Brmnnental Pratttim
Ertswcemert And
CwnpB
(2244>
Asm sne»
xS-EPA
EPASSW.95-QQ1
MaytSSS
PB95-269183
-------
'
KXT
Off Io» of
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PAGE
;
flue Ma,
T,nut AWMwmu - » . T*-
RCRA Corrective Action Inspection Guiaanee
Manual
of this document was tended i
wholly oe tn part? by the OS EPA under
Contract No. . 6S-KQ-QQG6,
SlSf ^SBiinSiiTSBIIiiili) ~~: ~ ~
United invireniiental Protection
Sl
,
401 H Street, SW:
Baaihingfeoni D.C.
RIPOHI
«hi» guidance is to the -Inspection
Manual 59i8,2b, Oetobec J9f3). '
"com
TJ; AMtwet "JESiaBj«ewoi«i>>:: , , ; .
The purpose of guidance ta to delineate Inaifaetiem
aofcivtei»s whiah ate oclfetcal for the successful eomplet;
o£ eeeceetive action aatlv'itlasa '^ currently underway at t_
facilities. has -weltfcen for irtsj»«etQ«j
the OS EPA ana State environmental agencies (or the;'
contractors) -who will be conducting owe!
of ownee/operatoir aetifltiea at i«oilltij
regulated and corrective action.
EPA and peeaonnel, as iiriters an|
personnel/shouid this fuidanoe manual *
If you any questions' regarding manual, contaot
folaanda afc 202-2SO-44i§.
on
i|iiny
|
|r
•sight
<)a
Many
T
liaeful.
iiriiS(ici'loFi'iSi=
' 1 *3 o i"
"'corTectfve Action, RGRA facility investigation,
inberim-neaauretf/ oorreoti¥» Btufly
w, MOHOTV
Of K1|NMT
tif riiiiaiw ew.itlfS'Sioff
Df MS PAOt
'SrMSl«»f»B«lMWiei|TlQN
fwnS»rtwS stiiftffiT1S
S|r HMHM. 4-,,
-------
NOTICE
The policies and procedures established in this document are intend!
guidance of employees of the U,S. Environmental Protection Agency*'
intended and cannot be relied ypon to create any rights, substantive
enforceable by any party In litigation with the United States, The Agency
to act at variance with these policies and procedures and to them
or without public notice.
id solely for the
They are- not
or procedural,
the
slit any tittle with
-------
OF
•
10 •• INTRODUCTION[[[ 14,
1.1 AND OF ,,,,., ,,,.,,».,.,,,,, U
U THE ,.,,.,..,.,,,,,,.,.„.„:. .1-2
121 ImpleraeBtatibB of (he Coiwelive Action PtegKBt .............:,,......, l«3
13 POR .... v............... 1-4
' 1,4 ......................,........,...............'...,.,.,. l-S
2,0 FOR .........! ............ M
2,1 : THE OF INSPECTION'...........,....,,,,.. J.,,,,,,,, 24
! 2.2 .............................,:.,,,,,,,, 2-2
2,3 .................... J......... 2-3
2,4 A AND 1ST .,,,,, 2-6
2,41 . Flu.,.,.,,........,...........,,,,. '•-.......... 2-6
2.45 ,.,,,,,,, 2-12
2.S FOR THE , „ J,,,,,.,, 2-12
2J .,,,..»,.,, ..,..,...,... L ,, 244
2.7 ,,,,,,,.,,,,,,,,,,,,,.,,,.,,,,,,.,,,,,«„,,.,, I,,,.,,,, V16
3,0 THE ,,,,,. 34
3,1 .,...........,.",..
3.1,1 to ComMer for ......... i........ i,.,...,.. 3»1
3.L2 Split ,,.,.,.,...,,,..,,,,,,,.,,.,,,,,,...,,, i........ k, 34'
3.1,2,1 .,,,.,,,,..,,,,..' i, L ........ 3>4
3,13,2 Tents and ,,,.,,,,,,,,,,,, j,,,,,,,.,, 3-5 .
3.1.2J Iplt Procedures ....................... r.......... 3-7
3,2 " ........... 1..,,...... 3-i
3,3 ......;........ ,|....... ,*348
3.4 t......'.,,'...|.........345-
3J .., |,,,,,.,,. 3-25 .; !
-------
CJMflter
44 .................................... |,.,..-.. 4-1
4.1.1 tie ...... i.,,. I....... 4-2.
41,2 ,...,,,,,,.,.....,»,....,..,,,,..,,,, L ...... 4-2
4,13 ..-.,...,, i,.,.,.,,,,,,»,, !....... 4-2
414 ^ the .,"....,.......,.,,........,... ,,...,, . 4-3
4.1 Al. Genera! Monnttiott .......... «, ;.,,,,,,,, !,»,,,,, 4-5
4.1.4,2 Sunuaaif of Action ,,,»,.,,,,,,,, "•....... 4-5
4.1,4.3 • Violations or ...'..,,... 4-5
42 ............................ ....... 4-fi
4,2.1 aid Field.Notes- t.,,!,,;,,., 44
4.2,2 and Data,,,,,.,...,,,.,,.,.;.,,..,, 4«6
4.2J Maps .......,,.,.,....,..,....»......,,...i\...... 44
4,2,4 ,'.»• • «»«••»•••»•>«>«<•« j ••••••> ^-?
4JJ ,.,,,,„,,.,,,,,,,...,,.»,..'.',, ,1....... 4-7
43 TO THE OF A
;..,...................,.,.....•.,.'.,.. j.. v ... 4-7
4,5 ,.,,.,,,',;,,»,,,,,,.., 4-8
4;6 .,,,.,,,,..,.,,..,,..,.....,.... ,=,..,.,,., I,,,.,,. 4-9
"
2 ............;.........;.....,. .2-7
2
.................. „ ............'...•..;,...........!....•.... 2-i
2 ........... i...........f. 2-10
.1 ' .....,,,,».,,..,.,,,I,,,,.. 2-15
4 ,, 4-4
-------
(CbaUaned)
Chanter
Agpendjcet , • :
A :
B FOE ISM, 1H, CMS, AMD CMf
C '
Tihfe - . \ Page
H OF ...............I..',.... 1-i
2-2 ' ,
ACTION ....................................... ;...... 2-4
2-2 ........................... 2-5
2-3 IN ............ A >13
34 OF TO FOR , J 3-2
3-2 OF .'.
3-3 ISM IKES... 3-9
3-4
3-5 CMS '.,,,i,,,,,, 3-24
34 CMI
ACTIVITIES ,......,,..,..,............,.;., ,;-...,,,,, J1.;.... 3^26
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Foreword
This was by the of Site Enforcement
(OSRE) in as He (Final), Alj tea
and and on .this
The of this this is to
are for the currently
underway at This to the RCRA'
(OSWER as
There are for a i %st, the ^
action will the project;manager or of a
the mil to tlje
to of to adhere'; to .the In
orders and conditions, (IM/Stabimtion, KPl/CMS,
CMI), bimonthly etc. Finally, an a facility's,fall ire to
to the and trigger stipulated
; ; ' • .
The the and
for and technical tin :
evaluating with and the
four of the
•
•
» ' '
The of and can be it
EPA or His is as and ail or of
this can be ts to a '.The
for t conducting corrective are
the and for use,
-------
1.1
IJ
AND OP
This has written for from the US, Ettwowneatijl Protection
(EPA) and Slate environmental (or
o£ at waste
Mho will be
the Act (RCRA) and
Allhoygh the text the "inspectors,* other 'ERA and as
permit writers and enforcement should End this Table
M Ifte different of action
1-1
' of
Interim/Stabilization
Inspection of to'control threats to
health or the environment
to the.
contamination, are
pursued
Corrective Study
Corrective Implementation
to and
of it the facility aid
or receptors,
of
the
identify
of bj : the
owner/operator to evaluate
lo at ''he
Impection.of activltlcis performed bj! the
owner/operator the
and of
i . 1
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1.2
THE
RCEA in iilfi to EPA.with authority to the
transportation, treatment, storage, and of wiste, and to EPA "with
to the EPA Inilii% tie
of ii; May 198QV Allhou|h and
to on t|e generation, treatment,
and of waste, 3M not all of or
hazardous from the that treat, store, or cf waste.
To this RC1A by the' and
of 1984 (HSWA) provided EPA with (!>r of
or at interim status «jr
permits. Hie of lh» new corrective action was to provtt p for'timely to
of or and
(TSDFs) that may a threat to human anc
3Q08(h) EPA to to TSDFs to
Jl In a
status1. 3W4{u) of RCRA EPA the to
Units {SWMUi) at-TSDFt by
permit This also w fi|r of
for 3TO4(v) of RC ^A EPA with the1
aythority to require owncn or to fnim *KDF$, 3005
(c)(3J of RCRA und 40 C.F.E, i2TO,S{b)(2) EPA to non-
SWMUi, as necessary to protect human intf ifce it j 7003 of
RCRA EPA to order tny contributing to i to tn
when the an and to or the.
environment This-order cni be any partyi or
generator-, ^insporteis, or owner/operators of the facility. Section JOJ13 of RCRA EPA to
an to a facility owner/operator to the nature and of a through
monitoring, and a to or the
the
* Fidllties sttijeet lo interim »re those authorized to operate under ;Sed!f» 3Q05(e) of RCRA<
1-2 ' I
-------
edits. Section 300? of RCRA allows EPA, an authorized State, or a representative of either of
these to enter any premises whete hazardous waste is handled to examine reojrds and take
samples of ihe waste, I;
1,2,1
Implementation of the Corrective Action Program
The RCRA corrective action program established by EPA generally o| four (1)
evalmte whether there has been a release to environmental media, (2) inve$ti||;ate the nature and
extent of release (3) evaluate and determine appropriate' corrective measures, jind (4) implement
corrective measures. The four-phase cleanup process for the RCRA earr«tiv| action program
Include the following; 1) RCRA Facility Assessment (RFA), 1) RCRA Paeiltij Investigation
(RFI), 3} Corrective Meiswre Study (CMS), and 4) Corrective Mea&wre ImplefpenlRlton (CMI).
In addition, EPA way require, at any time during the corrective action process;1 the
owner/operators to conduct Ipterint^tabtMzatton measures (!SMs).: ISMi are ujied la control
threats to human health or the environment from releases and/or prevent the further spread of
contamination, while longterin remedies are pursued, !;•
Intiaily, EPA or an authorized state cm conduct a RCRA Facility Assessment |(RFA) at facilities
to determine whether there is any threat to human health or the environment.!: The purpose of
the RFA Is to; 1) identity and evaluate SWMUs and other of fir to all
media md 2) determine the for furttier investigation and/or Interim measures. Once EPA
or the authorized ihe need for corrective action at a Iff A, or in
authorized state will Initiate corrective action at the facility in one of two waysj; i) through i
corrective action order, 2) or through permit conditions pursuant to RCRA Section 3004(u) nnci
(v) and/or 300S(c)(3). A corrective action order incorporates specific language^ {hat generally
requires the owner/operator to conduct a RCRA Facility Investigation (RFI) t& determine the
nature and extent of contamination and, if needed, to conduct a. Corrective Mcjisyre Study ^CMS)
10 evaluate various eteaoup alternates, Once ihe 'CMS has been completed, EPA or authorized
State selects a corrective measure to be Implemented at the facility and a Corrective
Implementation (CMI) order that requires the owner/operator to implement th'e: selected
1-3
-------
• permit, Regfoiiil or
for
thai over ibe lie of the The
i
requiring the or to an RFI If a CMS, th: CMS is
EPA or the • to'be it the
facility. EPA or the the facility's to-(squire a CMI,
Ife C^mejim__Mctiam____noasis._ The Corrective Action
the public to and ask faring the comedy} action
process,* In the s the opportunity to on lie Sti lenient of
(SB)1 and, wKfch
regulatory agency's proposed foe a facility. Following of.public joroments,
the regulatoiy a Decision and 10 Comments (ETC), In
which the Agency to public and the and
the for
FOR *
Under RCRA
(« by HSWA), may to
implement
if • thai its is equivalent 10 or then
the a Is mthoriied tor corrective action, the ipproprlatii State
action authorities and refutations are la lieu of requirements' t|> enforce
nid eorrective action. The Stale Ihen his nuthorily for correslve
In ihe of (MOA) EPA t
State may for EPA participation or Input, are,not currently to be iiothorized
for RCEA 3008(h), however, the is author) tv as part-of
the can call the RCRA/Saperfund Hotline-at t.|!00424-
9346 to on whieltStates Buthorisred for corrective actlorj or'cti
this within own
2 the CMI ii inmrporitod Into ihe orginM RFI/CMS/CM1 3008(h) ordar,
3 The of Basis, Is • public document whisk dcierlbei l'he-pfO|>f>sei ranieiy,-but
not the rera«% for a fiality. This allows for additional infotsiktion to
during the public period, ^ \
1-4
-------
For on the imptemenuiinn the pJEOpmni,
refer to A» which a •. .:ing for information
on the corrective program. For ytr-- : -.formation ati InspectoA amhoriltea
and to ••Linnatioii, of
etc,» to the RC™; \Jig{>ectiQn Manual-
October 1993,
t.4
SUMMAEf
In job, Action (CA) • of
considerations;
The of the RCRA CA
of CA
Content guidance document* available
Permit and cntorcemcnt tooli to cwrecllve »
1-5
-------
2J FOR
The an ovemew of the key in
preparation. The In of are in the
following
2,1
2,2
2,3
2.4
2,6
Guidance Maun! Section
AND OF
INSPECTION
ASSEMBLE
INSFBCTION
I
REVIEW
1ACKOROUND
INFORMATION
FACILITY-
SPECIFIC
INSPECTION PLAN
AND
INSPECTION
EQUIPMENT
1
AND
COMPLETfi
PIE-INSPECTION
WORlSHiiT
Kef
objectives
Determine CA activity by
owner/operator.
Identify to
conduct ca-si*e
fay
Contact Projett OBieer, idontily
tolereited w (
Fdenily level af tecfcnial required
Identify to
Review eorreertve Action orders tr correcilve
action provisions In penult, tpproied
and (Mter baelground
maerlal
workptans,
files
Develop Wllty«specific etwredivi1 action
plan, with ttep-by-step
procedires for "wrijiBg out
Ihe (1) prelnfpectioi
jireparationi (2) oa-site ;
fequlreioeolj; (J) health and iafirt;| plan; and
(4) ani ptaa mij
jhupecUon
for
Develop worksheet
Cocoplete
2-1
-------
2,1
TOE OF
The of ihe will upon the activities wnderwiy
'facility.
The of (he mil be in large put by the
owner/operator 1st
Conducting
to eharieterize
Conducting studies to evaluate corrective measure alternalrvefs) to
releases
corrective
It &
2,2
Corrective action can by a however, to ca ses, it may '
be for two or more inspectors to The two be
In ai Inspection team are the and of
The of inspectors factors,
* of the (c,f., number of Solid Waste Units (SWMUt))
« Nature and at the {&§,{, well
at 10 SWMUs and excavation mil ai
' !
» of the jl
* for conducting of muUipyipose
with or
activities or anothei office or is involved with,the
conducted) "-.
2-2 '
-------
The of to conduct a uorreetlve action Iispeetion will v iff according to lie
specific and the corrective aelivlties The
be when for the (I) The
technologies, or being in the corrective action (2) The t %
at the facility.
The or in corrective dictate-1 he of
required the underlying or
specific involved In activities. The use of
as and of for nay
reijylre that the include of the EPA.Regiaoal
combustion inspector/expert, or an or
pr an individual in
who is of evaluating tie such
The or Influence the
bf the Inspection
team. For if the his a environment and t for
of ffoundwiter,« on the to
the efficiency of the remedy.
[ (Vote.- Uttae may fce Jfiws tfK impeetaf nay juurf to £twmA
the; If the- am not la
]
(**
Ac imftetof an,
2,3
to
ill
H to the of corrective it Thift may
background under other federal, or State, eavironinentol
as and For EPA ia«t The
will support of the for • facility. , f
2-3
-------
Tables 2,1 and 2,2, below, identify the of to action
and also provide additions) that may be tow EPA, or
program offices to assist in preparing for
2-i
OF
TO
Action AeiMty InWrniatloi
Corrective action orders, or
Current Conditions
Stabilization Evaluation Questionnaires
Approved for ISM, RFI, or CMI
RH, CMS, and CM
Oonstaiction quality
Remedy implementation and Jong-term
Quality project
RCRA report
Progress
Aerial Photographs
RC1A Part A and Part B applications
or iftfoflHitJon iiatmay
on and
on SWMUs, at the and
National (NCAPS) and Happening
doeyrneilatfon - ,' \-.
Z-4
-------
2-2
OF
-Sources'-
.'Jp, .ok the National Pollutant irge Elimination
System /DBS) the Air Act (CAA), md the
-.
CEECLA (PA) ind Site (SI)
Restoration Program (IRP) for of
CERCLA Ranking (HRS)
CERCLA
CERCLA -I03(c)
the of CAA, the Tone Control 'Act
and the Act (CWA) j
Emergency community, such as the Fire Department, may on spills
which occurred ai the
40 CM 270.100) that .may be
for and itnpoundmenis,
information points, ind tS» likelihood of
human to
Solid and
under 40 CFR 265,75) that
the prewouf the of each
method of and of
from
of
and the
Notice to tuthoriijr (required 4fl CPR 255,14), a 'that is by the
owner or within 90 «fafi after of a and b Seseriptions of
the and quantities of wastes in units of the 40 CFR
Part 265 j
The RCEA in {he of
the order, or for and on It
E|SO into the
2«5
-------
2,4 A PLAN Cl
Once the inspector has the of the.inipeetlon, the with
(e,g., attorney to the I personnel), and
icviewed all information relevant to (he facility, should prepanj »'brief plan
outlining the for the facility. The inspection should provide;n
framework for Identify the and of i of the
leans, and provide a for the to double all r< Jevant
inspection it the
2,41
The primary of the inipectto'p is to lead the inspection learn through \ the inspection,
The provide a Hit on
the preitispeetion of documenU and any with or State staff. It should
the and of member of the The be
in with the of the In a llfkt will it
to him or her. In general, the plan the:
« Objectives of
* Brief facility
» to be
Quality Project Plan (QAPP) and Plan (SAP)
« Health and-Safety Plan
»
« Schedules
An and in of an insr-iiion b-provided on 2-7 and 2-
8, The ECRA Inipect Ion ..Manual, is a further »i* my to
aid them In tie of in or for toformatJon on facility ijotiftoiiion,
entiy to the facility, an opening itaff Interview!, md review of records..
-------
V,
VI,
VII,
FIGURES
i»MPLl
I. QMtcftyei • The be and bj
ai appropriate (Inspection Members,
etc.). The objectiw! the
inspection It to (&g
-------
ABC
Observe tin! determine compliance with I
blerim/staljfeitiBi workplun
Observe and collect split smn»pj«
The ABC Electrie Cwnpiny site ii in on rattely
100 k Topin, Ohio, In operation «nce 1944, the facility primarily plijtie and
copper dtd The facility » In by residential,
ia«l conunericat properties,
IB 1988, BPA Issued an Administrative Conseiit Or«te whluli required ABC to sibmit an
(ISM) far of in Are! af
Concern (AOC) 1 ind AOC 2 ani to perform a RCRA Finllty and a Cotflellw
Meiiure J
Sol samples from AOCi i and 2 (from a previous investlftliOB condieieiiby
ABC) of at PAHs, and
levels of cailuni, an J chromium been detected in moniloring In 4vOCs I
and 2. ire "3Sfl to
-------
PLAN TOE
« Meetings- with appropriate (toipeciion menst^ra,
prefect manager, ORC, managment)
» An on-stte inspection
with Inspection and project took place on 2fl and 31
5OCXX. Tho on-site is scheduled lo begin on April 15, XXXX),
The on-site inspection will indnda:
» of wrreeliw
faelitf
» Observing
samples
« Conducting will facility
Hcallh and Safely to fee the will ily
with those in the In general, will Follow the ficiliifs
ipproted health and safety plan and the Occupational Safety •ad Health Administration-(0-
set fcrlfc in W CFi 19I0.120(e) tnd (f),
Quality AaatirBiice H§B jOAf gLiBAiiaalteml Anabsta Plan.(SAB
The SAP aaif QAPP So be the will«
described in the SAF and QAPP plan.
« EPA and/or State
» EPA toxieolagist
» of laboratory to be used
« Region Environmental Serwcc Division support
Field and film,
steel toed hard hat, ear and wit.
ecjoipmeirt In ABC j
|HA)
idled ii let
1,
April 15, ,
April 2fl,
EPA X wilt wjlify-fadliiy'of (verbally and ii witting)
Miiatt on -site inspection • :
Draft to
2-9
-------
Example
VIM
FOR THE ISM ABC
The OSHA Site Worker (29 CPR 1910,120) and EPA
require prior to adhiUes. The faUowiog.fbnnBt is d
wilh requirements, Training and ., tiifications arc in addition to this plan,
menlteni_
Prwjecl Mmnaaen
OP ACTIVITY
If any o£ the folowiBg k N/A; If covered in the
"IP",
Name.
Approxhrnile
of lit and Job tasks to be
of ito
of Hie lnsp«GttoiK_
Site fcy air or r«ifls_
«P of of
it of
2-10
-------
r
AND
OR AT THE
Fill in fa Am it or
Facility Manes.
«T Quantity
.Interim TSBF
, Quantity Gen
TSDF
List Waste Units,
ChemtcBJ
PrtciiPtliBB
Explwiwty:
Radioactivity;
Oxygen Deficiency:
Tonic
Skin/Eye Coniict
Head, and
Gog|Ies
_
Glows
_ "fyvA Cm et ai
__ Coverall
Cotton Covert!
Suit
. Owjrboots
„ Gear
.
ResMiltflfl
, Afr
,
, Air fTartrMgefType: .................. 1
"Escape Ma*i ff5)pe;__ __ _ _. ..... _J !
. ............................. ::: _ • !
far
Eaiitonunt
2-11
-------
2,4,2
gcneri
While the plan as tie framework for an inspection, the
as documentary that the his been out. There to no
for all activities, requirements for
from facility to facility. Therefore, a must be tailored for
Inspection, In a checklist, the rely on
action or order, the worfcplan, and'documents
and Analysis (SAPs) and Quality (QAPFi]
for-ISM, RFI, CMS, and CMI cm be In Appendix
checklist
B
corrective
e corrective
OS
i of
B.
such
Citation of conditions, order requirements, or workplai
be .with or set of questions. question be so that itiey
can be with a jw or «a Additional ie left at the end of for
noting observations and addilional that may arise during the tnspeciion. j
In Inspectors use with field
inspection Inspeetos are to use' the
intf protocols when1 preparing insertion
checklists.
23
FOR THE
In planning a CA ii is to what will be needej lo -properly
that ntty be for a: CA
[Include!
equipment (for eximple, .a camera), and i!
equipment, i |
Tnble 2«3 is a list of equipment thai ti to The list
is into and equipment,-
2-12
-------
2-3
COMMONLY IN
General Eqolpmfnt' " • • |
» Field notebook
« Clipboard
» Wilerproof pen or
* Inspection
» Lap top (optional)
» and film
» Video cimcorier
* docymeois
«
• Tape recorder
Equipment
• Steel-toed
• • hat
« Ear
*
. Air
* Air pyri£yfa§ respirator
appropriate
» Tyvek (iarric^de) suit
* Impervious
» Gloves {eheniol
* *
» or
trowels
* pH or
» mixing bowk
* Chain-af-eustody
» Sampling bottles, and
» Cooleis
* or Tefloi
bailers
» Air and Tenax ti
»
• eiiuipl
with
nt)
ibes
"went
wft jfe ^>r 1% ion nal
anil ito not tt* jwopo" *a^«J> . ! ,
2-13
-------
2.6
PREINSPECTION
The, purpose of a pre-inspeolion worksheet Is to serve as;
An intern*! check on performance of all necessary pr liaipeetton activities
i pi'eirtspeetion activities more
A planning tool to enable the Inspector to perform ;
effectively
dippartu
The sample pre-inspeotion worksheet shown in Figure 3 is designed
identirmg, assembling, and reviewing all relevant MaterWls prior to
Completion of this worksheet helps to ensure that the inspection w£
will the objectives of the inspection. This worksheet-
and be to and the
i o assist inspectors in
;tire for an inspection,
be' performed efficiently and
only m a fuMe
of each
:2-14
-------
3
Y
Y
N
N
Completed
N/A
N/A
Y
Y
Y
Y
Y
Y
Y
Y
N
N
N
N
N
N
N
N
N/A '
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
N
N
N
•N
N
N
N
N
N
N
N
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
of Activity
Contact Project Office/Project
f . •
Contict/coordtaate other
Identify and obtain all relevant (See tit
Approved Workpims
jes 2-1. aid 2-2)
Previous corrective action tospaaioij.reports
Health and safety plan
Permit or order
reports i
Administrative
EFA report
Olher (e.g,, ISM J
inspection plan
SAP
'Develop GAPP ;
Notify the
Entry strirtegy
reviewAtaff Interview?
- ' .On-site
Spill !
dosing j
checklist ' j:
Identify and equtpmftnt =
L
-------
I
2.7
SUMMARY
them In
are
Inspectors lave with and that i
for action Although i
aw to Ife OQ pj»f /far
iJteJr
ta fitr a
Define the and of the
an
Review
Identify equipment
facility and
2-16-
-------
3.0
This OR %-IVT to corrective i
ind how to
• w.U' activities. The chapter flpe
with a of an-site and actfviti
es, may
to any of a conective The four are to
of the RCEA
fjr
studies, and tmpIanenlitioBf. of
t key to and f rob
of a
The in this is tue it in facfility-
I
and to the
and in B)» nay also be to li a
inspectioit when ie^he encounters correctiw activities and/oij equipment
needs.
3,1
The OB-site of i in the
Inspection by the This p in
the to- be the tentative-order In w lidi vrili
be To ibef at a
tteff
3.1,1,
to Consider fer
The and with
In ire i number of aoB tSit are
to and for df *
• , :
3-1
-------
8 .5
a 8
i:m
-------
,°
.fl'
3- S"
'**"
— i
ll
£4
le.
tee
or
the
1
*
1
5
fes
p
I
I
i
-------
3.1,2
Split
This Inspectors for a
corrective action of not be
if as
preparation in iwpeeior be of the
sampling and
ies t,
a corrective
the
key
This is not to be a complete en 'and
or a substitution to aad procedures,- This
manual is only to tin I he types be-required
during a and to on the of
The Is i list of b on tie
of _ '
UJ. firf
/or ,
UJ5. Protection. Agency. 19%; ACIU GtalmMHifer Monitoring:
CuUence, PB 93-139350.
UJL Protection' Agency, 1 986. Kwrt to *«
.
U.S, Protection Agency, 1987, 4 Compete torn of, SufiifunS PteU "
VS. 1SS7. Site ouf
./Sir UtJeiymaul . !
U,S, 1991. fotf mirf Malysif for
VUelllf Compound* • .1
U5, Proteclfon . 1992, fto J /br
U,S, Agency, ,19)88.
OSWER. Directive No. 99384. ';
-------
of
of (soil, : air, and
gas), the of t may be
requited for These verifying compliinc
orier'or eoraJltlons, to eon Ron after;
to act as a of by the
f .with a corrective
to the
of a corrective technology, or to the of
a
3.1,22
Tools n"*'<
The needed to an effective the to
collect and and rjr for
Ai all that an
will be out in the «od (SAP), An s!
with the use, and for collection.
and 'type of sample may or
be
to t The use of
the yse
-------
of the wrong equipment, or sampling techniques can fend to the coljjscllon of
yEiepresentttive If an is unfamiliar with the use or application of a particular
piece of sampling equipment, he/she ihowld seek out the advice of others|:who have had
experience with-the equipment. An example of application of equipment-is ins use of a
peristaltic pump to sample surface water, or groundwater, for and^her nonvotatile
parameters. The use of the peristaltic pamp for samplinfvetetile.ofganles or oil And grease
' Is not Kcammended. because the potential for volatile stripping to occur i|t very and the oil
ind grease can to the tubing of the pump. Examples of iitnpliug equipment commonly ,
used are found in Table 3-2, |i
TABLE 3-2 ^
OP COMMONLY .USED
f- • '''.I^lMi;iSfiie{Siiittfe3isSB;f
Surface Water
Sediment
Gnwisdwatetr
Soli Wrter (itnsatarftted
zone)
Soil
lei Gas
of Slurry
*/;".» *"*•"*." - "-"s "«"","*? *. •*•'"?,' "*,«" ."",". .'iiia.,",, lfl'ms f,ES,:P« f'jSi'.jjJ:*/!-". ,;IV "•%,':*, ! .""""""."• '' .
\ ,««"?,„,,,*, i ,„ < 'i ; ; ,,", ,, s,^,i, i, .N^«liif«»ilsSSMB vt - -»"*-! i^".*" ** *•* -,-i, *^ * ", * "
yw.-^.-s.v™. j. •:--.ii:rt^::ii •• '^^r. ; ^£ :, Jt*QPlpIllMII|l&iM]tT » awfc^"i •••'•,. ,- ..,.: - • >' •"• - -
Ketnraerer sampler = "
Van Dom sampler ='
Weighted-boltfe catcher :
f eristaltio pwmp [
Dredge |-
Corer ' :
Scoop t |-
Beilers; Putnps: |:
- Top-filling - Air-lift puftp
- Bottom-filling - Suction-Mi;
- Thief - SubmeratHs bladder
- Gas-drive^ipbton
Lysineter
Grain sampler or sampling trier (disirtttbed samples)
Split spoon (wndistuitieej sampler), flowel, scoop, or eorer
Vapor extraction sapor sampler
Gliis tube |'
Bacon j
Pumps i
Weighted-bottle sin plere j
Kemrnerer or Van Dorn sampler i
-------
to -be .'
Air
Monitoring)
' •'] V :- •. ''":':J 'L; ;' , ::;j' ''.•:'.: '=
Colorwetrie
Pumps
Air ?apor
ionfaatloji' detector, meters, ana
r
per, plioto-
bthen)
M.2,3
Generally, an the
use the following
« The will all fi, labels,
and containers, !
» The will ask the to spit the
and that the uses to Mi of her
This is to of by
the and the or that the
is from, I
» "Hie should the iampltag; protocol usi B,
tie and to the b
and i •
• An be of the of tSe pies
* I
« Ait know to the and coifeotly fllj out fie
sample chaln-of-custcxfy, forms, find =
• An be In and
and
the . 1
» If the EPA Contract Laboratory Program ii to be fcmiiarjty with the
of the B may to l"he to
-------
The is required, under 3007(*)» to give the
in a the prtc t
If tny Is of the inspect i
a of the results of to the owner, oj
operator, or
to leaving the
or is to
•, or in
(ISMi) are EPA or
it B to control, or to human ind/br the
eawronnient from to prevent, or the further
are pursued, Extci'jiles of ISMs Include
a arouai . Bid
are to the or
of
tattled-water,
etc.
tliat
Implementation of ISMs'is to a corrective
has an owaer|bpa«ter prepares documents that
will be eonstructed, Implemented, thosje
EPA, or an for Once the
approved, the is respomtble for the
with to 3,5 of this chapter for
concerning Ibe of
will he of a owner/op through either .
fa, a
ffhow the
to
in accordance
infonnatkm
more
order or a modification. The or permit:modification, specific
to be by the owner/operator, of a 'torkplan, a
and a and si and
plan. Where is to to hui ian and the
environment, EPA or an authorized ISM be
under an or If a not a i he
regarding Mow and authority t is to ISMi, Also, if n
facility voluntarily to conduct ISM • " ,e nay , ; '
eivfrortBienlal/nioiielaiy of such • -iction for both EPA®ite and the
3-S
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3,3
The RCRA Facility fRH) ii the in the The
RFI is to the and of or
units, units, and "other source it a ai [d to alt
necesuuy to i Corrective (CMS) and/or
under the RFI can
8 (e.g» soil,
ground-water, sludge, sulwofl, etc.) to The
of the RH nay vary on the per
to of a or a or modification. An
or will to be 1 by the
owner/operator, of i workplan, a and sis a .
that
piy
plan and i and plan. Table 3-4
for during EH activities. of
to.safely Inspectors are imniediitely
to the of the
3-18
-------
1 1
.Ii!9i?;
K5
1 v 1 K * 1
I * K JJ '8
M a S H s
08
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ih"
a I H
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3,4
A corrective (CMS) is a study that Is designed to and evaluate
for the of of fit
the The of for the part, is a pap
exercise. As of this however, EPA often-wD! or to
conduct treitaMitf to the of consideration'*
may tt as pujj
of the
Two types of treatablity may be as of-a CMS; and pilot-sea c,
tfeatahflfty of a usually
are in a laboratory, usually involve-applications, of a
.on • Pilot-scale treafabllfty
usually me at the owner's or
extensive of the-waste and the unit, TibJe 3-5
common CMS activities that for during
inspection. of may to
considentiotu. Inspectow are to' the
of the
3-23
-------
-------
3.S
conduct Jag a CM! inspection, in inspector should familiar wit! i the
being or as part of tha The
the CMI workplaa and (for impterne tnd long-
tern maintenance and and to v the
workptan requires the use of a technology. Once tie Inspector his A 'termined what
are required, the technologies, If
TKe also with the activities for
that are In the for the CMI. Tijbles 1-6 lists
types of corrective to aoi Idea :
need to look for or encounter the fatpection. af
may resolution flue to considerations, Insf should
are immediately brotight to the attention of the' •
e»n find Information on the
UJS, Environmental Protection Agency. 1989. GuUt to
for WOSK at Siia, EPA/54Qffl-89A>52,
U.S, Agency and U& Air 1$93.
U.S, Protection Agency, Ws8, TedinAffi i'r
a/ Jflllr o«i . \
far
Ritneiiai a
U.S. Protection 1985. . Hm&aclK
SOtt ,
UJS. Pratection j%gen«y, 1991, i •
ami la
3-2S
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4.0
4,1
"Hie that on the of to
or the CA be in i way
that-allows the officer {EPA or lind
to use of
• • . •
An report and all
I In i aai To
this objective, ihe in an report be
» Accurate • all be .and based, on
« - In' the-report be. pertinent to th| of the
" . .
* - the of the report be snbstantttted the
of al s' r
There »re to report ire
• * the and is
needed In the report . . 1:
• » In i («*.§.,
. i '•
« (inch is, ibe order,
or EH to ptoperly jp»e so the
CUB
» Write the narrtlife in an effective
.J
4-1
-------
4.1.1
Informatton Collected During the
A "of {e.|,, tctton or conditions,
etc.) be the report to the
and and to • to the
IB the feport For the or conditions,
will the fot violations. Text In the RH worfeplan or RFA can
provide factual on the
ifld SWMUi.
/41.2
the be in for It tp lie -
•report's The all the
•and provide captions. The of (be and
laboratory to be as in the report, tad oth
be and for to tie and cot
w
slould
be to give (if In the report
4.1,3
Tie a list that or that
(lie the For if the usei
of the corrective order or RFA, as of the tost, the
* Each-item.' that Is In the should
be * (such 11, XYZ Inc., 1986, RCRA? of ABC
Companj), to in any are tie author(s|rdate, and=title, The
final list as part of tie A of
in the is (hat ft lie of the and
for iflfarnriatton. • j. • i
4-2
-------
4.1.4
Writing th«
The focus on obtained the iaipectlon. To the
narrative of the report be written and and avoid
conjecture, When the the be but npi any
facts, or Finally, the proof and
the report For tncj
4 an for a
-------
4
A. and of
I,
C,
D,
E,
F,
G,
Facility
Telephone Number)
Facility Repre
Numbers)
or
Company, Title, Numbers)
of
Coordination by«{ of
report to.,)
(brief of the
or SWMUs relevant to the of
the
II. . OF
• I
A» Description of activities !'
at |h« site i
t
B, Activities by the
C, Dili Interpretation, if
HI. 'AND
APPENDICES
A.
-------
4.1,41
This of the Include a brief description of the purpose of the
Inspection, the of the the and of tie
of facility and a brief facility description.. HIB majority of this information
can be from the
4.1.4,2
of Corrective
This of the the following questions: what was 'inspected; how It wi
examined; and when it was of this information will be from the
inspector's field (if and The
references to appropriate when writing Ibis
Violations or Deviations Front Practices
4.1,43
This of tie report any deviations by the facility the
discovered the Any be aid to (he
of the corrective order or permit The'inspector
note, for any deviations from the owner/operitor'i workplin, ni jplfog and analysis
or tie joistmctlon plans,
health and plan, reports, or otherwise upon with or the Agency), If
many violations or deviations tre diieovered, the tnay to ase a to
tie For the hasr
at • locfttion specified In the The
why the wai ; • • j
42
Dcxsunteflfiff of the inspeclor's and (He
report's A report b not H tie [
4-5
-------
Documentary support
42,1
Photographs
Field
and
Maps
Correspondence
Checklists
Video fJocutnentatioB
Photographs and
Photographs and are the
The and the of is crucial to supporting liny
violations or All be numbered the, time, dote,
orientation, md § brief description. All photographs should be with (lie narrative
in the report. be and be to allow
reconstruction of the that occurred during the Inspection,
4,2,2
and
If during (he inipection, the incl Me the analytical
the report as support. The
relevant sampling iflfontnalton, such as tie location, type and aijfllytei. In:
addition, a location should be included in the report.
4,2.3
Maps
are in thai occurred the
may be as SWMU In the RFA or IH
4-6
-------
workplan, and modified to ill All ihoyld orieatatton, and i
key or lejend of
42,4
Correspondence
Copies of any correspondence (e,g,, notes written from or i
or as part of an and In the report-
Included in the supporting It fa the i II
' to during the and this in the The
avoid cenjeeture in documenting statements, and the
conclusions in the
, be
opinion, or
42J
Checklists
Checklists are set up In a with a eotymn the i
(such as a procedure) and the fa fin Is.
provided, adhered to, or not applicable. during lie are
the as an or in the report
of
4,1
TO THE OP A
Once a corrective report has completed, will
initiate a number of follow-up activities. These may include:
to
of the to or State.
]
' i
of the to the and (e.g.,
Stalls 1
of the in tie flies for the EPA or I
4-7
-------
The For the use of t corrective action will vwy within EP,
Stale, agency, Impedes should to Regional, or to determine
if any further technical or enforcement actions may be required.
or
4,4
When for and eondueliig
in that the of the may
be to an For
all the on-stte and prepiring thlp
action report. Any or during the ihould be
technically correct accurate. , I
Issuance of a
of a
Issuance of a
Initiation of a judicial eMi
of a
Although tie'type anil of to the will
vary, an a a* if will be
to support any of the j
-------
4,5 SUMMARY
Inspectors should focus on all of the foMmwp «* which tl*
following;;
Follow-up Aci""'fa«
. Correction AtttoB
Reviewini and infonttaiion and during prt-
inspeetlon report
Writing a concctive action inspection report
documentary for a corrective action report
Fotiowup s«* of corrective action report and
discussions with appropriate peaonnel
4-f
-------
A
-------
\
1914, OWES
; !: (OWRSQA-l,May,
:0.S. July 15, (50 Ht
i
1986, Assurance for
]
0»S j Agency. 1CJM Corrective >»
U.SJ
U.S.J
U»S;
1986.
i ;:
1, (|2 H8
, 1988. JM3M Aliw
May 31,
1989.
I9S9.
i ^ ' : ;
: t : -
My 27,
: ' ! Corrective Action fir S0IU ai
^
! 1991, flip JW3M
I !
-------
SJlEnvironmental Agency, October .25, 1991, (L
Directors), ttie Aal
ij.' Agency. 1992. 0/0JBJ «i Of
toRCM Corrective Aftion,
i 1952,
'
S|j Agency, 1992,
i;, Agaicy, 1992. £te
-------
U.S.
U.S.
U.S.
U.S.
U.S.
U.S.;
u,sJ
U.S.!
U.S.;
Agency. 1986. Corrective Action
II of 1986 Jferwr
1587,
i
198?,
I tn-HeaaaafdoHS Waste Consent Decrees,
Agency. 6f e«f
on
]
15, 1993,
Agenef. 1918. Use of Section JOSS^j
or No. 9502JOO-7,
' =
JSPO Policy.
" i ; :
OR
'
I
•U,S. i If S3. J?r |)f
'; asrf i | | ;
Agency, 1984.
1 • | :
U.S. 1984, Iteny
:i
U.S. 1985. «« qfSuijhci. Tmlt
I i
-------
U.S. Agency, 1985.
SIW
U.S. 1985, » Emmjttottsjrom
U.S. 1986, 0jt
|
ii
U.SjJ&wironunatal Agency. /&
7
1987. J?C3M Corrective
I
= U.S^Environniental 1988, Modeling-Remedial Actions at
'•••
U,Si, 1988, Guide/of •
,L
U,S; 1989,
i
U.S^ 1591,
,; ,
U.A. 1992. a«< Options for'f/ST
t
U,|, 1993.
I .' j ;
U.i, and U.S. At 1993,
4 =: ! j
0,1, 1991,
' ': i • . ! i
UJS» Agency. , L
j I ; _ ;
i • 4 i ! : J
-------
.
U.S. Agency, 1989. »
;;; « '
U.S. aad U.S. Air
I
-------
U.S. Agency, 1987.
Pstf /; XCL a«f EPA/530/SW-S7/017,
:
Agency. 1987, Graun4watert
••
U.S.: 1988, Alternative Limit
Fort Ik OH Com
. •
U.S. 1991, jbr|i/tt
• Inimllmlan of Ground-Water Monitoring Welk,
4
S0ii j •
U»S. 1984, 0/ltt-Place
$f
U.S. 1984, of la-Place
/6^
! ' |
'0,S,
No, !
• ! I '
j. ,: 1 i
U.S. Agency. IfSS, to Sell
. jjtew JWM
i. ,:,l*i
' I ;
U.S. IMS, W
j I
-------
U.S. Agency,
U.S. 1585. BK' Endangemern
No. |!
U.S. 1985. Permit Applicant's Manual for
KM, 3019* OSwER
' ' =
U.S. 1988,
v |i
U.S. Agency, I9S§,
2.-
U.S. fitt
JfVirrX.
;
U,S, 1989.
Volume 1: Part B.,
. "
U, S,
!»• Fa
PB92-96S340.
/; /tot C, •
AND |
lf,S, 1980. a«f
I
U.S, Agency, 1985. J%W Operating.Procetbifesfor
K. No,
U.S, Agency, 1985, Wrfrf Standard'Operating.
17. No,
-------
PB9I-213850.
U.S. Agency, 1985. Field Standard Operating Procedures for
Air Surveillance «8. No, 92S5.2-OJ,
U.S. Agency, Procedures for
of a Site Plan IS, No,
U.S. Agency, Dmiument:
Quality Assurance for Waste"Land Dispo'lal Facilities,
No, 9412,00-3.
U.S. 1986, Test Methods for Evalufyittg Solid
U.S. Agency. 1987. 4 o
U.S. Agency, 1987. Data Quality Oiijecfivai/or Remedial
2, No,
U.S. Agency. 1987, £>«jt Ste fl*
U.S. Agency, 19SS, Gift?
No,
1991. Soil Sampling and Anotysisjbr Volatile
Organic Compounds,
U.S. 1991, Hnrrt rt«
-------
1
FOE ISM, WI, CMS, AMID CMI
-------
ISM
IT
This example interim/stabilization measure* inspection checklist ii tor in interim
measure eonsisttei of: collection of soils for analytical lestieg to determine ihe of
contamination; excavation of contaminated'soils; loading of the ent^ trucks for off-site
disposal; completion of confirmatory sampling; and backfilling the area with clean soils.
All work is to be in accordance with a health and safety
which requires lir monitoring, level "C* personal protective qquipmeni.
dust control
by the facility,
(he use of
She Preparation Activities: Has ihe
the following procedures, in accordance
with the approved wotkplan?
a. Arc support facilities provided, as set forth tft the
approved workplan?
b, "Has the vertical and horizontal of ibe irea(s)
iybjeet to removal or excavation
and delineated, as required?
e, li to the excavation or removal
restricted, as required?
d. Has the site cleared of* as to
facilitate excavation and backfill operations!
e. His the (EZ) identified?
i His the reduction (CRZ)
tdcrtlfled?
g. Has He (SZ) identified?
b. Ate syrface-waier controls to
place?
i. Are soil erosion and dust prevention
in pliee?
j. Are and
as required?
k. Has tie facility a treatment, storage, or
facility for and other
of deeoniaminitton?
I, Hwe utilities notified of the removal or
excavation, as required?
Q P
Q
Q b
Q Q
Q a
a a
Q
a
a,
a
Q
a
b
b
b
b
b
b
-------
ISM
(cont(nitd)
Nffl Cojnpents
2. Excavation and Removal: Are the following proeedyres
being conducted In with the approved
«, Are the equipment arid crew in the
workplan being
b. Has the area been excavated to the required
horizontal
c. Is the excavated to the required depth?
cj. Is air monitoring being conducted continuoysly
during excavation?
e. Is equipment being decontaminated before transfer
from removal and excavation to another?
f. Are soil staging being us
Are containment measures taken to
contamination of clean areas?
ii. Arc ranon and runoff control in
place?
§. Aw the areas of eicavitfan ind removal covered
when removal operations are not underway!
h. Is the excavation or fenced?
of Off Site: Are the
following procedure! by the facility in accordance
with ihe workpltnf
a. Are the to to
do so in ihe appropriate
b, Ii as by
40 CFR
c. Is waste lined and covered as required it is
the site?
d. Are is required
they the
e, Have ihe appropriate environmental in- the
state receiving notified, as required?
f. Has the royie for the
identified!
-------
ISM
{continued)
g. Have the waste removal trucks been weighed (on
site or off site)?
h. Are the vehicles transporting the being
as required, the hazardous
hai into the vehicle?
4, and Dtta Maniienient; Is the
the following lusks, in accordance with the
approved workplnn?
a. Are daily field logs of the ISM kept?
b. Are the for the
the being kepi?
c. Is ihe that the
provided correctly
d. Is ihe facility receiving lie appropriate of
ihe manifest?
e. Are daily waste removal ind excavation inventories,
kept?
f. Is the regnlatory receiving the
documentation required by Use aeiiop
plan?
5. and Is the the
following IB with the
workplin?
a. Are workers at the site conforming to the
and
i. Is the protective
ii Is alt lir monitoring soapleted?
ilL Are the required
procedures
jv, Are excavation of live utility lines
antf (for example, gas and
and tanjcs}?
Ms
Q Q
Q a
a a
a a
a a
a a
a Q
a Q
Q Q
Q a
Q a
a a
a Q
Comments
-------
EXAMPLE ISM INSPECTION
''continued)
ft. Siimpb Acquisition and Laboratory Testing: !s the
fiicility performing the following activities, In
accordance with the approved workplan?
n. Are confirmatory samplw, being collected with the
required frequency?
b, Are approved methods being used in collecting
samples?
i. Soil
ii. Air
ili. Water
c. Are being handled and preserved as
required?
I, Soil
H. Air
iii. Water
d. Is all required documentation of sampling being
completed?
i. Soil
ii. Air
HI. Waier
e. Are required ehain-of-eystody procedures being
followed, including analysis for required
parameters?
f. Is sampling equipment decontaminated
properly before transfer one sampling location
to the next?
g. Are jaraplei picfcaged ind shipped in
accordance with procedures in the
approved workplao?
h. Are sufficient and appropriate quality control
sninples being taken?
Q P
Q Q
Q Q
Q Q
Q Q
Q Q
Q Q
a a
a a
a Q
a Q
a a ,
a a ,
a a .
Cam men Is
-------
EXAMPLE ISM CHECKLIST
(continued)
Mo
Spill Control; Is the faeilily implementing the following
procedures, in accordance with the approved workplan?
a. Are spill control equipment and supplies In place?
b. Do personnel at the site have documentation of
(raining in the implementation of spill control
procedures?
a a
a a
-------
RFI INSPECTION CHECKLIST
The .-tnmpte RFI inspection checklist has been developed for an inspection o
RUiiuilaciuring facility that has been required to characterize the nature and
contamination resulting from releases of various orpnfc and inorganic comtn.
scwra waste manaiemem units. The RH workplao that the facility
groundwmcr and soil sampling. The also prepared a and
sampling activities. '
a chemical
of
coiutitifents from its
conduct
>lan for these
1. W,;t Drilling Procedures; Is the facility implementing
the following proeedyres, ai specified in the approved
workplari?
a. Has the facility installed wells it the locations
specified?
b. Has the facility drilled all boreholes to the required
depth?
e. Hive the casing been to the required
depth?
d. Was the facility used the reqyired drilling
procedures?
e. Did the facility keep borehole logs, as required,
during drilling operations?
2, Well Construction Procedures; Is the fadiity
implementing the following procedures, in accordance
with the approved workplan?
a. Is each newly well equipped with
and casing stringjf
b. Did the facility use well screens of the correct
length and diameter?
c. Did the facility use the correct slot
d. Did the facility use the specified filter
material?
e. DM ihe facility use the specified well screen ind
material?
f, Has ihe. facility Instilled filter pack'material to the
Draper depth?
g. Has the facility placed tenioniie at the
proper depth?
Yes Ng
Q Q
Q Q
Q Q
Q Q
Q Q-
Q Q
a .a
a- -a
a Q
a a
a a
a a
Comments
-------
RFI
(continued)
h. Has the used the type of sealant at
the proper
i. Has the a and a
sloping concrete pad at well?
3, Well Is the
the in
the Ian?
a. Has the the well to
methods!
b. Did the facility pH,
and temperature during development?
c. Did the facility the required of water
at well?
d. Did the well In
with procedures?
4, Aquifer Is the facility the
In with the
wortpltn?
8, Did the facility
to Ike procedure?
b. Did the we the and
•c. Did the
in the weB,
5, Ground-Water b ihe
the in with the
- and pSin tad
(QAPP) In the
workplan?
• a. Was the of
well the
b. Did the pH, aad
well purging?
c. Did the all
to procedures?
Q
Q
Q
Q
Q
Q
a
Q
Q
a
a
a
a
a.
•Q
a
a
.Q
a
a
a
a
a
-------
6,
RFI
(continued)
4 Did Che facility the for the
organic and
e, the used In
f. Was a!! sampling
according to
g. Were md for
to procedures?
Soil Drilling and Sampling; Is the
the in
with the workplin?
a. Did the nie the In
drilling boreholes?
b, to the diameteii?-
c. Were collected at. required-depths?
• d. Were with the required
equipment?
e. Has the a drilling log, as
f. Was all
to
• g. and to
procedures?
h. Were to
7, Data Dfd the all
iles, as under the
workplanl
S. ana Is the tie
as in the
tnd plan?
• •. Are drill rigs at -the
fa. Are the of the as
required?
Si Hi J
Q a ,
Q Q,.
a Q .
a a
a a
a a
a a
a a
a Q
a a
a a
a a
a a
a a
a Q'
-------
RFI
(continued)
No Comment j
c. Are air
wearing-respiratory protection, as
d. Are and
maintained, as required?
the an
plan In as by the
approved workplan?
Q Q
Q Q
Q a
-------
This example CMS checklist has to (1) ensure all of a
inspection required of a facility have completed and (2) as doraroentatior; oC the
results of an inspection, A corrective action order stating and i workplan
by the facility - with its and (SAP) and qi lalii
insurance projeci (QAPP) »were used in the checklist, Actiwties currently
underway at the site a of an in-iftu vapor ertraetion jThe
to comamtatted groundwater, Treated is
-------
CMS
(continued)
h. Chain-of-custody procedures
L of
3. of in-Situ Vapor Are the
following operating parameters recorded as
in the
a. Air flow
b. Total of
4, of the Adsorption Unit: Is the
facility Ike unit to the
ia the for the
procedures!
a, -Malnleiaice for of
t», of
5. Sfld Is tie facility
protective as in tie
and plan?
a
a
Yes No C
a a
o a
pitmenls
a
a
a Q 1
a a i
a Q
-------
This example CM! is on the requirements that must be
required to instill a cap on an abandoned landfill. Specifically, the elements of tb
drown from the requirements set in the workplan, the
specifications, and the construction quality assurance plan (CQAP), The workplar
for the installation of a of compacted soil, a flexible liner, a
and filler layer, and a layer of and vegetation.
1, of a Layer of Sol; Is the
facility constructing the sell layer In aocordince -with
the in the
and and CQAP?
a. for clod slie
b.
c. Thickness o£ soil
d permeability and specifications
e. Moistyre content
f. for 01
the of Ufa and
g. Types of soil
I, Attoburg
i. Soil
' If. Particle size
h, Compiclioa
2, Installation of Membrane Liner (FML): Is the.
the in the
lid and
CQAP?
a. Thickness of FML
b. Use of required
c» for seaming
d. for of
e, for anchoring
Q
Q
Q
O
a
net by a facility
checklist were
drawings and
, specifically
synthetic
Yet Ma
a
a
a
a
a
a
a
o
a
Q
a
Q
a
a
a
a
a
a
Q
a
a
o
a
a
-------
CMI INSPECTION
. that
This example CMI inspection checklist Is based on the requirements
required 10 install a cap on an abindoned landfill, Specifically, the eleiticnls
drawn from the requirements set forth in the approved workplan, the
specifications, and the construe!fan quality assurance plan (CGAP).- 1
ailled for the installation of a of completed soil, a flexible memNane
drainage and filter layer, and a layer of topsail and vegetation.
must be met by a facility
of the checklist were
c sign drawings and
workplan specifically
liner, i synthetic
1. Installation of a Layer of Compacted Soil; Is the
facility constructing the soil layer to accordance with
the requirements specified in the approved workptatti
drawings and specifications, and CQAf ?
a. Requirements for maximum sue
b. specifications
c, Thickness of soil
d permeability and density specifications
e. Moisture content
f. Procedures for placement, including restrictions on
the placement of lifts and required coverage
g. Types of soil
i, Atterburg limits
ii. Soil classifications
iii. Particle size
h. Compaction requirements' .
2, Installation of Flexible Membrane Liner (FML): Ii the
facility meeting the lequircincnts specified in the
approved workplan, design and specifications, and
CQAP?
a. of FML
b. Use of required material
e. Procedures for seaming
A Procedures for sealing of holes
s. Procedures for metering
III
Q
Q
a
a
a
a
a
a
Q
a
Jffo
Q
o
:a
b
a
a
a
Q p
Q p
Q • :jb
a b
a a
-------
f. Use of respired procedures tor placement of FML,
required
3, • Initailation of Synthetic Drainage and Layer: Is
. ihe facility meeting the requirement! specified in the
' approved workpltn, design plans and specifications, and
•
i, of, material
b. Type of material
c. Procedures for including required
coverage
4 Procedures for anchoring
• c. Permeability requiiemenm for synthetic drainage
layer
4. Installation of Layer of Topsoil and Vegetation; b the
, facility meeting the following requfremfents in
approved workplaa, and speet&aifaas, and
CQAP?
a. Thickness of layer
b. Type of soil
c. Procedures for placement, required
coverage
d,
e. Type of vegetattoa
f,
g. Fertilizers required
h. material required.
Yes No
Q Q
Cormenti
Q Q
Q Q
a a
a -a
o a
a a
a Q
a a
a a
a a
a a
a a
a a
-------
c
OF A
AT THE FACIUfY
-------
c
or A
AT THE I
The the activities and of a eorrecjtlve
at i facility that is a RC1A (KM), B
of the that in the This
study not an actuil facility. it is on inform|tion a lumber
of at the country,
This is into four major C.I provides background
the C.2, on the
and the the pMse of the
C,3 the activities performed and Information eoleeteqi (faring the
at the in lie of a by the C.4
the that the and of tie
C.i
The i description of the facility and a of its RC1A
the of its KH work and tie of
RFI
C.I.I of the
The Trucking Corporation Trucking)
at the of trucks and Waste
an EPA POOS was it the :*
The removed the in 1985,
-------
C.I.2
Corrective Acttoo of the
A RCRA facility (IPA) in 1986 that of and
hazardous conitltuents had or could at
(SWMU) it the facility. The the of two
and i bay it which the were into trucks.
of the in the and soil and the
the- the for tie RF/L
of a with EPA in 1987 to
that The onder required the facility to
an RPI tie of of ft \ May 1987, the
'of the OKter, the an RFI to for Later
in 1987, the the woifc plan. The
a soil gas survey, of soil boriagt, of
weUs, of and for
In October 1§S8» Tmcking
that the
Bed to EPA IE RPI
tie KH a 1st ejf in the
RFI. the of soi tt tl« of
had ftat on soil
it He bay was Prom the of EPA
that of of the and its
tie wu
The the in a RPI ptm to
My 1990, EPA the RPI to 1990. =
-------
€.1,3
of the RFI Work
to be under the July RH work plan
» Prilling of soi to the
of the
€.1.4
ovciburden in the of the bay tod to the of
. ;
of to the of the
in the and the
to on
of the
to the 01[ the of
)
of RFI at the of the
of the EH WHS to
to October
1990. w the on October 15, 1990,
to soi and
the week of October 22,1390.
POM
The foUawhi tie in for the at the
(1) tie (2)
the on tie (3) the and of
the (4) the aad (5) the
:'
-------
CA1
can be on He (see D-l)
C.2.2
the
He to be follows.
» -
•
» RFI plan 1981)
* EH
» SEI ptao 1990)
» by the
* Tie (OH) the
of !
the of the
of the of Smfth'Thicklng Is the ftcffi^'s
the aid iip the facility's'Ji% KFI-wotk.
tnrf and with the to this 1987
The of the be to and to;' _
• for sott and aid of
» for
* for and
-------
CJL4
Procedures for development
for the and of and for qy illty
and of custody
for
of
to the of
contanlftitiofl
for KH activitwis
and
The
The fol individuals up the
7,
Doyle, 7,
David of
(MDNR), Field
CJ.S
The pbo and Ute CM be
on the C-2 and C-3).
-------
CJ 1
ThislseetlSo the by the the
at Smith Trucking. The is presented in
of field (see C-4),
C,4 I
The
of th'e Ins
a corrective inspection on the
(See Figure OS).
I
-------
C-l: for Action
I Trucking
Y N
Y N
Y N
Y N
Y N
Y N
Y N
Y N
Y N
Y N
Y N
Y N
Y N
y N
Y N
Y N
Y N
Y N
Y N
Task
Contact/eoonlinate with Regional and £
offices
? project coordinator
DNR
RH
RFI
Monthly
SAP
and
De¥elop
it
|tate
for
for M
! , ;
-------
C-1; for Action ton at
i
Task:
Pre-tnspectton Task
of
aid
-------
- BH
Plan
THE
plans
Mid with approved 1FI work
Observe of
for RFI
and
•The Trucking Tracking)
it tie of ami vehicles. an
EPA code'FOOS waste, was it the futility in two underground'waste
tanks.. The fas in 1985, A RCRA {UFA) in
ibat ani had or
at (SWMU) a the The SWMUs
were the of two tanks and a Bay at from
the into Bucks, of'die paint injthe. surface and
sol! and flw die the visit for the UFA.
of Trucking a with EPA li 1987 to
that "lie the to
an MH tit of of RCRA. In Miy 1987, M of
the order, the in RFI work to EPA for ii '1987, {he
facility tie approved,work Tie i soil gas
survey, drilling of sofl borings, of wells, sam.jllng of
arid for In
to EPA an RFI report that lite of the
I
After the RFI report, EPA a list of deficienciei In the .RFI,
tie of soil at the of the two
bad that t» soil at die.
.truck bay was the Elf A ttiat
of upper portions of die aw ft»
toe Tie the a =
RFI wore to BPA bi July 1990. IIPA fte -
RFI plan Ja 1990.
will be by; i
» »d EPA ffle§ , I
* with OSC»
. |i
» Ctondyctlng in on-sfte inspectioi. .['
-------
-
The and met on 10, 1990, The c M
is to on 29, 1990, The on-site Inspection will include:!
* of current-corrective action being with fieiiliy.:p
« Observitlon of procedures, of Investigation-derived wsstei, and
for RF1
* Observation of aid
« Closing with facility,
j
snd to be the will with
in the and r
\
The SAP awl QAPP to be the wilj with
in the SAP and QAPP plan, . =
R«
-------
C-35 Ml for
I, aptLSamaliig SoiLBortne Procedures
Xa Mi
i, 36 loil to
a I.D. rig, D O
b. Soil 3«ineh
in tn
Uner, which was 5 feet In , D D
c. Soil at of 6, 16,26,
and 40 feel D D
d. A was to split the
liner, D Q
e, A 10,0 electron volt of a
(HD) was slowly nin down the
of the He PID was-
in the log aid a was collected •
at that in to the at 6, 16,26, " ,
and 40 feet. D
P
II
-------
C-3: MM for
f, lit soil were Into the
twa 40-MI vials for VOCs; one S-oz
Jar For and
Q
D
g, Sampling gloves
and activities. These
it D D
h. 411 was by
to use, AH
borings, D D
i. AH wai bj>
with t
and was
with water. D D
j, VOC and The
sample the
wbldi WM thonm^ily D D
12
-------
C-3; for
o. at the
in the to Ae of
in the way and
by (he and for thft
as its primary D
k, AH immediately in ice-packed,
for to the laboratory, D D
1. A duiin-ofeustody WH filled out and
the and
to in D D
m. Trip by tie Ubonuoiy and
ill soil
to, be for V0&; the trip wai to b«
for D D
a, The
daily. was to
be for VOCs, semlvolatile orfinics, and
DKtBlS.
a a
p
13
-------
C-3; RF1 for
p, A was at 59 of lu
of locations tad for all
tor the O D
q. The wss logged OB log following
sampling of the core, D Pr
t. Soi i
sluny. D Q
s, Drll were in yellow
- O O
t, A was under the racks the
of soil
that Ml on this plastic of
with drill cuttings. D D
u. The In t with sh •
pet side and on D D
v, Alt was the of a
who the on an
exaniiitt»8 of and P1D reaJtap, O, O
-------
C-3i Rfl
w. The of the XYZ was
with the pro. If the HD read
of 5
the protective by
the aid plan was He WD
is ihe was an the
log,
2, Monitoring
n D
t, two-well were it the
In the RF1 • D
b. Wke-line was to drill
The tale was in
roller lit to to O
c» "He to» of 50 fat
D
d. Its were to t of ISO feet
" D
Q
-------
C-3t KB for
e. A ttn-foot-long, 4-iaeh 20 slot
PVC was tor the
string, A flve-foot-Iong 2-inci diameter, 20 slot
PVC will was in the D
f. He and were by A
minimum of two feet of prltets.
a a
g, A PVC cip was on well prior to
D O
h. ioth the and were constructed of
PVC which wii the as the
screen, to the A pack we
ta a of it two feet (be
top of the and was by approximately 2
feet of A WU
on top of the and to the
was with i
and i pad, D D
Tie wa»
cleaned.
a n
16
-------
C-3t RBI fur
J. Qoee tie monitoring wells tic vertical
aid of the
to to a USOS The lop of
Che PVC tie was was
permanently marked. D
k, AH walk was md Ae supervision of t
who the wells on
of and
Well Sampling Procedure
a, the cap was and
the off its well
with a calibrated PID,
a a
b. Either three well of was
well or the well we dry to
The of was on
well data D
Q
-------
c. The pH was with buffer
solutloo of pH 7 it well ste to
day in which would be
the pH was
of pH 4, 7, and 10. These recorded
on D D
d, and pH
dyriag well and
-------
C-3s RFI for
L
g, The water uid rinse water were placed
in •
Ground water,"
D D
h. "Hi was gently into the
when the VOC to
and loss of VOCs, VOC first.
The senuvotitile and
filled next, D
n
The-samples properly preserved In
with the (I) hydrochloric tcld was
to VOC (2) was to
and (3) ill
to coolers for to the
laboratory.
D D
j, A chilfHjf-ewtody form wu filW out awl
, the ad to the
laborauiy, O
D
19
-------
€-3$ RFI for
fc. The gigundwater well were
for VOCs, aentivolatlle and
and 6010,
respectively), The that
In fc work used.
1,
during and
gloves it well.
in. Trip provided by the laboratory ani
Ml water to be
fttr VOCS; the tilp was to be analyzed
for Q
n. Tie were
daily. WB to be
for VOCs, and D
o, at He
in tie to the of
container, in the way, and bf
the and for tie as
ite primary f ample. D
20
-------
C-3«* RF1 tor
p. A wis collected at 556 of its total
of and tor tit
for In the sample, D
a
4, Record Rewiew
a. The the
for the past 3 for by the RFI. O P
b: The facility ill logs tor soil and
well for RFI activities.
a a
c. The facility til
with and provisions of itie RFI work ptai,D
D
ct, Tie facility ill RFI
in 75 80 of the If 8? order J3 Q •
e, The JM was ia with the
In tie RFI work D D
21
-------
C-Si HW fur
5,
a. All Involved Ii the 1FI had the health
and and and i
to Ait O
D
b, All involved in.the RFI lad 4Wiour
and Act (OSHA) aid
(29 CPE 1910, D O
e, rigs and
D D
d. A WD was to the
of XYZ Invasive activities, D D
e. AH in the RFI involved in *
that was In
the RFI D O
f. The protective equipment in the
work was by ail personnel. • D D
22-
-------
C-* tor Corrective if
~h
1
•3
»
d
i
i
mm.
-\
i
\
•ff
*
1
X
I
":
1
'
4r
/ :
23
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-------
C-4: Logbook tor rf
•4 I
1 :^ i^^i^ J * j
i
* , «| i •««• **E -"i ; s*! #i
-
4,
3i
25
-------
C-4: for
-------
Corredin< Action oC-.Squtfa-.Tnicldng
/ r t if f f r j; i v f
-------
C-4; Legtxwk for •.£•
zs
-------
€!-* Notes'for
./'•t,lj ,'J
-------
C-Si Cornettre far
EPA ID
for
U.S.
7
CITY,
by
U.S.
29, 1990
30
-------
C-Ss for
1.0
2,0 . , . .
3,0 SUMMARY OP
3,1
3,2 OF RFI
3.3
4.0 OR v_, , It
Append ices
Photog Log (noi pro* In stoily)
fa to nut In
In C-4 of
Confidential claim (not In swdy)
Monitorinf well (not proridei In
31
-------
C-Ss Cun-eeilve IBP
Li
AND Of the with the
and in the facility's July 1990, RCRA t'Kii and
with the In tfia 3i, ]''»S?. Tke
included of and review of records.
West
Telephone number i» (417) 555-12 k Figure 1. fa a
location nip for the facility.
FACILITY toy H; !and Md and
of XYZ
pPA Oeolglst), and David Julwctn prtvlromifinial wiih the of
(MDNR)).
29, 1990
2,0
The M of-
and As a M the has
inn the wd of
in the soil anrf the the A RCRA ti
1
-------
C-Si Comcttve for
FU
tdM » KM J««» MM KX* MM HM
r=3
1" <• UNW
iRUGXiw
:
FACILITY ISCAflOM
33
-------
Figure C-5: Comctirc Keporllbr
that of and hid or
at at the facility. Tto
and i bay for'titt the
Into The of (he units we on !
In 1917, the Smith Tracking facility a wltfi EPA to that
past Under the of 'of HCRAf the
the to an RFI, In May 1987, tie if the'prder, Jie,facility
an RPI work to EPA tor approval* *Tta the
plan In 1987. The a soli gas atamy,
of wells, grwmiwatef and
to October 1988, Tracking to EPA in RFI that the of the
• . |;
the RFI EPA a in Ae RFI. 1T»e
the li a RFI
1PA the RPI work plan in 1990. ft
work
to EPA to July .1990.
• be the
Drilling .of salt to of tht In the
, of the bay to (fie extern of
of In the vletoltybf the
' |!
of ti the and the ,
to on of the
' f
•
: :
34
-------
€-§; Cffltreetlfa for
oau>
IMT
IWU1
snvue T««
•mu « list MCA «a a'
IHHU t warn MY
BUM
rowsune
nvawra
fMfOIIV MWAMtV
«J.
FACIUW.IAWOT AW
:WfLL.
35.
-------
C-5s Corwefife far
3.0 Of
The following the by EPA thn of
it the n the time of the- and 'a
by EPA the
3,1
At the of WSTM the ENSV Truckio |. of the
la to would be to facility.
Upon it the facility, the Mr. Roy ffelitnd, Mr,
die to ike at the facility. Mr, Mr, it the
The urf Mr, that the WB
the of 3007 of RCEA and the provisions of the
order. Mr, the of the and the that tie
would fellow, Mr, was that the had the to
tie at (Gil), Mr,
Rfc with tbe.CBI ail a CM to be it'the'end
of the lasfHialoB, and il the and the
that the was to
The interviiws of Mr, and Mr. on the' cff RFI ictivlttes
»the ficIJIty, The revlewai by the' facility for conjplJinet with
of the plan and the W§ then the
for sell sail and ,
also Ac facility's for and for
5 .
36
-------
C-S: Corrective for
L
the from wells. At the end of .the EPA discussed
tie of the Mr. CBI brans. No
C1I was Copies of the are la D,
3,2 OF BFI
A total of 36 soi was In the July 1990 RFI work plaa to'
and the soil it the bay. Tea of the had .-Additional.
borings »be on the day of the to of to the
and of the soils, to the of Tie
of all toil in the July RFI pita am la Ftfuip'3.
Tfat of well it lie lad . .Tie of to
monitoring well was to piovBeJnfonattlon OB
the Fife of the bad the'Ate oftke
Mr, Aat the bad to it of the
five of the two-well At Sow | jrodietlOB'aol
of lad to the 50 fat of bedrock aquifer, Thereftni, tie
bad thai ike of the to tie |w aid the
the not d» of
at the two was for the day of th«
Tie was i of In tie July RFI werk
plan, All at the facility to be and £0 be
for (VOC) ud Tlie purpose of the for
VOCi Is to aid to tie of Tie of f§r
b to aid to of In tbt m a of :
6 '•.
37
-------
OS: Corrective for
•. ' riNcsuwe
* -9 m
soit,
3S
-------
CǤ!
iddli
as of for
also Is to the of ik
of In probteiqi.- Monitoring wells-
tae July 1990 RFI work plan to be well had ,
been At the of the of tie walls tor sampling,
of the WB fix the
3 J
During the review of EPA looked at to by the RFI
Investigations, for toll tad tM lily 1990. RF! work
plan, aid the aid af tbe wofi| plan, for th
as a of Us IF! to be
of sail and wall to It also
that hail that (toy fcid read the
11 the RFI
EPA on tie RFI
Mr, and Mr,
aid by the the In
die July, 1990 RFI and of tie of. RFI
that the to to la with the in the IF! work
Ho tie of the
by the to of the RFI.
During -iba corrective HP A the drQIbujiof five soil it
the end of the. bay (SWMU.3), XYZ a rig
with a The »M with
S ' '!
-------
C-5: for
ajch five feet In
length, were to the sampler* oiifi, 16,26,
snd 40 were Hthologically Hid in the •
field , I
t (PID), In lo the In the
the for Tie i post
PID »it at: tie of bay iJSWMU 3)
(aee I), in the arta to b§ sift
XYZ was wUh four the
the to of ft e
ii a tub of and la (jee 2),
AH The with
i EPA no of .ftp
by XYZ from fci tie RPI work
plan. . |i
EPA the of at tfct two (see 3); 1 J'ire-liae raring
was to drill the At one of the in the from
the of awl to
the a i last 'In the If I i
two-well was weH wai with a
cilorWe (PVC) iereea ii the A was to the with an
tri-con lit, A Ifi-foot w*a toed for the 'Tl* and
by a of two feet of |
f . .:'
40
-------
C-Si for (i
EPA the of two wells, to and total
af the at an The wells .
with a. in with as the M-YZ
rccorial on as
and the tor to the
At the of Mil well activities, XYE
the wftfc the PID, in ttewoik plan's
uxLssfety
eni of the lay (SWMU 3), VQCs ref by toe
PID IB the 10 per (ppm). XYZ .
with* drilling at Has (tie' 4).
4.t OE
Ditffaf to EPA the following ,
from the RFI and .
» Tie fioU IB (he for fcf VOCs.
!o the of 4e wife •
<«* Photo S). TW§ Is' tnb
RFI plan Up raps to fce
• hot solution, j ;
I ;
• When- (he PID • of 5 VOCs tat .one of XYZ
* wtt the loi, This
the soil had split ud to Jba air. Hit of
for for VOQ fa eonififf'tb.tlui |i ftt
RFI wo A he to use to
of toil YOCs jiaf '
ii loti ;
10 I •
41
-------
C-5s
During drilling the bay, EPA thttXYE
had not plsced the racks tbe.ipKt-birrel
of the soil tad on the soil be i
Ait In of the soil -at ?«(see
6). jj
in die of water fad toll
cuttings'in drum, Hied :werc 'HAZARDOUS
- Groundwater," were
— Solid," EPA tiw in tbejyellow barrels.
Mi sol ta the rod 7), This an IB
the ing of investlgatkra-darlved wattes. ! ~
The RFI work for tie construetlon.of it I
However, the facility the In tie fide! of rved
As iot Installed in to In
a lack of or a lack of wm la the «| (per SO feet of
of condition, H ] iv§ of lie
specified In tito plan. A tie jof Sis
and is 3, ' i
well, MW4> was not all the way to tie top 8).. It that,.
feet of the hole to be Tie hi H beeiT'**
the A copy of At wi 11
die of the ii ii B,
11
42
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