vvEPA
               United States
               Environmental Protection
               Agency
            Office of
            Solid Waste and
            Emergency Response
DIRECTIVE NUMBER: 948L .OO^LO

TITLE: Implementation Strategy for Alternate Concentration Limits


APPROVAL DATE:  8/11/87

EFFECTIVE DATE: 8/L1/87

ORIGINATING OFFICE:

0 FINAL
               D DRAFT

                 STATUS:
          [ ]  A- Pending OMB approval
          { j  B- Pending AA-OSWER approval
          [ ]  C- For review &/or comment
          [ ]  D- .In development or circulating

                       headquarters
                REFERENCE (other documents):
  OSWER      OSWER      OSWER
fE    DIRECTIVE   DIRECTIVE

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G.CPA Washington. DC 20460 * V
wcrM QSWER Directive Initiation Request
2. Originator Information
Name of Contact Person jMail Code (Office
Ron Kolpa " WH-563B i OSW/PSPD/SPB
1 Directive Number
948L.OO-LO

Telephone Code
382-2221
3 Title
Implementation Strategy for Alternate Concentration Limits
4 Summary cf Ciirec'-.-e (include brief statement of purposei
The ground-water protection standards (40CFR Part 264, Subpart F) established under
RCRA require that facility permits establish a concentration limit for each hazardous
constituent entering the ground-water from a regulated unit. Concentration limits can
be established through Alternate Concentration Limits (ACLs) . This strategy describes
activities that will implement ACL regulations and guidance.
5. Keywords permic; Alternate Concentration Limit; Ground-water Standards; Land Disposal
F^riHry- TSHF
5a. Does This Dir'ecwe Supersede Previous U!fecT.i.e:5> • • ;
!xx;No i | Yes What directive
D. Does It Supplement Previous Directive(s)0 , : , ;
..'No i • Ves What directive
. j»_"_' !
7. Draft Levei
n:
8 •- Signed by Office Director C -- For Review & Corr

(numoer. title;
(number, title)
iment | D - in Development
      8. Document to be distributed to States by Headquarters?  [xxjYes
No
This Request Meets OSWER Directives System Format Standards.
5. Signature of Lead Office Directives Coordinator
vJjjMLifer-- ^ ftto^
^***^ ^\ — 	 — — — —
10. Name and Title^f Approving Official
Marcia Williams, Director, Office of Solid Waste
.Date
aMa?
.Date
; 8/11/87
  EPA Form 1315-17 (Rev. 5-87) Previous editions are obsoie'e
OSWER       OSWER         OSWER          O
E    DIRECTIVE      DIRECTIVE     DIRECTIVE

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32Z
UNITED 5TATES ENVIRONMENTAL PROTECTION AGENCY

            WASHINGTON D.C. 20 150.
                                                              •-.:': Of

                                                              '. :-. \ :MCY RESPONSE
                                  2 I 1987
  MEMORANDUM

  SUBJECT:   Implementation Strategy for Alternate Concentration
             Limits  (OSWER Policy Directive # 9481.00-10)

  FROM:      Ma re i a E. Williams, Director
             Office of Solid Waste

  TO:        Waste Management Division Directors
             EPA Regions 1-10


     Attached is a copy of the final implementation strategy for
  Alternate Concentration Limits.  This strategy was developed by
  a workgroup consisting of staff from EPA Headquarters, EPA Regions
  and State environmental agencies.  The workgroup identified the
  issues that the Agency might face in the implenent.ation of the
  ACL standards and guidance and proposed and evaluated various
  options for resolving those issues.

     This strategy outlines Agency activities in six distinct
  topic areas:   development of ACL-related data, technical assis-
  tance to EPA Regions and States, cross-media impacts, outreach
  and public education, data management and training.  For each
  indicated activity, the strategy identifies the Division or
  Branch of OSW having lead responsibility and establishes a
  schedule tor completion of the action.

     Let me take this opportunity to thank all of the Regions
  who participated in the formulation and review of this strategy.
  Any questions on the strategy should be directed to Bruce Weddle,
  Director, Permits and State Programs Division.
  cc:   Hazardous Waste Branch Chiefs, Regions 1-10
       Implementation Strategy Workgroup Participants

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                OSWER Policy Directive # 9481.00-10
     IMPLEMENTATION STRATEGY FOR
   ALTERNATE CONCENTRATION.LIMITS
 Permits and State Programs Division
        Office of Solid Waste
U.S. Environmental Protection Agency
             August 1987

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                               OSWER Policy Directive # 9481.00-10
                              PREFACE
     The  ground-water protection standards (GWPS) (40 CFR Part
 264,  Subpart  F) established under the Resource Conservation and
 Recovery Act  (RCRA), require that facility permits establish a
 concentration limit for each hazardous constituent entering the
 ground water  from a regulated land disposal unit (i.e., all
 surface  impoundments, waste piles, land treatment units, and
 landfills that receive hazardous waste after July 26, 1982).
 Concentration limits used to determine the GWPS are based on one
 of  three criteria: background levels of hazardous constituents,
 maximum  concentration limits (MCLs) listed in 40 CFR 264.94(a),
 or  alternate  concentration limits (ACLs).  To obtain an ACL, a
 RCRA permit applicant must demonstrate that hazardous
.constituents  detected in the ground water "will not pose a
 substantial present or potential hazard to human health or the
 environment"  at the level established.  A summary of the
 regulation is presented in Appendix A.

     EPA's Office of Solid Waste (OSW) is currently developing
 guidance for  permit applicants and permit writers on how to
 address  the regulatory criteria for obtaining an ACL.  This
 Implementation Strategy describes activities that will implement
 the ACL  regulations and guidance and the general order in which
 those activities will be carried out.  It identifies the
 responsible office in EPA (or at the State level, if appropriate)
 in  connection with each activity.  Although in  the past many
 Regions  and States were concerned over the possible  technical
 complexity or resource requirements of reviewing ACL
 applications, OSW expects that the ACL Implementation  Strategy
 and the  ACL Guidance should be helpful in streamlining the  review
 of  ACL applications and ensuring that the process is simpler,
 speedier, and less resource intensive.  The implementation
 strategy and  guidance will facilitate Regional  and State review
 of  ACL applications by identifying offices that reviewers may
 call upon for assistance and by providing additional procedures
 and coordination for ACL activities.

     The  ACL Implementation Strategy was developed by a workgroup
 consisting of staff from EPA Headquarters, EPA  Regions,  and State
 environmental agencies.  The workgroup assisted OSW  in
 identifying issues that the Agency might face in the
 implementation of the ACL standards and guidance, and  by
 proposing and evaluating alternative means for  resolving those .
 issues.  Eased on the workgroup discussions, OSW prepared  and
 distributed two reports, the ACL  Implementation Phase  I  Report
 and the  ACL Implementation Phase  II Report, summarizing the most
 important issues and potential means of addressing  the issues.
 This Implementation Strategy is based on the workgroup
                               -2-

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                               OSWER Policy Directive # 9481.00-10
recommendations.  A more detailed discussion and schedule of the
workgroup's activities to date and a list of workgroup
participants appear in Appendix B.

    An executive summary and schedules for implementation precede
the text of the strategy.
                              -3-

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                               OSWER  Policy  Directive  #  9481.00-10
                         TABLE OF CONTENTS

                                                            Page
PREFACE 	 	     2

    EXECUTIVE SUMMARY 	     5

        EXHIBIT 1:   Summary of ACL Implementation
        Activities  	     7

        EXHIBIT 2:   Schedule for Implementation
        Activities  for ACLs 	     8

    IMPLEMENTATION  STRATEGY 	     9

    1.   Development of ACL-related Data 	     9

    2.   Technical Assistance to EPA Regions
        and States  	     9

    3.   Cross-Media Impacts 	    10

    4.   Outreach and Public Education 	:	    11

    5.   Data Management	    11

    6.   Training .	    12

    APPENDICES

        Appendix A:  Summary of Rule	    13

        Appendix B:  Summary of Strategy Development 	    15
                              -4-

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                               OSWER Policy-Directive # 9481.00-10
                         EXECUTIVE SUMMARY
    This Strategy outlines six activities for implementing the
review of ACL applications.  The State Programs Branch (S?B)  will
have overall responsibility for coordinating these activities,
and will provide assistance to responsible offices.   The goal of
the strategy, in combination with guidance on ACL applications,
is to make the ACL decision-making process as simple,  speedy, and
efficient as possible.  The following section provides a synopsis
of each activity, the office primarily responsible,  and the
schedule for completion of specific tasks.

1.  Development of ACL-related Data

    EPA performed a number of telephone surveys in the spring of
1985,  and August 1986 to determine the number of. States that
allow ACLs in their regulations.  In order to update the
telephone survey data concerning ACLs, the Assistance Branch (AB)
conducted a survey in November 1986, at the New Orleans Regional.
Section Chiefs meeting to ascertain the number of ACL
applications already submitted and an estimate of the number
expected to be submitted in the future.  This survey indicated
that approximately 30 ACL applications had been received or were
expected.  From the survey data, AB developed an inventory that
established a framework for forecasting the likelihood of
additional ACL applications and for estimating the resources
required for ACL review.

2.  Technical Assistance to EPA Regions and States

    In order to assist Regions or States that may not currently
have the technical resources to fully analyze ACL applications,
and to promote national consistency in ACL reviews, the Land
Disposal Permit Assistance Team (PAT) of the Assistance Branch
(AB),  upon request, will aid in the review of specific issues and
aspects of the ACL application identified by the Regions and/or
States.  The AB will provide comments and recommendations on
submitted ACL applications to the Regions and States.  To promote
information transfer among the Regions, the. AB has prepared  and
distributed short fact sheets summarizing the issues  and
recommendations raised during each ACL application review.   The
first set of fact sheets was distributed to the Regions in
December 1986.  Updates have followed quarterly.  In  addition to
case studies contained in the Interim Final ACL Guidance  (July
1987), the Special Wastes Branch  (SWB) has incorporated other
screening methods into the guidance document.
                              -5-

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                               OSWER Policy Directive # 9481.00-10
3.  Cross-Media Impacts

    In order to ensure consistency within other EPA offices,  the
Assistance Branch will coordinate with EPA Offices to determine
the extent of cross-media impacts associated with ACL decisions.

4.  Outreach and Public Education

    Regions and States will be primarily responsible for
conducting site-specific outreach activities to inform the public
about the process involved in reviewing ACL applications,  such as
ground-water modeling, risk assessment, and other analytic
techniques.  The Office of Program Management and Support (OPMS),
with assistance from the Technical Assessment Branch, the
Assistance Branch, and the Special Waste Branch, will develop a
data sheet describing general ACL requirements, guidance,  and
other issues.  With the assistance of the Association of State
and Territorial Solid Waste Management Officials (ASTSWMO),  OPMS
will distribute the first data sheet in October 1987.  The data
sheet will be used at the discretion of the Regional Offices and
States to provide to the public basic information concerning ACLs

5.  Data Management

    The current number of ACL applications allows manual
collection, management, and tracking of ACL-related program
management data.  The Information Management Staff (IMS) will
determine whether modifications to the Hazardous Waste Data
Management System (HWDMS) or to the proposed RCRA Information
System (RCRIS) should be made to include ACL data or whether a
stand-alone ACL tracking system should be developed.  Until then,
Regions and States will continue to track the progress of ACL
applications manually and, upon request, to forward the data to
Headquarters.

6.  Training

    With assistance from other offices, the Office of Program
Management Support (OPMS) will identify problems Regions and
States have experienced with reviewing ACL applications.  Based
on their findings, OPMS may develop and present to the Regions  a
training package.
                              -6-

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                               OSWER Policy Directive # 9481.00-10
                             EXHIBIT 1

           SUMMARY OF THE ACL IMPLEMENTATION ACTIVITIES
                             Responsible
       Activity              Organization          Target Date


Permit Assistance          Assistance           Ongoing based on
on ACL Application         Branch               Regional and
Issues                                          State Requests

Conduct Inventory          Assistance           November 1986
Of ACL Applications        Branch               (Completed)
Currently Outstanding
or Anticipated

Prepare Fact sheets        Assistance           December 1986,
Summarizing ACL            Branch               then quarterly
Issues

Incorporate Screening      Special Waste        June 1987
Methods in ACL             Branch               (Completed)
Guidance

Issue Interim Final        Special Waste        June 1987
ACL Guidance               Branch

Develop and Distribute     OPMS                 October 1987,
Public Information                              Distributed as
Data sheet                                      Necessary

Evaluate Need for          OPMS                 October 1987
Providing Training
on ACL Application
Reviews
                               -7-

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                                                             EXHIBIT  2

                                          SCHEDULE  FOR  IMPLEMENTATION ACTIVITIES FOR ACLS
                                        1987
                                                                                               1988
             Act ivi ty
MAY    JUN    JUL    AUG    SEP    OCT
NOV
DEC    JAN    FEB    MAR
1.  Permit Assistance
2.  Fact Sheets
3.  Incorporate Screening Material
    into Guidance
it.  Guidance
                                   Ongoing


                                   Quarterly
                                  Ongo i ng
5. Coordinate ACL Program with
OLher EPA Offices
6. Public Information Data Sheet
7. Training on Application Reviews
Ongoing
X Ongoing at
Reg ionu 1
and State
Discretion
X Ongoing at
Headqua rter" s
L)i scret ion
0
in
s:
M
0
»-•
t->-
O
D
n
0)
n
ft
H-
                                                                                                                                   (D
                                                                                                                                   00
                                                                                                                                   O
                                                                                                                                   O
                                                                                                                                   I

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                               OSWER Policy Directive # 9481.00-10
                       IMPLEMENTATION STRATEGY
     This  Strategy  outlines  the major  activities that will be
 undertaken  to  implement  the ACL  standards and guidance.  The
 activities  required  include data collection, training
 coordination of  technical assistance, and outreach.  Each element
 of  the  Implementation  Strategy is discussed below in terms of the
 problem involved,  the  necessary  activities, and the offices that
 will be responsible  for  those activities.

 1.   Development  of ACL-Related Data

     In  the  spring  of 1985,  and August 1986, EPA collected
 information on State regulations concerning ACLs in a  series of
 informal  telephone surveys  that  did not  include all of the
•States.   Additional  information  was necessary to update the
 Agency's  records.  In  order to gather this data, the Assistance
 Branch  (AB) tabulated  the responses from the telephone surveys
 and the New Orleans  Regional Section  Chiefs meeting in November
 1986 and  used  the  results to develop  a nation-wide inventory of
 pending or  anticipated ACL  applications.  The survey indicated
 that approximately 30  ACL applications had been or were expected
 to  be received.  The inventory was used  to forecast workload,
 technical assistance requirements/ and data management
 requirements.

 2.   Technical  Assistance to.EPA  Regions  and States

     The number of  ACL  applications received by EPA may increase
 considerably as  additional  ground-water  characterization  and risk
 analysis  are performed at land disposal  facilities required
 either  to apply  for  operating permits or to cease operations.
 The number  of  additional ACL applications  is likely to depend on
 whether currently  pending ACL applications are approved or
 disapproved and  the  reasons for  the decisions.  Since  the
 regulations became effective on  January  26, 1983,  few
 applications have  been submitted, and only one has been
 approved.   Currently,  13 ACL applications  have been submitted by
 the Regions for  review by EPA Headquarters.  Some  authorized
 States  report  that they  expect to obtain additional applications.

     Some  Regions and States have sufficient resources,  including
 hydrogeological, toxicological,  and  environmental  effects
 personnel,  to  analyze  ACL applications without  formal  assistance
 from EPA  Headquarters.   Other Regions and  States have  expressed
 interest  in different  forms of assistance,  including  toxicology,
 ground-water modeling, risk assessment,  and fate  and  transport
 modeling.   In  addition.  Headquarters  reviews can  help  promote
 national  consistency and development  of  a  sound,  realistic,
 national.  ACL policy.  In order to provide  technical  assistance  to
 Regions and States,  the  following  steps  have  and  will  be  taken.
                               -9-

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                               OSWER Policy  Directive  #  9481.00-10
    First, the Assistance Branch (AB)  will,  upon  request,  make
technical assistance routinely available  to  the Regions  and
States through the Land Disposal Permit Assistance  Team  (PAT).
In providing ACL applications to the AB for  review,  Regions
should choose applications containing relatively  complete
supporting data.  The Region should carry out  an  initial analysis
of the ACL application and indicate specific questions  for the  AB
to address.   The AB will review the ACL issues and  methodology
questions and provide comments and recommendations  to the  Regions
and/or States.

    Second,  the Special Wastes Branch (SWB)  has  incorporated
screening methods into the ACL Guidance.   In part,  the  five  case
studies included in the guidance will provide  examples  that  can
be used to determine whether basic standards have been met in the
ACL application.  Other screening methods prepared  by the  SWB
will provide general outlines of the factors that must be
considered in reviewing an ACL application.  Screening methods
were developed in December 1986, and incorporated into the
Interim Final Guidance document, expected to be  released in  June
1987.

    Third, to promote information transfer among Headquarters and
the Regions, the Assistance Branch (AB) has  prepared a short fact
sheet on each ACL application reviewed in Headquarters.   The fact
sheet summarizes the issues raised by pending  ACL applications
and the recommended solutions to those issues.  If  a number  of
issues identified through the fact sheets described above
indicate that workshops are desirable, short information
workshops describing major points concerning ACL application
reviews will be held in the Regions by AB personnel.  The first
set of fact sheets were distributed in December 1986.  Updates
have followed at the end of each quarter.

3.   Cross-Media Impacts

    A number of different EPA offices, including the Office of
Research and Development (ORD), the Office of  Water  (OW),  the
Office of Toxic Substances (OTS), the Office of Emergency and
Remedial Response (OERR), and components  of OSW such as the
Technical Assistance Branch, develop toxicological data or
concentration limits to achieve their own missions.  Because an
ACL application may seek concentration limits  developed from
toxicological data for compounds that have had limited peer
review, technical assistance to permit writers from  other offices
in reviewing toxicological data and fate  and transport
calculations will be needed.  Such assistance will not only
support the ultimate decision on the ACL application, but will
also maintain consistency of methodology within the  Agency.
                              -10-

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                               OSWER Policy Directive # 9481.00-10
    To ensure consistency between the RCRA and SARA programs,  the
Special Waste Branch (SWB) has factored into the ACL technical
guidance document (OSWER Directive 9481.00-6C) the SARA
provisions pertaining to cleanup criteria.  The Agency's policy
incorporating the cleanup criteria can be found on pages 1-6
through 1-8 of the guidance document.

    The Assistance Branch (AB) has been assigned as the central
contact point to which Regions and States can direct their
technical questions involving ACL applications.  The AB is
responsible for determining to which EPA office or specialist the
question should be directed for assistance on an as-needed
basis..  In addition, the AB will coordinate with the other EPA
offices to determine the extent of cross-media impacts associated
with ACL decisions.

4.  Outreach and Public Education

    Some Regions recommended that organized public groups located
near the facility at which the ACL is being requested should be
contacted early in the ACL application review, so that the public
can become familiar with the entire process.  The public comment
period for the draft permit should not be relied upon exclusively
to provide information to the public concerning the nature and
purpose of ACLs, or to resolve public questions about particular
sites.  The public comment period may be too late to address
incorrect public impressions concerning ACLs.

    EPA Regions and States will be primarily responsible for
conducting ACL outreach and public education activities.  Regions
and States should design and implement their own outreach and
public education programs for particular ACL applications, so
that the outreach activities will be site-specific.  OSW's Office
of Program Management and Support (OPMS), with assistance from
the Special Waste Branch (SWB), the Assistance Branch  (AB),
Technical Assessment Branch (TAB) and ASTSWMO, will consult with
the Regions and States, and in October 1987 will prepare a data
sheet describing general ACL requirements, the ACL Guidance,  and
other issues upon which national consistency is particularly
desirable.  The data sheet will be distributed, upon request,  to
the Regions and States by OPMS and ASTSWMO to be used  during
public hearings or public meetings prior to the hearing.

5.  Data Management

    The current number of ACL applications allows manual
collection, management/ and tracking of ACL-related program
management data.  Using this method, Regions will continue
tracking ACL applications and will forward collected data to
Headquarters on request.  If the future number of ACL
applications overburden this informal tracking method,  the
                              -11-

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                               OSWER Policy Directive # 9481.00-10
Information Management Staff (IMS)  will determine if
modifications to the Hazardous Waste Data Management System
(HWDMS) or to the RCRA Information System (RCRIS) should be made
to include ACL data,, or if a stand-alone tracking system should
be developed.

    The advantage of tracking the progress of ACL applications
lies in improving the capability of predicting the future rate of
ACL applications and the ability to manage technical resources.
Another advantage results from being able to identify Regions
experiencing similar technical difficulties.

    To date, the number of ACL applications received or pending
does not warrant a stand-alone tracking system.

6.  Training

    Regional and State staff responsible for reviewing ACL
applications may need additional technical training.  The Office
of Program Management Support (OPMS), with the support of the
Assistance Branch (AB) and Special Waste Branch (SWB), will
identify problems Regions and States have experienced in
reviewing ACL applications submitted by certain facilities (i.e.,
wood treaters).  Based on their findings, OPMS may develop a
training package that could include workshops, brief fact sheets,
or training modules.  With the support of the AB and SWB, OPMS
will coordinate and present any training that is' needed.
                              -12-

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                               OSWER Policy Directive # 9481.00-10
                           .APPENDIX A
                          SUMMARY OF RULE
    The Resource Conservation and Recovery Act (RCRA)  requires
owners and operators of hazardous waste management facilities to
use design features and control measures that prevent  the leaking
of hazardous waste into ground water.  All land disposal
regulated units (i.e., all surface impoundments waste  piles,  land
treatment units, and landfills that receive hazardous  waste after
July 26, 1982) are also subject to the ground-water monitoring
and corrective action standards of 40 CFR Part 264, Subpart F.
These standards require the Regional Administrator to  establish a
ground-water protection standard (GWPS) in the facility permit
for each hazardous constituent entering the ground water from a
regulated unit.  Degradation of ground-water quality will not be
allowed beyond this GWPS.   Corrective action is required if the
GWPS is exceeded.

    Concentration limits used to establish the GWPS must be based
on one of three criteria:   background levels of hazardous
constituents; maximum concentration limits (MCLs) listed in 40
CFR 264.94(a); or alternate concentration limits (ACLs).  One of
the first two levels are established in the facility permit •
unless the facility owner or operator applies for and obtains an
ACL.  To obtain an ACL, a RCRA permit applicant must demonstrate
that hazardous constituents detected in the ground water will not
pose a substantial present or potential hazard to human health or
the environment at ACL levels.  ACLs are granted through the
permit process under 40 CFR Parts 264 and 270.

    In order to demonstrate that the proposed ground-water
concentration of the constituent will not adversely affect human
health or the environment, consideration of the following ten
factors is required:

    (1)  The physical and chemical characteristics of the
         particular waste constituent.

    (2)  The hydrogeologic characteristics  of the
         surrounding area.

    (3)  The quantity of ground water and the direction of
         ground-water flow.

    (4)  Regional precipitation patterns.

    (5)  The proximity of ground-water  and surface water
         users.
                              -13-

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                               OSWER Policy Directive # 9481.00-10
    (6)  The current and future uses of the ground water and
         the surface water in the area.

    (7)  The existing quality of ground water and surface
         water, including other sources of contamination.

    (8)  The potential for human health risks.

    (9)  The potential for damage to wildlife,  vegetation,
         agriculture, and physical structures.

    (10) The persistence of the contamination and permanence
         of potential adverse effects.

    Because the ACL approach is site-specific,  data on each of
these factors are not always required.   The type and amount of
data needed for an ACL demonstration also depends on whether the
applicant attempts to demonstrate that there will be no exposure
to contaminants or that the exposure will not pose a substantial
hazard to human health or the environment.
                               -14-

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                               OSWER Policy Directive # 9481.00-10
                            APPENDIX B
                   SUMMARY OF  STRATEGY DEVELOPMENT
     The  workgroup members  listed below participated in the
 initial  ACL  implementation strategy workgroup meeting on March 3,
 1986.  Workgroup members identified issues  involving the
 implementation  of the ACL  standards and guidance and options for
 measures to  address  those  issues.  The workgroup discussion
 provided the basis for  the draft Phase I Report on ACL
 implementation, which was  distributed to the workgroup
 participants on April 3, 1986.  Workgroup members provided
 written  comments on  the draft Phase I report, and participated in
 a telephone  conference  on  April 14, 1986, in which the issues
 included in  the draft Phase I report were discussed.  Based on
'the  results  of  the telephone conference and the written comments,
 a draft  Phase II report was prepared summarizing the most
 important issues and the pros and  cons of alternative methods of
 addressing those issues.   This draft Phase  II report was
 distributed  to  workgroup members on April 23, 1986.  Written
 comments once again  were obtained  from workgroup members, and a
 telephone conference on the draft  Phase II  report was held on May
 5, 1986.   Based on the  recommendations of the workgroup,
 particular implementation  activities were chosen for inclusion in
 the  draft ACL Implementation Strategy, which was completed on May
 15,  1986.  The  strategy has subsequently been reviewed by
 workgroup members, and  revised to  reflect their comments.  Final
 approval was given to the  strategy by the OSW Office Director in
 August 1987.

                  List  of  Workgroup Participants


           Workgroup Member    	Office	

           Alex Wolfe           EPA/HQ      OSW/SPB
           Vernon Myers        EPA/HQ    .  OSW/SWB
           Mark Salee           EPA/HQ      OSW-PAT
           Jacqueline Moya     EPA/HQ      OWPE -
           Nestor Aviles        EPA/HQ      OSW-PAT
           Bob  Kayser   .        EPA/HQ      OSW-PAT
           Terry Grogan        EPA/HQ      OSW-PAT
           David Levenstein    EPA/HQ      OWPE
           Jim  Bachmaier        EPA/HQ      OSW/LDB
           Kennan Garvey        EPA/HQ      OSW/OPMS
           Chaz Miller          EPA/HQ      OSW
           Ken  Skahn           EPA/HQ      OSW/CAD/SMB
           Ken  Jennings        EPA/HQ      OWPE
           Ann  Strickland       EPA/HQ      OECM
                               -15-

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                    OSWER Policy Directive # 9481.00-10
 List of Workgroup Participants (continued)
Workgroup Member

Mickey Hartnett
Paul Day
Rich Traub
Bob Stewart
Kathleen Tobin
Larry Wapensky
Jeff Scott
Joseph Keflemarian
Phil Retallick
Jan Radimsky
       Office
Region IV
Region X
Region V
Region VII
Region II
Region VIII
Region IX
Oklahoma
Delaware
California
                    -16-

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