530D85005
5050
                    DRAFT GUIDANCE  FOR

               FACILITY  MANAGEMENT  PLANNING






                                         ,-.^

                    Office of Solid Waste
             Office of Waste Programs Enforcement
                          July, 1985
                                     ;>F,v!ronmenta1 Protection Agency
                                                     Street

                                                  60604

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I.  INTRODUCTION AND OVERVIEW OF PROCESS
     The Hazardous and Solid Waste Amendments of 1984 have
a tremendous impact on the RCRA permitting and enforcement
programs.  More than ever before, enforcement and permitting
authorities overlap.  In addition, a major side effect of the
the Amendments is that EPA and the States are now partners in
every permitting action and many enforcement actions, even in
authorized States.  Facility management planning has been
developed by the Office of Solid Waste and the Office of
Waste Programs Enforcement to facilitate the close cooperation
among State and Regional permitting and enforcement staffs
that will be crucial for implementation of the Amendments.

     The facility management planning process is outlined in
the Draft Revised National Permits Strategy (NPS) and the FY
1985 and FY 1986 RCRA Implementation Plans (RIP).  As stated
in the FY 1986 RIP, this approach requires upfront planning
between those responsible for permitting and those responsible
for enforcement (both at EPA and in the States) in order to
develop facility specific plans leading to compliance with
the RCRA requirements.

     As described in the revised NPS and the RIPs, facility
management planning is a three step process:  initial screening,
preparation of individual facility plans, and development of
multi-year strategies.  Individual facility plans will be
prepared for all environmentally significant facilities
according to schedules described in the RIPs.  The plans are
flexible, working documents which should be revised as
necessary to reflect changing situations.

     Development of a plan for a typical facility should
require no more than two to four workdays per facility by
staff representing Regional and State permitting, enforcement,
and other appropriate offices (such as Offices of Regional
Counsel or State Attorney General), working jointly to complete
the analysis.
Initial Screening

     The initial screening will be conducted to identify
facilities for which FMPs must be developed (i.e., environmentally
significant facilities).  Section II of this guidance, "Initial
Screening", elaborates on the criteria to be used to determine
whether or not a facility is environmentally^significant.

     Some facilities do not require facility management"plans
because it is unlikely that coordination between enforcement
and permitting will be necessary.  For example, there are

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         facilities  that are high  priority  for  permit processing and
         have  only a snail  likelihood  of  an enforcement component.
         These include  applications  for  research,  development,  and
         demonstration  permits;  and  applications  for new facilities.
         In addition, some  facilities,  such as  those not seeking or
         subject  to  permits,  may be  dealt with  by  enforcement without
         facility management planning.

              Facilities that do not require FMps  will be included  in
         the multi-year strategy.
         Facilty Management Plans

              The second step in the process consists of three parts.
         First,  the  individual facility analysis outlines the current
         regulatory  status of the facility and summarizes available
         information.   In addition,  the analysis will identify information
         that is not available but must be obtained or developed.
         The second  part of the planning process is the consideration
         of prospective solutions to the problems identified in the
         analysis and of the variety of tools available to EPA and
         the States  to implement the selected options.  The final
         part is the development of an individual plan summary which
         gives a timetable for key elements of the plan and identifies
         the lead office for each action.
ik'
              Section III of this guidance includes a questionnaire
         which is designed to aid review of the relevant information
         about a facility.  There are also worksheets for evaluating
         the options available for each facility and a sample format
         for the plan summary.
         Development of the Multi-Year Strategy

              The third step in the facility management planning
         process  is  the development of a multi-year Facility Management
         Strategy.   The strategy is a State-by-State summary of
         projected permitting and enforcement outputs over the next
         year, incorporating the results of the individual facility
         plans as well  as planned actions for those facilities for
         which facility management plans were not required.

              Strategy development is an iterative process.  After the
         FMPs and other planned solutions are combined into a Strategy
         certain  adjustments will need to be made to accomodate resource
         and time constraints.   The Region and the State will need
         to make  choices among  the various options to ensure that the
         final Strategy can be  implemented with available and anticipated
         resources.   When choosing between options, the planning team
         should take into account relevant guidance, policies, and

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                                                  I  i
statutory requirements.

     As in the case of the individual facility plan, the
Strategies are flexible documents which can and should
be revised as necessary to reflect new information, changing
priorities, completion of intermediate solutions on which
later solutions depend, and individual facility solutions.
Relationship of Facility Management Planning to SPMS

     The Facility Management Strategy will provide a basis
for determining yearly Regional and State commitments  for the
Strategic Planning and Management System (SPMS).  This will
be addressed in each year's SPMS commitments and reports.
See the revised FY 1985 RIP and the recently issued FY 1986
RIP for priorities for developing FMS and for a complete
description of SPMS measures.
Use of this Guidance

     This guidance is intended to provide assistance to the
Regions and the States in implementing the facility management
planning process.  it offers several sample formats and
describes the breadth of scope and depth of coverage which is
expected in the facility management process.  It should be
considered a foundation upon which individual Regions and
States may build in addressing their individual facility
management planning needs.  None of the charts or forms is
mandatory.  They are offered as examples only, and may be
modified as appropriate.

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II.  INITIAL SCREENING

     The purpose of the initial screening is to identify those
facilities which are environmentally significant and, therefore,
require Facility Management Plans (FMPs).  The determination of
"environmental significance" rests with the Region and State
personnel who are most familiar with the particular facility.
However, certain criteria should be applied to provide a nationally
consistent definition of environmental significance.

     In some instances it is readily obvious, even with incomplete
information, that a facility is environmentally significant.  How-
ever, a conclusion that a facility is not environmentally significant
cannot be reached without a reasonably complete picture of the
facility.  Attachment A is a list of possible sources of information
on a facility.  These sources can be used to support the initial
screening and analysis stages.

     As previously stated, the criteria  for determining environ-
ment significance are the ones listed in the National Permit
Strategy.  The factors listed below the criteria are offered to
assist the reviewers in applying the general criteria to specific
facility situations.

     Each treatment, storage and disposal facility should be
evaluated.  The criteria listed below provide a guide.  The rela-
tive weights of these factors may vary from case to case, subject
to the discretion of Regional and State facility planners.  Prior-
ity considerations are designated by an asterisk (*).  In some
instances, a single factor  (such as violation of ground-water
monitoring requirements (interim status, permit application or
permit or actual contamination of ground water) may be sufficient,
regardless of the applicability of other factors, to require a
FMP for the facility.  In these instances,  which are expected to
predominate at land disposal facilities  (landfills, land treatment,
surface impoundments for treatment, storage or disposal, waste
piles and underground injection wells) the screen should be
conducted very quickly, and perhaps by only one member of the
planning team.  In other cases, while a  single criterion may not
trigger additional analysis, the presence of several factors may
warrant the preparation of a FMP.

     0 Facility is a recipient of wastes from a CERCLA site

     0 Facility may pose a potential public health or environment
       threat from releases.

          *-  The facility was evaluated as a potential CERCLA
              site and the evaluation showed evidence of:
              — environmental damage
              — ground-water contamination
              — close proximity to population or drinking water
                 source

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                                            i  t  .
                                                 DRAFT
     *-  The facility  is  or was the subject of a Federal or
          State CERCLA action

0  Facility violated  environmental standards or disregarded
  RCRA regulations as  evidenced by designation as a Signi-
  ficant  noncomplier  or  High Priority Violator for enforce-
  ment action.

  *-  The facility has failed to properly evaluate facility
      hydrogeology,  to properly install wells or properly
      monitor.

  *-  The facility is  a  significant noncomplier

      The facility has been known to  violate other environ-
      mental laws as evidenced by releases to air or surface
      water.

      The facility has not closed units properly, has not
      fully completed  post-closure permitting properly, or
      has closed  in  accordance with regulations but substantial
      contamination  remains.

0  Facility is suspected  or potential  source of ground-water
  or surface-water contamination (e.g., ground-water quality
  assessment has  identified presence  of hazardous waste con-
  stituents) or other  contamination by prior or continuing
  releases of hazardous  wastes.

   *- the facility is  known to be contaminating the ground
      water as evidenced  by:
      — initiation  of assessment or  compliance monitoring
      — physical evidence of contamination.

   *- The facility has known or suspected solid waste manage-
      ment units.

    - The facility may have  released  hazardous constituents
      into the  ground  water, surface  water, or air, as evi-
      denced by the  likelihood of or  reports of spills, odors,
      odd-tasting water,  or other unusual occurrence at or
      near the facility.

8  Facility poses  significant environmental or health risk,
  determined on the  basis of:

    -  proximity  to  population centers and/or aquifiers and
         surface  waters,

    -  facility size,

       amount,  nature, and  complexity of waste handled, and

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                                            I I .
      age of facility.

0 Degree of public concern about the facility:

   - congressional inquiries
   - organized local citizens groups,
   - high volume of public mail, or
   - local public official concern.

0 Anticipated financial insolvency or inability to
  properly close and conduct post-closure monitoring
  and maintenance.

  *- The facility has declared financial insolvency
     as evidenced through:
     —  application of modeling against financial
         test data, and
         information from institution providing
         financial assurance.

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III.  DEVELOPING THE PLAN
Part 1 - Evaluating the Facility

     The purpose of this part of the planning process is to
review the environmental and regulatory status of the facility.
The questionnaire format on the following pages is designed
to assist the reviewers in systematically addressing all
relevant information about the particular facility.  The
questions center on those areas of concern that will most
likely require coordination between Regional and State
enforcement and permitting staffs:

     — ground-water monitoring at regulated units
     — prior and continuing releases from solid waste
        management units
     — the adequacy of a facility's Part B application and/or
        closure plan, and
     — requirements of the Hazardous and Solid Waste Amendments
        of 1984.

     When completing the questionnaire, it is suggested that
the reviewers note any additional information which is not
specifically covered by the questions and highlight any
missing information which is necessary to evaluate the
facility.  The major problems and missing information will
form the basis of the analysis conducted under Part 2.

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                            FACILITY ANALYSIS

                                                             Date:
Facility Name

EPA I.D Nb:

Facility Address

Facility Contact
Facility Status:
Interim status        Y     N
Permitted             Y     N
Receiving Waste       Y     Some Units
Closed                Y     Some Units
Commercial            Y     N
CERCLA waste          Y     N
New unit(s) proposed  Y     N
                                                               N
                                                               N
FACILITY DESCRIPTION
Process Description (e.g., chemicals produced,  production processes)  and
general description of waste management processes
CHRONOLOGY (optional)
Attach chronology or narrative summarizing significant events and  information
related to the facility that may be used for multiple purposes,  including
informing other FMP team members of relevant facts.

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                              UNIT DESCRIPTION
                                                *******************
    UNIT
IDENTIFIER
CODE
(keyed to site
map)
TYPE OF
UNIT
Receivec
aft«
11/19/80
Y or N
1 waste
Jr :
7/26/82
Y or N
WASTE TYPE(S)
STATUS*
EXAMPLE:




     A






     B
landfill
SWMU
N
N
                    F006
unknown
                       active
closed
 *e.g., active/ inactive/  closed,  under constrution

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            GROUND-WATER MONITORING AND RELEASES AT REGULATED UNITS
The purpose of the following questions is to determine the compliance status
of the facility with respect to Part 265 and Part 270 ground water monitoring
requirements.
1. Does the facility have regulated units subject to interim status ground-water
   monitoring (surface impoundments, landfills, or land treatment units)?

   a.  Yes - List by each unit by   	
             identifier code
   b.  ND  - Skip this section
   c.  Under Dispute  (explain)
2. Is the facility operating under a waiver from ground-water rtonitoring require-
   ments?

   a. Reviewed and adequate      	     COMMENTS:
   b. Reviewed and not adequate  	
   c. Not reviewed               	
   d. Adequacy under dispute     	


3. Has the owner/operator performed a detailed site-specific study of the hydro-
   geology beneath the site including:

   a. a program of soil borings or rock corings?                           Y   N
   b. water level monitoring to determine ground-water flow direction?     Y   N
   c. hydraulic conductivity measurements                                  Y   N

   COMMENTS:
4. Has the hydrogeologic study yielded enough information to make reasoned decisions
   regarding well placement and depth?

   	  a. Yes for all regulated units
   	  b. Yes for some units (list exceptions by code)
   	  c. No

   COMMENTS:
* Use coding system established on previous page on "Unit Description"  chart

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5. Does the study provide good hydrogeologic information about areas underlying
   solid waste management units as well as areas underlying regulated units?

   Yes       No        COMMENTS:
6. Has the owner/operator installed a sufficient number of downgradient  wells  at
   adequate locations and depths to immediately detect the migration of  hazardous
   waste from regulated units into the uppermost aquifer  (defined  as the first
   saturated hydrogeologic formation that could serve as  a potential pathway for
   contaminant flow)?

   	  a. Yes at all units
   	  b. Yes for some units (list exceptions by code)
   	  c. No
   	  d. Don't Know


7. Has the owner/operator installed a sufficient number of background wells  at
   adequate locations and depths to characterize the spatial and temporal variation
   of ground water unaffected by the facility?

   a. Yes  	       b. No  	       c. Don't Know  	


8. Has the owner/operator established and maintained a ground-water sampling
   protocol that yields representative samples and maintains the integrity of
   the sample in light of the chemical parameters to be analyzed (e.g.,  does the
   equipment minimize de-gassing)?

   Yes  	     No  	   Cbn't Know  	

   COMMENTS:
9.  Has the owner/operator detected leakage from any regulated unit(s)?


    a) Yes 	 (list units)
    b) No  	
    c) Detected leakage, source unclear 	

    COMMENTS:

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10.  If not,  is the owner/operator's ironitoring system technically adequate to
     detect leakage should it occur?

     NOTE: When evaluating adequacy,  consider not only inadequacies that would
     constitute violations of the regulations  (e.g.   insufficient number of
     wells),  but any problem at the site  that may be  compromising the ability of
     the system to detect leakage (e.g.,  inability of four indicator parameters
     to detect level and type of contamination suspected at site).


     Yes for all units  	   Yes for some units 	    ND  	

     COMMENTS:
11.  Do the inadequacies identified  in question 10 represent violations of the
     Part 265 ground-water monitoring  regulations ?  Explain.
12.  If leakage has been detected,  has  the owner/operator assessed the plume(s)
     for hazardous waste constituents  (Appendix VII) using appropriate techniques
     (at a minimum direct  sampling  downgradient from the point of leakage)?


     Yes  	   Incomplete assessment  	  Complete assessment  	

     COMMENTS:
13.  Has the owner/operator characterized any plume(s) with respect to all
     Appendix  VIII constituents  as  required by §270.14(c)(4)?


     Yes 	   Incomplete charaterization   	   ND  	

     COMMENTS:
                                     12

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14. The owner/operator's permit application  includes plans for which of the
    following Part 264 ground-water monitoring/cleanup program(s)?
    a. Detection nonitoring  §270.14(c)(6)
    b. Compliance monitoring §270.14(c)(7)
    c. Corrective action     §270.14(c)(8)
    d. None of the above
15. Ebes the owner/operator's permit application include proposals for any
    Alternate Concentration Limits  (ACLs)?

    a. Yes, all proposals deemed  adequate     	
    b. Yes, some proposals  deemed inadequate  	List:
    c. Yes, all proposals deemed  inadequate   	
    d. Review not complete                    	
    e. No
16. Given the compliance status of  the facility's  interim status monitoring system
    and the validity or non-validity of any ACL proposals, has the owner/operator
    submitted plans for the appropriate Part  264 ground-water program?

    	 a. Yes
    	 b. No - inadequate Part  265 monitoring may be masking leakage; detection
                 monitoring may not be appropriate program.
    	 c. ND - ACL demonstrations inadequate, should have submitted corrective
                 action program
    	d. ND for other reasons  (explain)
         e. Not sure
17. If the answer to 16 is "yes,"  is  the ground-water program that is proposed
    adequate?

      Yes 	  Partially adequate  	  totally inadequate  	


     Explain deficiencies:
                                  13

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18.  Identify what actions,  if any,  EPA or the State  has  taken to bring the facility
     into compliance with Part 265 and 270 ground-water monitoring requirements
     (e.g., NCOs, §3008(a) order,  etc.)?
19.  Identify what actions,  if any,  EPA or the State has taken regarding releases from
     regulated units (describe by unit).
         PRIOR OR CONTINUING RELEASES FROM SOLID WASTE MANAGEMENT UNITS


The purpose of the following questions is to determine whether or not there have
been or may have been prior or continuing releases of hazardous waste or hazardous
constituents from solid waste management units which would require corrective action
under Sections 3004(u) or 3008(h) of RCRA as amended by HWSA.

The purpose of the analysis is to determine:

   a) CD such units exist?

   b) Have there been prior or continuing releases of hazardous waste or constituents
      from such units?

   c) Are releases presenting potential environmental threat that would warrent
      corrective action?

   d) If the above questions cannot  be answered, what additional data, information or
      investigation is needed to yield clear yes or  no answers?
                                   14

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The following sources of information should  be consulted  before  answering questions
regarding prior and continuing releases form solid  waste  management units:

    1.  Any response to the Solid Waste Management  Questionnaire sent  to facilities
    2.  CERCIA §103(c) Notification information
    3.  CERCLA or RCRA PA/SI information
    4.  Part A and Part B permit applications
    5.  Previous inspection reports

    (look especially for: evidence of past waste disposal practices not currently
     regulated under RCRA such as pile of waste or  rubbish,  ponds or surface
     impoundments that might contain waste,  active  or inactive landfills; evidence
     of discolored soils or dead vegetation  that might be caused by a  spill,
     discharge or disposal of hazardous wastes or constituents;  any reference to
     tanks that are used for waste storage which are located below grade and could
     possibly leak without being noticed by  visual  observation.
1.  Are there solid waste management units (SWMUs)  at the facility?

    a. Yes                    	
    b. No evidence of units   	
    c. Maybe                  	
2.  If the answer to question 1 is "maybe,"  provide the information that prompts
    suspicion that there may be SWMUs?
3.  Is there any reason to doubt the information which the applicant  has  submitted
    on the questionnaire re: the existence of Solid Waste Management  Units  and  the
    possibility of continuing or prior releases of hazardous wastes or constituents?

         Yes	  No 	


    Areas of doubt:
                                 15

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                                                            i  t  '
4.  If the answer to question 1 is "yes", describe what  is known about each
    SWMU in terms of the wastes present and  when the wastes were placed in the
    unit(s). (State whether a PA and/or SI has  been  undertaken and when. Reference
    reports on each where applicable).
5.  If there is a ground-water ironitoring network  installed at the facility (to
    nonitor regulated units), to what extent  is  the network capable of ironitoring
    releases from each SWMU?

              SWMU                           CAPABILITY
6.  Are the parameters being monitored  adequate to detect contamination from
    each SWMU?

    	 a. Yes
    	 b. Yes some units (list units)
    	 c. Don't know enough about wastes
    	d. No


7.  Is the sanpling and analysis methodology adequate  to detect contamination from
    each SWMU?

    	 a. Yes
    	 b. Yes some units (list units)
    	 c. Don't know enough about wastes
    	d. No


8.  Are there other environmental  monitoring systems at the facility  (air, surface
    water, soil, leak detection systems)?

    	a. Yes	> Describe:
    	b. No
        c. Don't Know
                                   16

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9.  Are the existing monitoring systems  considered capable of detecting releases
    from the SWMUs?

    	 a. Yes
    	 b. Yes some units (list)
    	c. No
    	d. Don't know


10. For those SWMUS known to be present,   available  information  indicates:

                                                                     LIST BY UNIT COD


    a. Releases of hazardous waste or constituents have occurred       	

    b. There is evidence that releases may have occurred               	

    c. Releases of hazardous waste or constituents have not occurred
    d. There is insufficient information to determine whether releases
       of hazardous waste or hazardous constituents  have occured.
11. Summarize any release in terms of  the  extent of  release, the media involved
    (ground water, surface water, soil,  air)  the constituents of the release,
    the unit(s)  involved,  and any other  pertinent  information.
12. Describe what additional information or testing  is  needed to determine if the
    releases suspected  in question 10 have  indeed occurred  (answer may refer to PA
    and/or SI and/or RI,  etc.).
                                  17

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 14.   Describe the potential threats that  facility poses  to health or the environment.
      Describe information needed to assess the significance of  these threats.
                          CERCLA/RCRA INTERFACE
1.  After reviewing the CERCLA NDtification form,  the RCRA Part A and  Part B
    appplications it appears that:


     	 a.  The RCRA units and CERLA units are one and  the same
     	 b.  The RCRA units and CERCLA units are clearly different units
     	 c.  There is overlap between the RCRA and  CERCLA  units some are  the same
             and some are different
     	d.  Not applicable
2. Is this facility included on the CERCLA National  Priorities  List?      Y    N


3.  Has a CERCLA PA/SI been completed for this site                       Y    N

     If yes,  summarize briefly the findings focusing on environmental
     contamination, environmenatal threats and wastes  found:
                                18

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             PERMIT AND CLOSURE STATUS, ISSUES AND ACTIONS NEEDED
The purpose of the following questions is to identify the degree to which the
applicant's stage in the permit process will affect the type of actions necessary
at the facility
1.  Key Dates   (Future dates may be noted as expected)

PART B:       a) Date Part B called  	

              b) Date Part B received 	

              c) Date First NOD sent 	

              d) Date first revised Part B received 	

              e) Date 2nd NOD sent
              f ) Date of Enforcement Actions for Deficient Part B

              g) Date 2nd Revised Part B received _

            * h) _

            * i)
CLOSURE:
PC PERMIT
a) Date closure plan submitted (by unit)

b) Date comments sent to o/o (by unit)
              c) Date revised closure plan submitted (by unit)

              d) Date closure plan approved (by unit) _

            * e)
              f)
a) Date post-closure permit called
              b) Date post-closure permit received

             *c)  	

             *d)	
    * Fill in further processing/enforcement actions that have taken place
                                 19

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                                                            fc  I
2.  Summarize the principal Part B deficiencies or  issues that  remain unresolved;
3.  Summarize the principal closure/post-closure deficiencies/issues that remain
    unresolved (by unit).
4.  Is the facility targeted by the National Permit strategy as a high priority
    for final permit determination (FY86 priorities include existing commercial
    incinerators;  expansion of facilities to provide alternate treatment or
    incineration capacity;  and research, development, and denonstration permits)

       Yes        Kb
5.  Is the facility targeted for expanded  public participation?


       Yes         tt>
                                20

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                                                           I  i  .
6.  In light of outstanding permit deficiencies,  the presence or absence of
    solid waste management units with prior or continuing  releases, and the priority
    given this facility in the National  Permit strategy, issuance of a permit
    to this facility (operating or post-closure)  is likely to take from    /  /   ;
                                                                         date

          Time                        Vbffr


    a.  0-6 nonths                 	

    b.  6-12 nonths                	

    c.  12-18 nonths               	

    d.  18-24 ironths               	

    e. more than 24 months
    After referrring to the attached  chart,  summarize  the Hazardous and Solid Waste
    Act Amendments that apply to  this facility  (note especially the requirements
    related to:  1) retrofitting surface impoundments by 1988;  2) exposure assessments
    for landfills  and surface impoundments;  Corrective action  and financial assurance
    for prior releases.
                                   21

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                        INFORMATION GAPS
     List those pieces of infornation that were identified as
missing from State or EPA files and which are needed to address
permitting and enforcement issues at the facility.  Describe
why it is needed.
                                23

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Part 2 - Considering the Solutions  to  Address  the Problems

    The purposes of this section are:   (a)  to  provide a means to
evaluate the possible solutions  to  the specific problems raised by
the answers under Part 1 and (b)  to identify the short-term
(FY 1985-1986) and long-term (FY 1987-1992) objectives for the
facility.

    The chart on the following page is offered as a possible
mechanism to use in considering  the solutions  to the problems.  The
problems identified in Part 1  would be listed  in the first column,
grouping them by subject matter.   In the  second column, the reviewers
would list the solutions to the  problems.   The solutions should be
consistent with the SPMS measures.   In the  third column, the tools
available to EPA and/or the State to accomplish these solutions would
be listed.  Attachment B provides a selection  of tools available to
EPA which may be used to resolve several  of the problems found at
facilities.  Attachment C is an  inventory of federal tools.

    The last column is intended  to provide  a condensed assessment of
the pros and cons or related concerns  associated with the various
tools as they pertain to the particular facility.  Issues such as
timeliness of the action, resources, and  "standard of proof" required
for an enforcement action may all be addressed in this section.  The
discussion under "Comments" should take into account appropriate
permit and enforcement guidance  issued by EPA  Headquarters.

    The spaces for short-term and long-term objectives are provided
to summarize the expectations  for the  particular facility.  These
objectives provide the basis for developing SPMS commitments.

    It is suggested that, after  consideration  of the pros and cons of
the various tools, the one chosen to resolve each identified problem
be highlighted by underlining  or other method  to distinguish the
selected tool.  This will facilitate the  transfer of that information
onto the plan under Part 3.  An  example of  a completed chart is
provided on page 19.

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Part 3 - Establishing the Plan

    The purpose of the individual plan is  to summarize  the  results of
the analysis under Parts 1 and 2, to describe the  tools chosen to
achieve the solutions to selected problems,  to establish a  timetable
for accomplishing the solutions to the problems, and  to identify
which office is responsible for that action.  The  plans for all
facilities will be combined to make up the core of the  Facility
Management Strategy.

    The chart on the following page is a possible  format for  the plan,
An example of a completed form follows the model format.

    When using the chart, the reviewer would list  the solutions and
the tools to accomplish those solutions agreed upon as  a result of
the analysis completed in Part 2.  The respective  lead  office would
also be identified.  This may be accomplished by establishing a code
system, as illustrated in the example, or  narratively.

    The.example format provides space for  indicating  the quarters
(for the remainder of the current and upcoming fiscal year) or the
years (for subsequent fiscal years) during which the  particular
solution or tool would be tracked.  The time tables should  be
detailed enough to be used to develop SPMS commitments.  Solutions,
in most cases, would be indicated by their completion dates.  Tools,
however,  may require start dates, completion dates, or  both.

    It is important to keep in mind that the statutory  deadlines for
making final determinations must be observed (i.e., all land  disposal
facility final determinations must be completed by November 1988).
The indications should be as specific as necessary to serve Regional
and State planning and scheduling needs.

    Finally, the estimated resource cost associated with planned
actions should be identified.  This will assist in the  iterative
process of developing a Facility Management  Strategy  which  is
consistent with available resources.

-------
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-------
                                               I t
                                                     Attachment  A
                          SOURCES OF DATA FOR
                     FACILITY MANAGEMENT PLANNING
Compliance History
     -  high priority violator
     -  number of compliance orders
     -  significant noncompliance
     -  violations of other laws or regulations
     -  types of violations

Part B Information
     -  type of facility
     -  commercial versus onsite
     -  releases indicated
     -  completeness of groundwater monitoring data
        requirement for double liners

Compliance Monitoring and Enforcement  Log
        types of violations
     -  enforcement actions

Major Facility Status Sheets
     -  inadequacy of financial information
     -  inadequacy of groundwater monitoring systems
     -  inadequacy of closure or postclpsure plans

Other Environmental Permits Which Apply to Facility
     -  NPDES
     -  PSD
        State permits (solid or industrial waste)

Results of facility site visit
        number and type of violations
        owner/operator approach to permit process, demonstrated
        willingness to cooperate
     -  distance between existing interim status activities  and  what
        must be in place for permit

-------
                                                I  L
Additional information requested d ". response to or  required  by  HSWA
        SWMUs present; apparent completeness of data  on  SWMUs
        releases exist; apparent completeness of data on releases
     -  corrective measures already underway
     -  exposure assessment data

Information on ERRIS and other Superfund databases
     -  PA/SI or RI/FS results
        enforcement actions
     -  notification under CERCLA §103
        Hazard Ranking System Score
        other data showing population exposure, threats  to human
        health or the environment

State files (depends upon authorization status)
     -  compliance history
        permitting history
        releases or spills
        state CERCLA actions/information/multi-site cooperative
        arrangements
        solid waste management unit information
        groundwater information

Personal knowledge of Regional and State staff

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                                        I  k
                                             Attachment B
        A SELECTION OF  TOOLS  TO ADDRESS  PROBLEMS
       RAISED DURING FACILITY MANAGEMENT PLANNING
  Problem

Evidence of release
Suspicion of release
Imminent hazard
Financial insolvency
No release
Incomplete Part B with
respect to ground-water
information
Incomplete Part B with
respect to information
other than ground
water
          Tools

§3008(h) Order
§3013 Order
final determination
post-closure permit

§3013 Order
final determination
§3008(a) Order if GWM
violation
§3007 letter or inspection
RCRA PA/SI
post-closure permit

§7003 Order
CERCLA §106 Order
fund-financed removal action
§3008(h) Order

§3008(h) §106 Order
Fund-financed removal or
remedial action

final determination
post-closure permit

§3008(a) Order
§3013 Order
§3008(h) Order
comprehensive ground-water
inspection
post-closure permit.
Notice of intent to deny
permit

§3008(a) Order
NOD
§3007 letter or inspection

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                                                     Attachment  C
                     INVENTORY OF TOOLS AVAILABLE
                    TO ADDRESS IDENTIFIED PROBLEMS
Permit Tools

    -  additional information request

       Notice of Deficiency

       post closure permit application request

    -  draft permit

       notice of intent to deny

    -  notice of availability of closure plans

       preparation of public involvement work  plan

       field assessment conducted

       public meetings

       public hearing

       permit issuance

       permit denial

       approval or denial of closure plan

Compliance Monitoring and Enforcement Tools

       §3007 information letter

       compliance evaluation inspections (CEI)

    -  comprehensive ground water evaluation (CME)

       sampling inspection (SI)

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                                                I  I
    -  §3008(a) order or civil  action  issued  for a violation of
       permit or interim status < tandards

       §3013 order issued to collect additional information

       §7003 order or civil  action for imminent hazards

       §3008(h) corrective action order
            —  for information gathering
            —  to conduct PA/SI
                to conduct RI
                to undertake corrective measures

       CERCLA §106 order or  civil action for  imminent hazards.

    -  §3008(d), §3008(e) or CERCLA §103(b) criminal action for
       knowing violations
Other Tools
       Preliminary Assessment/Site  Investigation  (PA/SI)

       RCRA Remedial Investigation  (RI)

       CERCLA §104 removal action

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Prot
    ection
       °n

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                                                    Attachment D
Principles of Facility Management  Planning

A Facility Management Plan should  be:
.Simple


Flexible
Built on Existing
Systems
Detailed
Time-oriented
A Cooperative Effort
Goal-oriented
It should clearly identify the key
steps to be undertaken.

The plan should not be set in
concrete, but should be flexible
enough to adjust to changes in the
facility, in actions taken at the
facility, or in the schedule.

The plan should be developed in the
context of existing planning and
management structures - not a "new
reporting system," but looked on as a
way to more- comprehensively address
existing systems.

The plan should describe work on a
quarterly basis of the current and
next fiscal year, but may be less
detailed for later years.

The plan should identify tentative
time frames when the next step depends
on completion of a former step.

The plan should be developed jointly
with region and state - permitting and
enforcement personnel.  CERCLA staff
and other necessary personnel should
also be involved as necessary.

The plan should identify problems at
the facility and the solutions to
those problems.

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U.SL  Environmental  Protection Agency

Region V, Library
230 South Dearborn Street
  hira    Hilnols  60604

-------