Brmnnental Pratttim
Ertswcemert And
CwnpB
(2244>
                                                  Asm sne
xS-EPA
EPASSW.95-QQ1
MaytSSS

                                                                     PB95-269183



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             '
             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 "JESiaBjewoii>>::                     ,	,	          ; .
  The purpose  of      guidance ta to delineate Inaifaetiem
  aofcivteis whiah ate oclfetcal for the successful  eomplet;
  o eeeceetive  action  aatlv'itlasa '^ currently underway at t_
  facilities.                 has      -weltfcen for  irtsjetQj
       the  OS  EPA ana State  environmental agencies  (or the;'
             contractors) -who will be conducting        owe!
  of ownee/operatoir aetifltiea at                 ioilltij
  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
                                  'SrMSlfBlMWiei|TlQN

                                                   fwnSrtwS stiiftffiT1S
                                                   S|r HMHM. 4-,,

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                                    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

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                                      OF

                                                          

10     INTRODUCTION[[[ 14,

      1.1             AND       OF           	,,,,.,	,,,.,,.,.,,,,, U

      U    THE                               ,.,,.,..,.,,,,,,.,..:.	.1-2

             121   ImpleraeBtatibB of (he Coiwelive Action PtegKBt .............:,,......, l3

      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,.,...,.. 31
             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  .; !


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 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,,,,,.,...,,,.,,.,.;.,,..,,  46
            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

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                                       (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,

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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

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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 earrtiv| 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

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                                                           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

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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

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            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 Wlltyspecific   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

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 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  '

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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          iat               The
will support             of the               for  facility. ,              f
                                            2-3

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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

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                                           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                                                	
                                       25

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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..

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V,
VI,
VII,
                             FIGURES
                             iMPLl
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 smnpj

       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,
                        ial conunericat properties,

       IB 1988, BPA Issued an Administrative Conseiit Orte 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 
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                      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       HB 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

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                                      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 lnspGttoiK_

Site           fcy air or rifls_

P of      of               	
                   it of
                                           2-10

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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 23       is a list of equipment thai ti               to                      The list
is        into                                                   and         equipment,-
                                          2-12

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            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 pyriyfa 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

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                           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

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I

             2.7
             SUMMARY
                                                                                    them In
                                                                            are
Inspectors lave              with           and           that       i
         for          action           Although                i
         aw            to        Ife                      OQ pjf                /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

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-------
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.              ';

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                       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^liifilsSSMB 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|bpater 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 EPAite 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?;

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                                                            OS

                                                            3

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a  
3  9
        ill
        iip

        ill
          *
        ,",,-
ft
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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'                       
          en 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 oi       .                  \
               far
Ritneiiai       a
              U.S.               Protection         1985. . Hm&aclK
                            SOtt          ,
              UJS.               Pratection j%geny, 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        jpe           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
    ]

0S j                      Agency.               1CJM Corrective     >
U.SJ
U.S.J
US;

                                   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 ef
       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      af                         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                                            

US.                                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.         af
                                                              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 1S8      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




Deelop
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                         3ineh
                                   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
    exaniiitt8 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

-------

-------
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.  1Te
                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        fr
                        b to aid to             of          In tbt                  m a     of     :
                                                         6                             '.
37

-------
        OS:  Corrective                         for
.   '     riNcsuwe
 *  -9     m

soit,
                                       3S

-------
              C!
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                 '   '!

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              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

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             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

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 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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