United States
             Environmental Protection
             Agency
             Office of Solid Waste and
             Emergency Response
             Washington DC 20460
EPA 530-SW-88 028
OSWER Directive 9902 3
June 1 988
xvEPA
RCRA  Corrective
Action  Plan
             Interim  Final

-------
                                   EPA/530-SW-88-028
                                  OSWER Directive 9902.3
                                          June 1988
RCRA CORRECTIVE ACTION PLAN

             (Interim Final)
            Office of Solid Waste
     Office of Waste Programs Enforcement

-------
                      NOTICE

This document has been reviewed in accordance with
U.S. Environmental Protection Agency policy and
approved for publication.  Mention of trade names
or commercial products does not constitute endorse-
ment or recommendation for use.
                       11

-------
                                   Table of Contents


                                                                                   Page

Foreword     	    v

Acknowledgments  	   vii

Introduction  	    1

RCRA Facility Investigation  	    4
 Task I:     Description of Current Conditions  	    4
 Task II:    Pre-lnvestigation Evaluation of Corrective
            Measure Technologies  	    6
 Task III:    RFI Workplan Requirements	    6
 Task IV:    Facility Investigation 	   10
 Task V:    Investigation  Analysis 	   14
 Task VI:    Laboratory and Bench-Scale Studies   	   15
 Task VII:   Reports  	   15

Corrective Measure Study   	   17
 Task VIII:   Identification  and Development of the Corrective
            Measure Alternative or Alternatives  	   17
 Task IX:    Evaluation of the Corrective Measure
            Alternative or Alternatives  	   18
 Task X:    Justification and Recommendation of the
            Corrective Measure or Measures   	     21
 Task XI:    Reports  	   21

Corrective Measure Implementation  	   23
 Task XII:   Corrective Measure Implementation Program Plan  	   23
 Task XIII:   Corrective Measure Design  	   24
 Task XIV:   Corrective Measure Construction   	   26
 Task XV:   Reports  	   27
                                           in

-------
                                        Foreword
This document was issued by Gene A. Lucero, Director, Office of Waste Programs Enforcement,
and  Marcia Williams, Director,  Office of Solid  Waste, on  November 14, 1986, as the  RCRA
Corrective Action Plan Guidance (Interim Final), OSWER Directive 9902.3.

The  RCRA Corrective Action Plan  (CAP) will assist you  in  development of Corrective  Action
Orders  (§3008(h))  and  corrective action requirements  in permit  applications and  permits
(§3004(u)&(v)). The purpose of the CAP is to aid Regions and States in determining and directing
the specific work the owner/operator or respondent must perform, as part of a complete corrective
action program. The CAP should be used as a technical framework  during the development of
Corrective Action Orders and corrective action permit requirements.

The  CAP provides a framework  for the development of a site-specific schedule of compliance to
be included in a permit or a compliance schedule in a  Corrective Action Order. It does  so by
laying out scopes of work for the three essential phases of a complete corrective action program.
These three phases and their objectives are as follows:

    Phase  I-    RCRA Facility Investigation (RFI) - to evaluate thoroughly the nature and  extent
                of  the  release  of hazardous waste and  hazardous constituents and to  gather
                necessary data to support the Corrective Measure Study.

    Phase  II-    Corrective Measures Study  (CMS)  - to  develop and  evaluate a corrective
                measure  alternative or alternatives  and  to  recommend the  final corrective
                measure or measures.

    Phase  III-   Corrective Measures  Implementation (CMI)  -  to  design,  construct,  operate,
                maintain and monitor the performance of the corrective  measure or measures
                selected.

The  CAP provides an overall model for a corrective action compliance schedule. The scopes of
work contained in the CAP should not be considered "boilerplate," but rather as a "menu" of
possible activities to  be required  on a site-specific basis. Only  those tasks  and reports necessary
and appropriate to the specific situation should be required of  the Owner/Operator [Respondent].
We also encourage the  Regions to make available to the Owner/Operator [Respondent] existing
model  plans that are relevant to RCRA activities. For example, the "Occupational  Safety and
Health  Guidance  Manual  for Hazardous Waste Site  Activities  Operating  Safety  Guidelines"
contains a model that can be used for the Health and Safety Plan outlined in the CAP.

A RCRA Facility Assessment (RFA) will  have been conducted at the facilities that are to receive
permits, and for some facilities which are issued §3008(h) Orders. The results of the RFA  should
be used as the basis for focusing the RCRA Facility Investigation (RFI) compliance schedules for
individual  sites, and should provide the necessary data for completion  of  the "background
information" components of the CAP.

Finally,  we feel it is necessary to stress the importance of site-specific  technical  detail  in the
development of Corrective Action orders and corrective action permit requirements. Each  facility
has unique characteristics and circumstances affecting it that need to be incorporated into any
requirements for  corrective action.  Without  this up-front detail,   many  owner/operators or
respondent will provide us with submittals which lack the technical detail necessary to perform a
thorough corrective measure program.  In addition to providing  a detailed scope of work, the
Agency  should also propose a site-specific time-frame for completion of the work.  Enforcement
of permit conditions or requests for relief in an Order is always easier  when very specific detail is

-------
included. Without a detailed schedule of compliance in a permit or a compliance schedule in a
Corrective Action Order, we can expect untimeliness in submittals and actions.

It was also intended that the model scopes of work in the CAP foster timely, concise submissions
by  Owner/Operators.  Therefore,  when  modifying  these scopes of work  with site-specific
information, the scopes of work should  only  require that information which is necessary for the
subject facility, thereby minimizing the number and length of Owner/Operator submissions and our
review time.
                                           VI

-------
                                  Acknowledgments


This document was prepared by Mark Gilbertson, Anna Duncan and Peter Ornstein of the RCRA
Enforcement Division in the Office of Waste Programs Enforcement. A special  thanks to Tony
Baney and Lloyd Guerci for their management support and the Office of Solid Waste and various
regional staff for their technical review and comments.
                                          VII

-------
Introduction
The  objective of  a Corrective Action Program  at  a
hazardous waste management facility  is to evaluate the
nature and extent of the release of hazardous waste or
constituents;  to evaluate facility characteristics;  and to
identify, develop, and implement  the  appropriate
corrective measure or measures adequate to  protect
human health and the environment. The following bullets
identify components necessary  to assure a complete
corrective action program.  It  should be  recognized  that
the detail required in  each  of these steps will  vary
depending on the facilty and its complexity:

•   Locate  the   source(s)  of  the  release(s)  of
    contaminants  (e.g.  regulated  units,  solid waste
    management units, and other source areas)

•   Characterize the nature and extent of  contamination
    both within the facility boundaries and migrating from
    the facility. This would include defining the pathways
    and methods of migration of the hazardous waste or
    constituents, including  the  media, extent, direction,
    speed, complicating factors influencing movement,
    concentration profiles, etc.

•   Identify  areas and  populations  threatened by
    releases from the facility

•   Determine short and long term, present and potential
    threats of releases from the facility on human health
    and/or the environment

•   Identify  and  implement  a  interim  measure or
    measures  to  abate  the  further  spread  of
    contaminants, control the  source of contamination, or
    otherwise control the releases themselves

•   Evaluate  the overall integrity of containment structure
    and activities  at  the site  intended for  long-term
    containment

•   Identify,  develop,  and  implement  a corrective
    measure  or measures to  prevent  and  remediate
    releases of hazardous waste or constituents from the
    facility

•   Design a program  to  monitor the  implementation,
    maintenance and performance of any interim or final
    corrective measure(s) to  ensure that  human health
    and the environment are being protected

The purpose of the  Corrective Action Plan  (CAP)is to aid
Regions and  States in determining  and  directing  the
specific work  the  owner/operator or  respondent must
perform, as part of a complete corrective action program.
The  Corrective Action  Plan is  a document specifically
intended to assist Regions and States in the development
of  Corrective Action Orders  (§3008(h))  and  corrective
action  requirements in permit applications and  permits
(§3004(u)&(v)). It does so by laying out  scopes of work for
the three essential phases of a complete corrective action
program which can  be  used to formulate facility-specific
scopes  of work  for  an order or permit.  These three
phases and their objectives are as follows:

    Phase I-    RCRA Facility  Investigation (RFI) - to
               evaluate thoroughly  the  nature and
               extent of the release of hazardous waste
               and  hazardous constituents  and  to
               gather necessary  data to  support  the
               Corrective Measure Study.

    Phase II-   Corrective  Measures Study (CMS) - to
               develop and  evaluate a  corrective
               measure alternative or alternatives and
               to recommend the   final  corrective
               measure or measures.

    Phase III-   Corrective Measures  Implementation
               (CMI)  -  to design, construct,  operate,
               maintain and monitor  the performance
               of the corrective measure or measures
               selected.

Users of the CAP should understand that it is designed to
identify  actions that facility owner/operator or respondent
must take as part of a corrective action  program.  It does
not identify the steps  that remain the responsibility of the
regulatory agency. To clarify this interaction between the
facility owner/operator or respondent, Figure 1 represents
the flowchart of owner/operator or respondent submittals
and Agency actions for the three phases of the CAP

The  CAP scopes  of  work  should not be considered
"boilerplate." The scopes of work in the CAP are models
and  must be modified, enhanced  or  sections  deleted
based on site-specific  situations. Information generated
from investigations such as RCRA  Facility Assessments
(RFAs)  should be used to  tailor the scope of  work to
address facility-specific situations.The  following  are
some   examples  where  site-specifics  require
modification to the CAP model scopes of work.

•   If the contamination problem at a facility is  merely a
    small soil  contamination  problem, then the  CAP
    should be scaled  down accordingly.

•   In complicated contamination situations, the Health
    and Safety Plan and Community Relations Plans may
    need to be  comprehensive.  However, in  simple
    contamination  situations, these plans may be very
    brief.

•   If site-specifics conditions require  more detail than
    what has been scoped out in any particular section of
    the  CAP,  then  the CAP should be enhanced
    accordingly.

•   If there is sufficient information  on  a site to preclude
    an  air release, then  it  would  not  be  necessary to
    require the owner/operator or respondent to perform
    an  air  contamination  characterization.  The  air

-------
Figure 1.    RCRA Corrective Action Plan.
                       Owner/Operator
                         Respondent
                                                                     Agency

>• c
0 *-

< £
0 >
cc £


30081 h)
Order

or
Permit


	 ^- RFI Workplan

.^^P I
^^ f
RFI Report
I

IT 	 — — **-






Approval &
Oversight


Approval &






Cleanup
Requirements
Established
                             i
Corrective Measure
Study


Oversight

111
V
I


V
x ^y
i ^
Public ^^
1 Participation













Approval &




I 	 1
1 EDO 1 or


Select
Corrective
Measure(s)



Permit
Modification











/e Measure
nentation
^^ CU
« Q.
t E
o —
CJ

3008(h)
Amended
Order
or
Permit
(Modified)




CMI Workplan
^/v \
^r



h~.
^

Design &
Construction
Operation &
Maintenance
Monitoring




	 -— *.
+— 	 '


Approval &
Oversight

Approval &
Oversight

    contamination  characterization work  under the RFI
    (Task IV, C, 4) should be deleted.

•   If interim  measures  are underway, scheduled  or
    contemplated at a facility, then the Interim Measures
    section under the RFI (Task I, C) should be modified
    to specifically reference the interim measures.
                                              If possible, the CAP should focus the owner/operator
                                              or respondent on specific solid waste  management
                                              units and other areas of  interest,  as well as  known
                                              waste  management activity  areas  (i.e.,  waste
                                              recycling units, wastewater treatment tanks).
                                              If  only one corrective  measure  alternative  is
                                              appropriate for a given situation, and it  would  not be

-------
    necessary to require the owner/operator or respond-
    ent to further investigate  the  possibility of other
    corrective measure alternatives, then the scopes of
    work  (citations)  would be  modified to reflect  this
    situation.
Finally, it  is necessary to stress the importance of site-
specific technical detail in the development of Corrective
Action Orders and corrective action permit requirements.
When the scope of  work is  specific to the facility,  it is
easier to enforce. Each facility has unique characteristics
and  circumstances affecting  it  that need to  be
incorporated into any requirements for corrective action.
Without this many owner/operators or  respondents will
provide us with  submittals which  lack the  necessary
information to  perform a  corrective  measure program.  In
addition to providing an  adequate  scope of work, the
Agency should  also propose  a site-specific  time-frame
for completion of the work.

-------
                            Scope of Work for a RCRA Facility Investigation (RFI)
                                                     at
                                           [Specify Facility Name]
Purpose

The  purpose of this  RCRA Facility Investigation is to
determine the nature and extent of releases of hazardous
waste or constituents  from regulated  units, solid  waste
management units, and other source areas at  the facility
and to gather all necessary data to support the Corrective
Measures Study. The Owner/Operator [Respondent] shall
furnish all personnel, materials, and services  necessary
for, or incidental to,  performing the  RCRA remedial
investigation at [specify facility name].

[NOTE:  This scope of work is  intended to foster timely,
concise submissions  by Owner/Operators.  To  achieve
this goal, it is important when using the model scope of
work to consider facility specific conditions. This scope of
work should be modified as necessary to require only that
information  necessary  to  complete the RCRA Facility
Investigation.]

Scope

The RCRA Facility Investigation consists of seven tasks:

    Task I:  Description of Current Conditions

            A.   Facility Background

            B.   Nature and Extent of Contamination

            C.   Implementation of Interim Measures

    Task II:  Pre-lnvestigation  Evaluation  of  Corrective
            Measure Technologies

    Task III: RFI Workplan Requirements

            A.   Project Management Plan

            B.   Data Collection Quality Assurance Plan

            C.   Data Management Plan

            D.   Health and Safety Plan

            E.  Community Relations  Plan

   Task IV: Facility Investigation

            A.  Environmental Setting

            B.  Source Characterization

            C.  Contamination Characterization
            D.  Potential Receptor Identification

    Task V:  Investigation Analysis

            A.  Data Analysis

            B.  Protection Standards

    Task VI: Laboratory and Bench-Scale Studies

    Task VII: Reports

            A.  Preliminary and Workplan

            B.  Progress

            C.  Draft and Final

Task I: Description of Current Conditions

The Owner/Operator [Respondent]  shall  submit for U.S.
EPA  approval  a  report  providing 'the background
information pertinent to the facility,  contamination and
interim measures as set forth below. The data gathered
during any  previous investigations  or inspections and
other relevant data shall be included.

A.  Facility Background

    The  Owner/Operator's [Respondent's] report shall
    summarize the regional location, pertinent boundary
    features,  general  facility  physiography,
    hydrogeology, and historical use of the facility for the
    treatment, storage or disposal of solid and hazardous
    waste. The Owner/Operator's [Respondent's]  report
    shall include:

    1.  Map(s) depicting the following:

        a.   General geographic location;

        b.   Property  lines,  with the  owners   of  all
            adjacent property clearly indicated;

        c.   Topography and surface drainage (with a
            contour interval of [number]  feet  and a scale
            of 1  inch  =  100 feet) depicting all  water-
            ways, wetlands, floodplains,  water features,
            drainage  patterns,  and  surface-water
            containment areas;

-------
       d.  All  tanks, buildings, utilities,  paved areas,
           easements,  rights-of-way,  and other
           features;

       e.  All  solid  or hazardous  waste  treatment,
           storage  or disposal  areas active  after
           November 19, 1980;

       f.  All  known past  solid or hazardous waste
           treatment,  storage  or disposal areas
           regardless of  whether they were active on
           November 19, 1980;

       g.  All  known past  and present product  and
           waste underground tanks or piping;

       h.  Surrounding  land  uses (residential,
           commercial, agricultural, recreational); and

       i.  The location of  all  production and ground-
           water monitoring wells. These wells shall be
           clearly labeled and ground and top of casing
           elevations and construction details included
           (these  elevations and  details may  be
           included as an attachment).

    All maps shall be consistent with the requirements
    set forth in 40 CFR §270.14 and be of sufficient detail
    and  accuracy to  locate  and report all current and
    future work  performed at  the site;

    2. A history  and  description  of  ownership  and
       operation, solid and hazardous waste  generation,
       treatment, storage and disposal activities at the
       facility;

    3. Approximate dates or periods  of past product
       and waste spills,  identification  of the materials
       spilled,  the amount  spilled, the location where
       spilled,  and a description of the response actions
       conducted (local, state, or federal response units
       or private parties), including  any  inspection
       reports  or technical reports generated as a result
       of the response; and

    4. A summary  of  past permits requested and/or
       received, any enforcement actions  and  their
       subsequent responses and a list  of  documents
       and studies prepared for the facility.

B.  Nature and Extent of Contamination

    The Owner/Operator [Respondent] shall prepare and
    submit for  U.S. EPA approval  a  preliminary report
    describing the existing information on the  nature and
    extent of contamination.

    1.  The  Owner/Operator's [Respondent's] report
       shall  summarize all  possible source areas of
       contamination. This, at a  minimum,  should
       include all   regulated units,  solid waste
       management units, spill areas,  and  other
        suspected  source areas of contamination. For
        each area,  the  Owner/Operator  [Respondent]
        shall identify the following:


        a.   Location  of  unit/area (which  shall  be
            depicted on a facility map);


        b.   Quantities of solid and hazardous wastes;


        c.   Hazardous  waste  or constituents, to the
            extent known; and


        d.   Identification  of  areas where  additional
            information is necessary.


    2.   The Owner/Operator [Respondent] shall prepare
        an  assessment  and description of the existing
        degree and  extent of contamination. This should
        include:


        a.   Available  monitoring  data  and  qualitative
            information on locations  and levels of
            contamination at the facility;


        b.   All potential  migration pathways  including
            information  on  geology,  pedology,
            hydrogeology, physiography,  hydrology,
            water quality, meterology, and air quality;
            and
       c.  The potential impact(s) on human health and
           the environment,  including  demography,
           ground-water and  surface-water  use,  and
           land use.
C.  Implementation of Interim Measures


    The Owner/Operator [Respondent's] report  shall
    document interim measures which were or are being
    undertaken at the facility. This shall include:


    1.   Objectives  of  the  interim measures: how the
        measure is mitigating a potential threat to human
        health  and  the environment and/or is consistent
        with and integrated into any long term solution at
        the facility;


    2.   Design,  construction, operation,  and  main-
        tenance requirements;


    3.   Schedules for  design,  construction  and
        monitoring; and

-------
    4.   Schedule for progress reports.
Task II: Pre-lnvestigation Evaluation of
Corrective Measure Technologies
Prior  to  starting the  facility  investigation,  the
Owner/Operator [Respondent]  shall submit to EPA a
report  that identifies the potential corrective  measure
technologies  that may be  used on-site or off-site for
the containment, treatment, remediation, and/or disposal
of contamination. This report shall also  identify any field
data that needs to be collected  in the facility investigation
to facilitate  the  evaluation  and  selection  of the  final
corrective  measure or measures (e.g., compatibility  of
waste and construction materials, information to evaluate
effectiveness, treatability of wastes, etc.).

Task III: RFI Workplan Requirements

The  Owner/Operator [Respondent] shall prepare a RCRA
Facility Investigation (RFI) Workplan. This RFI Workplan
shall include the development of  several  plans, which
shall be prepared concurrently. During the RCRA Facility
Investigation, it may be  necessary to revise the RFI
Workplan to increase or decrease the detail of information
collected to accommodate the facility  specific situation.
The  RFI Workplan includes the following:

A.  Project Management Plan

    The Owner/Operator [Respondent] shall  prepare a
    Project  Management  Plan  which will include a
    discussion  of  the  technical  approach, schedules,
    budget,  and personnel. The  Project  Management
    Plan will also include a description of qualifications of
    personnel performing or directing the RFI, including
    contractor personnel. This  plan shall also  document
    the overall management  approach to the  RCRA
    Facility Investigation.

8.  Data Collection Quality  Assurance Plan

    The Owner/Operator  [Respondent] shall  prepare a
    plan to  document  all monitoring  procedures:
    sampling, field measurements  and sample analysis
    performed during the investigation to characterize the
    environmental setting, source, and  contamination, so
    as  to ensure that all information,  data  and resulting
   decisions are technically sound,  statistically valid,
   and properly documented.

    1.  Data Collection Strategy

       The strategy  section  of the  Data Collection
       Quality Assurance Plan shall include but not be
       limited to the following:
                                                               a.
    c.
    d.
    e.
    Description of the intended uses for  the
    data, and  the necessary  level  of  precision
    and accuracy for these intended uses;

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

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

    i)   Environmental conditions at the time of
        sampling;

    ii)   Number of sampling points;

   iii)   Representativeness of selected  media;
        and

   iv)   Representativeness of selected  analyt-
        ical parameters.

    Description of the measures to be taken to
    assure  that the  following  data sets can be
    compared to each other:

    i)   RFI   data  generated   by   the
        Owner/Operator over some time period;

    ii)   RFI data generated  by  an  outside
        laboratory or consultant versus data
        generated by the Owner/Operator;

   iii)   Data generated by separate consultants
        or laboratories; and

   iv)   Data generated by an outside consultant
        or laboratory over some time period.

    Details relating  to  the  schedule  and
    information to  be provided  in  quality
    assurance  reports. The  reports should
    include but not be limited to:

    i)   Periodic assessment of measurement
        data  accuracy,  precision,  and
        completeness;
    ii)

   iii)

   iv)
            Results of performance audits;

            Results of system audits;
            Significant quality assurance  problems
            and recommended solutions; and
2.
    v)


Sampling
            Resolutions of  previously  stated
            problems.

-------
The  Sampling section  of the  Data Collection
Quality Assurance Plan shall discuss:

a.   Selecting appropriate  sampling locations,
    depths, etc.;

b.   Providing a statistically  sufficient number of
    sampling sites;

c.   Measuring all necessary ancillary data;

d.   Determining  conditions  under  which
    sampling should be conducted;

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

f.   Determining  which parameters are  to  be
    measured and where;

g.   Selecting the frequency of sampling  and
    length of sampling period;

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

i.   Measures  to  be  taken to  prevent
    contamination  if the sampling  equipment
    and cross contamination between sampling
    points;

j.   Documenting field sampling operations and
    procedures,  including:

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

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

   iii)   Documentation  of specific  sample
        preservation method;

   iv)   Calibration of field devices;

    v)   Collection of replicate samples;

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

   vii)   Potential interferences  present at  the
        facility;

  viii)   Construction materials and techniques,
        associated  with monitoring wells  and
        piezometers;
       ix)  Field equipment  listing and sample
           containers;

       x)  Sampling order; and

       xi)  Decontamination procedures.

    k.  Selecting appropriate sample containers;

    I.   Sample preservation; and

    m. Chain-of-custody, including:

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

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

3.   Field Measurements

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

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

    b.  Providing a statistically sufficient number  of
       field measurements;

    c.  Measuring all necessary ancillary data;

    d.  Determining conditions under  which  field
       measurements should be conducted;

    e.  Determining  which  media   are  to be
       addresssed  by  appropriate  field
       measurements (e.g., ground water, air,  soil,
       sediment, etc.);

    f.   Determining which  parameters are  to be
       measured and where;

    g.  Selecting  the   frequency  of  field
       measurements   and  length  of  field
       measurements period; and

    h.  Documenting field measurement operations
       and procedures, including:

        i)  Procedures and forms for recording raw
           data and the exact location,  time,  and
           facility-specific  considerations
           associated with the data acquisition;

       ii)  Calibration of field devices;

       iii)  Collection of replicate measurements;

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

-------
       v)   Potential interferences present at the
            facility;

       vi)   Construction  materials and techniques
            associated with  monitoring  wells  and
            piezometers use to collect field data;

      vii)   Field equipment  listing;

      viii)   Order in which field measurements were
            made; and

       ix)   Decontamination procedures.

4.   Sample Analysis

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

    a.   Chain-of-custody  procedures,  including:

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

       ii)   Provision  for  a  laboratory  sample
            custody  log  consisting  of  serially
            numbered  standard  lab-tracking report
            sheets;  and
       iii)   Specification of  laboratory  sample
            custody  procedures  for  sample
            handling, storage, and dispersement for
            analysis.

    b.  Sample  storage  procedures  and storage
       times;

    c.  Sample preparation methods;

    d.  Analytical procedures, including:

       i)   Scope and application of the procedure;

       ii)   Sample matrix;

       iii)   Potential interferences;

       iv)   Precision  and  accuracy  of  the
            methodology; and

       v)   Method detection limits.

    e.  Calibration procedures and frequency;

    f.   Data reduction, validation and reporting;
       g.  Internal quality control  checks,  laboratory
           performance  and  systems  audits  and
           frequency, including:

           i)  Method blank(s);

           ii)  Laboratory control sample(s);

           iii)  Calibration check sample(s);

           iv)  Replicate sample(s);

           v)  Matrix-spiked sample(s);

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

          vii)  Control charts;

          viii)  Surrogate  samples;

           ix)  Zero and span gases; and

           x)  Reagent quality control checks.

           [A performance audit  will be conducted by
           U.S. EPA on the laboratories  selected by the
           Owner/Operator  [Respondent]. This  audit
           must be completed and approved  prior to
           the facility investigation.]

       h.  Preventive  maintenance procedures  and
           schedules;

       i.   Corrective action  (for  laboratory  problems);
           and

       j.   Turnaround time.

C.  Data Management Plan

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

    1.  Data  Record

       The data record  shall include the  following:

       a.  Unique sample or field measurement code;

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

       c.  Sampling or field measurement raw data;

       d.  Laboratory analysis ID number;

-------
       e.   Property or component measured; and

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

    2.  Tabular Displays

       The following data shall be presented in tabular
       displays:

       a.   Unsorted  (raw) data;

       b.   Results for each medium, or for each con-
            stituent monitored;

       c.   Data reduction for statistical analysis;

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

       e.   Summary data.

    3.   Graphical Displays

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

       a.   Display sampling location and sampling grid;

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

       c.   Displays  levels  of contamination at each
            sampling location;

       d.   Display geographical extent of  contam-
            ination;

       e.   Display contamination levels, averages,  and
            maxima;

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

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

D.  Health and Safety Plan

    The  Owner/Operator  [Respondent] shall  prepare  a
    facility  Health and Safety Plan.

    1.  Major elements of the  Health and Safety Plan
       shall include:

       a.   Facility description including  availability of
            resources such  as roads, water  supply,
            electricity and telephone service;
    b.   Description  of the  known  hazards and
        evaluate the  risks  associated with  the
        incident and  with each activity conducted;

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

    d.   Delineation of work area;

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

    f.   Establishment  of procedures to control site
        access;

    g.   Description  of decontamination  procedures
        for personnel and equipment;

    h.   Establishment of  site  emergency  pro-
        cedures;

    i.   Emergency  medical  care for  injuries and
        toxicological  problems;

    j.   Description  of  requirements for  an
        environmental surveillance program;

    k.   Routine  and  special training  required for
        responders; and

    I.   Establishment  of  procedures  for  protecting
        workers  from weather-related problems.

2.   The  Facility Health and  Safety Plan shall be
    consistent with:

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

    b.   EPA Order 1440.1  - Respiratory  Protection;

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

    d.   Facility Contingency Plan;

    e.   EPA  Standard Operating  Safety  Guide
        (1984);

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

    g.   State and local regulations; and

    h.   Other EPA guidance as provided.

-------
£.   Community Relations Plan
    The  Owner/Operator  [Respondent] shall prepare a
    plan, for the  dissemination  of  information to the
    public regarding investigation activities and results.

Task IV: Facility Investigation

The  Owner/Operator [Respondent] shall conduct those
investigations  necessary to: characterize the facility
(Environmental Setting); define  the  source  (Source
Characterization);  define the  degree and extent  of
contamination (Contamination  Characterization);  and
identify actual or potential receptors.

The  investigations  should result  in data  of  adequate
technical  quality  to  support the  development  and
evaluation  of  the  corrective  measure alternative  or
alternatives during the Corrective Measures Study.

The  site investigation activities  shall  follow  the plans set
forth in  Task  III.  All sampling  and analyses  shall be
conducted in accordance with the Data Collection Quality
Assurance  Plan.  All  sampling locations  shall  be
documented in a log and identified on a detailed site
map.

A.  Environmental Setting
    The  Owner/Operator  [Respondent]  shall collect
    information  to supplement and  verify  existing
    information on the environmental setting at the
    facility.  The  Owner/Operator [Respondent]  shall
    characterize the following:

    1.   Hydrogeology

        The Owner/Operator [Respondent]  shall conduct
        a program to evaluate hydrogeologic conditions
        at the facility.  This  program  shall provide the
        following information:

        a.   A description  of the regional  and facility
            specific  geologic   and  hydrogeologic
            characteristics affecting ground-water  flow
            beneath the facility, including:

            i)   Regional   and  facility  specific
               stratigraphy:  description  of strata
               including strike and dip, identification of
               stratigraphic contacts;

           ii)   Structural geology:  description of local
               and regional structural features (e.g.,
               folding, faulting, tilting, jointing, etc.);

          iii)    Depositional history;

          iv)   Identification  and characterization  of
               areas and  amounts of recharge  and
               discharge;

           v)   Regional  and  facility  specific ground-
               water flow patterns; and
   vi)   Characterize seasonal variations in the
        ground-water flow  regime.

b.  An analysis of any topographic features that
    might  influence the  ground-water flow
    system. (Note: Stereographic  analysis of
    aerial photographs may aid in this analysis).

c.  Based  on field  data,  test, and  cores,  a
    representative and  accurate  classification
    and  description  of the hydrogeologic units
    which  may  be  part of  the migration
    pathways at the facility (i.e., the aquifers and
    any  intervening  saturated and  unsaturated
    units), including:

    i)   Hydraulic conductivity and  porosity
        (total and effective);

    ii)   Lithology, grain size,  sorting, degree of
        cementation;

   iii)   An   interpretation  of  hydraulic
        interconnections between  saturated
        zones; and

   iv)   The  attenuation  capacity  and
        mechanisms  of the  natural  earth
        materials (e.g.,  ion exchange capacity,
        organic carbon content, mineral  content
        etc.).

d.  Based on field studies and  cores, structural
    geology and  hydrogeologic cross  sections
    showing the  extent (depth, thickness, lateral
    extent) of hydrogeologic units  which  may be
    part of the migration pathways identifying:

    i)   Sand  and  gravel  deposits  in
        unconsolidated deposits;

    ii)   Zones of fracturing  or channeling in
        consolidated   or   unconsolidated
        deposits;

   iii)   Zones of higher permeability  or low
        permeability that might  direct  and
        restrict the flow of contaminants;

   iv)   The uppermost  aquifer: geologic
        formation, group of formations, or part of
        a formation capable of  yielding  a
        significant amount of ground water to
        wells or springs;  and

    v)   Water-bearing  zones  above the  first
        confining  layer  that  may  serve as a
        pathway  for  contaminant migration
        including perched zones of saturation.

e.  Based  on data obtained  from ground-water
    monitoring wells and piezometers  installed
                                                    10

-------
       upgradient and downgradient of the potential
       contaminant  source,  a  representative
       description of water level or  fluid pressure
       monitoring including:

       i)   water level  contour  and/or  poten-
           tiometric maps;

       ii)   Hydrologic  cross  sections  showing
           vertical gradients;

       iii)   The flow  system, including the vertical
           and horizontal components of flow; and

       iv)   Any  temporal  changes  in  hydraulic
           gradients, for example, due  to tidal or
           seasonal influences.

    f.  A  description of  man-made influences that
       may  affect  the  hydrogeology of the  site,
       identifying:

        i)   Active and  inactive  local water-supply
           and  production  wells   with  an
           approximate schedule of pumping; and

       ii)   Man-made  hydraulic  structures
           (pipelines,  french  drains,  ditches,
           unlined ponds, septic tanks,  NPDES
           outfalls, retention areas, etc.).
2.  Soils
    The Owner/Operator [Respondent] shall conduct
    a program to characterize the soil and rock units
    above the  water  table  in the  vicinity  of the
    contaminant release(s).  Such  characterization
    shall include but not be  limited to, the following
    information:

    a.   SCS soil classification;

    b.   Surface soil distribution;

    c.   Soil profile, including ASTM classification of
        soils;

    d.   Transects of soil stratigraphy;

    e.   Hydraulic  conductivity  (saturated  and
        unsaturated);

    f.   Relative permeability;

    g.   Bulk density;

    h.   Porosity;

    i.   Soil  sorptive capacity;

    j.   Cation exchange capacity (CEC);

    k.   Soil  organic content;

    I.   Soil  pH;
       m.  Particle size distribution;

       n.   Depth of water table;

       o.   Moisture content;

       p.   Effect of stratification on unsaturated flow;

       q.   Infiltration

       r.   Evapotranspiration;

       s.   Storage capacity;

       t.   Vertical flow rate; and

       u.   Mineral content.

3.  Surface Water and Sediment

   The  Owner/Operator  [Respondent] shall  conduct a
   program to characterize the surface-water bodies  in
   the vicinity of the facility. Such characterization shall
   include,  but not be limited to, the following activities
   and information:

       a.   Description of the temporal and  permanent
           surface-water bodies including:

           i)  For lakes  and  estuaries:   location,
              elevation, surface area, inflow, outflow,
              depth, temperature stratification,  and
              volume;

           ii)  For  impoundments: location,  elevation,
              surface area, depth, volume, freeboard,
              and purpose of impoundment;

          iii)  For  streams,  ditches, drains,  swamps
              and channels:  location, elevation, flow,
              velocity,  depth,   width,  seasonal
              fluctuations, and  flooding  tendencies
              (i.e., 100 year event);

          iv)  Drainage patterns; and

          v)  Evapotranspiration.

       b.   Description  of  the  chemistry  of the natural
           surface water and sediments. This includes
           determining  the  pH,  total dissolved  solids,
           total  suspended solids, biological oxygen
           demand,  alkalinity, conductivity,  dissolved
           oxygen  profiles,  nutrients  (NHa,  NOa"
           /NOg",  P04"3),   chemical   oxygen
           demand, total  organic  carbon,  specific
           contaminant  concentrations, etc.

       c.   Description  of  sediment characteristics   in-
           cluding:

           i)  Deposition area;

           ii)  Thickness profile; and
                                                 11

-------
           iii)   Physical and chemical parameters (e.g.,
                grain  size,  density,  organic  carbon
                content, ion  exchange capacity,  pH,
                etc.).
    4.  Air
        The  Owner/Operator  [Respondent] shall provide
        information  characterizing  the climate  in  the
        vicinity of the facility. Such information shall
        include, but not be limited to:
        a.  A description of the following parameters:
            i)   Annual and monthly rainfall averages;
            ii)   Monthly temperature averages   and
                extremes;
           iii)   Wind speed and direction;
           iv)   Relative humidity/dew point;
            v)   Atmospheric pressure;
           vi)    Evaporation data;
           vii)   Development of inversions; and
           viii)   Climate extremes that  have been known
                to occur in  the vicinity of the facility,
                including frequency of occurrence.
        b.  A  description of  topographic and  manmade
            features which affect air flow and emission
            patterns, including:
            i)   Ridges, hills  or mountain areas;
            ii)   Canyons or valleys;
           iii)   Surface water bodies (e.g., rivers, lakes,
                bays, etc.);
           iv)   Wind breaks and forests; and
           v)   Buildings.
B.  Source Characterization
    The Owner/Operator  [Respondent]  shall collect
    analytical data to completely characterize the wastes
    and  the  areas  where  wastes  have  been  placed,
    collected  or  removed  including: type;  quantity;
    physical form; disposition (containment or nature of
    deposits); and facility characteristics affecting release
    (e.g., facility security, and engineered barriers). This
    shall include quantification  of the  following specific
    characteristics, at each source area:
    1.   Unit/Disposal Area Characteristics:
        a.   Location of unit/disposal area;
        b.  Type  of unit/disposal area;
    c.   Design features;
    d.   Operating practices (past and present);
    e.   Period of operation;
    f.   Age of unit/disposal area;
    g.   General physical conditions; and
    h.   Method used to close the unit/disposal area.
2.   Waste Characteristics:
    a.   Type of waste placed in the unit;
        i)   Hazardous  classification  (e.g., flam-
            mable, reactive, corrosive, oxidizing  or
            reducing agent);
        ii)   Quantity; and
       iii)   Chemical composition.
    b.   Physical and chemical characteristics;
        i)   Physical form (solid, liquid, gas);
        ii)   Physical description (e.g., powder, oily
            sludge);
       iii)   Temperature;
       iv)   pH;
        v)   General chemical class (e.g., acid, base,
            solvent);
       vi)   Molecular weight
       vii)   Density;
      viii)   Boiling point;
       ix)   Viscosity;
        x)   Solubility in water;
       xi)   Cohesiveness of the waste;
       xii)   Vapor pressure; and
      xiii)   Flash point.
    c.   Migration  and dispersal  characteristics of the
        waste;
        i)   Sorption;
        ii)   Biodegradability, bioconcentration  bio-
            transformation;
       iii)   Photodegradation rates;
       iv)    Hydrolysis rates; and
        v)   Chemical transformations.
                                                       12

-------
    The Owner/Operator  [Respondent]  shall document
    the procedures used  in  making  the  above
    determinations.

C  Contamination Characterization
    The  Owner/Operator  [Respondent]  shall  collect
    analytical  data on  ground-water, soils,  surface
    water, sediment, and subsurface  gas  contamination
    in  the  vicinity of the facility.  This data shall  be
    sufficient to define the extent, origin,  direction,  and
    rate of  movement of contaminant  plumes. Data shall
    include time and location  of  sampling,  media
    sampled, concentrations found, and conditions during
    sampling,  and  the identity  of the  individuals
    performing the  sampling  and  analysis.  The
    Owner/Operator [Respondent] shall  address  the
    following types of contamination at the facility:

    1.   Ground-water Contamination

    The  Owner/Operator [Respondent]  shall conduct a
    Ground-water  Investigation  to  characterize  any
    plumes of  contamination  at  the facility.  This
    investigation shall at  a minimum provide the following
    information:

        a.   A description of the horizontal  and  vertical
            extent  of any  immiscible  or dissolved
            plume(s) originating from  the facility;

        b.   The  horizontal  and  vertical direction of
            contamination movement;

        c.   The velocity of contaminant movement;

        d.   The horizontal and  vertical  concentration
            profiles of Appendix  VIII  constituents in the
            plume(s);

        e.   An evaluation of factors  influencing  the
            plume movement; and

        f.   An extrapolation  of future  contaminant
            movement.

        The Owner/Operator  [Respondent]  shall
        document  the procedures  used in  making the
        above determinations  (e.g.,  well design,  well
        construction, geophysics, modeling, etc.).

    2.   Soil Contamination

        The Owner/Operator [Respondent] shall conduct
        an  investigation  to  characterize   the
        contamination of the soil and rock  units above
        the water table in the vicinity  of the  contaminant
        release. The  investigation  shall include  the
        following information:

        a.   A description  of the  vertical and horizontal
            extent of contamination.
    b.   A description of contaminant  and  soil
        chemical  properties within the contaminant
        source area  and plume. This  includes
        contaminant  solubility,  speciation,
        adsorption, leachability,  exchange capacity,
        biodegradability, hydrolysis, photolysis,
        oxidation and other factors that might affect
        contaminant migration and transformation.

    c.   Specific contaminant concentrations.

    d.   The velocity and direction of contaminant
        movement.

    e.   An extrapolation of  future  contaminant
        movement.

    The Owner/Operator  [Respondent]  shall
    document  the procedures used  in making the
    above determinations.

3.   Surface-Water and Sediment Contamination

    The Owner/Operator [Respondent] shall conduct
    a surface-water investigation to characterize
    contamination  in surface-water bodies resulting
    from contaminant releases at the facility.

    The investigation shall include, but not be limited
    to, the following information:

    a.   A description of the  horizontal and vertical
        extent of any immisicible or dissolved
        plume(s) originating from the facility, and the
        extent  of contamination  in  underlying
        sediments;

    b.   The horizontal and  vertical  direction  of
        contaminant movement;

    c.   The contaminant velocity;

    d.   An evaluation of the physical, biological and
        chemical  factors influencing contaminant
        movement;

    e.   An extrapolation of  future  contaminant
        movement; and

    f.   A description  of the  chemistry of  the
        contaminated surface waters and sediments.
        This  includes determining  the  pH,  total
        dissolved solids, specific  contaminant
        concentrations, etc.

    The Owner/Operator  [Respondent]  shall
    document  the procedures used  in making the
    above determinations.
                                                    13

-------
    4.   Air Contamination

        The Owner/Operator [Respondent] shall conduct
        an investigation  to characterize  the  participate
        and gaseous contaminants  released into  the
        atmosphere. This investigation shall provide the
        following information:

        a.   A description of  the horizontal and vertical
            direction  and  velocity  of contaminant
            movement;

        b.   The rate and amount of the release; and

        c.   The chemical and physical composition of
            the  contaminants(s)  released,  including
            horizontal and vertical concentration profiles.

        The Owner/Operator [Respondent]  shall
        document the  procedures used  in making the
        above determinations.

    5.   Subsurface Gas Contamination

        The Owner/Operator [Respondent] shall conduct
        an investigation to characterize subsurface gases
        emitted from  buried  hazardous  waste and
        hazardous constituents in the ground water. This
        investigation  shall  include  the  following
        information:

        a.   A description of  the horizontal and vertical
            extent of subsurface gases mitigation;

        b.   The chemical composition  of  the  gases
            being emitted;

        c.   The rate, amount, and density of the  gases
            being emitted; and

        d.   Horizontal and vertical  concentration profiles
            of the subsurface gases emitted.

        The  Owner/Operator [Respondent]  shall
        document  the  procedures used  in making the
        above determinations.

D.  Potential Receptors

    The Owner/Operator  [Respondent] shall collect data
    describing the human populations and environmental
    systems that  are   susceptible  to contaminant
    exposure from  the  facility. Chemical  analysis of
    biological  samples may be needed.  Data  on
    observable  effects   in  ecosystems  may also  be
    obtained.  The  following  characteristics  shall  be
    identified:

    1.   Local uses  and possible future  uses  of ground
        water:
    2.
a.   Type  of  use (e.g.,  drinking  water source:
    municipal  or  residential,   agricultural,
    domestic/non-potable, and industrial); and

b.   Location  of groundwater users  including
    wells and discharge areas.

Local uses and possible future uses of surface
waters draining the facility:

a.   Domestic and municipal  (e.g., potable and
    lawn/gardening watering);
        b.   Recreational (e.g., swimming, fishing);

            Agricultural;

            Industrial; and
c.

d.

e.
            Environmental  (e.g.,  fish  and  wildlife
            propagation).

    3.   Human use  of  or  access to the facility  and
        adjacent lands, including but not limited to:

        a.   Recreation;

        b.   Hunting;

        c.   Residential;

        d.   Commercial;

        e.   Zoning; and

        f.   Relationship  between  population locations
            and prevailing wind direction.

    4.   A description of the biota in surface water bodies
        on, adjacent to, or affected by the facility.

    5.   A description of the ecology  overlying  and
        adjacent to the facility.

    6.   A demographic profile of the people who use or
        have access  to the facility and adjacent land,
        including,  but not limited to: age;  sex;  and
        sensitive subgroups.

    7.   A description of any  endangered or threatened
        species near the facility.

Task V: Investigation Analysis

The Owner/Operator [Respondent] shall  prepare an
analysis  and summary of all facility investigations  and
their results. The objective of this task shall be to ensure
that the investigation data are sufficient  in quality (e.g.,
quality assurance procedures  have been followed)  and
quantity  to describe  the  nature and  extent  of
contamination, potential threat to human health and/or the
environment, and to  support the  Corrective  Measures
Study.
                                                     14

-------
A.  Data Analysis
    The  Owner/Operator [Respondent] shall analyze all
    facility  investigation data outlined in  Task  IV  and
    prepare  a  report  on  the  type  and extent of
    contamination at the facility  including  sources  and
    migration  pathways. The report shall  describe the
    extent  of  contamination (qualitative/quantitative) in
    relation to background levels indicative for the area.

B.  Protection Standards [where applicable]
    1.  Ground-water Protection Standards

        For  regulated  units the  Owner/Operator
        [Respondent] shall  provide  information to
        support  the  Agency's  selection/development of
        Ground-water Protection Standards for all of the
        Appendix VIII constituents found in the ground-
        water during the Facility Investigation (Task IV).

        a.   The Groundwater Protection Standards shall
            consist of:

            i)   For any constituents listed  in Table  1 of
                40  CFR 264.94,  the  respective value
                given in  that  table (MCL)  if  the
                background level of the  constituent is
                below the given in Table 1; or

                The background level of that constituent
                in the groundwater; or

                A  U.S.  EPA approved Alternate
                Concentration  Limit (ACL).

        b.   Information  to support the  Agency's
            subsequent  selection  of  Alternate
            Concentration  Limits  (ACLs) shall  be
            developed   by  the  Owner/Operator
            [Respondent]  in accordance with U.S.  EPA
            guidance. For  any proposed ACLs  the
            Owner/Operator [Respondent]  shall  include
            a justification based  upon the criteria set
            forth in 40 CFR 264.94(b).

        c.   Within [insert number] days of receipt of any
            proposed ACLs, the U.S. EPA shall notify
            the  Owner/Operator [Respondent] in writing
            of approval, disapproval or modifications, the
            U.S. EPA  shall  specify  in  writing  the
            reason(s)  for  any  disapproval   or
            modification.
        d.  Within [insert number] days of receipt of the
           U.S. EPA's notification or disapproval of any
           proposed  ACL,  the  Owner/Operator
           [Respondent] shall amend and submit
           revisions to the U.S. EPA.

    2.   Other Relevant Protection Standards

        The Owner/Operator  [Respondent] shall identify
        all  relevant and  applicable  standards for the
        protection of human health and the environment
        (e.g., National Ambient Air  Quality  Standards,
        Federally-approved  state  water quality
        standards, etc.).

Task VI: Laboratory and Bench-Scale Studies

The Owner/Operator  [Respondent]  shall  conduct
laboratory and/or bench  scale studies to determine the
applicability of a  corrective measure technology  or
technologies to facility  conditions. The  Owner/Operator
[Respondent]  shall  analyze the technologies, base^d on
literature review, vendor contracts, and past experience to
determine the testing requirements.

The Owner/Operator [Respondent] shall develop a testing
plan identifying the type(s) and  goal(s) of the study(ies),
the level of effort needed, and the procedures to be used
for data management and interpretation.

Upon completion of the  testing, the  Owner/Operator
[Respondent]  shall evaluate the testing results to assess
the technology or technologies  with respect  to the site-
specific questions identified in the test plan.

The Owner/Operator [Respondent] shall prepare a  report
summarizing the testing program and its results, both
positive and negative.

Task VII: Reports

A.  Preliminary and Workplan

    The Owner/Operator [Respondent] shall submit to the
    EPA reports on Tasks I and  II when it submits the
    RCRA Facility Investigation Workplan (Task III).

B.  Progress

    The Owner/Operator [Respondent]  shall  at   a
    minimum provide the EPA with signed, [monthly,
    bimonthly] progress reports containing:
                                                    15

-------
1.   A description and estimate of the percentage of
    the RFI completed;

2.   Summaries of all findings;

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

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

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

6.   Actions being taken to rectify problems;

7.   Changes  in  personnel  during  the reporting
    period;

8.   Projected work for the next reporting period; and

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

Draft and Final
Upon  EPA  approval,  the  Owner/Operator
[Respondent]  shall  prepare a  RCRA Facility
Investigation Report to present  Tasks  IV-V. The
RCRA Facility  Investigation  Report shall be
developed in draft form for U.S. EPA review. The
RCRA Facility  Investigation  Report shall be
developed in  final format  incorporating comments
received  on the  Draft  RCRA Facility  Investigation
Report. Task VI shall  be submitted  as a separate
report when the  Final  RCRA Facility  Investigation
Report is submitted.

[Number] copies  of all  reports, including the Task I
report, Task II report,  Task III  workplan, Task VI
report and both the  Draft and Final RCRA  Facility
Investigation Reports (Task  IV-V) shall be provided
by the Owner/Operator [Respondent] to U.S. EPA.
[THE FOLLOWING  FACILITY SUBMISSION SUMMARY
MAY BE  PLACED IN THE BODY OF THE ORDER OR
PERMIT  AND REMOVED  FROM  THE  SCOPE OF
WORK. NOT ALL OF THE ITEMS LISTED  BELOW MAY
BE REQUIRED AT EACH FACILITY.]

Facility Submission Summary
A summary  of the information  reporting  requirements
contained in the  RCRA Facility Investigation  Scope of
Work is presented below:
    Facility Submission

 Description of Current
  Situation
    (Task I)

 Pre-lnvestigation
  Evaluation of
  Corrective Measure
  Technologies
    (Task II)

 RFI Workplan
    (Task III)

 Draft RFI Report
    (Tasks IV and V)

 Final RFI Report
    (Tasks IV and V)
 Laboratory and Bench-
  Scale Studies
    (Task VI)

 Progress Reports on
  Tasks I through VI
        Due Date
[DATE
[DATE
[ DATE]
[NUMBER] days after
RFI Workplan Approval

[ NUMBER ] days after
EPA comment on Draft
RFI Report

Concurrent with Final RFI
Report
[ MONTHLY, BI-
MONTHLY 1
                                              16

-------
                              Scope of Work for a Corrective Measure Study
                                                    at
                                          [Specify Facility Name]
Purpose

The purpose of this Corrective Measure Study (CMS) is
to develop and evaluate the corrective action alternative
or alternatives and to recommend the corrective measure
or measures to be taken at [specify facility name]. The
Owner/Operator [Respondent] will furnish the personnel,
materials, and services  necessary  to prepare the
corrective measure study, except as otherwise specified.

[Note:  This scope  of work is intended to foster timely,
concise submissions by Owner/Operators. To achieve
this goal, it is  important when using the model scope of
work to consider facility specific conditions. This scope
should be modified as necessary  to require only that
information necessary to complete  the Corrective Mea-
sure Study.]

Scope

The Corrective Measure Study consists of four tasks:

    Task VIII:    Identification and  Development of  the
                Corrective  Measure  Alternative or
                Alternatives

                A.  Description of  Current Situation

                B.  Establishment  of Corrective  Action
                   Objectives

                C.  Screening of  Corrective  Measures^
                   Technologies
                                                    "'i'i
                D.  Identification  of the  Corrective
                   Measure Alternative or Alternatives

    Task IX:     Evaluation of  the  Corrective Measure
               Alternative or Alternatives

               A.  Technical/Environmental/Human
                   Health/Institutional

               B.  Cost Estimate

    Task X:     Justification  and Recommendation  of
               the Corrective Measure or Measures

               A.  Technical

               B.  Environmental

               C.  Human Health
     Task XI:    Reports

                A.  Progress

                B.  Draft

                C.  Final

 TASK VIII: Identification and Development of the
 Corrective Measure Alternative or Alternatives

 Based on the results of the RCRA Facility Investigation
 and consideration of the identified Preliminary Corrective
 Measure  Technologies (Task II),  the Owner/Operator
 [Respondent]  shall  identify,  screen  and develop the
 alternative  or  alternatives  for  removal,  containment,
 treatment and/or other remediation of the  contamination
 based on  the  objectives  established  for the corrective
 action.

 A.  Description of Current Situation

     The Owner/Operator [Respondent] shall  submit  an
     update  to  the  information describing the current
     situation at the facility and  the known  nature and
     extent of the contamination  as documented by the
     RCRA Facility  Investigation  Report.  The
     Owner/Operator  [Respondent]  shall  provide  an
     update to information presented in Task I of the RFI
     to the Agency regarding previous  response  activities
'"    and any interim measures which  have or are being
     implemented at the facility.  The Owner/Operator
     [Respondent]  shall  also make  a  facility-specific
|s    statement of the purpose for the response, based on
     the results  of the RCRA  Facility  Investigation. The
 s    statement of purpose should  identify the actual or
     potential   exposure  pathways  that should  be
     addressed  by corrective measures.

 B.  Establishment of Corrective Action Objectives

     The Owner/Operator  [Respondent], in conjunction
     with  the  U.S. EPA,  shall  establish site  specific
     objectives for the corrective action. These objectives
     shall  be based on public health  and  environmental
     criteria, information  gathered during  the  RCRA
     Facility Investigation,  EPA  guidance,  and the
     requirements of any applicable Federal statutes. At a
     minimum,  all corrective actions concerning ground-
     water releases from  regulated  units  must  be
                                                    17

-------
    consistent with, and as stringent as, those required
    under 40 CFR 264.100.

C.  Screening of Corrective Measure
    Technologies

    The  Owner/Operator [Respondent]  shall  review the
    results of the  RCRA  Facility  Investigation  and
    reassess  the  technologies specified in the  Task II
    report as approved by EPA and identify additional
    technologies which are applicable at the facility. The
    Owner/Operator [Respondent] shall  screen the
    preliminary  corrective  measure technologies
    identified  in Task II of the RCRA  Facility Investigation
    and  any  supplemental technologies  to eliminate
    those that may prove  infeasible to implement, that
    rely on technologies unlikely to perform satisfactorily
    or  reliably, or that do not achieve the corrective
    measure  objective within  a reasonable time period.
    This screening process focuses on eliminating  those
    technologies which have  severe  limitations  for a
    given set of waste and site-specific conditions. The
    screening step  may  also  eliminate  technologies
    based on inherent technology limitations. Site, waste,
    and  technology  characteristics which  are  used to
    screen  inapplicable technologies are  described in
    more detail below:

    1.   Site Characteristics

        Site  data  should be reviewed  to  identify
        conditions that may limit or promote the use of
        certain technologies. Technologies  whose use is
        clearly precluded by  site  characteristics should
        be eliminated from further consideration;

    2.   Waste Characteristics

        Identification of waste characteristics that  limit
        the effectiveness or feasibility of technologies is
        an  important part of  the  screening process.
        Technologies clearly  limited  by  these  waste
        characteristics should be eliminated  from
        consideration. Waste  characteristics  particularly
        affect  the  feasibility of in-situ  methods, direct
        treatment methods, and land disposal  (on/off-
        site); and

    3.   Technology Limitations

        During  the  screening  process,  the level of
        technology  development,  performance  record,
        and inherent construction,  operation,   and
        maintenance problems should  be  identified for
        each  technology considered. Technologies that
        are unreliable, perform  poorly,  or  are  not fully
        demonstrated may  be  eliminated  in  the
        screening  process.   For  example,  certain
        treatment methods  have been  developed to a
        point where they can be implemented in the field
        without  extensive technology  transfer or
       development.
D.  Identification of the Corrective Measure
    Alternative or Alternatives

    The Owner/Operator [Respondent] shall develop the
    corrective  measure alternative or alternatives based
    on the corrective  action objectives and analysis of
    Preliminary Corrective  Measure  Technologies,  as
    presented in Task  II  of the  RCRA  Facility
    Investigation and  as supplemented  following the
    preparation of the RFI  Report.  The Owner/Operator
    [Respondent] shall rely on  engineering practice to
    determine which  of  the  previously  identified
    technologies  appear  most suitable  for  the site.
    Technologies can  be combined to form the overall
    corrective  action  alternative  or alternatives. The
    alternative  or alternatives developed should represent
    a workable number of option(s) that each  appear to
    adequately address all site problems and  corrective
    action objectives. Each alternative may consist of an
    individual technology  or  a  combination  of
    technologies. The Owner/Operator [Respondent]
    shall  document  the reasons for  excluding
    technologies, identified  in  Task II, as  supplemented
    in the development of the alternative or alternatives.

Task IX: Evaluation  of the  Corrective Measure
Alternative or Alternatives

The  Owner/Operator [Respondent]  shall  describe each
corrective  measure alternative that passes  through the
Initial Screening in Task VIM and  evaluate each  corrective
measure alternative and it's components. The  evaluation
shall be based  on technical, environmental, human health
and  institutional  concerns.  The  Owner/Operator
[Respondent] shall also develop cost estimates of each
corrective measure.

A.  Technical/Environmental/Human
    Health/Institutional

    The Owner/Operator  [Respondent] shall  provide  a
    description of  each corrective measure alternative
    which includes but  is  not limited to the following:
    preliminary process flow  sheets; preliminary sizing
    and type of construction for buildings and structures;
    and rough quantities  of utilities required. The
    Owner/Operator [Respondent] shall  evaluate  each
    alternative  in the four following areas:

    1.  Technical;

       The Owner/Operator [Respondent] shall evaluate
       each  corrective measure  alternative  based  on
       performance,  reliability, implementability and
       safety.

       a.   The Owner/Operator  [Respondent]  shall
            evaluate  performance based on the
            effectiveness and useful life of the corrective
            measure:

            i)    Effectiveness  shall  be  evaluated  in
                terms of the  ability to perform intended
                                                    18

-------
       functions,  such  as  containment,
       diversion, removal,  destruction,  or
       treatment. The effectiveness  of  each
       corrective measure  shall be determined
       either  through design specifications or
       by performance evaluation. Any specific
       waste or site characteristics which could
       potentially  impede  effectiveness  shall
       be considered. The evaluation should
       also  consider the effectiveness  of
       combinations of technologies; and

   ii)  Useful life is defined as the  length of
       time the level of effectiveness can  be
       maintained.  Most corrective  measure
       technologies, with the  exception  of
       destruction, deteriorate with time. Often,
       deterioration  can be slowed  through
       proper   system   operation  and
       maintenance, but the  technology
       eventually may  require replacement.
       Each  corrective measure shall  be
       evaluated  in  terms of the projected
       service  lives   of its component
       technologies. Resource  availability in
       the future life of the technology, as well
       as appropriateness  of the technologies,
       must be  considered in estimating the
       useful  life of the project.

b.   The  Owner/Operator [Respondent]  shall
    provide information on the reliability of each
    corrective measure including their operation
    and maintenance  requirements and  their
    demonstrated reliability:

    i)  Operation   and  maintenance
       requirements include the frequency and
       complexity of necessary operation and
       maintenance. Technologies  requiring
       frequent  or  complex operation and
       maintenance  activities  should  be
       regarded as  less  reliable   than
       technologies requiring  little  or
       straightforward operation  and  main-
       tenance. The  availability of labor and
       materials to  meet  these requirements
       shall also be considered; and

   ii)  Demonstrated and expected reliability is
       a  way of measuring the risk and effect
       of failure.  The  Owner/Operator
       [Respondent] should  evaluate  whether
       the  technologies  have  been  used
       effectively under  analogous conditions;
       whether the combination of technologies
       have  been used  together  effectively;
       whether  failure of any one technology
       has an immediate impact on receptors;
       and whether the corrective measure has
           the flexibility to deal with uncontrollable
           changes at the site.

    c.   The Owner/Operator [Respondent] shall
        describe the implementability  of each
        corrective measure including the relative
        ease of installation (constructability) and the
        time required  to  achieve  a given level of
        response:

        i)  Constructability  is   determined  by
           conditions both internal and external to
           the facility conditions and include such
           items  as location of  underground
           utilities,  depth  to  water  table,
           heterogeneity of subsurface materials,
           and  location of the facility (i.e.,  remote
           location vs.  a congested urban area).
           The  Owner/Operator [Respondent] shall
           evaluate what measures can be taken to
           facilitate  construction   under  these
           conditions. External factors which affect
           implementation include the  need  for
           special permits  or  agreements,
           equipment availability, and the location
           of suitable  off-site  treatment  or
           disposal facilities; and

        ii)  Time has two components that shall be
           addressed:  the time  it  takes  to
           implement a corrective measure and the
           time it takes  to actually see  beneficial
           results.  Beneficial results are defined as
           the reduction of contaminants to some
           acceptable, pre-established  level.

    d.   The Owner/Operator [Respondent] shall
        evaluate  each corrective measure alternative
        with regard  to safety. This evaluation shall
        include  threats  to  the  safety  of nearby
        communities and  environments  as well as
        those to workers  during  implementation.
        Factors to consider are fire,  explosion, and
        exposure to  hazardous substances.

2.   Environmental;

    The Owner/Operator [Respondent] shall perform
    an  Environmental  Assessment  for each
    alternative. The Environmental Assessment shall
    focus on the  facility conditions and pathways of
    contamination  actually  addressed  by each
    alternative. The  Environmental Assessment for
    each alternative  will include, at a minimum, an
    evaluation  of: the  short-  and  long-term
    beneficial and adverse effects of the  response
    alternative;  any   adverse   effects  on
    environmentally  sensitive areas; and  an analysis
    of measures to mitigate adverse effects.
                                            19

-------
    3.  Human Health; and

       The Owner/Operator [Respondent] shall assess
       each alternative in terms of the extent of which it
       mitigates  short-  and  long-term potential
       exposure to any  residual contamination  and
       protects  human health  both  during and  after
       implementation of the corrective  measure.  The
       assessment will describe  the levels  and
       characterizations  of contaminants  on-site,
       potential  exposure  routes,  and  potentially
       affected  population.  Each alternative will  be
       evaluated to determine the level of  exposure to
       contaminants and the reduction over time.  For
       management of mitigation measures, the relative
       reduction  of  impact will  be  determined  by
       comparing residual levels of each alternative with
       existing  criteria,  standards,  or  guidelines
       acceptable to EPA.

    4.  Institutional;

       The Owner/Operator [Respondent] shall assess
       relevant  institutional  needs for  each alternative.
       Specifically, the  effects  of Federal, state  and
       local environmental and public health standards,
       regulations, guidance, advisories,  ordinances, or
       community relations  on  the  design, operation,
       and timing of each alternative.

B.  Cost Estimate

    The Owner/Operator [Respondent] shall develop an
    estimate of  the cost of  each corrective  measure
    alternative  (and for each phase or segment  of  the
    alternative). The cost estimate shall include both
    capital and operation and maintenance costs.

    1.  Capital costs consist of direct (construction) and
       indirect (nonconstruction and overhead)  costs.

       a.   Direct capital costs include:

            i)   Construction  costs: Costs of  materials,
               labor (including  fringe  benefits  and
               worker's  compensation), and equipment
               required  to  install   the  corrective
               measure;

           ii)   Equipment costs: Costs  of treatment,
               containment, disposal and/or service
               equipment  necessary to  implement  the
               action; these materials remain until  the
               corrective action is complete;

           iii)   Land  and  site-development costs:
               Expenses associated  with  purchase of
               land  and  development of  existing
               property; and

          iv)   Buildings and services costs:  Costs of
               process  and  nonprocess  buildings,
            utility connections, purchased  services,
            and disposal costs.

    b.   Indirect capital costs include:

        i)   Engineering   expenses:  Costs  of
            administration,  design, construction
            supervision, drafting,  and  testing  of
            corrective measure alternatives;

        ii)   Legal fees and license or permit costs:
            Administrative  and  technical costs
            necessary  to obtain  licenses  and
            permits for installation and operation;

       iii)   Startup and shakedown costs: Costs
            incurred during  corrective measure
            startup; and

       iv)   Contingency allowances: Funds to cover
            costs  resulting  from unforeseen
            circumstances, such as adverse weather
            conditions,  strikes, and  inadequate
            facility characterization.

2.   Operation and  maintenance costs are  post-
    construction  costs  necessary  to   ensure
    continued effectiveness of a corrective measure.
    The Owner/Operator [Respondent] shall consider
    the  following  operation and  maintenance  cost
    components:

    a.   Operating labor costs:  Wages,  salaries,
        training,  overhead,  and  fringe  benefits
        associated with  the  labor needed  for post-
        construction operations;

    b.   Maintenance  materials  and labor  costs:
        Costs for labor, parts, and other resources
        required for routine maintenance of facilities
        and equipment;

    c.   Auxiliary  materials and  energy: Costs  of
        such items  as chemicals and electricity  for
        treatment plant operations,  water and sewer
        service, and fuel;

    d.   Purchased  services:  Sampling  costs,
        laboratory fees, and professional  fees  for
        which the need can be predicted;

    e.   Disposal  and  treatment costs: Costs  of
        transporting, treating, and disposing of waste
        materials, such  as treatment plant residues,
        generated during operations;

    f.   Administrative costs: Costs associated with
        administration of corrective measure
        operation  and  maintenance not  included
        under other categories;

    g.   Insurance, taxes, and licensing costs: Costs
        of such  items as liability and  sudden
        accidental insurance; real  estate  taxes  on
                                                    20

-------
           purchased  land  or  rights-of-way;  licensing
           fees for  certain technologies; and  permit
           renewal and reporting costs;

       h.  Maintenance reserve and contingency funds:
           Annual payments into escrow funds to cover
           (1) costs of anticipated  replacement  or
           rebuilding of equipment and  (2) any  large
           unanticipated operation and  maintenance
           costs; and

       i.   Other costs: Items that do not fit any of the
           above categories.

Task X: Justification and Recommendation of
the Corrective Measure or Measures

The  Owner/Operator  [Respondent]  shall justify and
recommend a  corrective measure  alternative  using
technical, human health, and environmental criteria. This
recommendation shall include summary  tables which
allow  the  alternative  or alternatives to be  understood
easily. Tradeoffs among  health  risks,  environmental
effects, and other pertinent factors shall be highlighted.
The  U.S.  EPA  will  select the  corrective  measure
alternative or  alternatives to be  implemented based  on
the results of Tasks  IX and X.  At  a minimum, the
following criteria will be used to justify the final corrective
measure or measures.

A.  Technical

    1.  Performance - corrective measure or measures
        which are  most effective  at  performing  their
        intended  functions  and maintaining  the
        performance  over extended periods of time will
        be given preference;

    2.  Reliability  - corrective  measure  or measures
        which do  not  require  frequent  or  complex
        operation and  maintenance activities  and that
        have  proven effective under waste and facility
        conditions  similar  to those anticipated  will  be
        given preference;

    3.  Implementability  -  corrective  measure  or
        measures which  can  be constructed  and
        operating to  reduce levels of contamination to
        attain  or exceed applicable  standards in the
        shortest period of time will be preferred; and

    4.  Safety - corrective measure or measures which
        pose the least  threat to  the  safety of  nearby
        residents and environments as well as workers
        during implementation will  be preferred.

B.  Human Health

    The corrective  measure or  measures must  comply
    with  existing  U.S. EPA criteria, standards,  or
    guidelines  for the  protection of human  health.
    Corrective measures which provide the minimum
    level of exposure to contaminants and the maximum
    reduction in exposure with time are preferred.

C.  Environmental

    The corrective measure or measures posing the least
    adverse  impact (or greatest improvement) over the
    shortest  period of time  on  the environment will be
    favored.

Task XI: Reports

The Owner/Operator  [Respondent]  shall  prepare a
Corrective Measure Study Report presenting the results
of Task VIII  through X and  recommending a corrective
measure alternative, [number] copies of the preliminary
report shall be  provided  by the  Owner/Operator
[Respondent].

A.  Progress

    The  Owner/Operator  [Respondent]  shall at a
    minimum provide  the EPA  with signed, [monthly,
    bimonthly] progress reports containing:

    1.   A description and estimate of the percentage of
        the CMS completed;

    2.   Summaries of all findings;

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

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

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

    6.   Actions being taken to rectify problems;

    7.   Changes in personnel during reporting period;

    8.   Projected work for the next reporting period; and

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

8.  Draft

    The Report shall at a minimum include:

    1.   A description of the facility;

        a.   Site topographic   map  and  preliminary
            layouts.

    2.   A summary of the corrective measure  or
        measures;

        a.   Description  of  the  corrective  measure  or
            measures and rationale for selection;

        b.   Performance expectations;
                                                    21

-------
    c.  Preliminary design criteria and rationale;

    d.  General  operation and  maintenance re-
       quirements; and

    e.  Long-term monitoring  requirements.

3.   A summary of the  RCRA Facility Investigation
    and impact on the selected corrective measure
    or measures;

    a.  Field  studies (ground-water, surface  water,
       soil, air); and

    b.  Laboratory studies (bench scale, pilot scale).

4.   Design and Implementation Precautions;

    a.  Special technical problems;

    b.  Additional engineering data required;

    c.  Permits and regulatory requirements;

    d.  Access,  easements,  right-of-way;

    e.  Health and safety requirements; and

    f.  Community relations activities.

5.   Cost Estimates and Schedules;

    a.  Capital cost estimate;

    b.  Operation and  maintenance cost estimate;
       and

    c.  Project  schedule  (design,  construction,
       operation).
    [Number] copies of the draft shall be provided by the
    Owner/Operator [Respondent] to U.S. EPA.

C.  Final

    The Owner/Operator [Respondent]  shall finalize the
    Corrective Measure  Study Report  incorporating
    comments received from EPA on the Draft Corrective
    Measure Study Report.

[THE  FOLLOWING FACILITY SUBMISSION SUMMARY
MAY BE PLACED IN THE BODY OF THE ORDER OR
PERMIT  AND REMOVED  FROM  THE  SCOPE OF
WORK. NOT ALL OF THE ITEMS LISTED BELOW MAY
BE REQUIRED AT EACH FACILITY.]

Facility Submission Summary

A summary  of the  information reporting  requirements
contained  in the Corrective Measure Study Scope of
Work is presented below:
    Facility Submission

 Draft CMS Report
     (Tasks VIII, IX, and X)
 Final CMS Report
     (Tasks VIII, IX, and X)
 Progress Reports on
  Tasks VIM, IX, and X
    Due Date

[ NUMBER ] days
after submittal of the
final RFI

[ NUMBER ] days
after Public and EPA
comment on the Draft
CMS

[ MONTHLY.BI-
MONTHLY ]
                                               22

-------
                       Scope of Work for the Corrective Measure Implementation
                                                   at
                                         [Specify Facility Name]
Purpose

The purpose of this Corrective Measure Implementation
(CMI) program is to design, construct, operate,  maintain,
and monitor the performance of the  corrective  measure
or measures selected  to protect human health and  the
environment.  The  Owner/Operator  [Respondent] will
furnish all personnel, materials and  services necessary
for the  implementation of the corrective measure or
measures.

[Note: This scope  of work is  intended to  foster  timely,
concise  submissions by Owner/Operators. To achieve
this goal, it is important when  using the model  scope of
work to  consider facility  specific conditions. This scope
should be  modified as necessary to require only that
information necessary  to  complete the Corrective
Measure Implementation.]

Scope

The  Corrective Measure  Implementation  program
consists of four tasks;

    Task XII:    Corrective  Measure  Implementation
               Program Plan

               A.  Program Management Plan

               B.  Community Relations  Plan

    Task XIII:   Corrective Measure Design

               A.  Design  Plans and Specifications

               B.  Operation and Maintenance Plan

               C.  Cost Estimate

               D.  Project Schedule

               E.  Construction  Quality Assurance
                   Objectives

               F.  Health and Safety Plan

               G.  Design  Phases

    Task XIV:   Corrective Measure Construction

               A.  Responsibility and Authority
               B.  Construction  Quality Assurance
                   Personnel Qualifications

               C.  Inspection Activities

               D.  Sampling Requirements

               E.  Documentation

    Task XV:    Reports

               A.  Progress

               B.  Draft

               C.  Final

Task XII: Corrective Measure Implementation
Program Plan

The  Owner/Operator  [Respondent] shall prepare  a
Corrective  Measure Implementation Program Plan. This
program will include the development and implementation
of several plans, which require concurrent preparation. It
may be necessary to  revise  plans as  the  work  is
performed  to focus efforts on a particular problem. The
Program Plan includes the following:

A.  Program  Management Plan

    The Owner/Operator [Respondent]  shall prepare a
    Program Management Plan which will document the
    overall management strategy for  performing the
    design, construction, operation,  maintenance  and
    monitoring of  corrective measure(s). The plan shall
    document  the responsibility  and  authority of all
    organizations  and  key  personnel involved  with the
    implementation. The  Program Management Plan will
    also include  a description of  qualifications of key
    personnel  directing  the  Corrective  Measure
    Implementation  Program,  including contractor
    personnel.

B.  Community Relations Plan

    The Owner/Operator [Respondent]  shall revise the
    Community Relations Plan to include any changes in
    the  level  of  concern of  information  needs  to the
    community during design and construction activities.

    1.   Specific  activities  which  must be  conducted
        during the design stage are the following:
                                                   23

-------
        a.  Revise the facility  Community  Relations
           Plan to reflect knowledge of citizen concerns
           and involvement at this stage of the process;
           and

        b.  Prepare  and distribute a public  notice and
           an  updated fact sheet at the completion  of
           engineering design.

    2.   Specific activities to be conducted  during the
        construction  stage could  be  the  following:
        Depending on citizen interest at a facility at this
        point  in  the  corrective action  process,
        community relations activities could range from
        group meetings to  fact sheets  on  the  technical
        status.

Task XIII: Corrective Measure Design

The  Owner/Operator [Respondent]  shall prepare final
construction plans and  specifications to implement the
corrective measure(s) at the facility as defined  in the
Corrective Measure Study.

A.  Design Plans and Specifications

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

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

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

        b.  Minimization of environmental and  public
           impacts.

    2.   Discussion of the technical factors of importance
        including:

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

        b.  The constructability of the design; and

        c.  Use of currently  acceptable  construction
           practices and techniques.

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

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

    5.   Detailed  drawings  of  the proposed  design
        including:

       a.  Qualitative flow  sheets; and

       b.  Quantitative flow sheets.

   6.  Tables listing equipment and specifications;
    7.   Tables giving material and energy balances;

    8.   Appendices including:

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

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

        c.  Results of laboratory or field tests.

B.  Operation and Maintenance Plan

    The Owner/Operator [Respondent] shall  prepare  an
    Operation and  Maintenance Plan  to  cover  both
    implementation  and  long-term maintenance  of  the
    corrective measure. The plan  shall be composed of
    the following elements:

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

        a.  Description of tasks for operation;

        b.  Description of tasks for maintenance;

        c.  Description  of  prescribed  treatment  or
           operation conditions; and

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

    2.   Description of potential operating  problems;

        a.  Description  and  analysis  of  potential
           operation problems;

        b.  Sources of information regarding problems;
           and

        c.  Common and/or anticipated remedies.

    3.   Description  of routine monitoring  and laboratory
        testing;

        a.  Description of  monitoring tasks;

        b.  Description of required  laboratory tests and
           their interpretation;

        c.  Required QA/QC; and

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

    4.   Description  of alternate O&M;

        a.  Should  systems fail, alternate procedures to
           prevent undue hazard; and
                                                    24

-------
       b.  Analysis of vulnerability  and additional
           resource  requirements  should a  failure
           occur.

    5.  Safety plan;

       a.  Description  of  precautions, of necessary
           equipment, etc., for site personnel; and

       b.  Safety tasks required in event of systems
           failure.

    6.  Description of equipment; and

       a.  Equipment identification;

       b.  Installation of monitoring components;

       c.  Maintenance of site equipment; and

       d.  Replacement schedule  for equipment  and
           installed components.

    7.  Records and reporting mechanisms required.

       a.  Daily operating logs;

       b.  Laboratory records;

       c.  Records for operating costs;

       d.  Mechanism for reporting emergencies;

       e.  Personnel and maintenance records; and

       f.  Monthly/annual reports to State agencies.

       An initial Draft  Operation and Maintenance Plan
       shall  be  submitted simultaneously with  the
       Prefinal  Design Document  submission  and the
       Final  Operation  and  Maintenance Plan  with the
       Final  Design Documents.

C.  Cost Estimate

    The Owner/Operator [Respondent] shall develop  cost
    estimates for the purpose of assuring that the facility
    has the financial resources necessary to  construct
    and  implement  the corrective  measure. The cost
    estimate developed in the Corrective Measure Study
    shall  be refined  to reflect the more detailed/accurate
    design  plans and  specifications being developed.
    The  cost estimate shall include both capital  and
    operation  and  maintenance  costs. An  Initial Cost
    Estimate  shall be submitted simultaneously  with the
    Prefinal  Design submission and  the  Final  Cost
    Estimate with the Final  Design Document.

D.  Project Schedule

    The  Owner/Operator [Respondent]  shall develop a
    Project   Schedule   for  construction  and
    implementation of the corrective measure or
    measures which identifies  timing for initiation  and
    completion of all critical  path tasks. Owner/Operator
    [Respondent]  shall  specifically identify dates  for
    completion  of  the project  and  major  interim
    milestones. An  Initial Project Schedule shall  be
    submitted  simultaneously with the  Prefinal  Design
    Document submission and  the   Final  Project
    Schedule with the Final Design Document.

£.  Construction Quality Assurance Objectives

    The Owner/Operator [Respondent] shall  identify and
    document  the objectives  and framework for the
    development  of a  construction quality  assurance
    program including,  but not limited to the following:
    responsibility  and authority; personnel qualifications;
    inspection  activities;  sampling requirements;  and
    documentation.

F.  Health and Safety Plan

    The Owner/Operator [Respondent] shall modify the
    Health Safety  Plan  developed  for  the RCRA Facility
    Investigation  to  address  the  activities  to  be
    performed  at the facility to  implement the corrective
    measure(s).

G.  Design Phases

    The design of  the corrective measure(s)  should
    include the phases outlined  below.

    1.   Preliminary design

        The Owner/Operator [Respondent] shall submit
        the Preliminary design when the design effort is
        approximately 30% complete. At this stage the
        Owner/Operator [Respondent] shall have  field
        verified the existing conditions of the facility. The
        preliminary  design shall reflect  a level  of  effort
        such that the  technical  requirements  of the
        project have been  addressed and  outlined so
        that they  may  be reviewed to determine if the
        final design  will provide an operable and usable
        corrective  measure.  Supporting data  and
        documentation shall be provided with the design
        documents defining the functional aspects of the
        program.  The  preliminary  construction drawings
        by the Owner/Operator [Respondent] shall reflect
        organization and clarity.  The  scope  of the
        technical  specifications shall  be  outlined  in a
        manner reflecting the  final specifications.  The
        Owner/Operator [Respondent] shall include with
        the  preliminary submission design  calculations
        reflecting  the same percentage of completion as
        the designs  they support.

    2.   Intermediate design

        Complex  project design may  necessitate review
        of  the  design  documents   between  the
        preliminary  and the  prefinal/final design. At  the
        discretion of the  Agency,  a design review may
        be required at 60% completion of the  project.
                                                    25

-------
    The intermediate design submittal should include
    the same elements as the prefinal design.

3.   Correlating plans and specifications

    General correlation  between drawings and
    technical specifications, is a basic requirement of
    any  set of  working  construction  plans and
    specifications. Before  submitting the  project
    specifications, the Owner/Operator [Respondent]
    shall:

    a.   Coordinate   and  cross-check  the
        specifications and drawings; and

    b.   Complete the  proofing  of  the  edited
        specifications and required cross-checking
        of all drawings and specifications.

    These activities shall  be completed prior to the
    95% prefinal submittal to the Agency.

4.   Equipment startup and operator training

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

5.   Additional studies

    Corrective Measure Implementation may require
    additional studies  to  supplement  the available
    technical data. At the direction of the Agency for
    any such studies required, the Owner/Operator
    [Respondent]  shall furnish  all services, including
    field work as required, materials, supplies, plant,
    labor, equipment,  investigations,  studies and
    superintendence. Sufficient sampling, testing and
    analysis  shall  be  performed  to  optimize  the
    required treatment  and/or disposal operations
    and systems. There shall be  an initial meeting of
    all  principal  personnel  involved  in the
    development of the program. The purpose  will
    be  to  discuss  objectives,  resources,
    communication channels,  role of  personnel
    involved  and  orientation of  the site, etc. The
    interim  report shall present the results of  the
    testing  with  the  recommended  treatment  or
    disposal  system (including  options). A  review
    conference shall be scheduled after the interim
    report has  been  reviewed by all  interested
    parties. The  final  report  of the  testing shall
    include all data taken during the  testing  and  a
    summary of the results of the studies.
    6.   Prefinal and final design

        The Owner/Operator [Respondent] shall submit
        the prefinal/Final design documents in two parts.
        The first submission shall be at 95% completion
        of design  (i.e., prefinal). After approval of the
        prefinal  submission, the  Owner/Operator
        [Respondent]  shall   execute  the  required
        revisions and submit the final documents 100%
        complete  with reproducible  drawings  and
        specifications.

        The prefinal design submittal shall consist of the
        Design Plans and  Specifications, Operation and
        Maintenance Plan, Capital  and  Operating  and
        Maintenance Cost Estimate,  Project Schedule,
        Quality Assurance Plan  and Specifications for
        the Health and Safety Plan.

        The final  design submittal consists of the  Final
        Design  Plans and   Specifications  (100%
        complete), the  Owner/Operator's  [Respondent's]
        Final  Construction Cost Estimate,  the Final
        Operation and  Maintenance Plan, Final Quality
        Assurance Plan, Final Project Schedule and Final
        Health and  Safety  Plan specifications. The
        quality of the design documents should be such
        that the Owner/Operator [Respondent] would be
        able to include  them in a bid package and invite
        contractors  to submit  bids  for the construction
        project.

Task XIV: Corrective Measure Construction

Following  EPA approval  of  the  final design,  the
Owner/Operator  [Respondent] shall  develop  and
implement  a  construction quality  assurance (CQA)
program to ensure, with a reasonable degree of certainty,
that a completed corrective measure(s) meets or exceeds
all design criteria, plans  and specifications. The CQA plan
is  a facility  specific  document which must be submitted
to the Agency  for approval  prior  to the  start of
construction. At a minimum, the CQA plan should include
the elements,  which are summarized below. Upon EPA
approval  of  the  CQA   plan the  Owner/Operator
[Respondent] shall construct and  implement  the
corrective  measures in accordance with  the  approved
design, schedule and the CQA plan. The Owner/Operator
[Respondent] shall also implement  the elements of the
approved Operation and Maintenance plan.

A.  Responsibility and Authority

    The responsibility and authority of all organizations
    (i.e., technical  consultants,  construction firms,  etc.)
    and key personnel involved in the construction of the
    corrective  measure shall  be described  fully in  the
    CQA plan. The Owner/Operator [Respondent] must
    identify a  CQA officer and  the necessary supporting
    inspection staff.
                                                26

-------
B.  Construct/on Quality Assurance Personnel
    Qualifications

    The qualifications of the CQA officer and supporting
    inspection personnel shall be presented in the CQA
    plan  to demonstrate that  they  possess the  training
    and  experience necessay to fulfill  their  identified
    responsibilities.
C.  Inspection Activities

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

    1.   Preconstruction inspection and meeting

        The Owner/Operator [Respondent] shall conduct
        a preconstruction inspection and meeting to:

        a.  Review methods  for documenting  and re-
           porting  inspection data;

        b.  Review methods for distributing and storing
           documents and reports;
        c.  Review work  area security  and safety
           protocol;
        d.  Discuss any appropriate modifications of the
           construction quality  assurance  plan to
           ensure  that site-specific  considerations are
           addressed; and
        e.  Conduct a site walk-around to verify  that
           the design criteria, plans, and specifications
           are understood and  to review material and
           equipment storage locations.
    The preconstruction inspection and meeting shall be
    documented by a  designated  person and  minutes
    should be transmitted to all parties.

    2.   Prefinal inspection
        Upon  preliminary   project  completion
        Owner/Operator [Respondent]shall notify  EPA for
        the purposes of conducting a  prefinal inspection.
        The prefinal inspection will consist of  a  walk-
        through inspection of the entire project site. The
        inspection is to determine whether the project is
        complete and consistent with  the contract
        documents  and the EPA approved corrective
        measure. Any  outstanding construction items
        discovered  during  the  inspection  will  be
        identified  and noted. Additionally, treatment
        equipment will be  operationally tested by  the
        Owner/Operator  [Respondent].   The
        Owner/Operator [Respondent] will certify that the
        equipment has performed to meet the purpose
        and intent of the specifications. Retesting will be
        completed where deficiencies are revealed. The
        prefinal  inspection  report should  outline  the
        outstanding construction items,  actions required
        to  resolve  items,  completion  date for  these
        items, and date for final inspection.

    3.   Final inspection

        Upon completion of any outstanding construction
        items, the Owner/  Operator [Respondent] shall
        notify EPA for the purposes of conducting a final
        inspection. The final inspection  will consist of a
        walk-through inspection  of the project site. The
        prefinal  inspection  report  will  be  used  as a
        checklist with the final inspection focusing on  the
        outstanding construction  items  identified  in  the
        prefinal inspection.  Confirmation shall be made
        that outstanding items have been resolved.

D.  Sampling Requirements

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

£.  Documentation

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

Task XV: Reports

The  Owner/Operator [Respondent]  shall prepare  plans,
specifications,  and  reports  as set forth in  Tasks  XII
through Task XV to document the design, construction,
operation, maintenance, and monitoring of the corrective
measure. The  documentation shall include,  but not be
limited to the following:

A.  Progress

    The  Owner/Operator  [Respondent]  shall  at a
    minimum provide the  EPA with signed, [monthly,
    bimonthly] progress reports during the  design  and
    construction  phases and [semi-annual] progress
                                                    27

-------
    reports  for  operation and maintenance  activities
    containing:

    1 -  A description and estimate of the percentage of
       the CMI completed;

    2.  Summaries of all findings;

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

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

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

    6.  Actions  being taken to  rectify problems;

    7.  Changes  in  personnel during  the  reporting
       period;

    8.  Projected work for the next reporting period; and

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

B.  Draft

    1.  The Owner/Operator [Respondent] shall submit a
       draft Corrective  Measure Implementation
       Program Plan as outlined in Task XII;

    2.  The Owner/Operator [Respondent] shall submit
       draft  Construction  Plans and  Specifications,
       Design  Reports, Cost Estimates, Schedules,
       Operation  and  Maintenance Plans, and  Study
       Reports as outlined in Task XIII;

    3.  The Owner/Operator [Respondent] shall submit a
       draft  Construction  Quality Assurance Program
       Plan and Documentation as outlined in  Task XIV;
       and

    4.  At the "completion" of the construction  of the
       project,  the  Owner/Operator [Respondent] shall
       submit  a  Corrective Measure  Implementation
       Report  to the  Agency. The  Report shall
       document  that the project is consistent with the
       design  specifications,  and that  the corrective
       measure is performing adequately. The Report
       shall include, but not be limited  to the following
       elements:
       a.  Synopsis of the corrective  measure and
           certification of the design and construction;

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

       c.  Listing of the criteria, established  before the
           corrective measure was initiated, for judging
           the functioning  of  the  corrective measure
           and  also  explaining any modification  to
           these criteria;

       d.  Results of facility monitoring, indicating that
           the corrective measure  will meet  or exceed
           the performance criteria; and

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

    This report should  include all of the  daily  inspection
    summary  reports,  inspection  summary reports,
    inspection  data sheets, problem  identification and
    corrective measure reports, block evaluation reports,
    photographic reporting  data  sheets,  design
    engineers' acceptance  reports,  deviations from
    design  and material specifications  (with  justifying
    documentation) and as-built drawings.

C.  Final

    The Owner/Operator [Respondent] shall finalize the
    Corrective  Measure  Implementation  Program Plan,
    Construction  Plans and  Specifications,  Design
    Reports, Cost Estimates, Project Schedule, Operation
    and Maintenance  Plan, Study Reports, Construction
    Quality Assurance  Program Plan/Documentation and
    the Corrective Measure Implementation  Report
    incorporating comments  received   on  draft
    submissions.

[THE  FOLLOWING FACILITY SUBMISSION  SUMMARY
MAY BE  PLACED IN THE BODY OF THE ORDER OR
PERMIT  AND  REMOVED   FROM  THE SCOPE  OF
WORK. NOT ALL OF THE ITEMS LISTED BELOW MAY
BE REQUIRED AT EACH FACILITY].

Submission Summary

A summary of the information reporting requirements
contained  in the  Corrective Measure  Implementation
Scope of Work is present below:
                                                   28

-------
                 Facility Submission
Draft Program Plans (Task XII)

Final Program Plans (Task XII)

Design Phases (Task XIII A)
- Preliminary Design (30% completion)
- Intermediate Design (60% completion)
- Prefinal Design (95% completion)
- Final Design (100% completion)
(Tasks XIII B through G)
- Draft Submittals
-Final Submittals
Additional Studies: InterimReport (Task XIII F)
Additional Studies: Final Report (Task XIII F)
Draft Construction Quality Assurance Plan (Task XIV)
Final Construction Quality Assurance Plan (Task XIV)

Construction of Corrective Measure(s)
Prefinal Inspection Report (Task XIV)
Draft CMI Report (Task XV)
Completion of Construction
Final CMI Report (Task XV)

Progress Reports for Tasks XII through XIV
Progress Reports During Operation and Maintenance
                     Due Date
 [DATE
[ NUMBER ] days after EPA comment on Draft Program
Plans
[ NUMBER ] days after submittal of Final Program Plan
[ NUMBER ] days after submittal of Final Program Plan
[ NUMBER ] days after submittal of Final Program Plan
{ NUMBER ] days after submittal of Prefinal Design

Concurrent with Prefinal Design
Concurrent with Final Design

[ DATE ESTABLISHED PRIOR TO FINAL DESIGN ]

[ NUMBER ] days after EPA comment on Interim Report

Prior to construction

[ NUMBER ] days after EPA comment on Draft
Construction Quality Assurance Plan

As approved in Final Design

[ NUMBER ] days after Prefinal Inspection

Upon completion of construction phase

As approved by EPA in the Corrective Measure Design

[ NUMBER ] days after EPA comment on Draft CMI
Report

[ MONTHLY.BI-MONTHLY ]

[ SEMI-ANNUAL]
                                                  29

-------
                                         Annotated Bibliography
                                                  for the
                                         Corrective Action Plan**
 Guidance on  Remedial Investigations Under  CERCLA',
 May 1985

    Provides detailed guidance on the information  that
    should  be collected in  performing  a  CERCLA
    Remedial  Investigation. This document should  be
    consulted  in performing  the investigation portion of
    the  RFI/CMS  since most of  the RCRA Facility
    Investigation data needs  are  identical  to  these in
    CERCLA.

 Guidance on  Feasibility  Studies Under CERCLA;  April
 1985.

 -   Provides a framework for developing, screening, and
    selecting a remedial  action under CERCLA. Most of
    the techniques described  are  appropriate for the
    developing, screening, and selection of the RCRA
    Corrective Measures. However, the management and
    policy  objectives  presented in the document  (i.e.;
    fulfilling the requirements  of the CERCLA National
    Contingency Plan) are not  appropriate to RCRA and
    should be omitted  from  the Corrective  Measure
    decisionmaking framework.

 Chemical, Physical and  Biological Properties  of
 Compounds  Present  at Hazardous Waste  Sites;
 EPA/OWPE; September 1985.

    Provides  detailed  technical information of  the
    physical and toxicological properties of a wide range
    of chemicals. Such information should be included in
    the RCRA Facility Investigation and should be  used
    in developing Corrective Measures.

 Endangerment Assessment  Handbook;  EPA/OWPE;
 August 1985.

    Provides guidance on developing  a  CERCLA (or
    RCRA 7003)  Endangerment  Assessment.  The
    information presented might be  useful  in assessing
    health and environmental effects in the RFI/CMS.

 Methods for  Chemical Analysis of  Water  and Waste;
 EPA-600/4-79-020;  March  1979.

    Provides  test  procedures for  monitoring waste
    discharge water supplies, and ambient waters.

 Toxicology Handbook    Principles  Related  to
Hazardous Waste Site  Investigations;  EPA/OWPE;
August 1985.

    Discusses  toxicological principles. Intended as an aid
    for  non-toxicologists.

Remedial Action at  Waste  Disposal  Sites (Revised);
EPA/625/6-85/006;  1985.
    Provides basic reference material on the design and
    implementation  of  remedial  action. Although the
    document  is  geared  towards  the  CERCLA RI/FS
    process, most of the material  presented is  directly
    applicable to the RCRA Corrective Action Plan.

Test  Methods  for   Evaluating   Solid  Waste,
Physical/Chemical Methods; SW-846; July 1982.

    Provides  procedures that  should be  used to
    determine whether a waste is a hazardous waste as
    defined by 40  CFR Part 261.

Superfund Remedial  Design  and  Remedial  Action
Guidance; February 1985.

    Provides guidance  on developing  remedial design
    and remedial  actions at  Superfund sites. Although
    procedurally focused on  satisfying the NCP, the
    document provides useful managerial information for
    implementing  RCRA Corrective Meaures.

Guidance on Remedial Actions for Contaminated Ground
Water at Superfund Sites; Draft; May 1986.

    Provides technical discussions of CERCLA remedial
    alternative  screening  and  case studies  which are
    largely applicable to the RFI/CMS.  The guidance is
    intended to be consistent with  EPA's Ground Water
    Protection Strategy and with RCRA.

Construction Quality Assurance  for  Hazardous  Waste
Land Disposal Facilities; EPA/530-SW-85-031; July
1986.

-   Public guidance on construction quality assurance for
    hazardous  waste landfills, surface impoundments,
    and wastepiles.

RCRA  Ground-Water Monitoring Technical Enforcement
Guidance Document;  Final;  EPA/OWPE; September
1986.

    Provides  guidance  on data  collection and  well
    spacing and design for detection  and assessment
    monitoring of  Interim Status facilities. This guidance
    should be  consulted  in  both the RCRA  Facility
    Investigation and Corrective  Measure stages of the
    RFI/CMS.
"NOTE:   This is not a complete listing of the Agency guidance which
        may be relevant to the corrective action process. A number of
        documents are presently under development  and have not
        been included.
                                                   30
                                                               &U. S. GOVERNMENT PRINTING OFFICE: 1988/548-158/67132

-------