
O
Q.
C
O
ts
jo"
"c
0
E
'5
cr
0
Q.
13
c
03
0
o
_0
><
0
M—
0
O
E
O)
c
o
Q.
1
-4— •
"c
o
•o
0
c
0
_c
£
[uiremen
o
0
educing procedural r
dd value; and
Z. 03
'
innovative
JD
^^
flexibility
0
iving companies mo
D)
i
i
CO
0
e measu
,>
'^*
pproaches to correct
03
considered
0
jQ
o
C **— '
£ CD
s 1
co 9-
^ ^
.-ti 0
CO >
A Corrective Action
candidates for rede
o: -o
o 8
a: §)
-------
•
<
•
^s
•
•
1
•
(
r
n
o
CO
o
a.
Q.
^t>
o.
c
g
4—*
CO
N
CO
+^
0
^
C/)
V
O
S—
£
CD
0
•L^J
a corporate s
s developed
CO
O
D)
C
O
"co
CO
E
E
o
0
0
"D
76
Iz
0
E
r~-
enviror
CO
"o
.03
"o
development
0
c
03
cf
"co
0
E
0
D)
ID
a
C
03
E
_CO
O
^^^It
m ^^*m
13
CO
0
&? CO
0 *
,o '5
c
03
0
13
CO
_g
o
c
O)
"5
CO
ve approach
t3
03
O
CL
D)
C
"*- „,
D
"o
03
M—
C
03
E
o
CD
0
O
M—
O
-1— '
C
0
E
Q.
O
0
0
0
CO
O
ID
O)
O
-i— »
CO
o
Osl
0
C
constructed i
CO
-1— »
03
~Q_
5)
O)
X —
0
O
"co
CQ -
-------
\pproacl
^«
_g
IJIIjp
CO
.N
n^n^
JO
0
o:
CO
»\
•^^"™
^g^
CD
00
^
Q.
O
Q.
M-
o
03
O
^matic appr
'velopment:
"So "O
>% CD
CO •<"
c/5 CD
:> S
0 2
•
D)
-2
"co
CO
"c
Redevelopm
^
0
D)
5
CO
1
D)
C
"c
g
CO
E
E
o
0
0
Q
D)
C
"9
"5
00
c\i
0
O)
-2
CO
1
C
0
E
CO
ff\
CO
0
CO
CO
_0
CO
"co
Environment
tion
. . CO
• • ^ \J
CO ^
0 0
O) P-
£ 0
CO C£
1
-------
o
03
o
Q.
(~\
LJL
^^
c
_g
"03
.N
^^^j
0
C£
V)
(D
CD
pment Strategy
<~i
1: Redevek
"V
0
0)
CO
o
E
o
o
o
0
03
"o
0
CO
v+—
o
"c
0
plex assessm
E
o
O
1
-2
c
i the site's environme
_c
•*—*
~o
0
Q.
13
O
O
"o
c
o
•ements for remediati
i_
'5
CJ
•D
c
03
C
g
T5
c
o
o
cussions with local
CO
O)
13
O
0
.*_i
.03
'co
O
O
"c
03
Q.
0
.c
-4— •
^—
0
0
'*&
0
*03
"c
0
E
c
s_
0
O
D)
•o
C
03
e
0
prospective develop
c
i focused whe
O
i
ied and appropriate
rtn
"c
0
03
-9
ff\
CO
0
c
•D
_0
"55
Q.
E
0
o
0
JD
C
03
O
0
O
C
0
D)
0
D
~03
•4— •
C
0
C
O
i_
c
0
-------
ssioning
• ^^
2: Building Decomm
0
D)
fm&
03
cb
c
0 £
fj
CDS
^ronmental decommission
^
c
LLJ
<~>
_0
1
0
£2
"o
03
E
"3
_Q
"o
ited waste materials
ro
removal/disposal of accumul
and obsolete products;
quipment containing
(D
~03
t)
Hh- »
0
CD
to
O
O
C
03
D)
C . „
is
jo
'5.
T3
c
03
to
Q.
E
to
~05
•4—
o
H— •
13
O
c
03
CD
O
asbestos abatement;
c
05
g
"c
03
CD
0
0
o
M—
demolition, as necessary.
CO
CO
-------
O
03
O
CO
3
CO
J5
"c
Environmel
CO
0
D)
5
00
'co
lent/Remedi
E
CO
CO
^m k
0
CO
CO
^
iplemented utilizing a
E
03
c/)
0
CO
03
Q.
O)
C
1
0
i
1
0
CO
zs
c
c
o
0
CO
03
_Q
atic approach
E
-2
to
CO
ent opportunities:
Q.
o
0
0
0
T3
C
03
CO
C
0
ts
"o*
Q.
:e Assessment
CO
"03
~t->
c
f\\
se 1: Environme
05
.c
D_
te Investigation
CO
"c
0
se II: Environm
03
CL
Dnmental Site
>
c
LU
T3
0
C
03
CL
X
LU
0
CO
05
.C
Q.
c
o
"-*-•
05
D)
to
0
TJ
=3
-H- »
CO
se IV: Feasibilil
03
CL
c
o
-• «
se V: Remedial
05
LL
Maintenance
.==:
"D
C
03
C
g
"os
0
CL
O
0
to
05
Q_
CD
-------
ion Approach
_i •
Revitalizal
JP
O
M
CQ
Jevelopment
\^f
for Successful Re
CO
• -•
^^^v
c
0
0
LU
c
• —
RA Corrective Act
O
D£
C
'1
f environmental
0
:e a proactive review <
is
-*— • *—
0 0
Q. ±i
/? §
O o
1
CL
111
C7)
ID
CD
0
O
1
i of Current
L_
a detailed Descriptio
Q_
O
0
Q
1
0
M—
0
C
_o
0
H— •
•*—•
0
00
0
-*— •
0
Q.
0
o:
o
o
Q,
00
c
_g
^F^^ > ^
•— o
"O fl5
^ VL/
O Q-
"D
C
CD
CD
0
00
0
00
00
~£
"c
identified environme
00
00
0
"D
1
sures
CD
\ W
0
|
0
H— •
x:
D)
|
^
0
'o
0
with community and
*^-
"S
o
o
o
2
TJ
0
O
O)
CD
.55
_Q
-2
"oo
QJ
1
ikeholders
vu
-1— •
00
0
"o
-------
CO
E
03
O
"~ co
0 CO
co
O o
0
O
-------
C/)
E
03
O
CO
0)
CD
CD
CD
O
o
*-»
CO
O
03
LL-
eavy duty trucks and
ntral Manufacturing
.c
C
03
Z5
0
E
egan producing
GO
0
o
o
03
"E
0
CL
0
E
o
LL
0
H— '
-*-»
03
CO
0
CO
ZJ
JO
CM
T-
c
*c
nd Assembly Pla
03
eluded machining,
•glass laminating, heat
C
CO
0
'-§
03
CO
c:
lajor manufacturi
^
0
CO
"0
CO
CO
c
In
CL
CO
c
'CL
E
jE
'co
CO
~03
0
CO
C
03
CO
C
"c
'03
Q.
CO
C
ts
0
-i— •
"U5
C
03
CO
CO
c
"5
-Q
o
CD
C
03
H— >
0
O
E
o
i *
0
>perations expan
o
CO
s>
o
03
o
ID
00
C
o
o
o
o
o"
o
LO
A
-------
LO
00
DL
0
o
CO
-------
C/)
Q.
E
03
O
tt>
C/)
0
C
'CD
13
GO
C
o
CD
0
O
_o
to
±
o
03
LJL
"O
c
CO
o
O)
CD
T —
^_j
to
Z5
O)
ZJ
c
0
CO
CO
0
o
to
c
CO
v_
0
Q.
O
O)
•53
13
O
C
CO
O}
O}
M—
o
0
E
1
CO
0
r-
c
•o
0
CO
0
o
"c
CO
a.
0
c
•a
0
ts
ZJ
•D
C
0
o
CO
CO
LfT
1
a>
a>
D)
c
o
'co
CO
E
E
0
o
0
Q
ampus
O
CO
CO
0
"to
DQ
-»— »
c
"o
Q.
0
•+-*
C
0
O
0
.c
JZ
1 '
_
_o
t3
c
Zi
"E"
0
o
-+-j
0
Q.
"0
0
0
CC
CO
"c
0
0
o
.CO
"c
o
DL
0
E
o
LL
0
«+^
o
i}±
O
O
o
o"
o
o
co"
•D
c
CO
0
c
o
ommissh
o
0
T3
CO
CO
5
-4— •
C
CO
Q.
D)
"C
Z3
JO
CO
£
0)
O)
0
0
"5)
c
0
C
CO
CO
CO
"5
JD
-Q
c:
CO
T"3
XM/
0
CO
"o
0
-------
o
4—9
O
CL
CD
Q
-------
C/)
••••I^^HWH
E
CO
O
CO
CO
0
"co
•T
_3
CO
•^••j
c
"o
a.
_a>
"c
0
O
O
&
O
a:
*c
BO
IS
jj>
1o
(D
^^^
ivironmenta
LU
* /H
CO
CO
=>
M—
o
:5
o
O
To
h-
CO
M—
o
D)
C
Decommission
0
0
O
c
0
O)
• HMHi
• BHMl
0
13
•D
"co
-i—*
C
0
c
o
•^
c
0
Completion of
9
M—
O
C
_o
"-1—'
03
13
03
0
73
03
-2
"S
~03
O
^^y
fV*
03
C
03
« •
Assessment ol
9
CO
0
+3
03
C
l_
-t— «
03
r—
remedial actior
O5
sw
73
E
2
!^_
ID
C
03
D)
C
missio
ecom
713
.
0
r-
Implementatiol
0
id
"o
CO
•a
H-T 0
c 0
0
El
Q. 03
'|o
0 C
M- 0
O '-*=
o.5
^S
c x
Z^ /is
05 CU
E «
=5§
D) "JJ
C 23
TD ±3
activities, inclu
demolition of s
_co
'o
t3
03
"o
"03
CO
O
Q.
f f\
CO
"T!3
s_
0
and treatment
o
&
13
T3
0
s_
Q.
0
0
C
O
o
o
f
-2
"E
13
"co
Inspections of
9
CO
-I— »
c
0
33
H— '
'•s
O
O
CO
3
o
•D
^•M
03
N
03
D)
C
"c
'03
H— »
C
o
0
CO
waste material
T3
C
03
CO
_0
O
0
L_
O
M—
O
c
0
H_>
_03
S
"co
c:
— co
go
=5 <
13 i •
~7\ 03
O
t— ~
CO 0
•43 D)
co .E
•^o
CO ±^
0 c
> 0
0
-------
0)
13
Q.
E
CD
O
C/)
CO
0
c
"c/)
13
CO
"c
'o
Q_
MH^MH
0
+->
c
0
O
<
o
2
O
£
"c
o
1 Res to rat i<
as
+•»
c
0)
c
o
>
c
LLJ
• *
Waste Managemeni
[•g
"o
CO
00
CM
-o
0
t^
0
CL
LU
CO
•
Z>
•^
N-
00
O^
C
"c/T
o
O
c
0
o
v^
c
0
O
"o
CO
03
s
3
"E
D
0
-+— •
CO
CD
C
13
T3
CO
0
<
CO
n additional 4
03
•D
0
M—
^^^
^^^^
0
;g
^
O
994/1 995
activities in 1
-«— »
c
0
Q.
O
0
0
Vlx
0
OCC in 1994/1 995
Q
"O
C
03
Q_
O.
<
O
03
T3
2
03
Q.
£
Q.
^
O
0
o
^h^
<\ 3008h RFI/CMS w
£
O
C£
03
O)
C
"-*— •
_0
E °°
8?
^*> Q
^ O)
3 0
0 E
9
=
"o
-j
i
— D
0
E
0
^03
es completed
leasur
<^
E
CD
C
,
0
O
Q.
Q.
03
0
0
0)
03
O
-i— •
CO
_0
o
o
c
03
03
0
<|
ergoing RFI/CMS
currently und<
CO
0
ji .^
"o ^
-^ ~Q
CO 03
.
0
o
o
CN
0
JQ
0
Vii^
O
0
Q
c
CO
LU
"0
^>
.
-------
o
4-*
O
CL
c
o
o
E
o>
-------
o
4-*
O
DL
c
o
.
o
E
o
0:
-------
to
o
o
QL
c
o
o>
E
0
-------
(/>
13
CL
E
CD
O
to
C/)
0
c
"(/)
D
OQ
^^^m
"o
Q_
0
C
0
O
15
0)
O
ss Campus
0
nterpoint Busi
0
O
0
CO
0
D
O
C
development i
0
or
0
nter-Central;
0
0
Truck Product
i
JD
E
t/i
CO
03
LU
0
03
"c
0
Q_
1
0
5
t:
0
O
Truck Product
i
-£•.
c
Hotels;
Restaurants; a
i i
03
0
£
o
O
1
-------
CM
i
O
"o
CL
CD
-------
V)
o
CL
O)
C
CD
mm^^^^
O
-------
o
•*—p
o
Q_
O)
00
0)
O
-------
C/)
o
Q_
D)
OQ
•••••r
O
-------
o
o
Q_
O)
00
CD
O
-------
V)
o
CL
O)
GQ
CD
^^^^^v
O
-------
CD
Q_
O
-------
O
0
0
0
CO
_co
O
t/)
X
+2
CO
£
"o
^—
o
_03
•^^
TU
03
O
^>
O
CO
0
•e
03
CT
03
0
X
'•^
J—
o
5
0
&_
O
LL
CO
CD
CD
C
TD
0
H— »
03
O
_g
£
"c
13
c
0
'w
Q
03
O
CO
03
£
.^
c
03
IT)
CD
1^~"
C
C
03
O)
0
_Q
'o
^5
c
'03
E
<-K-
c
g
Demolit
CD
^
03
0
-Q
JD
'S)
Q.
E
o
o
0
C
o
N
-+— «
c
0
E
0
£
o
Q.
E
LU
S
0
•a
0
c
•a
B
to
0
jO
^
tr
0
Q.
O
ol
-------
LO
C\l
Q_
CD
-------
in
LO
CL
0
-------
o
00
O)
I
o
"o
Q_
0
-------
o
O
JH
PH
-------
th
c
BO
V5
2
o
+-
0)
0
tf
15
'c
0)
ronm
• •M
^•H
0
0
_Q
0
05
JZ
C/3
_0
"-4—*
[>
^t— »
O
05
C
.2
^£3
2
o
H— »
c/>
0
"05
>*-j
C
0
vironm
c
LLJ
C
05
0
D
CO
0
o
"c
05
Q.
0
O
_c
"c/>
o
^^^
^^
"iZ
_05
"c
"o
1!
0)-^
^"™" ^*r
o .E
concern (PAOCs
M—
O
(0
CO
0
i_
CO
^
Hh->
c
CD
•+-»
o
Q.
M—
O
c
o
Vj
CO
o
H=
"c
CD
^
nof AOCs;
o
"-t— •
CO
CD
C
AOCs/del
Q_
M—
O
c
o
'U-'
CO
O)
1/>
CD
C
0)
.CD
H-»
'>
T5
CO
c
o
"-I—I
CO
T3
CD
£
CD
C
CO
15
CO
O
O
^
5
"co
13
0)
E
«
C
g
IT5
VU
O
i*—
1±
O
c
o
ts
E
HH- '
0
0
JD
C
0
w»
s
^"
0
C
03
O
^
-------
JCO
o
c
05
<
C/)
HI
(D
CO
05
D)
C
O5
CD
LO
0>
05
LJL
C
c
"O O
CD '^3
•4= O
£3 c E
C -g S
0 - -o
•u
O
o
c
o
13
(/)
o
o
<
s-
o
c
o
*3
(0
0)
c
"35
Q
1H
O
O
C c
ection
0)
c
E
05
D)
2
CL
O)
.E
!|
-Q
CD
CO
03
JC
Q.
0
*mfc^.
W
O
0
Q.
E
CD
—
O
CO
to"
0
0
^
0
i_
0
XJ
o
CM
A CO
*+— '~r
O t£
11
_CD ro
"CD £"
«^>j ^^
CO 4=5
ss|i
m\i/ _—
> ^0
— "o ~o
"^™ ^ r~
CD d m
vi/ J»- m
co — °
5 1
Q_
to
O
O
<
T3
0
s_
0
•D
'co
C
O
o
0
_Q
^
0
0
CO
O
o
<
Q_
x:
0
^
T3
0
Jt
~C
0
1
CO
LU
—
CD
CO
05
-C
QL
_
o
03
OS
_
0
««— >
CD
E
~a
0
t)
CD
a.
£
c
0
-i—•
X
0
0
0
-*—«
CD
0
C
"0
•a
o
0
c
0
-a
O
<
JD
"CD
-i—•
to
c
0
0
CO
O)
C
o
CO
"CD
c
o
"O
CD
O
O
A
-------
CO
CO
Q_
>>
C5)
O
O
C
C"m
o
0
1 •
1 '
0
CD
^ij
V)
±£
JH
0)
0)
"^
]>
*5
o
^*
o
.Is
E
*~cn
O) CO 7=
o 8.8 S
x: .!2 J= T3 ~
~ -o --K co c
^T3 5-Jo =
-o c -o 0 Q
0 03 0 jr; h-
•4_J ^— i ^^ j
03 ~O 03 T3 H
.C 0) C C -1
E 03 £ CD CP
5 S ^ "§ -2
C O c •*= 03
0 >< 0 5 m
0 0 0 > S
._ 03 *-*-
.•= CO r= o c
c^ic^^l
O
-------
Q.
O)
o
o
c
o
0
"0
CD
1 •
CO
_JL.
^.
03
•^••H
O
losures
o
J2
O)
o
01
of impacted material at the former RCRP
_
."co
0
0
01
•
*rim Status Hazardous Waste Container
\JJ
-4— •
c
O
_0
.1±
~Q
(O
S
i
o
LU
Q
0
o
Q.
Q.
•+-•
"c
D
LIST systems and associated impacted
_i
"o
"co
0
0 -5
01 8
•
ocumentation completed and submitted
"O
3
CO
Q.
2
Q.
0.
•
a>
CD
CO
CD
CD
c
o
LU
Q
*>
2
1 closure documentation for LUST
CO
M—
o
"co
o
CL
CL
•
Q
H
CO
6
LU
Q
^
+t\
CO
0
^i^
CO
CO
ronmental activities, as required
">
c
0
CD
C
'o
D)
C
0
•
-------
CO
CL
JD
O)
C
•^
^^ •
O)
o
o
^™"
o
ViX
h-
•HJ"""*
0
0
CO
.^
•M^i
s^
03
O
c
o
15
B_
ifZ
t
0)
o
~o
0
if—
't:
8
C
03
~O
_0
~03
ID
0
E
0
C
CO
o
•MMM
0
03
CO
0
O
c
>
o
•
-4— »
c
03
ii »
CO
o
o
•4— <
c
0
T3
C
0
Q.
0
"O
C
_j
~o
CO
'co
03
0
13
0
CO
03
C
03
C
O
T3
0
CO
CO
0
03 0
0 |_
CO "0
•- >
^ 0
^ "I
•
-------
O)
03
O
O
CO
c
O
O
O
c
_g
"e
0
E
0
o
O
Q_
-------
03
CL
D)
O
m^^fm
O
o
0
0
0
o
c
c
05
to"
CO
vu
^-;
CO
^^
^_
CO
•••^H
o
-------
0)
Q
05
O)
O)
00
-------
-------
Q_
O
CD
CO
Q_
-------
03
<
CD
CD
00
CM
Q.
<
(C
Q_
>.
O)
C)
O
c
-C
O
0)
0)
0)
-»-•
CO
O
>4—
O
0
'>
"ro
'»_
0)
-------
CD
O
ULJ
CD
CD
C
03
D)
O
O
O
C\l
05
13
C
03
—J
(D
O
C
CO
LLJ
0
Z5
C
0
05
D)
O
-------
O)
OQ
0)
X
LJJ
16
CD
LJ_
-------
o
O
o
CM
03
13
C.
05
—)
O
Q)
-------
0
03
O
C/)
C/)
0
LU
o
CD
o
CO
60
00
£
CD
60
a
•i—i
i
CD
>
• rH
+->
O
<3
o
*H
PH
GO
CO
OH
0
CD
CO
OJ
CD CD
PQ Q
CD
CO
CD
2
CO
CO
- T—(
^3
CD
«
• i-H
•g
CD
nd
•r-H GO
CO
CO
CD
-S
asur
T3
§
>^
-f->
« i-H
§
o
o
o
o
CD
& 2
LJ *H
CD
T3
2 °
p^
•S
en
er s
CO
W O
PQ -S
-------
Phyto-Cover at a RCRA Site
presentation by
Martin Hamper
Principal Scientist
Arcadis, Geraghty and Miller, Inc.
-------
LLf
CO
LO
O
o
"D
'c
Z)
CL
Q
-------
CO
CV
LU
O
O
1
O
I
CL
g
Is
03
CD
O
-------
o
Q
m
o
o
o_
X Q.
Q. <
ro
f
8
Q
o
LU O
-------
Q
O
LU
Q
O
£
o>
«
2 §
Enhances rrt
the zone
J/J
B
9
CD
<
-------
o
X
tj
to
CD
u
13
CD
N
*—— •••§
5 E
CJ
o
U
E
•a
£
E
-------
LJU
'iiiiiiimiiii
<
O
CJ
O
u 1
Q
O 2
U
OQ
QL '
D.
-------
o
U
0)
N
-------
-------
-------
-------
-------
0)
-------
en
o:
LJLJ
LII >
O O
u_
LLJ
to
DC
-------
fC
er
-------
o
CD
&
c/i
G
D)
IS 9
CX5
£
&
£ g
* »
£
E CN
^ gj
«
'O
ii to
G
S i gS
tn
CO
LL O
1^
Q
to
tn CD tn q_ nr
in Q. ^ 15 g^
11811
s g
C/l
tn
O3
CD
en
O
J£ O
S G
c/i S.
to U2
E =
< o
e
-------
LH
CD
Q
CD
1
o
j§
in
§ £
ei/2
t
0)
'o
cs
o
^ 15 ^
^u u
O)
gs
ui
« 5
£ §^
LO U=
CD
^z.
*
V—^ —'e V^
< 5 u
tn
ro c
o
V3
= B
_ 2g
^ CO >
-------
03
b
CD
CO
CD =
CD CD
to
CD
CL O
S
03
CO
-------
-------
m'zation of
yj
CL
tf
=
C
CO
CD
CO
js
to
fiC
-------
to
u
CD
O
mz
TO
03
m
a
03
c
o
^=3
i
;s.
Q.
U
CO
Q
u
n
03
II
O
M=3
ro
O
K
CD
CL
LLI
b2
Q
-------
-------
in
CD
03
LO
CM
d L-
iA
O3
Si
tg
= a>
CD
CD
*==• in
CT> ^J
Q. T-' CA
03 <*>
^ S
E ^ ^ o3
^1^6
03 '2. S U "B. 2
, 03 °S 6 03 °0
H U O *i U O
m
9
iA
-------
er- Benefits
I
<
-------
Phytoremediation at Wood River
presentation by
David Tsao, Ph.D
Environmental Research Engineer
BP Amoco
-------
Q.
2
£
o
i
=
^ a> o 3
S S? 9 P
^ S O
O
C
0
E
0
O)
CO
c
03
C
0
C
o
'>
c
LU
T3
C
03
C
O
_Q
CD
O
O
-------
o
Q
8
t
Q
tS
0)
V)
o
o
a
n
-------
-. ifjgp
CO
Q>
-------
Q)
IT CT G:
Q Q Q
o o o
0) Q) CD
S P P
to to w
c c c
£££n
o o o o
(D Q) CD CD
TJ TJ T3 S
(0
3 3 _ =
O O O O
J2 # Q
3 3 Q
T-CMCONOT-CMCO
CMCgCMCMCOCOCOCO
d.d.d.d.d.d.d.d.
(A
a.
•
l
y)
-------
-------
CO
c
o
1»*
*
H*.
O
c
o
'^
I
o
o
Q.
.Q
Q.
0>
0)
en
co
_0
0
O
•O Q.
0) ^>
E 1
0)
-------
OOOOOOOO
•\ r\ •\«\V\B\V%*
OOOOOOOO
(AdouBQPlOJAQI.)
(AdouBQPlOJASI.)
(PIO SJB9A 9)
(AdouBQPlOJAOZ)
(PIO SJB9A
saqsnjjng
(S9|09dS
peay UOLULUOQ
|BOjdAi)
(SSBJQ
|BO|dAl)
SlNVld
Jed ABQ jed suo||eo
0}
o
o
-------
CO
CD
O
CD
.0:
Q.
.Q
CO CO
0 0
E E
3 13
Z Z
0 0
0 0
CO CO
03 03
CO DO
V V
V V
V V
V V
V V
|
ts
CD
CO
£ CD
O
O
*t
3
C
O
05
-i—•
C
o
N
O
X
CO
CD
1 2
t 0>
ca +3 __
> 'tn ™
x" O -
05 Q. m
O
C
CO
O
c
g
'co
o
CL
0) f t
c
Q.
0)
O
1
#
0
"o
0
a
(0
o
CD
|
(0
a.
^c?
CT^
T—
4
0
^
i *
CO
03
CL
CO
CO
03
5
S
13
H-*
03
Z
^C5
C^^
CD
CM
CO
0
'o
0
Q.
C/)
v/^
•D
0
X
S
^^^D ^J^5
CJ^ CD^^
T— <^-
CO CO
CO
CO
2
O
^
*: 03
D ±:
OQ <
0^
h^-
m
0
-•— •
CO
0
13
CO
o
m
^
Is*.
m
CO
CO
03
CD
o
"c
03
CL
"03
wj^^
o*^
o
CD
O
m
luestem
00
0
&
_j
C^ 0^ 0^
^r ^r o
CM CM CO
0
0
H
L_
LL
CO CO C
g) 0 03
^ §
CD CO Q-
O < CO
3
O
X
O
UJ
c
'<5
m
c
o
0)
(0
(0
m
CO
O
c
0
0
D)
CO
C
CO
CO
•*-«
c
(D
E
c
o
c
LLJ
c
CO
c
o
-Q
8
2
T3
-------
05
c|
.2 §
S £
a o
O)00
§
"S c:
15
si
CL
JD
c
o
(0 0>
o >»
"
o
CO
2
O
CO CO CO
CO CO CO CO CO
CO CO CO CO CO
LU LJJ 111 LU LU
O O O O O
o o o o o
D D ID D D
CO CO CO CO CO
g
.«
CO &
2^
£
2^
i- o
o
2
t
c "nT T-I
S I o
$oi«|lt|
= ;;££> = >£
5 -^
<« Q
^5 W
!<§£
0)
5 ^ -
« geng o
^ 2 »= o
m o GQ 5 o
UL U. U. U- LL
0)
*
tn O C to — O
8lMii
;! "• c
LU o to +j o o
Q a: o co > i
LU
a.
CO
c
0
0
D)
CO
c
CO
CO
•+-•
0)
c
o
c
LU
TJ
c
CO
c
O
.Q
CO
O
-------
C O
m ^
M
n
O .C
(0
I
E
0)
O)
03
C
CO
•*-<
c.
0
£
c
LLJ
T3
C
OS
c
O
.Q
4_
cc
O
I
-------
LI
C
(D
O)
CO
OS
C
CD
E
c
o
u.
._.
c
LLI
T3
C
03
C
O
o
o
X
-------
c o
0> wi
a — —•nmina
• 42
^ 5
o .5
O oS
i ^
C 6
C.
0
E
0
CD
CO
C
(0
CO
•+-J
C.
CD
C
o
C
LU
T3
C
CO
C
O
to
o
o
-------
OJ
O)
05
c
CO
c
0
E
c
o
I™
'>
c
ILJ
c
o
L_
03
O
o
S™
"O
-------
Q
Sc
€H
C ^ G?
® H 15
CD <#> *5
t» O C
O Q^ C
*-
S -s
(0 C
"^Sfc .?»«
C
0
E
0
O)
CO
•4— •
C
0
C,
a
LU
T3
C
CO
C
o
CO
o
2
-------
c
0
a>
03
C
0)
O
i_
'>
C
UJ
c
o
o
o
-------
c
CD
E
0
O)
03
C
cu
05
*~j
C
CD
C
o
c
UJ
"D
C
03
C
o
03
O
O
X
-------
c
o
2
o
12
§.a>
o>
a
n
-------
c
4S
CO
Conten
H a
C
.2
•43
o
0
0
CO
0
0
h-
LL
Q
O
o
•+-*
"c
CO
k_
0
o
H
t
"c
CO
CD
O
'"y«f
"O
o
o
LL
^
JD
"03
.1
O
CD
JD
'5
C/5
t
O)
2
o
CO
LL
t
•iiifci.ii
£
"w
LU
5
>
03
LU
t
JZ
o
m
CD
E
T3
O
O
C
O
"5
O
CO
O
CO
QQ
c
0
E
0
D)
CO
C
CO
3
°C
0
E
c
o
c
LU
T3
C
CO
c
o
.Q
L_
CO
o
o
-------
0 &
0(0
O) s-
O CD
O
0 0
CO T3 0
-------
=3 v.
V) CD
a:
£ o
50
*3 O
M
C 5
2
GO
a
(jq/uiui) 13d
CD
C3
in
C)
CO
CD
C\j
o
CD
C)
0
cy £ £
L. L_
O
O
03 O ^
CD O §
co
CM
c
Q)
E
0
O)
(0
C
C
Q)
E
c
o
'>
c
LJJ
"D
C
(D
CO
O
o
-------
-------
-------
o
o
6S
CN
O
CO
CO
O
o E
o
CO
0
E
0
O)
(0
c
CO
CD
-t->
C
0
£
c
c
LU
T5
C
CD
o I
s *
h- o
tuojj ajn)sio|/\| i;
-------
o
c
o
o
a
(/)
^
••••
Q.
^
•D
0)
O
it
o
(A
0)
medial Capabiliti
a!
0
i_
^^/
0
CO
c
g
"-i— •
CO
i^
-i— •
c
0
^
Q.
1
C
,0
*3
a.
CD
o
0)
^»-*
JC
c
"J5
a:
t
S
"c
o
o
g
1
-o
JC
0
0
cL
.2
"^M
2
a
i
c
CO
CO
-i— •
Q.
S
CO
t
0
.9
CO
o
Q.
C^*
c^*
O-
a.
^
CO
c
g
en
h concentn
g>
i
c
o
to
Tolerance to Hydrocar
t
'c
0)
_ _^_
&-
0)
Q.
X
111
O)
BC
"E
o
£
o
nducting Plant S
o
o
"O
0
H—
0
-1— <
S
c
o
"o
"0
CO
CO
.0
0
Q.
CO
~CO
C
M—
O
"c
CO
^^^J
*ftu*
-C
g>
c
Invaluable at providing
t
iignificant cost
V)
"D
.0
0
-i— •
"D
0
0
O
O
Q.
15
o
Q.
a
(0
•o
'a.
5
c
'co ^
"D O)
0 C
"0 m
I CO
t
T3
0)
iZ
0)
o
O)
mc
necessary
CO
^—1
o
0
'£*
Q.
C
<^k
Multi-year demonstratic
t
JD
H>
{ft
15
C
• MM
0)
o
^)
'S
o
Q.
k.
O
o
c
Designed to potentially
t
0^
Q.
5
CO
CO
0
o
o
CO
CO
o
aramount t<
Q.
?
BW
Successful plant estab
(spend the $$$ here)
t
lishment
_Q
"co
0
"c
^ J5
1= O
• 100% tree survivabi
• 100% groundcover
c
0)
0)
D)
CD
C
CO
CO
-I— '
c
0)
E
c
o
c
LU
•D
C
CO
c
o
CO
o
o
-------
(0
0)
0)
o:
2
0)
£
t
s
Q.
if
,0
.Is
rii
Guide to Phytorerm
(/)
•N
c
o
£1
O
citguide/phyto.htl
CO
• •
.gov/swertio1/producl
03
CL
0
§
^
&
ilopment Forum
V
>
tion Technology De
CO
"••
0)
E
0)
Q£
E
"4 ""*
org/public/phyto/defa
il_!
"D
tr
J
^
>
atural Landscapes
Q
0
D
.gov/greenacres/
03
CL
0
J
^
S
>ry Cooperation
u
Q.
C
O
C
0
"(5
c
Q
"jjj
(0
^
c
o.^o.^cLB-^S-gS-c;
UJ£UJ£UJ:C.E:C |^i
CO^CO^CO^fCOifi^^UJ
D ' D ' D ' D ' £ ' ^
c
0
0
O)
03
C
CO
05
-*-•
C
0
E
c
o
c
LU
TJ
C
(D
C
O
.Q
8
-------
Exit Strategy
presentation by
George Hamper, Chief
Corrective Acton Section
Enforcement and Compliance Assurance Branch
U.S. EPA, Region 5
-------
Corrective Action Completion Guide
Decision Tree
Is it likely that
hazardous
constituents have
been released to
e environmen
Send Exit letter #1
and enter CA070
NO, CA725 YE and
CA750 YE
Did all of the
releases originate
from regulated
T/S/D units that
are subject to
CRA closure
Enter CA070 NO
and direct the
owner/operator to
complete RCRA
closure
Was RCRA
closure
successfully
completed?
Is the
owner/operator
bankrupt or
recalcitrant?
Refer the facility to
CERCLA and enter
CA210 SF
Impose a RCRA
Facility
Investigation
(CA100)
Has the nature and
extent of the
contamination
been determined?
Figure 1
-------
Figure 1 (Continued)
Would the contamination pose
any human health risk if the
land use was residential, or
any unacceptable ecological
risk, or does the groundwater
quality need to be restored?
Select "No
Further Action"
Remedy
Send Exit Letter
#2 and enter
CA999, CA725
YE and CA750
YE
(any 1)
Have all current
human health risks
and migration of
contaminated
groundwater been
controlled?
Enter CA725YE
and CA750YE
Select remedy to abate future
human health risks, unacceptable
ecological risks, and restore
groundwater quality.
Enter CA550 upon completion
of construction of the remedy
Monitor operation and
maintenance of the
remedy
teve the Final"
Decision
cleanup
objectives been
achieved?
Yes
Send Exit Letter #3
and enter CA999
-------
Risk Management Strategy
presentation by
Paula Williams, Toxicologist
Corrective Acton Section
Enforcement and Compliance Assurance Branch
U.S. EPA, Region 5
-------
Introduction
*• Risk assessment is the primary tool used to direct
remedy selection.
•#• EPA policy established the continuum for risk
managers to work with, such as the cancer risk range
of 10-4tolO-6
& Risk managers apply their professional judgement to
each case to arrive at a final remedy decision.
^ The purpose of this guidance is to unify the thinking
of the project managers and unify their professional
judgement, therefore ensuring consistent risk-based
remedy selections.
The big picture
^ Primary remedy driver
wetlands
large amount of public interest
Environmental Indicator determination
* Influence of other statutes or programs
TSCA
UST
-------
The art of the risk assessment
%• Confidence level for the sampling data
Sufficient samples
Use of historic data
Background levels
Data gaps
^ Confidence and certainty in the risk assessment
Calculations are based on sampling results
Reasonably conservative assumptions if land use
is not certain. A conservative assessment is
flexible.
If risk assessment is not reliable or conservative,
a more conservative remedy may be merited
^ Use of the NCP cancer risk range
Confidence in risk estimations will influence
final acceptable estimated risk within the
range
Other corrective action goals
Ecological receptors or sensitive ecosystems
Reduction of toxicity, mobility or volume of wastes,
especially for PBTs
Groundwater restoration
"Maximal beneficial use"
-------
PBT Strategy
presentation by
Gregory Rudloff, Correction Action Project Manager
Corrective Action Section
Waste Management Branch
U.S. EPA, Region 5
-------
-------
-------
-------
-------
-------
-------
-------
Appendix 2 - Meeting Handouts
October 13, 2000, Guide to Performance-Based RCRA Corrective
Action
January 2001, RCRA Cleanup Reforms II
-------
^£0 sr47. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
* * . REGION 5
z Waste, Pesticides and Toxics Division
? 77 W. Jackson Blvd, Chicago, Illinois 60604-3590
Date: October 13, 2000
To: RCRA Corrective Action Staff
From: Robert Springer, Director (signed)
Waste, Pesticides and Toxics Division
Subject: Guide to Performance-Based RCRA Corrective Action
Introduction
The Waste, Pesticides and Toxics Division (WPTD) initiated an effort to streamline and accelerate
RCRA corrective action in October 1998. We had concluded that corrective action should be efficient
and less process-driven. WPTD has implemented a series of changes and intends to continue its
streamlining initiative. This initiative has had several successes and has led us to an understanding of
how corrective action can be made more efficient. Our goal is to ensure that facilities control risks to
human health and the environment as quickly and effectively as possible, and continue the effort through
the completion of corrective action. The purpose of this Guide is to express a set of implementation
principles that will form the foundation for all of our RCRA corrective action decisions.
This Guide builds on the foundation of program flexibility that has been encouraged through national
guidance and the 1999 RCRA Reforms. The RCRA corrective action program has matured to the point
where review and approval of implementation activities conducted by many facility owner/operators
(O/O) can be made simpler and more efficient. The U.S. Environmental Protection Agency Region 5
(Agency) has provided extensive policy and guidance to enable the regulated community to understand
what level of implementation performance is expected. For selected facilities, we believe formal
Agency involvement can be limited to a few crucial decision points. By reducing time-consuming and
repetitive formal document reviews, revisions and approvals, the Agency and O/Os can devote more
resources to improve communications and to expedite corrective action.
A performance-based approach will provide more implementation flexibility throughout corrective
action. This approach should also foster an effective professional working relationship between WPTD,
the O/O and their consultant(s). We are confident that a performance-based approach to RCRA
corrective action, using real time practical decision making, will not only reduce the time needed to
complete corrective action, but also will increase the efficiency and cost effectiveness of the overall
RCRA corrective action process.
Elements of the Performance-Based Process
To date our efforts to evaluate corrective action have identified certain essential elements:
• Development of a concise history and status report for the facility in the form of a
-------
-2-
Current Conditions Report
• Development of a Conceptual Site Model, that is a constantly evolving working
hypothesis of potential sources, risks, data needs, cleanup objectives and corrective action
solutions that can be used as an effective implementation tool
• Information and Data Collection Planning based on the above two elements, in order to
focus the overall corrective action effort on those releases that may pose an unacceptable
risk to human health and the environment
• Facility Investigation to confirm what is known about a facility and to fill data gaps
• Development and implementation of appropriate Interim Measures while final Corrective
Measures are established
• Evaluation of Corrective Measures and Selection of a remedy to address the identified
environmental risks presented by the facility
• Implementation of the Selected Corrective Measure(s) including appropriate operation
and maintenance of the remedy
• Confirmation and certification of successful completion of RCRA corrective action
We have determined that, even though all of these essential elements must be completed, four regulatory
decision points are central to satisfactory completion of RCRA corrective action. These decision points
are:
• Determination that the two Government Performance and Results Act (GPRA)
Environmental Indicators have been successfully achieved
• Evaluation of Corrective measure alternatives and selection of the Final Corrective
Measure(s)
• Planning and scheduling implementation of the selected Corrective Measure(s)
• Determination and certification of successful completion of the RCRA corrective action
In order to ensure these four corrective action decisions have a solid foundation, Agency or state staff
must have confidence in the quantity and quality of the data collected, and in particular, that sampling
and data analysis under the essential element of facility investigation have been conducted with adequate
quality assurance. WPTD intends, except as discussed in the Selection Criteria Section below, to limit
its formal decision making to the above four decision points. It is therefore critical that the O/O ensure
that the data provided to the Agency meets the WPTD QA/QC Policy. Corrective measure alternatives
must be based on a thorough understanding of releases to the environment and any contaminant migration
that may have occurred. Because the Agency has transferred greater responsibility and flexibility to the
O/O by removing many of the traditional approval requirements, this understanding can best be achieved
-------
-3-
through use of the conceptual site model and effective information exchange established through a
relationship built on trust and mutual respect.
Implementation of Corrective Action Elements
RCRA corrective action is primarily environmental risk management. It is intended to identify and
confirm current and potential environmental risks, to gather data through facility investigation, and then
to select a remedy that will eliminate, to the extent possible, the hazards to human health and the
environment. Several important features of performance-based corrective action are cross-cutting in
nature and therefore affect all stages of the process. These features are:
1. Iterative Nature: It must be recognized that the various elements or phases of
corrective action should be implemented in an iterative manner. This is in contrast to
the more traditional system which calls for a series of clearly defined steps that are often
carried out in a rigid order. Thus, for example, under the traditional system, a) all
investigative work would be performed during the RCRA Facility Investigation (RFI)
which often ends with a formal risk assessment, b) the process would move to the
Corrective Measures Study (CMS), which in turn c) would lead to the selection of the
entire facility remedy, d) then move to the design and construction of the remedy in the
Corrective Measures Implementation (CMI) phase, and e) any Interim Measures
identified during the process would require formal proposal, design and approval.
A performance-based approach recognizes that corrective action projects can benefit
from more flexible implementation. Corrective action will be more efficient if the
various steps are performed in an iterative way, sometimes with overlapping process
elements and time frames. For example, the development of a conceptual site model
early in the process and the implementation of data collection activities based on this
conceptual site model is encouraged. In addition, the performance-based process
encourages the implementation of corrective measures as early in the process as
possible. This may result in corrective measures being implemented at a portion of the
facility while investigation is continuing at a different portion. Likewise, some
investigative tasks might be reserved until after the implementation of interim corrective
measures in order to determine the need for further cleanup activity or to verify the
success of the interim measure. In order to make appropriate corrective measures
decisions at any one time, we have determined that data should be gathered and
decisions made on an iterative basis to allow flexibility, encourage prompt action and
select practical solutions.
2. Risk Based Decision-Making: Performing risk analysis is by its nature an iterative
process and an example of how corrective action can benefit from fully incorporating
these principles. A deliberate objective of risk-based decision-making is to bring
forward, as appropriate, risk criteria decisions in order to include them as early as
possible in the corrective action process. This practice would enable the project
manager, who functions as the risk manager, to make initial risk criteria decisions based
on data and information available at the outset in order to guide the nature and extent
of the investigative work. Communication among the risk manager, risk assessor, and
-------
-4-
other interested stakeholders must occur throughout the corrective action effort. Risk
analysis and risk management decisions will be conducted throughout the entire
corrective action effort. Therefore, a traditional risk assessment, in the sense of
preparing a single comprehensive document that once and for all provides a full risk
analysis to be used in making all the final remedy decisions, may not be necessary.
Making risk criteria decisions early, and as quickly as the data allow for an appropriate
choice, will help to focus the corrective action effort on those factors that present the
potential threat(s) to human health and the environment.
3. Data Collection: The collection of information and data, whether in an initial survey
to prepare a conceptual site model or in a formal investigation to evaluate the conceptual
site model, should be carried out in stages that most efficiently match the conditions and
needs of each particular facility. The planning and performance of investigative work
commonly occurs as in a series of actions, with each phase of the investigation building
upon and governed by the results of earlier phases. The facility investigation should be
organized to carry out a series of often separate efforts that best fits the conditions of the
facility and ensures that an adequate facility-wide investigation is completed. The
investigation of one portion of a facility should not necessarily wait for the rest of the
current phase of an investigation to be completed for the whole facility. Data collection
should proceed to a logical conclusion for each portion of the facility. It is critical for
data collection to be focused on those factors that present, or have the potential to
present, a risk. Risk management decision-making needs should be the primary driver
for all data collection. Therefore, only data that support the corrective action decision
process should be collected.
The greatest opportunities to achieve the benefits of streamlining RCRA corrective
action occur during the facility investigation, in particular, in the area of data collection.
In many instances it is not necessary or beneficial to exercise all of the prescriptive
Agency oversight called for in existing permits and orders for the investigation of
contamination at a facility. By balancing Agency oversight activities with an increased
responsibility on the O/O to do the data collection and to do it right, WPTD believes it
is possible to expedite cleanups and focus limited Agency resources.
4. Stakeholder involvement: Stakeholders should be identified at the beginning of the
corrective action process. Properly managed stakeholder involvement will address the
Agency's public participation requirements and enhance the relationship between the
facility's O/O, the surrounding community and other individuals or groups that have an
interest in the corrective action. Stakeholders should be involved throughout the
process, with a communications plan that addresses the needs and circumstances of the
stakeholders and O/O of the facility. The communications plan should be modified as
needed to reflect developments that occur during the corrective action in order to ensure
prompt and accurate information exchange. Stakeholders in the performance-based
process include not only representatives of the community surrounding the facility, but
also regulatory agency representatives and others who may be impacted by the corrective
action.
-------
-5-
5. Owner/Operator responsibility: Successful implementation of corrective action
requires that an effective level of confidence and cooperation be established between the
affected O/O's, the regulatory officials responsible for the facility, and other
stakeholders. One of the key assumptions implicit in this Guide is that the responsible
O/Os have sufficient knowledge, competence and integrity to assume expanded
responsibility and the flexibility to implement RCRA corrective action without
compromising the results. The O/O's ability to implement corrective action with
significantly reduced oversight depends on whether the ultimate standards that govern
the effort are clearly established or can be effectively determined for the facility. On an
iterative basis, the O/O should evaluate, investigate and remediate a contaminated
facility in accordance with a functionally driven process and schedule appropriate to the
facility conditions.
WPTD recognizes that not all policy issues related to RCRA corrective action have been
resolved. We intend to continue our efforts to resolve these remaining issues.
Nevertheless, the key to effective performance-based corrective action is continued
effort on the part of O/Os and regulatory officials to establish practical solutions to
implementation issues.
6. Transparent and Definitive Process: It is critical that the corrective action decision
process be obvious to the point it is transparent and definitive with no hidden agendas.
Determinations made by the O/O or by U.S. EPA should, whenever possible, provide
closure to an issue. RCRA corrective action can be a lengthy process. Because GPRA
Environmental Indicators determinations are based on current facility conditions, and
can be modified to address changes in facility status, they provide an excellent interim
decision stage in the corrective action process. The Indicators are achieved when the
Agency determines that the facility no longer presents a current risk to human health and
when migration of contaminated ground water is controlled. This interim success point
will provide assurance that a facility presents no current environmental threat while the
RCRA corrective action is completed. A final RCRA corrective action completion
determination is particularly important when the facility as a whole, or as determined
by the Agency, portions of the facility have achieved the cleanup action levels
established for the facility. Similarly, if institutional controls are used as part of
corrective action, those controls must be clear, effective and enforceable.
Selection Criteria for Performance-Based Corrective Action
WPTD has developed a performance-based model consent order and voluntary agreement. We are
currently using these performance-based models to initiate corrective action at remaining facilities
subject to RCRA corrective action. However, we recognize that not all facilities subject to RCRA
corrective action will benefit from a change in process. In addition, not all facility O/Os have the
interest or capability to implement a performance-based approach. For these facilities a traditional
consent or other type of order will be utilized.
WPTD is also evaluating facilities that have already initiated corrective action under a traditional order
or permit issued by the Agency to determine which facilities could benefit from a shift to a
-------
-6-
performance-based approach. In order to ensure O/Os have the knowledge, competence and other
factors necessary to effectively participate in this performance-based approach to corrective action,
WPTD staff will evaluate each facility scheduled for corrective action to determine the most
appropriate implementation mechanism. If identified by the Agency as a potential candidate for this
performance-based approach, the O/O of the facility will be contacted to discuss the option of a
streamlined approach. WPTD staff will then recommend a mechanism to management for final
selection.
O/Os of a facility under a federal traditional order or permit who have an interest in switching to a
performance-based approach should contact their proj ect manager. The O/O must define for the project
manager why they feel corrective action at their facility would benefit from a change in approach.
WPTD management will then select facilities where this performance-based approach could be used
based on appropriate, including criteria:
• The current status of the corrective action mechanism based on: a) how much of
the process has been completed, and b) how the change in approach would result
in implementation improvements.
• The implementation improvements that will result from the change in approach.
• The facility O/O's demonstration of financial and technical capability to
implement a performance-based approach.
• The compliance and corrective action performance history of the facility' s O/O.
• The O/O's degree of commitment to expedite corrective action.
Conclusion
Effective implementation of a corrective action that promptly addresses environmental concerns
requires the Agency to provide adequate tools for implementation. We now have two approaches to
corrective action implementation:!) the traditional process and 2) the performance-based approach
outlined in this Guide. This Guide establishes an alternative to the traditional approach to corrective
action for those facilities administered by WPTD. It also reinforces the direction of the RCRA
Corrective Action Reforms issued by OS WER Assistant Administrator Tim Fields in July 1999 to instill
greater flexibility and practicality in our overall implementation of RCRA corrective action. We
recognize that program improvement is an ongoing effort. We intend to monitor this approach and to
modify it as appropriate in order to continue our efforts to streamline RCRA corrective action.
cc: Steve Heare, OSW
RCRA State Division Directors
RCRA Regional Division Directors
John Quarles, RCAP, Morgan, Lewis and Bockius
-------
United States Environmental
Protection Agency
Solid Waste and Emergency
Response (5305W)
EPA530-F-01-001
January 2001
httpVAwww.epa.gov/osw
Office of Solid Waste
vc/EPA RCRA CLEANUP REFORMS
Reforms II: Fostering Creative Solutions
The U.S. Environmental Protection Agency (EPA) is implementing a second set of administrative
reforms to accelerate the cleanup of hazardous waste facilities regulated under the Resource
Conservation and Recovery A ct (RCRA). EPA 's 1 999 Reforms promoted faster, focused, more
flexible cleanups. The 2001 Reforms reinforce and build upon the 1999 Reforms and will pilot
innovative approaches, accelerate changes in culture, connect communities to cleanup, and
capitalize on redevelopment potential, while maintaining protection of human health and the
environment.
Why Is EPA Reforming the RCRA
Corrective Action Program?
The goals for the RCRA Corrective Action program remain
very challenging. To more effectively meet these goals and
speed up the pace of cleanups, EPA introduced RCRA
Cleanup Reforms in 1999 and is implementing additional
Reforms in 2001. The 1999 and 2001 Reforms build upon
actions taken by EPA and the states in recent years to
accelerate cleanups. EPA believes mat the 1999 Reforms
remain central to successful implementation of the program.
The 1999 Reforms were designed to:
• Focus the program more effectively on achievement
of environmental results, radier than fulfillment of
steps in a bureaucratic process.
• Foster maximum use of program flexibility and
practical approaches to achieve program goals.
• Enhance public access to cleanup information and
improve opportunity for public involvement in the
cleanup process.
The 1999 Reforms set the near-term focus of the program
on attainment of the two Environmental Indicators and
established an environment for program implementors to be
innovative and results-oriented. The 1999 Reforms have
successfully led the program toward faster, focused, more flexible
cleanups. An example of progress since 1997 is that the
number of RCRA cleanup facilities meeting both
Environmental Indicators has increased from 47 to 504.
What are the Goals of the RCRA Corrective Action
Program?
EPA has established two fleae-term goals, leaned
"Environmental Indicators," for the RCRA Corrective Action
ptogtaou These goals, undei the Govftttiment Petfottnance and
Results Act {GPKA}, a*e that by 2005, jfee states aod EPA wiE
verify wd4ocnmeat t)pat 95 percent ofti^s 1^4 RCRA
cleanup facilities under GPRA focus wfll have "current human
exgoiBites under control," and 70 percent of these fadliJes wfll
have "raigratJott of coatamiaated gtoundwater uadet conttol."
TJbs J0ag-te«s gwdof Su; pregpiMs
-------
• Pilot innovative approaches.
• Accelerate changes in culture.
• Connect communities to cleanups.
• Capitalize on redevelopment potential.
The 2001 Reforms include just some of the innovative
approaches that have been identified by program
implementors and stakeholders. EPA intends to continue
work in other areas critical to meeting program goals. In
particular, we seek to: continue a dialogue with interested
parties on groundwater cleanup and other issues relating to
final cleanup; provide guidance for cleanup at facilities with
limited resources to pay for cleanup; and, continue to work
with federally-owned facilities to meet their Environmental
Indicator goals. Similarly, we encourage program
implementors and stakeholders to use approaches that
improve the program yet are not specifically included in the
RCRA Cleanup Reforms.
I. Pilot innovative approaches.
The RCRA Cleanup Reforms Pilot Program will support
state and EPA Regional Offices in dieir efforts to use
innovative, results-orientated and protective approaches to
speed achievement of Environmental Indicator goals and
final cleanup. Stakeholders are encouraged to contact state
and EPA Regional Offices with their pilot ideas.
EPA has set a target of 25 pilot projects to be launched in
2001. EPA expects at least one pilot project in each EPA
Region, administered by the state or EPA. EPA will
showcase pilot projects to share successes and lessons
learned and to promote use of similar approaches at other
facilities. EPA recommends that stakeholders consider pilot
projects in one or more areas. For example, pilots that:
— Achieve program goals most effectively at
companies with multiple facilities
— Improve stakeholder involvement and
communication to resolve issues where cleanup
progress is slow
- Use site characterization technologies or strategies
that efficiently assess Environmental Indicators
- Enhance the use of protective and accountable state
non-RCRA Cleanup programs to achieve program
goals
— Establish EPA Regional or state "corrective action
expediters" to focus on cleanups that are stalled or
delayed
- Expedite achievement of program goals at
federally-owned facilities
- Use Superfund or emergency authorities at RCRA
sites for bankrupt or unwilling facilities
What is the RCRA Corrective Action Program?
In 1980, when die RCRA law and regulations went into effect,
thousands of facilities became subject to hazardous waste
maaageaaeot teguMoas- These regulations have helped ensure
that hazardous waste generated from industrial operations is
properly managed and does not contribute to a future
generation of toxic waste sites. However, many of these
facilities had soil and groundwater cotttartuflatioa resulting
from their waste management practices prior to 1980- The
RCRA Corrective Action program addresses cleanup of
contamination at these operating industrial facilities,
Who Runs the RCRA Corrective Action Program?
The RCRA Corrective Action program is tutthy both EPA and
the states, witfe 38 states and territories authorized to :
implement the program. Corrective action is conducted under
RCRA .permits, orders and other approaches.
II. Accelerate changes in culture.
EPA will help program implementors and stakeholders
accelerate changes in culture in how they implement the
program by: focusing on results over process; encouraging
frequent, informal communication among stakeholders;
partnering in training; promoting methods of information
exchange; and, using new approaches to meet
Environmental Indicator and long-term cleanup goals. EPA
will:
* Promote nationwide dialogue among program impkmentors and
stakeholders on RCRA cleanups. EPA Regional Offices will
work with states in an effort to hold at least one meeting
in 2001 in each EPA Region, open to all stakeholders
who wish to interact, provide input, or learn more about
the RCRA Corrective Action program. Discussion
topics could cover local, regional or national topics
relevant to corrective action.
Conduct targeted training in partnership with program
implementors and stakeholders. EPA will work with
interested parties to deliver targeted training, depending
upon the needs of those requesting the training and
available resources. Training topics could cover, for
example: innovative technical and administrative
approaches to cleanup; success stories and lessons
learned from implementation of the 1999 Cleanup
Reforms; Corrective Action program basics; and use of
performance-based approaches to corrective action.
Use web-based communication to share successes and lessons
learned and promote innovative approaches. EPA will support
the establishment of a web-based interactive tool to
promote the sharing of successes and lessons learned
and to provide for frequent exchange of ideas among all
-------
stakeholders on any corrective action topic, including
those that are technical, policy-oriented or site-speci6c.
Overcome barriers to achieving Environmental Indicators. EPA
will clarify the relationship between Environmental
Indicators and final cleanups, and how Environmental
Indicators can be met within the context of existing
orders and permits. EPA will answer "Frequently Asked
Questions" about Environmental Indicators, and issue
technical guidance on ways to assess the impacts of
contaminated groundwater on surface water and indoor
air quality. In addition, EPA will demonstrate new uses
of enforcement tools to achieve Environmental
Indicators.
Focus on Results
The JtC&A Qeaaup Reforms foster creative, practical, resales-
based approaches to corrective action. la die field, this means:
« TfrwiMngiaikmloversight, E&ttinateadministrativeor
technical steps where not needed to assure effective
performance.
* Using bolistit approaches. Evaluate facilities for overall risk
and apply laoBty-wide corrective: actioa measures.
» Exerstfingprv&durafj&xtUStjr. Emphasize results over
mechanistic process steps and eliminate unproductive
activities,
- Stttittgpttfiamnxx standards. Establish clear protective
standards the owner/operator must fuJfiEto complete
corrective action. . .
* I'argtiitgdatatalketion. Examine actual conditioas at each
corrective action decisions.
III. Connect communities to cleanups.
EPA will provide the public with more effective access to
cleanup information. EPA seeks to increase public interest
in and awareness of cleanup activities, and to further
enhance the public's ability to become more involved in
decisions about cleanups in communities. EPA will:
• Clarify principles and expectations for public involvement in
corrective action cleanups. EPA will set out general
principles and expectations for providing the public with
the opportunity to become involved at corrective action
sites. EPA also will share examples of successful public
involvement approaches that have been used at RCRA
cleanup sites and lessons learned.
• Increase support of Technical Outreach for Communities (TOSQ.
The TOSC program provides communities with
technical and educational assistance from universities on
issues associated with cleanup of hazardous sites. EPA
will provide resources to the TOSC program for
community involvement at RCRA cleanup sites and
advertise the availability of this program.
• Place Environmental Indicator evaluation forms and site
summaries on EPA web sites. EPA will place
Environmental Indicator evaluation forms and
summaries of site cleanup activities of 1,714 RCRA
facilities on the web sites of EPA Regional Offices. The
evaluation forms and site summaries will provide readily
available information on the status of cleanup at these
sites.
• Publicise and promote the use of readily accessible cleanup
information sources. EPA will produce and distribute a
pamphlet for the general public that explains how to
access RCRA Corrective Action program information
and site-specific cleanup information.
IV. Capitalize on redevelopment
potential.
EPA encourages program implementors and stakeholders to
capitalize on the redevelopment potential of RCRA cleanup
sites. Many of these sites are located in areas that are
attractive for redevelopment and are poised for community
revitalization. These factors can
motivate interested parties to pursue an expedited cleanup,
sometimes with additional resources. EPA will:
• Initiate Additional RCRA Krownfields Pilots. EPA will
launch 4-6 additional RCRA Brownfields pilot projects
in 2001. These pilots will be designed to showcase the
flexibility of RCRA and the use of redevelopment
potential to expedite or enhance cleanups. Pilot
applicants could be program implementors or
stakeholders. Pilot participants also benefit from
technical assistance. Limited funding may become
available for public meetings and related activities.
• Initiate the Targeted Site Effort (TSE) Program to spur cleanup
at RCRA sites with significant redevelopment/reuse potential.
EPA will ask each Regional Office to identify two sites
for the TSE in 2001. The TSE program will apply to
sites that have significant redevelopment/reuse potential,
and require a limited amount of extra EPA support to
help spur cleanup. The TSE program will provide
participants with focused attention, access to RCRA
brownfields expertise, and limited funding for EPA to
conduct public meetings and related activities.
• Provide training and outreach to program implementors on using
redevelopment potential to meet program goals. EPA will
provide training and outreach to program implementors
and stakeholders to promote the environmental and
community benefits that can be gained by integrating
brownfields redevelopment opportunities and RCRA
facility cleanups.
-------
• Promote cleanup and redevelopment with RCRA
"Comfort/Status" Letters. "Comfort/status" letters
provide information regarding EPA's intent to exercise
its RCRA corrective action response and enforcement
authorities at a cleanup site. EPA will issue examples of
letters that have been used to spur cleanup and
redevelopment at RCRA facilities.
How Will EPA Measure the Results
of the Reforms?
Measuring and recording the results of the RCRA Cleanup
Reforms is a priority for EPA and the states to ensure
continued improvement of the Corrective Action program.
EPA will measure progress in putting the reforms into
practice. EPA recognizes program implementors are using
new approaches that may or may not be highlighted in the
Cleanup Reforms, and will measure progress under these
approaches as well. While the ultimate goal of the
Corrective Action program is to achieve final cleanups, EPA
will continue to measure the near-term success of the
program against its Environmental Indicator goals for
controlling human exposure and migration of contaminated
groundwater. v ,
How Will EPA Involve
Stakeholders in Implementing the
Reforms?
EPA will provide periodic updates on the RCRA Cleanup
Reforms and solicit input from stakeholders through several
means, including focus meetings, Federal Register notices,
the RCRA Corrective Action Newsletter, Internet postings,
and press releases.
EPA seeks continuous feedback from all stakeholders on the
need for additional reforms beyond those already underway.
EPA values and appreciates the feedback and interest of all
stakeholders. However, limited resources may not allow us
to respond individually. Based on stakeholder input and our
ongoing assessment of the program, we will continue to
refine and add to the RCRA Cleanup Reforms, as needed,
and will communicate program changes.
If you would like to provide written comments on the
RCRA Cleanup Reforms, please mail your comments to:
RCRA Information Center (5305W), U.S. Environmental
Protection Agency, Ariel Rios Building, 1200 Pennsylvania
Avenue, NW, Washington, DC, 20460-0002, or send an
email to the RCRA docket at rcra-docket@epa.gov. Please
include the following number on all correspondence, written
or e-mailed, to the RCRA Information Center: F-2001-CRII-
FFFFF.
For More Information
For information on corrective action cleanups, please visit
state and EPA Regional web sites, which can be linked via
the EPA corrective action web site at
http://www.epa.gov/correctiveaction. The EPA corrective
action web site has the latest and more detailed information
on the RCRA Cleanup Reforms.
If you have questions regarding the RCRA Cleanup
Reforms, please call the RCRA Hotline at 800-424-9346 or
TDD 800-553-7672, or visit their web site at
http://www.epa.gov/epaoswer/hotline/index.htm.
------- |