EC-G-2002-100
                         OSWER Directive  9902.3-2A
                                         May 1994
RCRA CORRECTIVE ACTION PLAN

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

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NOTICE: The policies set out in this do cum ent are not final agency action, but are
intended solely as guidance.  They are not intended, nor can they be relied upon, to create
any rights enforceable by any party in litigation with the  United States.  'EPA. officials may
decide to follow the guidance provided in this docum ent, or to act at variance with the
guidance, based on an analysis of specific  site circum stances.  The agency  also  reserves the
right to change this guidance at any time without public notice.

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                                Table of Contents


Foreword	  v

Chapter I:  Corrective Action Process Update  	  1

Chapter II:  Interim Measures To Achieve Stabilization	  11

Chapter III: RCRA Facility Investigation	  17
       Introduction	  17
       Release Assessment [optionalphase]	  18
       Section I: Description of Current Conditions  	  22
       Section II: RFI Workplan	  26
       Section III: Facility Investigation	  33
       Section IV: Preliminary Evaluation of Corrective Measure
       Technologies by Laboratory or Bench-Scale Studies [optional]	  48
       Section V: Investigation Results and Analysis  	  49
       Section VI: Progress Reports	  52
       Section VIII: Proposed Schedule	  53

Chapter IV: Corrective Measures Study  	  55
       Introduction	  55
       Section I:  Corrective Measures Study Workplan	  60
       Section II: Corrective Measures Study Report	  60
       Section III: Progress Reports	  68
       Section IV: Proposed Schedule  	  69

Chapter V:  Corrective Measures  Implementation  	  70
       Introduction	  70
       Section I:  Conceptual Design (15% Design Point)  	  75
       Section II: Operation and Maintenance Plan	  77
       Section III: Intermediate Plans  and  Specifications (30, 50, 60, 90  and/or
       95% Design Point)  	  80
       Section IV: Final Plans and Specifications (100% Design Point)	  81
       Section V: Construction Workplan	  81
       Section VI: Construction  Completion Report  	  84
       Section VII:  Corrective Measure Completion Report	  85
       Section VIII: Health and Safety Plan	  85
       Section EX: Public Involvement Plan	  87
       Section X: Progress Reports  	  88
       Section XI: Proposed Schedule  	  88
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Appendix A - Corrective Action Reference List	 90

Appendix B - Chapter One of "Test Methods for Evaluating Solid Waste,
Physical/Chemical Methods", EPA Publication SW-846 [Third Edition as
amended by Update I (July 1992)]	 94

Appendix C - Definitions	 127

Appendix D - Corrective Action Stabilization Questionnaire	  129

Appendix E - Example Scope of Work for Interim/Stabilization Measures	  138

Appendix F -Summary of Important Geologic Information	 147

Appendix G - Sources of Information on Human Health and Ecological Risk
Assessments	 149
                                       IV

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                                    Foreword

       This document was issued by Bruce M. Diamond, Director, Office of Waste
Programs Enforcement, and Michael Shapiro, Director, Office of Solid Waste, in May,
1994 as the RCRA Corrective Action Plan Guidance (Final), OSWER Directive
Number 9902.3-2A replacing the RCRA Corrective Action Plan Guidance (Interim
Final), OSWER Directive 9902.3, dated June, 1988.  The interim final guidance was
updated with the help of a workgroup made up of representatives from several States
and EPA Headquarters and Regions. The updated guidance reflects the experience the
Regions and States have gained and changes that have occurred in the corrective action
program.  In addition, new technical information has been added.

       The purpose of the RCRA Corrective Action Plan (CAP) is to aid Regions and
States in determining and directing the specific work that a Permittee/Respondent
must perform, as part of a complete corrective action program.  The CAP will assist
the Regions and States in developing corrective action requirements in permits under
§3004(u)  and (v) and §3005(c)(3) (omnibus) and  corrective action orders under §3008(h)
and §7003.

       The CAP provides a framework for developing a site-specific schedule of
compliance to be included in a permit or a corrective action order. It does so by
laying out scopes of work for the four main components of a corrective action
program.  These four components and their objectives are as follows:

       •        Interim I Stabilisation Measures  (ISMs) -to control or abate threats to
               human health and/or the environment from releases and/or to
               prevent or minimize the further spread of contamination while long-
               term remedies are pursued.

       •        RCRAFaci/itj Investigation (RFI) -to evaluate thoroughly the nature
               and extent of the releases of hazardous waste and hazardous
               constituents and to gather necessary data to support the Corrective
               Measures Study and/or interim/stabilization measures.

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

       •        Corrective Measures Implem entation  (CMI) - to design, construct,
               operate, maintain and monitor the performance of the corrective
               measure(s) selected.

       A chapter on interim/stabilization measures (Chapter II) has been added in the
final CAP. This optional phase is generally the first phase of corrective  action but
may be conducted at any time in the process. The term  "interim/stabilization
measures" is being used in this document to encourage the use of interim measures to
achieve stabilization.  Interim/stabilization measures are actions to achieve the goal of
stabilization, which is stated above and in Chapter II.

       Another optional phase, the  Release Assessment or Phase I RFI, could be
performed by the Permittee/Respondent before an RFI (or as a first phase of an RFI)

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and after a RCRA Facility Assessment (RFA) to determine whether
interim/stabilization measures are necessary and/or to focus an RFI.  A release
assessment should be used to minimize corrective action activities (i.e.,  by focusing
the RFI) and not to add another step in the process. See section III.D. ("Phasing of
Activities") of Chapter I and the beginning of Chapter III for further discussion and a
model scope of work for release assessments.

      The CAP provides an overall model for the corrective action process. The
scopes of work contained in the CAP should not be considered boilerplate; rather,
they should be considered as a menu of possible activities to be required on a site-
specific  basis.  The model scopes of work in the CAP are intended to foster timely,
concise, and technically adequate  submissions by the Permittee/Respondent.
Therefore, when modifying these scopes of work with site-specific information, only
information that is necessary for the subject facility should be required, in order to
minimize the number and length  of Permittee/Respondent submissions and
implementing agency review time. The implementing agency decides which
components will be included in the permit or order.
                                       VI

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                  Chapter I:  Corrective Action Process Update

       Since the interim final CAP was published in June 1988, several changes have
occurred in the RCRA corrective action program.  New philosophies and strategies
were expressed in the July 1990, RCRA Implementation Study (RIS), and new
technical information has become available. The revised CAP reflects these changes, as
well as the experience of the Regions and States in implementing the corrective action
program.  Some of the key  changes are discussed below following an introduction to
the corrective action program and an explanation of how to use the CAP.

I.   Introduction

       The objective of a Corrective Action Program at a hazardous waste
management facility is to evaluate the nature and extent of the releases of hazardous
waste or constituents; to evaluate facility  characteristics; and to identify, develop, and
implement an appropriate corrective measure or measures to protect human health
and environment.  The following components are necessary to ensure a complete
corrective action program.  It should be recognized that the detail required in each  of
these steps will vary depending on the facility and its complexity; only those tasks
appropriate for a specific site should be imposed on the Permittee/Respondent.

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

2.      Characterize the nature  and extent of contamination that is both within the
       facility boundary and migrating beyond the facility boundary.  This would
       include defining the pathways  and methods of migration of the hazardous
       waste or constituents, including the media affected, the extent, direction and
       speed of the contaminants, complicating factors influencing movement,
       concentration profiles, etc.

3.      Identify areas and populations  threatened by releases from the facility.

4.      Determine  actual and potential threats of releases from the facility to human
       health and/or the environment in both the short and long term.

5.      Identify and implement  an interim/stabilization measure or measures to abate
       the further  spread of contaminants, control the source of contamination,  or
       otherwise control the releases themselves.

6.      Evaluate the overall integrity of containment structures and activities at the site
       intended for long-term containment.

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

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

The four main components of a complete corrective action  program and their
objectives are as follows:

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       •        Interim I Stabilisation Measures  (ISMs) -to control or abate threats to
               human health and/or the environment from releases and/or to
               prevent or minimize the further spread of contamination while long-
               term remedies are pursued.

       •        RCRAFaci/itj Investigation (RFI) -to evaluate thoroughly the nature
               and extent of the releases of hazardous waste and hazardous
               constituents and to gather necessary data to support the Corrective
               Measures Study and/or interim/stabilization measures.

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

       •        Corrective Measures Implem entation  (CM I) -to  design, construct,
       operate maintain and monitor the performance of the corrective
       measure(s) selected.

As discussed in section VI of this chapter, all of the  components may be streamlined
or phased, and alternatives to the "traditional" corrective action process  (i.e., RFI ""*
CMS ""* CMI) may be appropriate.

       A RCRA Facility Assessment (RFA) or equivalent assessment will have been
conducted at the facilities that are to receive permits and for some facilities that are
issued §3008(h) Orders. The results of the RFA should be used as the basis for
focusing the RCRA Facility Investigation (RFI) for individual  sites and should provide
the necessary data to complete the "background information" components of the
CAP.  In some cases, a Release Assessment (Phase I  RFI) may be needed to further
focus the RFI  or to determine whether ISMs are necessary.

       Exhaustive characterization  and studies of a  facility during the RFI/CMS, in
the sense of completely eliminating uncertainty, are generally not required to achieve
environmentally protective results.  Therefore, it is  important  for the implementing
agencies to clearly define scopes of work to be performed that  require the appropriate
amount of information to characterize contamination and identify the cleanup
alternative(s) without "going overboard." Reasonable time frames should be set for
activities such as gathering data and conducting studies.

II.     How to Use the CAP

       Users of the CAP should understand that it  is designed to identify  actions that
facility Permittees/Respondents may be required to undertake as part of a corrective
action program. It does not identify the steps that are the responsibility of the
implementing agency.  However, some guidance language  is provided in the CAP for
such agencies and is indicated by brackets ([]) and italics.  Additional guidance
language is found at the beginning of Chapters II, III, IV, and V, and before the model
scopes of work. Specifying conditions that will be placed  in orders and permits is one
key area of responsibility  for implementing agencies. The CAP incorporates certain
provisions that are already required by statute or regulations. If the required
information is already present in permits or permit  applications, the implementing
agency may allow the Permittee to reference the appropriate sections of such

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documents.  The remainder of the CAP is guidance, not a rule, and has not gone
through public comment; therefore, use of provisions in the CAP should be justifiable
and tailored to fit site-specific conditions.

       Regions and States should incorporate the appropriate provisions of the
corrective action plan in a draft permit.  If public comments are received on these
provisions, the implementing agency's response to comments should include a site-
specific justification for the provisions in question, with supporting data as
appropriate.  For guidance on public involvement for corrective action under permits
and RCRA §3008 (h) orders, see the RCRAPublic Involvement Manual (EPA530-R-93-
006, September 1993).

       Limitations exist on the release or discussion of information during the
enforcement process (particularly during negotiations or if a case is referred to the
Department of Justice). However, respondents that are issued RCRA §3008 (h)
administrative orders have the right to request a hearing concerning any material fact
in the order or the terms of the order which may include scopes of work derived from
the CAP.  Respondents to §3008 (h) orders may request informal settlement
conferences. Agencies are encouraged to settle such enforcement actions through
informal discussions.

       Traditional risk assessment techniques may be a significant factor in designing
RFI, CMS, and ISMs work plans. Risk management decisions should be used in
selecting corrective measures and ISMs, along with current and future land use
scenarios,  background levels, health-based and technology-based standards.

       To clarify the interaction between the agency and the facility
Permittee/Respondent, a flow chart of Permittee/Respondent submittals that may be
imposed and the agency actions for the stages of the CAP is represented in Figure 1
below. It  is important to note that this is the "traditional" model and many variations
of the process are possible (see "Alternate Corrective Action Models" section VI.F. on
page nine).

                   Figure l.RCRA Corrective Action Process

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III.    Modifications of CAP Scopes of Work

       The CAP scopes of work should not be considered boilerplate. The scopes of
work in the CAP are models that should be modified based on site-specific situations.
Information generated from investigations such as RCRA Facility Assessments (RFAs)
should be used to tailor the scope of work to address facility-specific situations. The
following are some examples of situations where  modification to the CAP model
scopes of work would be appropriate.

       •         If the contamination problem at a facility is small or simple (e.g., a
                small soil contamination problem), then the implementing agency
                may decide to scale down the CAP accordingly. The agency  could
                require excavation and removal by ISMs or by corrective measures
                after approving a streamlined CMS (e.g., with only  the one alternative
                evaluated).

       •         If the contamination problem at a facility is complicated,  the Health
                and Safety Plan and Public Involvement Plans may  need to be
                comprehensive. However, in less complicated contamination
                situations, these plans may be very brief.

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

       •         If there is information on air releases at a site which is sufficient to
                suggest a remedy which would prevent  such an air release, then it
                would not be necessary to require the Permittee/Respondent to
                perform an air  contamination characterization. The air
                contamination  characterization work under the RFI should be
                deleted.

       •         If interim/stabilization measures  are underway, scheduled or
                contemplated at a facility, then the interim/stabilization measures
                section under the RFI should be modified to  specifically reference
                such measures.

       •         If possible, the  CAP should focus the Permittee/Respondent on
                specific solid waste management units (SWMUs) and other areas of
                interest, as well as known waste management activity areas (e.g., waste
                recycling units).

       •         If only one corrective measure  alternative is appropriate for a given
                situation, and it would not be necessary to require the
                Permittee/Respondent to further  investigate  the possibility of other
                corrective measure  alternatives, then the scopes of work contained in
                this document  should be modified to reflect this situation.

IV.    Available Guidance

       The Regions and States are encouraged to make available to the
Permittee/Respondent existing model plans that are relevant  to RCRA activities. For

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example, the Occupational Safety and Health Guidance Manual for Hazardous Waste Site
Activities Operating Safety Guidelines contains a model that can be used for the Health
and Safety Plan outlined in the CAP. In addition, guidance documents such as the
RCRA Facility Investigation (RFI) Guidance; Interim Final (May 15, 1989, document
number PB89-200-299, four volumes available from NTIS, phone number (703) 487-
4650) may be referenced.  Other corrective action guidance documents and  sources of
related information are provided in Appendix A.

V.     Tailoring the Work to be Performed for the Site

       It is necessary to stress the importance of site-specific technical detail in
developing corrective action  orders, permits, and, particularly, scopes of work. Each
facility has unique characteristics and circumstances that need to be considered and
incorporated into any requirements for corrective action.  Without this up-front
detail, many  Permittees/Respondents will provide deficient submittals that lack the
technical detail necessary to perform a thorough corrective measure program.  In
addition to providing a detailed scope of work,  the implementing agency should also
establish a site-specific time frame for completing the work. Enforcement of permit
conditions or an order is always easier when specific detail is included.  These
documents should contain schedules for submittals such as reports and work plans.
Without a detailed schedule of compliance in a corrective action permit or  a
corrective action order, submittals and actions may be delayed or untimely.

VI.    New Developments in Corrective Action

       A. Streamlining the Corrective Action Process

       The introductory remarks in the original CAP (June 1988) stressed the
importance of concise submissions based on site-specific detail and that the  scopes of
work contained in the CAP should not be considered boilerplate. The revised CAP
continues to  emphasize this policy as well as an overall goal of streamlining the
process in an effort to expedite cleanups. Of course, this goal must  be balanced with
the goal of maintaining the technical integrity of the program. Decisions concerning
how and when to streamline  the process are to be made at the discretion  of the
implementing agency.

       The revised CAP encourages using alternatives to the traditional sequential
approach (e.g., the use of interim measures to achieve stabilization). It presents a
menu of options that are to be tailored to individual sites,  taking into account site-
specific conditions.  In addition, some steps have been combined or eliminated to
reduce redundancy.

       B. Addition of Interim Measures to Achieve Stabilization (Chapter II)

       The following chapter, Interim Measures to Achieve  Stabilisation has  been added
to the CAP as an optional phase to be conducted at the discretion of the implementing
agency. The 1990 RIS suggested that the RCRA corrective action program  needed to
adjust its longtime program emphasis.  While final cleanup remains  the long-term goal
of the corrective action program, the RIS recommended more frequent use, where
appropriate,  of interim/stabilization measures in the early stages of corrective action
to achieve near term environmental protection  at facilities with the most serious
problems.  This approach, which may also be appropriate during later phases of the

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process, emphasizes controlling sites by stabilizing identified releases to prevent the
further spread of contamination and degradation of the environment. Note that the
term "interim/stabilization measures" is being used in this document to encourage the
use of interim measures to achieve stabilization.

       C. Corrective Action Management Units (CAMUs) and Temporary
                Units (TUs)

       The February  16, 1993,  Federal Register (58 FR 8658) finalized provisions for
Corrective Action Management Units (CAMUs) and Temporary Units (TUs) under
subpart S of 40 CFR Part 264.  These units function solely to manage remediation
wastes generated at a RCRA facility as a result of required corrective action activities.
EPA recognized that the existing regulatory structure of RCRA Subtitle C (e.g.,
permitting, land disposal restrictions), when applied to management of hazardous
wastes for remedial purposes, can often impede the ability to select and implement
effective remedies. CAMUs/TUs were developed to expedite hazardous waste
cleanups by reducing or eliminating certain waste management requirements of the
current RCRA Subtitle C regulations. The use of TUs at a site does not in any way
preclude the need for a final remedy to eventually be implemented at the site; whereas
CAMUs may be included in a final remedy.

       The final CAMU/TU provisions are intended to provide flexibility for
decision- makers in implementing protective, reliable, and cost-effective remedies.  The
CAMU/TU regulations provide the Regional Administrator (RA) with the authority
to designate and approve such units if the RA determines  criteria specified in 40 CFR
§ 264.552(c) will be met. If the remediation wastes are managed in accordance with
these provisions, remediation waste (as opposed to process or "as-generated" waste)
will not be subject to the RCRA land disposal restrictions (LDRs) and the minimum
technology requirements (MTRs). The CAMU/TU regulations apply to corrective
action implemented under RCRA permits and Section 3008(h) orders.

       D. Phasing of Activities

       A phased approach to corrective action may be appropriate where a variety of
releases (or threats of releases) exist, particularly if some of the releases or threats can
be stabilized. Under this approach, the initial investigation  should first focus on the
areas that pose the greatest threats to human health and the  environment and then
focus on lower priority  areas.  Stabilization for the high priority units may be
required before  focusing the investigation on the lower priority units. Phasing may
also be appropriate when  determining the extent of contamination if it is believed that
substantial migration of contaminants has occurred.

       Release Assessments (Phase I RFIs), or other RFI phasing activities are also
intended to streamline the corrective action process. They may be required to
determine whether interim measures/stabilization are necessary and/or to focus an
RFI. A release assessment may be performed between the RFA and RFI and may be
desirable if there is some uncertainty about releases (e.g., due to subsequent activities)
at a facility after the RFA. Note that RFAs are conducted by implementing agencies
and release assessments or Phase I RFIs are conducted by Permittees/Respondents.
The release assessment should be viewed as away of focusing an RFI or determining
whether interim/stabilization measures are necessary prior to the RFI.

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       It is important to note that a release assessment is generally used to minimize
corrective action activities (i.e., by focusing or streamlining the RFI) and not to add
another step in the process.  See the beginning of Chapter III for further discussion
and a model scope of work for release assessments.

       The CMS may be phased as discussed in the CMS section of the document;
however, all elements of the facility that are of concern eventually should be addressed
in a CMS. Eventually, the CMS will most likely result in a comprehensive evaluation
of corrective measures to be implemented at the entire site, even if the study is most
logically conducted in phases.

       E.  Quality Assurance Project Plans and Data Quality Objectives

       A fundamental requirement of the RCRA corrective action program is the
collection of environmental data that can be documented and are of adequate quality
to support decision  making.  To meet this requirement, data quality objectives
(DQOs) should be established through the quality  assurance project planning process.
A July 7, 1993, memorandum transmitted to the EPA Regions from Sylvia Lowrance,
OSW Director, and H. Matthew Bills, Office of Modeling, Monitoring Systems and
Quality Assurance Director within the Office of Research and Development, discusses
the application of the DQO process to the ground-water monitoring and corrective
action program. As a follow-up to the memorandum, the two offices are developing
examples of Quality Assurance Project Plans (QAPjPs). These examples are intended
to demonstrate that QAPjPs can be of varying complexity depending upon their
associated DQOs and that review and approval of QAPjPs designed to achieve less
complex DQOs can be expedited in certain cases.

       As stated in the July 7, 1993, memorandum, "The overall level of uncertainty
that a decision maker is willing to accept in this decision making process is known as a
DQO."  The memorandum also  explains that QAPjPs are used as a management
control to ensure that DQOs are  defined and documented. QAPjPs may vary in
complexity (e.g., in  certain cases,  sampling and analysis plans may substitute for and
be the equivalent of QAPjPs), but the minimum elements of a quality assurance
program for all data collection activities in RCRA are outlined in Chapter One
(Quality Assurance) of "Test Methods for Evaluating Solid Waste, Physical/Chemical
Methods" (EPA SW-846 Third Edition as amended by Update One, July 1992).  For
this reason, Chapter One of SW-846 is included as an appendix (Appendix B) to the
CAP.  References to this appendix also are made in Chapter Three (RFI) and Chapter
Five (CMI).

       F.  Alternate Corrective Action Models

       The following sample alternatives to  the traditional corrective action model
(i.e., RFI ->  CMS "*" CMI) are provided as examples. Note that an RFA would
precede these activities.  Except for use in the term "Interim/Stabilization Measures,"
the slashes indicate that activities  may be conducted concurrently. In addition,  more
than one scenario may be taking place at a site at one time.

1) Release Assessment ""* No further action

2) Release Assessment ""* Streamlined RFI ""* No further action

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3)  Release Assessment -" Streamlined RFI -> CMS -" CMI

4)  Interim/Stabilization Measures -" RFI -> CMS -" CMI

5)  Interim/Stabilization Measures ""* RFI ""* Interim/Stabilization Measures ""*
  CMS -" CMI

6)  RFI -> Interim/Stabilization Measures -" CMS -" CMI

7)  RFI/CMS -" CMI

8)  RFI/CMS/Intenm/Stabilization Measures -" CMI

9)  RFI -> Streamlined CMS -" CMI

10) Phased RFI/CMS -" CMI

11) Phased RFI/CMS/Intenm/Stabilization Measures -" CMI

12) Phased RFI/CMS/CMI

      This is not intended to be an exhaustive list but rather examples of some
possible scenarios. The following chapter provides more guidance on phasing interim
measures to achieve stabilization.

      G. Reimbursement of Oversight Costs

      EPA is examining various options for recovering oversight costs in the RCRA
program.  The Agency may issue guidance on this issue in the future.

      H. Definitions

      To facilitate use of the CAP, a Definitions Section has been added as an
appendix (Appendix C).  For additional guidance on technical terms used in the
Corrective Action Program, the U.S. EPA issued the "Corrective Action Glossary"
(OSWER Directive Number  9902.3-la) in July, 1992.  The Glossary is available
through NTIS, phone number (703) 4874650.

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             Chapter II:  Interim Measures To Achieve Stabilization
Introduction
       The RIS recommended using interim actions to achieve near-term
environmental results at facilities with the most serious problems.  The overall goal of
this process, termed "stabilization," is to control or abate threats to human health
and/or the environment from releases and/or to prevent or minimize the further
spread of contamination while long-term remedies are pursued. Since 1992, the U.S.
EPA and the States have  been implementing a major initiative to achieve this goal.
Interim/stabilization measures (ISMs) are the actions used to achieve the goal of
stabilization.

       The stabilization effort builds  on work that has already been initiated at many
corrective action sites.  Many of the ISMs implemented at numerous RCRA  facilities
across the country were undertaken to address actual or  imminent  threats to human
health  or the environment.  Guidance on implementing ISMs was provided in the
original CAP, the RCRA Corrective Action Interim Measures Guidance (OSWER
Directive 9902.4, June 1988), the proposed subpart S rule (55 FR 30880, July  27, 1990),
and more recently in the RCRA Stabilization Strategy transmitted to the EPA
Regions in a memorandum from Sylvia Lowrance, OSW Director,  and Bruce
Diamond, OWPE Director (October  25, 1991). The subpart S proposal generally
constitutes EPA's most authoritative policy  statement on corrective action.  As
discussed in these guidance documents, a release or threat of a release, need only be
potential (i.e., it does not have to be actual or imminent) to require the
Permittee/Respondent to implement  ISMs.

       Although intended to be implemented more quickly than traditional  remedial
measures, ISMs may be short-term or  long-term. Examples of ISMs include:
providing bottled water, erecting a fence around heavily contaminated soil, hydraulic
containment of a contaminated ground-water plume, and excavating and removing
heavily contaminated soil.

       To a large extent, the stabilization effort builds on work that has been ongoing
in the Regions and States.  These agencies historically have required facility
Permittee/Respondents to undertake  interim measures to address obvious
environmental problems, particularly  where actual or imminent exposure of human or
environmental populations has been identified. However, these actions have often
been pursued in conjunction with the final, comprehensive remedy for a facility.

       The stabilization initiative focuses limited agency resources  on near-term
activities to control or abate threats and/or to prevent or minimize the further spread
of contamination across many facilities rather than following the traditional process of
pursuing final, comprehensive remedies at a  few facilities. By imposing such
expeditious actions, the extent and incidence of continued environmental degradation
from existing releases should be significantly reduced. In addition, the environmental
benefit gained by  taking this early action should enable greater efficiency in final
remedies undertaken.

Timing of Stabilization Activities

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       Interim/stabilization measures are used to achieve the goal of stabilization and
allow the implementing agency to redirect its resources or defer some corrective action
activities to address the worst sites (or parts of sites) first.

       In many cases, it will be possible to  identify early in the corrective action
process the need for interim measures.  The implementing agency may identify such a
need through the combination of the RFA,  the facility's rank (using the National
Corrective Action Prioritization  System (NCAPS)), and stabilization  evaluation.
Individual solid waste management units (SWMUs) with the worst releases and
presenting the most imminent threats can also be identified by using these tools. A
phased approach may be taken during the initial RFI information gathering stage to
focus the investigation on collecting data to design, implement, and monitor interim
measures at high priority SWMUs. The facility-wide RFI (and CMS)  can be done
concurrently or be put on a slower track while interim measures are implemented at
the worst SWMUs first.  Although the CMS will generally not be completed when
deciding on interim measures, potential final remedies  should be under consideration
because the interim measures taken to achieve stabilization should be  consistent with
the final remedy.  In cases where  they will deviate due  to the interim nature of the
actions, the interim measures should at a minimum not conflict with the final  remedy.

Conditions Appropriate for Stabilization

       Several conditions should  exist at a facility (or part of a facility) for
stabilization to be appropriate.  Generally, interim measures are most effective when a
specific aspect of the overall contamination  at the facility can be isolated.  As discussed
earlier, exposure threats to humans or ecosystems should be present.  If these receptors
could be exposed to contaminants within five to 10 years or interim measures  could
reduce the present or near-term (e.g., less than two years) risks,  then this criterion has
been met. Addressing releases expeditiously through interim measures may prevent
further significant contamination of environmental media.  If contaminants are
migrating off site,  stabilization may be appropriate to stop or slow the migration.
Also, if previously implemented interim measures have been unsuccessful in
preventing the further spread of contamination, new or modified measures may be
needed. Sufficient  information about the contaminants and the  facility's
environmental setting (e.g., site hydrogeology) must be known  for stabilization to be a
viable option. Finally, a decision to proceed with stabilization activities should be
made only if appropriate technologies are available to deal with the known
contaminants.

Examples of Interim Measures to  Achieve Stabilization

       Stabilization can be achieved through a variety  of interim measures that are
based on site-specific conditions.  Stabilization can include source control,
contaminated media cleanup, and/or limiting exposure to contamination. As  an
ecological example of interim measures to limit exposure, migrating waterfowl could
be prevented from using open surface impoundments,  ponds, etc., with contaminants
of ecological concern by placing a temporary cap over  the surface impoundments or
removing the hot spot contamination from  such units.

       As another example of a facility that has implemented interim measures to
achieve stabilization, consider the following: The initial screening at a chemical
manufacturing plant identified dioxin contamination in superficial soils and

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trichlorobenzene non-aqueous phase liquid (NAPL) in the bedding of the facility's
sewer system. Both of the contaminated areas were located near the facility boundary
and posed a threat to a nearby residential area. Interim measures included installing a
fence to prevent access, capping the dioxin-contaminated soil and installing a grout
wall for hydraulic isolation, and initiating a free-product removal program to
eliminate the source and prevent continued NAPL migration along the sewer system.

       As a third example, investigations at a wood treating facility identified past
releases from unlined impoundments, which resulted in considerable quantities of
creosote being present in the ground water as a dense NAPL or DNAPL. Dissolved
hazardous waste constituents were present both on and off site in the underlying
Karst aquifer. The facility installed a downgradient ground-water extraction trench
with extraction sumps  to remove free product and contaminated ground water. The
extraction system was expanded throughout the stages of corrective action.  Early
action  to remove product and contaminants and to limit the plume's extent was
particularly important at this facility because of the uncertain flow patterns associated
with many Karst aquifer  systems.

       The U.S. EPA has developed guidance documents to facilitate implementation
of the stabilization initiative. One such document, Stabilization Technologies for
RCRA Corrective Actions (EPA/625/6-91/026, August 1991)  is a handbook which
provides guidance on identifying the types of environmental settings that are
amenable to stabilization, various technical approaches to accelerate  data gathering,
and phasing the RFI. This guidance document also includes a Corrective Action
Stabilization Questionnaire (see Appendix D) that can be used immediately after an
NCAPS ranking as a first step to gather stabilization-related information. The
questionnaire examines individual solid waste management units (SWMUs).  In
addition, stabilization fact sheets are under final review by the U.S. EPA and should
be released in the near future.

       The following table provides examples of interim measures that may be
implemented for specific media.  Note that these may  also be used for final remedies.

                           Example Interim Measures
  Ground Water
       Interceptor Trench/Sump/Subsurface Drain
       Pump and Treat System (Source Removal and Containment)
       Physical Barriers (Covers/Slurry Walls)	
  Soils
       Run-off/Run-on Control (Diversion or Collection Devices)
       Cap/Cover
       Source Removal (Excavation)	
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  Surface Water Release fPoint and Non-Point")
       Overflow/Underflow Dams
       Filter Fences
       Run-off/Run-on Control (Diversion or Collection Devices)
       Regrading/Revegetation	
  Gas Migration Control
       Barriers/Collection (e.g., vapor extraction)/Treatment/Monitorin^
       Evacuation (Buildings)
  Particulate Emissions
       Truck Wash (Decontamination Unit)
       Revegetation
       Application of Dust Suppressant
       Cover/Cap
Interim Measures for Stabilization Scope of Work Outline

The following scope of work outline may be used as a model for the items that could
be included to address stabilization activities at a facility.  An example of a detailed
scope of work for implementing ISMs is provided in Appendix E.

        INTERIM MEASURES FOR STABILIZATION SCOPE OF WORK
  I.    Introduction/Executive   Summary   -  A   brief   description   of   any
       interim/stabilization measures that are being recommended in Section 3 below
       to achieve stabilization.
  II.    Current Conditions -A brief description of the current conditions at the site
  	including a review of any interim measures that are underway at the site.	
  III.   Interim Measures for Stabilization (implementing agency  will choose
       applicable requirements)
       A.     Interim Measures Objectives
       B.     Description of Interim Measures and Conceptual Design (may include
              performance-based design)
       C.     Construction/Implementation (may be phased)
       D.     Operation and Maintenance
       E.     Waste Management (e.g., CAMU/TU)	
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IV.  Sampling and Analysis (if applicable)
     A.     Purpose/Data Quality Objectives (may not be as stringent as for RFI)
     B.     Summary of Sampling Activities
     C.     Field Methods and Sample Analysis
            1.      Sample Locations and Depths
            2.      Sample Location Maps
            3.      Summary Tables including sampling methods, holding times,
                   analytical methods, preservation methods, sample depths, etc.
            4.      Field Quality Control
	D.     Quality Assurance/Quality Control	
     Project Management
     A.     Project Organization
            1.     Personnel/Organizational Chart
     B.     Project Schedule
     C.	Reporting Requirements (e.g., Report of Findings)
VI.  Other Submittals
     A.     Health & Safety Plan
     B.     Public Involvement Plan (optional at implementing agency's
            discretion)
     C.     Final Report on the Success of the ISMs in meeting stated goal of
            stabilization.
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                    Chapter III:  RCRA Facility Investigation

Introduction

       As stated in Chapter I, the objective of the RFI is to evaluate thoroughly the
nature and extent of the releases of hazardous waste and hazardous constituents and to
gather necessary data to support the CMS and/or interim/stabilization measures
(ISMs). The RFI may be focused specifically on ISMs data needs.  Alternatively,
environmental threats may be discovered or other situations may  arise that warrant
the implementation of ISMs during the RFI.

       The RFI model scopes of work (SOWs) are intended to provide guidance for
determining the specific work to be performed by the Permittee/Respondent and to
foster timely, concise, and technically adequate submissions by
Permittees/Respondents. The model scopes of work are also intended to assist in
streamlining the corrective action process. To achieve these goals, it is important
when using the model scopes of work to consider facility-specific  conditions.

       Based on facility-specific  circumstances some data collection steps may not be
necessary.  The implementing agency should endeavor to minimize unnecessary and
unproductive investigations, and to focus resources on characterizing actual
environmental problems at facilities.  For example, for inactive units that do not
contain substantial volumes of volatile organic compounds, RFIs will rarely need to
address air releases. In addition, RFIs may be phased to  avoid unnecessary
investigations where a concern can be quickly eliminated.  These determinations will
be made at the discretion of the implementing agencies.

       The information collected during the RFI will be used to either determine the
need for the next step in the corrective action process - the CMS and/or ISMs - or
alternatively, used to support the recommendation for no further action.  If, as a result
of the RFI, a CMS (or ISMs) is determined to be  necessary,  data collected during the
RFI (and release assessment, if performed), should be used to support the decision-
making process for identifying potential technologies to be considered during the
CMS (or ISMs).  Appendix F presents typical geologic data needs for standard
technologies, which may be considered during the CMS or  ISMs.  These scopes of
work should be modified as necessary at the discretion of the implementing agency to
require only that information necessary to complete the  RFI.

       The RFI stage of the corrective action process requires ongoing interaction
between the Permittee/Respondent and the implementing agency. At various times
during the RFI, there are requirements to submit reports to the implementing agency.
At the end of the following sections, where appropriate, the required report
submissions are noted in detail.  At the end of this chapter, a proposed schedule is
presented, which would indicate where in the RFI process each required report would
need to be submitted to the implementing agency.

Release Assessment  [optional phase]

       A release assessment may be performed as the first phase of an RFI. This step
would take place between the RFA and RFI. The release assessment (or Phase I RFI)
may serve as an update to the RFA if there is some uncertainty about releases after the
RFA.  Some examples of when the release assessment might be appropriate include

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when the implementing agency believes confirmatory sampling is needed or when
new waste management activities have begun at a facility.  In addition, it may help
determine if there has been a release to ecological/living resources.

       The release assessment may help  determine if the RFI should focus on one area
before another and/or if interim/stabilization measures are necessary. Therefore, the
release assessment should be viewed as an optional step  to minimize corrective
action activities (i.e., by focusing or streamlining the RFI) and not as an added
step in the process.

       The following scope of work may be used as a model for a release assessment.
Note  that it serves as an outline, and additional detail  may be obtained from the
appropriate section of the RFI Scope of Work that follows it.

                        Release Assessment Scope of Work

1.     Release Assessment Investigation

       1.1     Objectives
                    -Release Assessment Investigation Objectives
                    -Rationale for this Release Assessment Investigation
       1.2     Description of Current Conditions
                    -Facility Background (include findings from RFA-address, at a
                    minimum, each SWMU and AOC identified in the RFA)
                    -Summary of previous field conditions/investigations (if any)
       1.3     Project Description/Workplan
                    1) Objectives of Workplan
                    2) Field Investigation (sample locations map, media to be
                    sampled, number and location of samples to be taken, etc.)
                    3) Field Sample Collection Procedures
                    4) Field Measurements
                    5) QA/QC Procedures
                    6) Sample Analysis:  Methods, Laboratories
                    7) Data Management: Data Records,  Display Format (Tabular,
                    Graphical)
                    8) Schedule
                           -Dates to submit Progress Reports (if necessary)
                           -Dates to submit Findings Report
                    9) Health and Safety Plan
                    10) Public Involvement Plan  (optional at implementing agency's
                    discretion)

2.     Findings Report

              2.1    Overview
                    -Confirmation of Adherence to Workplan
                    -Identification and Logging of all Sample Locations
                    -Summary of findings
              2.2    Data Analysis and Determination of Further Action
                    1)     Analysis of all facility assessments and results
                    2)     Assessment of type and known extent of contamination
                           at each SWMU  or  area of concern (AOC)

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                    3)     Recommendation for further action (implementing
                           agency makes decisions)
                           -RFI
                           -Phase 2 Release Assessment (conducted under rare or
                           unusual circumstances)
                           -Interim Measures to achieve stabilization
                           -CMS
                           -CMI
                           -Combinations of the above
                           -No Further Action
             2.3    Provide a Description of the Selected Recommendation
                    -Rationale/Objectives
                    -Process/Technology /Actions
3.      Schedule for next phase (addressing major step(s))
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 [NOTE: With certain exceptions, the provisions set out in Sections I through VII are
 intended as guidance, and these provisions should be justifiable and tailored to site-specific
 co n ditio ns when in co rporated in to perm its or o rders. The exceptio n s are certain provisio n s
 which are based on specific regulatory or statutory requirements applicable to permitting.
 Regulatory and statutory requirements are  binding and do not require site-specific
justification. Applicable requirem ents include: public notice requirem ents specified in 40
 CFR subpart D, requirem ents in 40 CFR §264.101, and applicable inform ation
 requirem ents in 40 CFK Jf 270.14, including information requirem ents for SWMUs in §
 270.14(d).]

              Scope of Work for a RCRA  Facility Investigation (RFI)

 Purpose

        The purpose of the RCRA Facility Investigation (RFI) is to determine the
 nature and extent of releases of hazardous waste or constituents from regulated units,
 solid waste management units, and other source areas at a facility and to gather all
 necessary data to support a Corrective  Measures Study. The Permittee/Respondent
 shall furnish all personnel, materials, and services necessary for, or incidental to,
 performing the RFI.

 Scope

        The RCRA  Facility Investigation is one step in the corrective action program.
 The RFI consists of the following components, which for clarity have been designated
 as sections.

 [NOTE- The implem enting agency may choose to combine or eliminate som e of the sections
 below.  Some typical examples include combining sections III, IV, and Vinto one "RFI
 Report" and eliminating section IV.]

        Section I: Description of Current Conditions

              A.     Facility Background

              B.     Preliminary Assessment of Nature and Extent of
                     Contamination

              C.     Implementation of Interim/Stabilization Measures

        Section II: RFI Workplan

              A. Purpose/Objectives

              B. Project Management

              C. Data Collection/Quality Assurance

              D. Data Management and  Reporting

              E. Health and Safety Plan
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       F. Public Involvement Plan

       G. Schedule for Facility Investigation

Section III: Facility Investigation

       A. Purpose/Objectives

       B. Environmental Setting

       C. Source Characterization

       D. Contamination Characterization

       E. Potential Receptor Identification

Section IV: Preliminary Evaluation of Corrective Measure Technologies by
Laboratory or Bench-Scale Studies [optional]

Section V:  Investigation Results and Analysis

       A. Data Analysis

       B. Media Cleanup Standards [where applicable]

       C. Analysis of Risk [optional]

Section VI: Progress Reports

Section VII: Proposed Schedule
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Section I: Description of Current Conditions

       The Permittee/Respondent shall submit, for implementing agency approval, a
report (as set forth below) providing the background information  on the facility,
contamination, and interim measures.  The Permittee/Respondent shall indicate in the
applicable section if some of this information is not available.  This report shall
contain information that is consistent with the data gathered during the RFA (and the
release assessment, if performed). The current condition report shall be submitted
prior to, or concurrently with, the submission  of the RFI to allow the implementing
agency time to review it.

[NOTR- The RFA (and the release assessment, ifperformed) may be submitted as the
current conditions report, with updates when applicable.  The implem enting agency also
m ay allow the Permittee/Respondent to reference  the appropriate sections of the RFA or
other such documents (i.e., perm it application or permit). For example, if map information
is already present in a permit application, the agency m ay allow the Permittee to reference
the appropriate provisions of the application^

A. Facility Background

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

       1. Map(s). For permitted facilities, all maps shall be consistent with the
       requirements set forth in 40 CFR §270.14 and be of sufficient detail and
       accuracy to locate and report all current and future work performed at the site.
       (Aerial photographs should be included with SWMUs and AOCs
       superimposed on them.)  Maps  shall depict the following (to the extent not
       already included in map requirements under 40 CFR §270.14 (b)(19) for
       permitted facilities):

              •      General geographic location;

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

              •      Topography and surface drainage (with a contour interval of
                    [number] feet and a scale  of 1 inch =100 feet) depicting all
                    waterways, wetlands, flood plains, water features, drainage
                    patterns, and surface-water containment areas;

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

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

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

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

                    Surrounding land uses (residential, commercial, industrial,
                    agricultural, recreational);

                    The location of all production and groundwater monitoring
                    wells on the facility and within a 2-mile radius of the facility
                    boundary. These wells shall be clearly labeled and ground and
                    top of casing elevations and construction details included (these
                    elevations and details may be included as an attachment); and

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

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

       4.     A summary of past permits applied for and/or received, any
             enforcement actions and their subsequent responses and a list of
             documents and studies prepared for the facility. This may include
             information from previous  owner/operators, if available.

B. Preliminary Assessment of Nature and Extent of Contamination

       The Permittee/Respondent shall prepare  and submit, for implementing agency
       approval, a preliminary report describing the existing information on the
       nature and extent of contamination.
       1.     The Permittee's/Respondent's report shall summarize all possible
             source areas of contamination. This, at a minimum, shall include all
             RCRA-regulated units, solid waste management units, spill areas, and
             other suspected source areas of contamination. For each area, the
             Permittee/Respondent shall identify the following:

             •      Location of unit/area (to be depicted on facility map provided
                    in Section I);

             •      Quantities of solid and hazardous wastes (both managed and
                    spilled or released);

             •      Type of Hazardous waste or constituents (both causing or
                    potentially causing contamination), to the extent known;

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              •      Identification of areas where additional information is necessary;
                    and

                    The results of both the RCRA Facility Assessment (RFA)  and a
                    summary of suggested further actions for all SWMUs and Areas
                    of Concern  (AOCs) and the release assessment (if performed).

       2.      The Permittee/Respondent shall prepare a preliminary assessment and
              description of the existing degree and extent of contamination. This
              shall include:

              •      For  each medium where the permit or order identifies a release
                    (e.g., soil, ground water, surface water, air, etc.), a description of
                    the existing extent of contamination. This description must
                    include all available monitoring data and qualitative information
                    on the locations and levels of contamination at the facility  (both
                    onsite  and offsite).  Include biodata (e.g., fishkills, distressed
                    vegetation, abnormal  individuals of a species, carcasses, tissue
                    studies, etc.). Include a general assessment of the data quality, a
                    map showing the location of all existing sampling points and
                    potential source areas and contour maps showing any existing
                    ground water plumes at the facility (if ground water release).
                    Highlight potential ongoing release areas that would warrant use
                    of interim corrective measures (see Paragraph C.
                    Implementation of Interim/Stabilization Measures).

              •      A list and brief description of all previous investigations that
                    have occurred at the facility, who they were conducted for (i.e.,
                    agency) and agency contacts.

       3.      The Permittee/Respondent shall prepare a preliminary assessment and
              description of potential migration pathways. This shall include:

              •      All potential migration pathways including information on
                    geology, pedology, hydrogeology, physiography, hydrology,
                    water quality, foodwebs, meteorology, and air quality;

              •      Physical properties of contaminants; and

              •      An assessment of whether off-site migration of contaminants has
                    occurred; (may  include a conceptual model of contaminant
                    migration).

       4.      The Permittee/Respondent shall describe the potential impact(s) on
              human health and the environment, including demography,
              identification  of possible sensitive subpopulations (e.g., schools, homes
              for the elderly, hospitals and ecosystems), ground water and surface
              water use, and land use.

C.     Implementation of Interim/Stabilization Measures

       [NOTR- See Chapter IIfor m ore guidan ce and a m odel scope of w ork]

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       The Permittee's/Respondent's report shall document past, present, or
       proposed interim/stabilization measures at the facility.  This shall include:

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

              •       Design, construction, operation, and maintenance requirements;

              •       Schedules for design, construction and monitoring;

              •       Schedule for progress reports; and

              •       Data in support of the potential need for future interim
                     measures or related to any assessment undertaken to determine
                     the need for future interim/stabilization measures.


Section II: RFI Workplan

       [NOTE- The implementing agency willreview the RFI Workplan to determine its
       technical accuracy and completeness and to determine its effectiveness toward
       conducting a sound, comprehensive investigation of all contamination at the
      facility^

A. Purpose/Objectives

       The Permittee/Respondent shall prepare an RFI Workplan.  The purpose of
       the RFI Workplan is to present to the implementing agency the
       Permittee's/Respondent's specific plans to characterize the nature and extent of
       contamination.  This RFI Workplan shall include  the development of several
       plans, which shall be prepared concurrently.  During the RCRA Facility
       Investigation,  it  may be necessary to revise the RFI Workplan to increase or
       decrease the detail  of information collected to accommodate facility-specific
       situations.

       [NOTE- The implem enting agency generally will require the
       Permittee/Respondent to test m edia to determine the  presence and levels of
       hazardous constituents.  The implementing agency may use AppendixTXto 40
       CTKpart 264 - Ground-Water Monitoring List for ground w ater. Tor purposes
       of establishing a list for other m edia, the implem enting agency may use Appendix
       XI - Concentration-Based Exemption Criteria for Media from the Hazardous
       Waste Identification Rule (HWIR)proposed rule (57TK 21450, May 20, 1992).
       This appen dix lists con stituentsfor w hich an alytical m ethods are available. To
       streamline the list of constituents requiring analysis, the implem enting agency
       m ay use other inform ation  (e.g., lists of chemicals used at a facility) as
       appropriate^

B. Project Management

       The Permittee/Respondent shall prepare a Project Management Plan, which

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       will include a discussion of the technical approach, schedules, (including
       submittal of the CMS Workplan, if required), budget, and personnel. The
       Project Management Plan will also include a description of qualifications of
       personnel performing or directing the RFI, including contractor personnel.
       This plan shall also document the overall management approach to the RFI.

C. Data Collection/Quality Assurance

       To ensure that all information, data and resulting decisions are technically
       sound, statistically valid, and properly documented, the Permittee/Respondent
       shall prepare a Quality  Assurance Project Plan (QAPJP) to document all
       monitoring procedures, sampling, field measurements and sample analyses
       performed during the investigation to characterize the environmental setting,
       source, and contamination. The Permittee/Respondent shall use quality
       assurance, quality control, and chain-of-custody procedures approved by the
       implementing agency.

       These procedures are described in the soon to be released EPA Requirements
       for Quality Assurance Project Plans for Environmental Data Operations (EPA
       QA/R-5), which will replace Interim Guidelines and Specifications for
       Preparing Quality Assurance Project Plans. (QAMS-005/80,  December 29,
       1980).   The minimum elements of a quality assurance program for data
       collection activities are in Chapter One of SW-846 [see AppendixBJznd are
       outlined below.
       1.0     INTRODUCTION

       2.0     QA PROJECT PLAN
              2.1    Data Quality Objectives
              2.2    Project Objectives
              2.3    Sample Collection
              2.4    Analysis and Testing
              2.5    Quality Control
              2.6    Project Documentation
              2.7    Organization Performing Field or Laboratory Operations
                    2.7.1  Performance Evaluation
                    2.7.2  Internal Assessment by QA  Function
                    2.7.3  External Assessment
                    2.7.4  On-Site Evaluation
                           2.7.4.1 Field Activities
                           2.7.4.2 Laboratory Activities
                    2.7.5  QA Reports

       3.0     FIELD OPERATIONS
              3.1    Field Logistics
              3.2    Equipment/Instrumentation
              3.3    Operating Procedures
                    3.3.1  Sample Management
                    3.3.2  Reagent/Standard Preparation

                    3.3.3  Decontamination

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                    3.3.4   Sample Collection
                    3.3.5   Field Measurements
                    3.3.6   Equipment Calibration and Maintenance
                    3.3.7   Corrective Action
                    3.3.8   Data Reduction and Validation
                    3.3.9   Reporting
                    3.3.10  Records Management
                    3.3.11  Waste Disposal
             3.4    FIELD QA AND QC REQUIREMENTS
                    3.4.1   Control Samples
                    3.4.2   Acceptance Criteria
                    3.4.3   Deviations
                    3.4.4   Corrective Action
                    3.4.5   Data Handling
             3.5    QUALITY ASSURANCE REVIEW
             3.6    FIELD RECORDS
       4.0    LABORATORY OPERATIONS
             4.1    FACILITIES
             4.2    EQUIPMENT/INSTRUMENTATION
             4.3    OPERATING PROCEDURES
                    4.3.1   Sample Management
                    4.3.2   Reagent/Standard Preparation
                    4.3.3   General Laboratory Techniques
                    4.3.4   Test Methods
                    4.3.5   Equipment Calibration and Maintenance
                    4.3.6   QC
                    4.3.7   Corrective Action
                    4.3.8   Data Reduction and Validation
                    4.3.9   Reporting
                    4.3.10  Records Management
                    4.3.11  Waste Disposal
             4.4    LABORATORY QA AND QC PROCEDURES
                    4.4.1   Method Proficiency
                    4.4.2   Control Limits
                    4.4.3   Laboratory Control Procedures
                    4.4.4   Deviations
                    4.4.5   Corrective Action
                    4.4.6   Data Handling
             4.5    QUALITY ASSURANCE REVIEW
             4.6    LABORATORY RECORDS
D. Data Management and Reporting

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

The data record shall include the following:

       •       Unique sample or field measurement code;

       •       Sampling or field measurement location and sample or
              measurement type;

       •       Sampling or field measurement raw data;

       •       Laboratory analysis ID number;

       •       Property or component measured; and

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

2.      Tabular Displays

The following data shall be presented in tabular displays:

       •       Unsorted (raw) data;

       •       Results for  each medium or for each constituent monitored;

       •       Data reduction for statistical analysis;

       •       Sorting of data by potential stratification factors (e.g., location,
              soil layer, topography); and

       •       Summary data.

3.      Graphical Displays

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

       •       Sampling location and sampling grid;

       •       Boundaries of sampling area, and areas where additional data are
              required;

       •       Levels of contamination at each sampling location;

       •       Geographical extent of contamination;

       •       Contamination levels, averages, and maxima;

       •       Changes in concentration in relation to distance from the
              source, time, depth or other parameters;
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              •      Features affecting intramedia transport; and

              •      Potential receptors.

E. Health and Safety Plan

       The Permittee/Respondent shall submit a Health and Safety Plan for all field
       activity, although it does not require review and approval by the implementing
       agency. The Health and  Safety Plan shall be developed as a stand alone
       document but may be submitted with the RFI Workplan.

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

              •      Facility description including availability  of resources such as
                    roads, water supply, electricity, and telephone service;

              •      Description of the known hazards and evaluation of the risks
                    associated  d with each activity conducted;

              •      A list of key personnel and alternates responsible for site safety,
                    response operations, and protection of public health;

              •      Delineation of work area;

              •      Description of protective clothing or other protective items  to
                    be worn by personnel in work area;

              •      Procedures to control site access;

              •      Description of decontamination procedures for personnel and
                    equipment;

              •      Site emergency procedures;

              •      Emergency medical care needed for injuries and toxicological
                    problems;

              •      Description of requirements for an environmental surveillance
                    program;

              •      Routine and special training required for response personnel;
                    and
              •      Procedures for protecting workers from weather-related
                    problems.

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

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

              •      EPA Order 1440.1 -Respiratory Protection;
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              •      EPA Order 1440.3 -Health and Safety Requirements for
                    Employees engaged in Field Activities;

              •      Facility Contingency Plan;

                    EPA Standard Operating Safety Guide (1984);

                    OSHA regulations particularly in 29 CFR 1910 and 1926;

              •      State and local regulations; and

              •      Other applicable EPA guidance as provided.

F.     Public Involvement Plan

       [NOTE- It is strongly recommended that the implementing agency oversee
       Permittee's /Respondent'spublic involvem ent activities. Public involvement is an
       important part ofRCRA corrective action.  The public must be notified of
       significant changes to permits and orders regarding corrective action.  In som e cases,
       they also must be provided with the opportunity to review and com m ent on the
       changes. Notice requirem entsfor permits are set out at 40 CFR Part 270 subpartD.
       Further guidance on thisprocess is in the CMS, and in the document entitled RCRA
       Public Involvem ent Manual (EPA/530-R-93-006, Septem her,  1993).]

       All Public Involvement Plans prepared by the Permittee/Respondent  shall be
       submitted to the implementing agency for comment and approval prior to use.
       Permittees/Respondents must never appear to represent or speak  for the
       implementing agency before the public, other government officials, or the
       media.

       Public Involvement activities that may be required of the
       Permittee/Respondent include the following:

              1.     Conducting an open house or informal meeting (i.e., availability
                    session) in a public location where people can talk to agency
                    officials and Permittee/Respondent on a one-to-one basis;

              2.     Preparing fact sheets summarizing current or proposed
                    corrective action activities  (all fact sheets should be reviewed by
                    the implementing agency prior to public distribution);

              3.     Communicating effectively with people who have vested interest
                    in the  corrective action activities, (e.g., providing written or
                    verbal information in the foreign language of a predominantly
                    non-English-speaking community); and

              4.     Maintaining an easily accessible repository (such as a town hall
                    or public library  or the facility itself,  in some limited
                    circumstances) of information on the facility-specific corrective
                    action program, including the order or permit, approved
                    workplans, and/or other reports.
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       A schedule for community relations activities shall be included in the Public
       Involvement Plan.

G.     Schedule for Facility Investigation

       [NOTE- Schedules should be as detailed as possible, but can be represented as a
       series of contingent activities (e.g., sampling beginning within 30 days of RFI
       Workplan approval).  This schedule may be required or revised during the next
       section entitled "Facility Investigation"^
       \.     Sampling

       2.     Analysis

       3.     Reports

       4.     Public Involvement Activities

       5.     Laboratory or Bench-Scale Studies

Section III: Facility Investigation

A.      Purpose/Objectives

       The Facility Investigation phase of an RFI is the first step of the
       implementation process. Prior to this implementation phase, all
       documentation and reports for the Description of Current Conditions and RFI
       Workplan are drafted and submitted to the implementing agency for review
       and approval.  The Permittee/Respondent must have approval prior to
       implementing the procedures outlined in the RFI Workplan.  Throughout the
       RFI implementation phase, it is critical that the Permittee/Respondent comply
       with report submission requirements. The Permittee/Respondent shall submit
       both progress reports and a draft RFI Report, which must be submitted to the
       implementing agency for review.  At the direction  of the implementing agency,
       the Permittee/Respondent shall develop in final format the RFI Report, which
       will incorporate any comments received on the draft report.

       The Permittee/Respondent shall conduct those investigations (including
       sampling) as approved in the RFI Workplan with all modifications to:
       characterize the facility (Environmental Setting); define the source (Source
       Characterization); define the degree and three dimensional extent of
       contamination (Contamination Characterization);  and identify actual or
       potential receptors.

       The investigations should result in data of adequate technical  quality to
       support the development and evaluation of the corrective measure
       alternative(s) during the Corrective Measures Study (CMS) and/or ISMs.

       [NOTE As discussed in the 40 CFKpart 264 subpart Sproposed rule (55 FK
       30875-30876, July  27, 1990), the implementing agency m ay require the
       Permittee/Respondent to conduct a CMS whenever concentrations of hazardous
       constituents in an aquifer, surface water, soils, or air exceed action lev els for any
       en v iron m ental m edium.  Action levels are health- and en v iron m ental-based

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       levels determined by the agency to be indicators for protection of hum an health
       and the environment. EPA's recommended action levels are set out in the
       subpart S'proposed rule.  'EPA, currently is working on revisions to the
       recommended levels and willprovide notice of any changes to the subpart S
       recom m en dations.}

       The site investigation activities (including sampling) shall follow the plans set
       forth in the RFI Workplan.

       [NOTE- The implem enting agency may require the investigation to be phased
       (e.g.,  by media or SWMU/Area of Contamination), the amount of inform ation
       collected to be limited, and/ or the level of detail to be reduced^

B.     Environmental Setting

       The Permittee/Respondent shall collect information to supplement and verify
       existing information on the environmental setting at the facility (when
       information already submitted  to the implementing agency  is not sufficient).
       The implementing agency may request additional information not included on
       the following lists.  The Permittee/Respondent shall characterize the following
       areas (the implementing agency should require characterization of some or all
       of the following areas depending on the specifics of the site):

       1.     Hydrogeology

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

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

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

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

                           Depositional history;

                           Areas and amounts of recharge and discharge;

                           Influence of tidal actions on groundwater flow regimes
                           near coastal areas or large rivers;

                           Regional and facility-specific ground-water flow patterns;
                           and

                           Seasonal variations in the ground-water flow regime.

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

A representative and accurate classification and description of
the hydrogeologic units based on field data, tests, and cores that
may be part of the migration pathways at the facility (i.e.,  the
aquifers and any intervening saturated and unsaturated zones),
including, but not limited to:

       Hydraulic conductivity, intrinsic permeability
       (particularly when non-aqueous phase liquids (NAPLs)
       are present), and porosity (total and effective);

       Lithology, grain size, sorting, degree of cementation;

       An interpretation of hydraulic interconnections between
       saturated zones; and

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

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

       Sand and gravel in unconsolidated deposits;

       Zones of fracturing or channeling in consolidated and
       unconsolidated deposits;

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

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

       Water-bearing zones above the first confining layer that
       may serve as a pathway for contaminant migration,
       including perched zones of saturation; and

       All other geologic formations, or parts thereof, yielding
       a significant amount of ground water.

Based on data obtained from ground-water monitoring wells and
piezometers installed upgradient and downgradient  of the
potential contaminant  source, a representative description  of
water level or fluid pressure monitoring including:

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                     Water level contour and/or potentiometric maps;

                     Hydrologic cross sections showing vertical flow
                     gradients;

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

                     Any temporal changes in hydraulic gradients, (due to
                     tidal or seasonal influences, etc.)

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

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

                     Man-made hydraulic structures (pipelines, French drains,
                     ditches, unlined ponds, septic tanks, NPDES outfalls,
                     retention areas, etc.).
2.      Soils
       [NOTE: Soil characterisation includes the chemical,physical, and
m in eralogical analysis of soils. The implem enting agency m ay vary the required
level of characterisation based on data needs for the CMS/ISMs.  Where removal of
co n tarn in ated soil is the logical rem edial actio n,     Urn ited physical info rm atio n
m ay be required. Where in-situ soil  treatm ent m ay be the rem edial action, a full
characterisation may be       appropriate.  Where an estimation of contaminant
transport is necessary,  some type of in term edi ate level characterisation m ay be
required.]

       The Permittee/Respondent shall conduct a program to characterize the
       soil and rock units potentially affected by contaminant release(s). Such
       characterization shall include, but not be limited to, the following
       information:

       •       Where remediation by removal of soils is the only corrective
              measure option, provide map(s) and perpendicular cross  sections
              showing:

                     The extent of contamination;

                     Depth of groundwater; and

                     The consistency and distribution of soils (using the
                     Unified Soil Classification System (USCS) (ASTM D
                     2487));

/NOTE: The above information is important for stability of cuts. If such factors
are not considered when excavating,piling, or sloping material, the stability of
surrounding w alls and piles of m aterial m ay be compromised.]

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Where remediation by removal is the likely option, and it is
necessary to determine the extent of migration (e.g., to assess the
mobility of wastes from an unlined surface impoundment or
landfill), provide the following in addition to the requirements
immediately above:

       Depth to bedrock and the characteristics of the bedrock
       including discontinuities such as faults, fissures, joints,
       fractures, sinkholes, etc.;

       A detailed soil survey conducted according to USDA Soil
       Conservation Service (SCS) procedures including:

              USDA Textural Soil Classification and soil
              profiles showing stratifications or zones which
              may affect or direct the subsurface flow;

              Hydraulic conductivity and the SCS hydrologic
              group classification of A, B, C or D;

              Relative permeability (only if the waste may have
              changed the soil's hydraulic conductivity, such  as
              concentrated organics);

              Storage capacity (if excavated soil will be stored);

              Shrink-swell potential (where extreme dry
             weather could lead to the formation of cracks);

              Potential for contaminant transport via erosion,
              using the Universal  Soil Loss Equation;

              Soil sorptive capacity;

              Cation exchange capacity;

              Soil organic content; and

              Soil pH.

       The following contaminant characteristics must be
       included:

              Physical state;

              Viscosity;

              pH;

              pKa;
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                           Density;

                           Water solubility;

                           Henry's Law Constant;

                           KOW;

                           Biodegradability; and

                           Rates of hydrolysis, photolysis and oxidation.

       •       Where in-situ soil treatment will likely be the remediation, the
              above information and the following additional information
              must be provided:

                    Bulk density;

                    Porosity;

                    Grain size distribution;

                    Mineral content;

                    Soil moisture profile;

                    Unsaturated hydraulic conductivity;

                    Effect of stratification on unsaturated flow; and

                    Infiltration and evapotranspiration.

3.     Surface Water and Sediment

The Permittee/Respondent shall conduct a program to characterize the surface
water bodies likely to be affected by  releases from the facility. Such
characterization shall include the following activities and information:

•      Description of the temporal and permanent surface water bodies
       including:

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

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

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

              For wetlands obtain any available delineation;

                                 33

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              Containment measures in place (e.g., levees, concrete lining, etc.)

              Drainage patterns; and

              Evapotranspiration rates.

•      Description of the chemistry of the natural surface water and sediments.
       This includes determining:

              pH;

              total dissolved solids;

              total suspended solids;

              biological oxygen demand;

              alkalinity;

              conductivity;

              dissolved oxygen profiles;

              nutrients (NH3, N03  /N02, PO/);

              chemical oxygen demand;

              total organic carbon; and

              specific contaminant concentrations.

•      Description of sediment characteristics including:

              Deposition area;

              Thickness profile; and

              Physical and chemical parameters (e.g., grain size, density,
              organic carbon content, ion exchange capacity, pH, etc.).

4.      Air

The Permittee/Respondent shall provide information characterizing the
climate in the vicinity of the facility.  Such information shall include:

•      A description  of the following parameters:

              Annual and monthly rainfall averages;

              Monthly temperature averages and extremes;

              Wind speed and direction;

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                    Relative humidity/dew point;

                    Atmospheric pressure;

                    Evaporation data;

                    Development of inversions; and

                    Climate extremes that have been known to occur in the vicinity
                    of the facility, including frequency of occurrence.

      •      A description of topographic and man-made features that affect air flow
             and emission patterns, including:

                    Ridges, hills, or mountain areas;

                    Canyons or valleys;

                    Surface water bodies (e.g., rivers, lakes, bays, etc.);

                    Wind breaks and forests; and

                    Buildings.

      /NOTE: The above descriptions should be updated to include any air m odeling that
      is perform ed.]

C.    Source Characterization

      [NOTE: The implem enting agency m ay focus source characterisation  on the
      specific units, disposal areas, or other areas (e.g., exposure pathways) that have
      been identified by the agency to be of concern.]

      The Permittee/Respondent shall collect analytical data to characterize the
      wastes and the areas where wastes have been placed, collected or removed
      including: type; quantity; physical form; disposition (containment or nature of
      disposal); and any facility characteristics that may affect or have affected a
      release (e.g., facility security, engineered barriers). This shall include
      quantification of the following specific characteristics, at each source area:

      1.     Unit/Disposal Area/Area of Concern Characteristics:

      •      Location of unit/disposal area;

      •      Type of unit/disposal area;

      •      Design features;

      •      Operating practices (past and present) including the history of releases;

      •      Period of operation;
                                        35

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•      Age of unit/disposal area;

•      General physical conditions; and

•      Method used to close the unit/disposal area.

2.      Waste Characteristics:

•      Type of waste placed in the unit;

              Hazardous classification (e.g., flammable, reactive, corrosive,
              oxidizing or reducing agent);

              Quantity; and

              Chemical composition.

•      Physical and chemical characteristics;

              Physical form (solid, liquid, gas);

              Physical description (e.g., powder, oily sludge);

              Temperature;

              pH;

              General chemical class (e.g., acid, base, solvent);

              Molecular weight;

              Density;

              Boiling point;

              Viscosity;

              Solubility in water;

              Cohesiveness of the waste;

              Vapor pressure; and

              Flash point.

•      Migration and dispersal characteristics of the waste;

              Sorption;

              Biodegradability, bioconcentration, biotransformation;

              Photodegradation rates;

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                    Hydrolysis rates; and

                    Chemical transformations.

       The Permittee/Respondent shall document the procedures used in making the
       above determinations.

D.     Contamination Characterization

       The Permittee/Respondent shall collect analytical data on ground water, soils,
       surface water, sediment, air, and subsurface gas likely to be affected by releases
       from the facility. This data shall be sufficient to define the extent, origin,
       direction, and rate of movement of contaminant plumes.  Data shall include:

       •      time and location of sampling;

       •      media sampled;

       •      concentrations found;

       •      conditions during sampling; and

       •      the identity  of the individuals performing the sampling and analysis.

       The Permittee/Respondent shall address the following types of contamination
       at the facility:

       1.     Groundwater Contamination

       The Permittee/Respondent shall conduct a groundwater investigation to
       characterize any plumes of contamination at the facility.  This investigation
       shall, provide the following information:

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

       •      The horizontal and vertical direction of contaminant movement;

       •      The velocity of contaminant movement;

       •      The horizontal and vertical concentration profiles of Appendix IX
             constituents in the plume(s);

       •      An evaluation of factors influencing the plume movement; and

       •      An extrapolation of future contaminant movement over the time period
             specified by  the implementing agency.

       The Permittee/Respondent shall document the procedures used in making the
       above determinations (e.g., well design, well construction, geophysics,
       modeling, etc.).
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[NOTE: It m ay be helpful for the Permittee/respondent to refer to applicable
guidance documents such as "RCRA Ground-w ater Monitoring Technical
Enforcement Guidance Document (TEGD),"OSWER. Directive 9950.1, September
1986.]

2.     Soil Contamination

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

•      A description of the vertical and horizontal extent of contamination;

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

•      Specific contaminant concentrations;

•      Velocity and direction of contaminant movement; and

•      An extrapolation of future contaminant movement over the time period
       specified by  the implementing agency.

The Permittee/Respondent shall document the procedures used in  making the
above determinations.

/NOTE- Analytical data collected under Section III. C. "Source  Characterisation",
Num her 2. "Waste Characteristics" m ay be relevant to this section.  This data m ay
be used to supplem ent this section or elem ents of the tw o  sections regarding w aste
characteristics m ay be combined.]

3.     Surface Water and Sediment Contamination

The Permittee/Respondent shall conduct a surface water investigation to
characterize contamination in surface water bodies resulting from contaminant
releases at the facility. The Permittee/Respondent may also be required to
characterize contamination from storm water runoff.

The investigation shall include the following information:

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

•      The horizontal and vertical direction of contaminant movement;

•      The contaminant velocity;
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•      An evaluation of the physical, biological, and chemical factors
       influencing contaminant movement;

•      An extrapolation of future contaminant movement over the time period
       specified by the implementing agency; and

•      A description of the chemical and physical properties of the
       contaminated surface waters and sediments.  This includes determining
       the pH, total dissolved solids, specific contaminant concentrations, etc.

The Permittee/Respondent shall document the procedures used in making the
above determinations.

4.      Air Contamination

The Permittee/Respondent shall conduct an investigation to characterize the
particulate and gaseous contaminants released into the atmosphere. This
investigation shall provide the following information:

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

•      The rate and amount of the release; and

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

The Permittee/Respondent shall document the procedures used in making the
above determinations.

5.      Subsurface Gas Contamination

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

•      A description of the horizontal and vertical extent of subsurface gas
       migration;

•      The chemical composition of the gases  being emitted;

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

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

The Permittee/Respondent shall document the procedures used in making the
above determinations.
E.     Potential Receptor Identification

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The Permittee/Respondent shall collect data describing the human populations
and environmental systems that currently or potentially are at risk of
contaminant exposure from the facility.  Chemical analysis of biological
samples may be needed. Data on observable effects in ecosystems may also be
required by the implementing agency.  The following characteristics shall be
identified:

1.      Local uses and possible future uses of ground water:

       •      Type of use  (e.g., drinking water source: municipal or
              residential, agricultural, domestic/non-potable, and industrial)
              and

       •      Location  of ground water users including wells and discharge
              areas.

2.      Local uses and possible future uses of surface waters characterized in the
       "Environmental  Setting" or "Contamination Characterization" Sections
       above:

       •      Domestic and municipal (e.g., potable and lawn/gardening
              watering);

       •      Recreational (e.g., swimming, fishing);

       •      Agricultural;

       •      Industrial; and

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

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

       •      Recreation;

       •      Hunting;

       •      Residential;

       •      Commercial;

       •      Zoning; and

       •      Relationship between population locations and prevailing wind
              direction.

4.      A demographic profile of the people  who use or have access  (authorized
       or unauthorized) to the facility  and adjacent land, including, but not
       limited to: age; sex;  sensitive subgroups; and environmental justice
       concerns.
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       5.      A description of the ecology of the facility and adjacent areas, including
              habitat and species present and expected to be present.

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

       7.      A description of any state and federal endangered or threatened species
              (both proposed and listed) near the facility.
Section IV:  Preliminary Evaluation of Corrective Measure Technologies by
Laboratory or Bench-Scale Studies [optional]

       The Permittee/Respondent may conduct laboratory and/or bench scale studies
       to determine the applicability of a corrective measure technology  or
       technologies to facility conditions. These studies may be conducted at any
       time during the RFI; the intent is to collect information that will  be useful in
       evaluating potential technologies and to conduct additional studies when
       sufficient data is available and useful. The Permittee/Respondent shall analyze
       the technologies, based on literature review, vendor contracts, and past
       experience to determine the testing requirements.

       [NOTE: Appendix f'presents standard geologic data requirem entsfor consideration
       in the technology decision process, and Appendix'^provides referencesfor technical
       assistance (e.g.,  "Guidancefor Conducting Rem edialInvestigations and Feasibility
       Studies Under CEKCLA" - Chapter 5).]

       The Permittee/Respondent shall develop a testing plan identifying the type(s)
       and goal(s) of the study or studies, the level of effort needed, and the
       procedures to be used for data management and interpretation.

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

       The Permittee/Respondent shall prepare a report summarizing the testing
       program and its results (if studies are performed), both positive and negative.
Section V: Investigation Results and Analysis

       The Permittee/Respondent shall prepare an analysis and summary of all facility
       investigations and their results. The investigation data should be sufficient in
       quality (e.g., quality assurance procedures have been followed) and quantity to
       describe the nature and extent of contamination, potential threat to human
       health and/or the environment, and to support the Corrective Measures Study
       and/or ISMs.

A.     Data Analysis

       The Permittee/Respondent shall analyze all facility investigation data outlined
       in Section III and prepare a report on the type and extent of contamination at

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       the facility including sources and migration pathways. The report shall describe
       the extent of contamination (qualitative/quantitative) in relation to
       background levels indicative for the area.

B.     Media Cleanup Standards

       The Permittee/Respondent shall provide information as required by the
       implementing agency to support the agency's selection/development for media
       cleanup standards of any releases that may have adverse effects on human
       health and the environment due to migration of waste constituents.  Media
       cleanup standards are to contain such terms and provisions as necessary to
       protect human health and the environment, including, the provisions stated
       below.

       /NOTE: Implementing agencies should determine which of the following items
       under 1 through 4 below are necessary on a site-specific basis.]
       \.     Ground-water Cleanup Standards

       The Permittee/Respondent shall provide information to support the
       implementing agency's selection/development of ground-water cleanup
       standards for all of the Appendix EX constituents found in the ground water
       during the Facility Investigation (Section III). The implementing agency may
       require the following information:

             •      For any constituents for which an MCL has been promulgated
                    under the Safe Drinking Water Act, the MCL value;

             •      Background concentration of the constituent in the ground
                    water; or

             •      An alternate standard (e.g., an alternate concentration limit
                    (ACL)  for a regulated unit) to be approved by the implementing
                    agency.
       2.     Soil Cleanup Standards

       The Permittee/Respondent shall provide information to support the
       implementing agency's selection/development of soil cleanup standards.
       The implementing agency may require the following information:

             •      The volume and physical and chemical characteristics of the
                    wastes in the unit;

             •      The effectiveness and reliability of containing, confining, and
                    collecting systems and structures in preventing contaminant
                    migration;

             •      The hydrologic characteristics of the unit and the surrounding
                    area, including the topography of the land around the unit;

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       •      The patterns of precipitation in the region;

       •      The existing quality of surface soils, including other sources of
             contamination and their cumulative impacts on surface soils;

       •      The potential for contaminant migration and impact to the
             underlying groundwater;

       •      The patterns of land use in the region;

       •      The potential for health risks caused by human exposure to
             waste constituents; and

       •      The potential for damage to domestic animals, wildlife, food
             chains, crops, vegetation, and physical structures caused by
             exposure to waste constituents.

3.      Surface Water and Sediment Cleanup Standards

The Permittee/Respondent shall provide information to support the
implementing agency's selection/development of surface water and sediment
cleanup standards. The implementing agency may require the following
information:

       •      The volume and physical and chemical characteristics of the
             wastes in the unit;

       •      The effectiveness and reliability of containing, confining, and
             collecting systems and structures in preventing contaminant
             migration;

       •      The hydrologic characteristics of the unit and the surrounding
             area, including the topography  of the land around the unit;

       •      The patterns of precipitation in the region;

       •      The quantity, quality, and direction of ground-water flow;

       •      The proximity of the unit to surface waters;

       •      The current and potential uses of nearby surface waters and  any
             water quality standards established for those surface waters;

       •      The existing quality of surface waters, including other sources of
             contamination and their cumulative impacts on surface waters;

       •      The potential for damage to domestic animals, wildlife, food
             chains, crops, vegetation and physical structures caused by
             exposure to waste constituents;

       •      The patterns of land use in the region; and
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              •      The potential for health risks caused by human exposure to
                    waste constituents.

       4.      Air Cleanup Standards

       The Permittee/Respondent shall provide information to support the
       implementing agency's selection/development of air cleanup standards. The
       implementing agency may require the following information:

              •      The volume  and physical and chemical characteristics of the
                    wastes in the unit, including its potential  for the emission and
                    dispersal of gases, aerosols and particulates;

              •      The effectiveness and reliability of systems and structures to
                    reduce or prevent emissions of hazardous constituents to the air;

              •      The operating characteristics of the unit:

              •      The atmospheric, meteorological, and topographic
                    characteristics of the unit and the surrounding area;

              •      The existing quality of the air, including other sources of
                    contamination and their cumulative impact on the air;

              •      The potential for health risks caused by human exposure to
                    waste constituents; and

              •      The potential for damage to domestic animals, wildlife, crops,
                    vegetation, and physical structures caused by exposure to waste
                    constituents.

       5.      Other Relevant Cleanup Standards

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

C.     Analysis of Risk [optional]

       The implementing agency may require the Permittee/Respondent to prepare
       an analysis of risk at the facility. This analysis may include ecological as well
       as human health risk.  Generally a baseline risk assessment would be conducted
       during the RFI stage with further analysis occurring during the CMS stage.

       [NOTE:  While som e implementing agencies may require the Permittee/Respondent
       to conduct a risk assessment,  the policy  on  conducting risk assessm ents in  the
       corrective action program is  evolving.  Currently, their use is optional at the
       discretion of the implem enting agency and should be based on site-specific
       conditions. AppendixG presents a list of available guidance for conducting risk
       assessm ents.]
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Section VI:  Progress Reports

       The Permittee/Respondent will, at a minimum, provide the implementing
       agency with signed [monthly, bimonthly, or quarterly] progress reports. These
       reports may be required to contain the following information, but agency
       requirements are not limited to this list:

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

       2.      Summaries of all findings in the reporting period, including results of
              any sampling and analysis;

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

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

       5.      Summaries of all contacts made regarding access to off-site property;

       6.      Summaries of all problems encountered during the reporting period;

       7.      Actions being taken to rectify problems;

       8.      Changes in relevant personnel during the reporting period;

       9.      Projected work for the next reporting period; and

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

Section VIII: Proposed  Schedule

The Permittee/Respondent will provide the implementing agency
with RFI reports according to the following schedule:

    Facility Submission              Due Date

    Description of Current          [DATE]
    Conditions
    (Section I)
   RFIWorkplan                  [DATE]
   (Section II)
   Draft RFI Report               [NUMBER ] days after
   (Sections III and V)              RFI Workplan Approval

   Final RFI Report                [ NUMBER ] days after
   (Sections III and V)              the implementing agency
   comments on Draft RFI                      Report, (date

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of approval                      may be tied to this submittal
of the CMS                      Workplan, if required,)

Laboratory and Bench-           Concurrent with Final RFI
Scale Studies                     Report
(Section IV)

Progress Reports on             [ MONTHLY, BI-
Sections I through V             MONTHLY, other ]
[see Section VI above for guidance on progress reports.]
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                    Chapter IV:  Corrective Measures Study

Introduction

   The purpose of the Corrective Measures Study (CMS) portion of the RCRA
corrective action process is to identify and evaluate potential remedial alternatives for
the releases that have been identified at a facility.  The scope and requirements of the
CMS, however, need to be balanced with the expeditious initiation of remedies and
rapid restoration of contaminated media, both major goals of the RCRA corrective
action program. In keeping with these goals, the implementing agency may allow a
streamlined approach to remedy selection, enabling a facility to move from facility
investigation to corrective measures implementation more rapidly. Information
gathered during the implementation of ISMs should be used to augment the CMS and
avoid duplicative efforts. Aspects of the implemented ISMs may be viewed as an early
and focused CMS.  In some cases, the ISMs may substitute for the final CMS/CMI
after review and approval by the implementing agency. The Permittee/Respondent
shall furnish all personnel, materials, and services  necessary for, or incidental to,
performing the CMS.

   It is anticipated that Permittees/Respondents of larger sites with complex
environmental  problems may need to evaluate several alternative remedial approaches
in determining the most appropriate remedy for the facility. For other RCRA
facilities, however, it may be appropriate for the implementing agency to allow the
Permittee/Respondent to evaluate only one alternative.

   Studies needed for developing sound, environmentally protective remedies may be
relatively straightforward at some RCRA facilities, and may not require extensive
evaluation of a  number of remedial  alternatives. Such "streamlined" CMS's can be
tailored to fit the complexity and scope of the remedial situation presented by the
facility.  For example, if the environmental problems at a facility were limited to a
small area of soils with low-level contamination, the CMS might be limited to a single
treatment approach that is known to be effective for such types of contamination. In
a different situation, such as with a large municipal-type landfill, it may be obvious
that the source control element of the CMS should be focused  on containment
options, while contaminated media  remediation may require more extensive study.  It
is anticipated that a streamlined or highly focused CMS may be appropriate in the
following types of situations:

   1.     "Low risk" facilities.  Facilities where environmental problems are
          relatively small, and where releases present minimal exposure concerns.
          Such facilities might have limited on-site soil contamination.

   2.     High quality remedies proposed by the Permittee/Respondent. The
          Permittee/Respondent may  propose a remedy which is highly protective
          (such as an action which  would remediate to non-detectable levels)  and
          which is consistent with  all other remedial objectives.

   3.     Facilities with straightforward remedial solutions.  For some contamination
          problems, standard engineering solutions can be applied that have proven
          effective in similar situations. An example might be cleanup of soils
          contaminated with PCBs by excavation, removal and treatment, then
          disposal.

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    4.     Phased remedies. At some facilities the nature of the environmental
          problem will dictate development of the remedy in phases, which would
          focus on one aspect (such as groundwater remediation) of the remedy, or
          one area of the facility that requires immediate measures to control further
          environmental and human exposure problems. In these situations, the
          CMS could be focused on that specific element of the overall remedy, with
          follow-up studies as appropriate to deal with the remaining remedial needs
          at the facility.  Such  studies should be documented in later CMS phases.
          For particularly large facilities, several phases should be designated.

    It is also recognized that, in contrast to the above situations, some facilities with
very extensive or highly complex environmental problems will likely require an
assessment of a number of alternative remedial technologies or approaches.  The
following are examples of situations which would likely need relatively extensive
studies to be done to support sound remedy selection decisions:

    1.     "High risk" facilities with complex remedial solutions.  Such facilities
          might have large volumes of both concentrated wastes and contaminated
          soils, for which several treatment technologies could be applied to achieve
          varying degrees of effectiveness (such as reduction of toxicity or volume),  in
          conjunction with different types of containment systems for residuals.

    2.     Contaminant  problems for which several different approaches are
          practicable. There may be several, quite distinct technical approaches for
          remediating a problem at a facility, each of which offers varying degrees of
          long-term reliability, and could be implemented over different time frames.
          In such cases, remedy selection decisions will necessarily involve a difficult
          balancing of competing goals and interests.  Such decisions must be
          supported with adequate information.

    3.     Facilities for which innovative treatment technologies may be viable.

    In addition to the above examples of situations calling for either a limited, or
relatively complex CMS, other  studies will fall in the middle of that range. Given the
wide range of possibilities for structuring the CMS, this guidance encourages the
implementing agency to focus the evaluation on appropriate remedies, tailoring the
scope and substance of the study to fit the complexity  of the situation. It will also be
the responsibility of the implementing agency to determine what level of evaluation
and documentation is necessary  in order to support the ultimate remedy selection for
the facility.

    The implementing agency has the discretion to not require sections of the plan
and/or report that are specified in this guidance, in those site-specific situations where
all the requirements may not be appropriate. The implementing agency also may
require the Permittee/Respondent to conduct additional studies beyond what is
discussed in the  scope of work  in order to support the CMS. The
Permittee/Respondent will furnish all personnel, materials  and services necessary to
conduct the additional tasks.
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 [NOTE: With certain exceptions, the provisions set out in sections I through IV are
 intended as guidance, and these provisions should be justifiable and tailored to site-specific
 co n ditio ns when in co rporated in to perm its or o rders. The exceptio n s are certain provisio n s
 which are based on specific regulatory or statutory requirements applicable to permitting.
 Regulatory and statutory requirements are  binding and do not require site-specific
justification. Applicable requirem ents include: public notice requirem ents specified in 40
 CFK subpartD and requirem ents in 40 CFK §264.101.  The following Scope of Work
 (SOW)for the Corrective Measures Study isintended to be aflexible document capable of
 addressing both simple and complex site situations.}
              Scope of Work for a Corrective Measures Study (CMS)
Purpose
    The purpose of the Corrective Measures Study (CMS) portion of the RCRA
 corrective action process is to identify and evaluate potential remedial alternatives for
 the releases that have been identified at a facility.

 Scope

    A Corrective Measures Study Workplan and Corrective Measures Study Report
 are, unless otherwise specified by the implementing agency, required elements of the
 CMS. The CMS consists of the following components:

 Section I:         Corrective Measures Study Workplan

 Section II: Corrective Measures Study Report

           A.     Introduction /Purpose

                  Description  of Current Conditions

                  Corrective Action Objectives
B.

C.

D.
                  Identification, Screening and Development of Corrective Measure
                  Alternatives
           E.     Evaluation of A Final Corrective Measure Alternative

           F.     Recommendation by a Permittee/Respondent for a Final
                  Corrective Measure Alternative

           G.     Public Involvement Plan

 Section III:       Progress Reports

 Section IV:       Proposed Schedule
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Section I: Corrective Measures Study Workplan

The Corrective Measures Study (CMS) Workplan may be required by the
implementing agency. If required, it shall include the following elements:

    1.     A site-specific description of the overall purpose of the Corrective Measure
          Study;

    2.     A description of the corrective measure objectives, including proposed
          target media cleanup standards (e.g., promulgated federal and state
          standards,  risk derived standards) and points of compliance or a description
          of how a risk assessment will be performed (e.g., guidance documents);

    3.     A description of the specific corrective measure technologies and/or
          corrective  measure alternatives which will be studied;

    4.     A description of the general approach to investigating and evaluating
          potential corrective measures;

    5.     A detailed description of any proposed pilot, laboratory and/or bench scale
          studies;

          [NOTE- Appendix Aprov ides references for technical assistance (e.g., "Guidance
          for Conducting Rem edialInvestigations and Feasibility Studies Under
          CEKCLA" - Chapter 5.)\

    6.     A proposed outline for the CMS Report including a description of how
          information will be presented; and

    7.     A description of overall project management including overall approach,
          levels of authority (include organization chart), lines of communication,
          project schedules,  budget and personnel. Include a description of
          qualifications for personnel directing or performing  the work.

Section II:  Corrective Measures Study Report

The Corrective Measures Study (CMS) Report shall include the following elements:

    A.     Introduction/Purpose

          The Permittee/Respondent shall describe the purpose of the document and
          provide a summary description of the project.

    B.     Description of Current Conditions

          The Permittee/Respondent shall include a  brief summary/discussion of any
          new information that has been discovered since the RFI current conditions
          report was finalized.  This discussion should concentrate on those issues
          which could significantly affect the evaluation and selection of the
          corrective  measures alternative(s).

          [NOTE- The implem enting agency m ay allow the Permittee/Respondent to

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       reference the RFI current conditions report in lieu of additional discussion in
       this section^

C.     Media Cleanup Standards

The Permittee/Respondent may propose media cleanup standards.  The standards
must be based on promulgated federal and state standards, risk derived standards,
all data and information gathered during the corrective action process (e.g., from
interim measures, RCRA Facility Investigation, etc.), and/or other applicable
guidance documents.  If no other guidance exists for a given contaminant and
media, the Permittee/Respondent shall propose and justify a media cleanup
standard.

[NOTE- The implem enting  agency m ay set cleanup standards before the CMS stage.
The information to support the agency's decision may be submitted by the
Permittee I Respondent as part of the investigation analysis (see Section  V of the RFI
scope of work). The Permittee/Respondent m ay propose to m odify the m edia cleanup
standards during the CMS. As a result of this or other new inform ation, the
implementing agency may modify the cleanup standards. Finalmedia cleanup
standards are determined by the implementing agency when the remedy is selected and
are documented in the Statem ent of Basis/Response to Comments (SB/RTC) or perm it
m odifi cation.}

D.     Identification, Screening, and Development of Corrective Measure
       Alternatives

       1.      Identification:  List and briefly describe potentially  applicable
              technologies for each affected media that may be used to achieve the
              corrective action objectives. The Permittee/Respondent should
              consider including a table that summarizes the available
              technologies.  Depending on the site-specific situation, the
              implementing agency may require the Permittee/Respondent to
              consider additional technologies.

              The Permittee/Respondent should consider innovative treatment
              technologies, especially in situations where there are a limited
              number of applicable corrective measure technologies. Innovative
              technologies are defined as those technologies utilized for
              remediation other than incineration, solidification/stabilization,
              and pumping with conventional treatment for contaminated
              groundwater [see Appendix C].  Innovative treatment technologies
              may require extra effort to gather information, to analyze options,
              and to adapt the technology to the  site-specific situation.
              Treatability studies and on-site pilot scale studies may be necessary
              for evaluating innovative treatment technologies.

       2.      Screening [optional]:  When the Permittee/Respondent is required
              to, or chooses to, evaluate a number of corrective measures
              technologies, the Permittee/Respondent will evaluate the
              technology limitations to show why certain corrective measures

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              technologies may prove unfeasible to implement given existing
              waste and site-specific conditions.

              Likewise, if only one corrective measure alternative is being
              analyzed, the Permittee/Respondent must indicate any
              technological limitations given waste and site-specific conditions at
              the facility for which it is being considered.  The Permittee/
              Respondent should consider including a table that summarizes these
              findings.

       3.      Corrective Measure Development [optional]: As required by the
              implementing agency, the Permittee/Respondent shall assemble the
              technologies that pass the screening step into specific alternatives
              that have potential to meet the corrective action objectives for each
              media. Options for addressing less complex sites could be relatively
              straight-forward and may only require evaluation of a single or
              limited number of alternatives.

              Each alternative may consist of an individual technology or a
              combination of technologies used in sequence (i.e., treatment train).
              Depending on the site specific situation, different alternatives may
              be considered for separate areas of the facility.  List and briefly
              describe each corrective measure alternative.

E.     Evaluation of a Final Corrective Measure Alternative

       For each remedy which warrants a more detailed evaluation, including
       those situations when only one remedy is being proposed, the
       Permittee/Respondent shall provide detailed documentation of how the
       potential remedy will comply with each of the standards listed below.
       These standards reflect the major technical components of remedies
       including cleanup of releases, source control and management of wastes
       that are generated by remedial activities. The specific standards are
       provided below.

       1.      Protect human health and the environment.
       2.      Attain media cleanup standards set by the implementing agency.
       3.      Control the source of releases so as to reduce or eliminate, to the
              extent practicable, further releases that may pose a threat to human
              health and the environment.
       4.      Comply with any applicable standards for management of wastes.
       5.      Other Factors.

       In evaluating the  selected alternative or alternatives the
       Permittee/Respondent shall prepare and submit information that
       documents that the specific remedy will meet the standards listed above.
       The following guidance  should be used in completing this evaluation. This
       guidance provides examples  of the types of information that would be
       supportive; the implementing agency may require additional information.

1.     Protect Human Health and the Environment
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       Corrective action remedies must be protective of human health and the
       environment.  Remedies may include those measures that are needed to be
       protective, but are not directly related to media cleanup, source control, or
       management of wastes.  An example would be a requirement to provide
       alternative drinking water supplies in order to prevent exposures to releases
       from an aquifer used for drinking water purposes.  Another example would
       be a requirement for the construction of barriers or for other controls to
       prevent harm arising from  direct contact with waste management units.
       Therefore, the Permittee/Respondent shall include a discussion on what
       types of short term remedies are appropriate for the particular facility in
       order to meet this  standard. This information should be provided in
       addition to a discussion  of how the other corrective measure alternatives
       meet this standard.

2.      Attain  Media Cleanup Standards Set by  the Implementing Agency

       Remedies will  be required to attain media cleanup  standards set by the
       implementing agency which may  be derived from existing state or federal
       regulations (e.g. groundwater standards) or other standards.  The media
       cleanup standards for a remedy will often play a large role in determining
       the extent of and technical  approaches to the remedy. In some cases,
       certain technical aspects of the remedy, such as the practical capabilities of
       remedial technologies, may influence to some degree the media cleanup
       standards that  are established.

       As part of the necessary information for satisfying this requirement, the
       Permittee/Respondent shall address whether the potential remedy will
       achieve the preliminary  remediation objective as identified by the
       implementing agency as well as other, alternative remediation objectives
       that may be proposed by the Permittee/Respondent.  The
       Permittee/Respondent shall also include an estimate of the time frame
       necessary for each  alternative to meet these standards.

3.      Control the Sources of Releases

       A critical objective of any remedy must be to stop  further environmental
       degradation by controlling or eliminating further releases that may pose a
       threat to human health and the environment.  Unless source control
       measures are taken, efforts  to clean up releases may be ineffective or, at
       best, will essentially involve a perpetual cleanup. Therefore, an effective
       source  control program is essential to ensure the long-term effectiveness
       and protectiveness of the corrective action program.

       The source control standard is not intended to mandate a specific  remedy
       or class of remedies.  Instead, the Permittee/Respondent is encouraged to
       examine a wide range of options.  This standard should not be interpreted
       to preclude the equal consideration of using other protective remedies to
       control the source, such as  partial waste removal, capping, slurry walls, in-
       situ treatment/stabilization and consolidation.

       [NOTE: When evaluating potential alternatives, further releases from sources of
       contamination are to be controlled  to  the extent practicable. This qualifier is

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       intended to account for the technical limitations that m ay in some casesbe
       encountered in achieving effective source control.  For some very large landfills,
       or large areas of widespread soil contamination, engineering solutions such as
       treatm ent or capping to prevent further leaching m ay not be technically
       practicable, to eliminate further releases above health-based contamination
       levels. In such cases, source controlsmay need to be combined with other
       m easures, such as plum e m anagem ent or exposure  controls, to ensure an effective
       and protective remedy.]

       As part of the CMS Report, the Permittee/Respondent shall address the
       issue of whether source  control measures are necessary, and if so, the type
       of actions that would be appropriate. Any source control measure
       proposed should include a discussion on how well the method is
       anticipated to work given the particular situation at the facility and the
       known track record of the specific technology.

4.      Comply With Any Applicable Standards for Management of Wastes.

       The Permittee/Respondent  shall include a discussion  of how the specific
       waste management activities will be conducted  in compliance with all
       applicable state or federal regulations (e.g., closure requirements, land
       disposal restrictions).

5.      Other Factors

       There are five general factors that will be considered as appropriate by the
       implementing agency in  selecting/approving a remedy that meets the four
       standards listed above. These factors represent  a combination of technical
       measures and management controls for addressing the environmental
       problems at the facility.  The five general decision factors include:

       a.      Long-term reliability and effectiveness;
       b.      Reduction in the toxicity, mobility or volume of wastes;
       c.      Short-term effectiveness;
       d.      Implementability; and
       e.      Cost.

       The implementing agency may request the Permittee/Respondent to
       provide additional information to support the use of these factors in the
       evaluation of viable remedial alternatives. Examples of the types of
       information that may be requested are provided below:

       a.      Long-term Reliability and Effectiveness

              Demonstrated and expected reliability is away of assessing the risk
              and effect of failure.  The Permittee/Respondent may consider
              whether the technology or a combination of technologies have
              been used effectively under analogous site conditions, whether
              failure of any one technology in the alternative would have an
              immediate impact on receptors, and whether the alternative would
              have the flexibility to deal with uncontrollable changes at the site
              (e.g., heavy rain storms, earthquakes, etc.).

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       Most corrective measure technologies, with the exception of
       destruction, deteriorate with time.  Often, deterioration can be
       slowed through proper system operation and maintenance, but the
       technology eventually may require replacement. Each corrective
       measure alternative  should be evaluated in terms of the projected
       useful life of the overall alternative and of its component
       technologies.  Useful life is defined as the length of time the level of
       effectiveness can be maintained.

b.     Reduction in the Toxicity, Mobility or Volume of Wastes

       As a general goal, remedies will be preferred that employ
       techniques, such as treatment technologies, that are capable of
       eliminating or substantially reducing the inherent potential for the
       wastes in SWMUs (and/or contaminated media at the facility) to
       cause future environmental releases or other risks to human health
       and the environment. There may be some situations where
       achieving substantial reductions in toxicity, mobility or volume
       may not be practical or even desirable.  Examples might include
       large, municipal-type landfills, or wastes such as unexploded
       munitions that would be extremely dangerous  to handle, and for
       which the short-term risks of treatment outweigh potential long-
       term benefits.

       Estimates of how much the corrective measures alternatives will
       reduce the waste toxicity, volume, and/or mobility may be helpful
       in applying this factor. This may be done through a comparison of
       initial site conditions to expected post-corrective measure
       conditions.

c.      Short-term Effectiveness

       Short-term effectiveness may be particularly relevant when remedial
       activities will be conducted in densely  populated areas, or where
       waste characteristics are such that risks to workers or to the
       environment are high and special protective measures are needed.
       Possible factors to consider include fire, explosion, exposure to
       hazardous substances and potential threats associated with
       treatment, excavation, transportation, and redisposal or
       containment of waste material.

d.     Implementability

       Implementability will often be a determining variable in shaping
       remedies. Some technologies will require state or local approvals
       prior to  construction, which may increase the time necessary  to
       implement the remedy. In some cases, state or local restrictions or
       concerns may necessitate eliminating or deferring certain
       technologies or remedial approaches from consideration in remedy
       selection. Information to consider when assessing implementability
       may include:
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              1.     The administrative activities needed to implement the
                    corrective measure alternative (e.g., permits, rights of way,
                    off-site approvals, etc.) and the length of time these activities
                    will take;

              2.     The constructibility, time for implementation, and time for
                    beneficial results;

              3.     The availability of adequate off-site treatment, storage
                    capacity, disposal services, needed technical services and
                    materials; and

              4.     The availability of prospective technologies for each
                    corrective measure alternative.

       e.      Cost

                    The relative cost of a remedy may be an appropriate
                    consideration, especially in those situations where several
                    different technical alternatives to remediation will offer
                    equivalent protection of human health and the environment,
                    but may vary widely in cost.  However, in those situations
                    where only one remedy is being proposed, the issue of cost
                    would not need to be considered.  Cost estimates could
                    include costs for: engineering, site preparation, construction,
                    materials, labor, sampling/analysis, waste
                    management/disposal, permitting, health and safety
                    measures, training, operation and maintenance, etc.

F.     Recommendation by Permittee/Respondent for  a Final Corrective Measure
       Alternative

       In the CMS Report, the Permittee/Respondent may recommend a
       preferred remedial alternative for consideration by the implementing
       agency. Such a recommendation should include  a description and
       supporting rationale for the proposed remedy, consistent with the remedial
       standards and the decision factors discussed above. Such a recommendation
       is not required and the implementing agency still retains the role of remedy
       selection.

G.     Public Involvement Plan

       After the CMS has been performed by the Permittee/Respondent and the
       implementing agency has selected a preferred alternative for proposal in the
       Statement of Basis, it is the agency's policy to request public comment on
       the Administrative Record and the proposed corrective measure(s).
       Changes to the proposed corrective measure(s) may be made after
       consideration of public comment.  The implementing agency may also
       require that the Permittee/Respondent perform additional corrective
       measures studies. If the public is interested, a public meeting may be held.
       After consideration of the public's comments on the proposed corrective
       measure, the agency develops the Final Decision and Response to

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          Comments (RTC) to document the selected corrective measure, the
          agency's justification for such selection, and the response to the public's
          comment.  Additional public involvement activities may be necessary,
          based on facility specific circumstances.

          [NOTE- Notice requirements for permits are set out at 40 CFK Part 270

          subpart D.  See RCRAPublic Involvement Manual EPA/530-R-93-006,
          Septem her 1993 for further guidance.}

Section III: Progress Reports

   The Permittee/Respondent will, at a minimum, provide the implementing agency
   with signed [monthly, bimonthly, or quarterly] progress reports.  These reports
   may be required to contain the following information, but agency requirements
   are not limited to this list:

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

   2.     Summaries of all findings in the reporting period, including results of any
          pilot studies;

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

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

   5.     Summaries of all contacts made regarding access to off-site property;

   6.     Summaries of all problems encountered during the reporting period;

   7.     Actions being taken to rectify problems;

   8.     Changes in relevant personnel during the reporting period;

   9.     Projected work for the next reporting period; and

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

Section IV: Proposed Schedule

The Permittee/Respondent will provide the implementing agency with CMS reports
according to the following schedule:

   Facility Submission          Due Date

   CMSWorkplan             [DATE]
   (Section I)

   Draft CMS Report          [ NUMBER ] days after
   (Section II)                  CMS Workplan Approval

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Final CMS Report           [ NUMBER ] days after
(Sections II)                 the implementing agency
                            comments on Draft CMS Report

Progress Reports on         [ MONTHLY, BI-
Sections I and II             MONTHLY, other ]
[see Section III above for guidance on progress reports.]
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                Chapter V:  Corrective Measures Implementation

Introduction

   The purpose of the Corrective Measures Implementation (CM I) portion of the
RCRA corrective action process is to design, construct, operate, maintain and monitor
the performance of the corrective measure(s) selected by the implementing agency.
Thus far in the corrective action program, the CMI process generally entailed a
conceptual design phase for the selected remedy, a detailed review of intermediate
plans and  specifications by the implementing agency, and the development of final
plans and  specifications.

   The new CAP encourages implementing agencies to make the process more
flexible and streamlined.  Intermediate design plans may or may not be required at
specific design points (30, 50, 60, 90, and/or 95% are given as examples).  Other
sections may be combined or eliminated.

   For example, a CMI Workplan may be submitted to the implementing agency
rather than the Conceptual Design (Section I), Intermediate Plans and Specifications
(Section III), and Construction Workplan (Section V). The implementing agency may
approve (or conditionally approve with comments) the CMI Workplan and not
require submittal of Final Plans and Specifications (Section IV) and Construction
Workplan (Section V). A Health and Safety Plan (Section VIII) and Public
Involvement Plan  (Section IX) also may be included in a CMI Workplan.
Implementing agencies may consider other approaches to expedite the process and
initiate implementation of corrective measure(s) more quickly.

   As  discussed in Chapter II, one such approach involves initiating ISMs prior to the
CMI. Plans submitted for ISMs (e.g., health and safety plans, public involvement
plans) may be used or updated during the CMI, particularly since ISMs should be
compatible with final corrective measures.  In most cases this will be true, with the
only changes being an expansion/adjustment of the ISMs to constitute a final remedy.

   Another approach to expedite the CMI process involves setting final remedial (or
stabilization) media cleanup standards but not specifying the process by which the
standards would be attained.  This performance-based approach should lower
oversight by the implementing agency and promote faster cleanup.  The implementing
agency should give special consideration to the types of progress reports (see Section
X) it will require from the Permittee/Respondent so that it can monitor progress
toward achieving the media cleanup standards if this approach  is taken.
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 [NOTE: With certain exceptions, the provisions set out in sections I through XI are
 intended as guidance, and these provisions should be justifiable and tailored to site-specific
 co n ditio ns when in co rporated in to perm its or o rders.  The exceptio n s are certain provisio n s
 which are based on specific regulatory or statutory requirements applicable to permitting.
 Regulatory and statutory requirements are binding and do not require site-specific
justification.  Applicable requirem ents include: financial responsibility requirem ents in
 RCRA section s 3004(u) an d 3004(v) an d 40 CFK J 264.101.]

             Scope of Work for Corrective Measures Implementation

 Purpose

    The purpose of the Corrective Measures Implementation (CM I) program is to
 design, construct, operate, maintain and monitor the performance of the corrective
 measure or measures selected by the implementing agency.  Corrective measures are
 intended to protect human health and/or the environment from releases from the
 facility. The Permittee/Respondent will furnish all personnel, materials and services
 necessary to  implement the corrective measures program.

 Scope

    The documents required for Corrective Measures Implementation  are, unless the
 implementing agency specifies otherwise, a Conceptual Design, Operation and
 Maintenance Plan, Intermediate Plans and Specifications, Final Plans and
 Specifications, Construction Workplan, Construction Completion Report, Corrective
 Measure Completion Report, Health and Safety Plan, Public Involvement Plan, and
 Progress Reports. The scope ofwork (SOW)  for each document is specified below.
 The SOW's are intended to be flexible documents capable of addressing both simple
 and complex site situations.  If the Permittee/Respondent can justify, to the
 satisfaction of the implementing agency, that a plan and/or report or portions thereof
 are not needed in the given site-specific situation, then the implementing agency may
 waive that requirement.

    The implementing agency may require the Permittee/Respondent  to conduct
 additional studies beyond what is  discussed in the SOW's in order to support the CMI
 program.  The Permittee/ Respondent will furnish all personnel, materials and
 services necessary to conduct the additional tasks.

 [NOTE: See  introduction for discussion on streamlining sections of the CMI Scope of
 Work.]

    The CMI consists of the  following components, which for clarity are designated as
 sections in this Scope of Work.

    Section I:     Conceptual Design (15% Design Point)

           A. Introduction/Purpose

           B. Corrective Measures Objectives

           C. Conceptual Model of Contaminant Migration
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       D. Description of Corrective Measures

       E. Project Management

       F. Project Schedule

       G. Design Criteria

       H. Design Basis

       I. Waste Management Practices

       J. Required Permits

       K. Long-lead Procurement Considerations

       L. Appendices

Section II:     Operation and Maintenance Plan

       A.  Introduction/Purpose

       B. Project Management

       C.  System Description

       D. Personnel Training

       E. Start-up Procedures

       F. Operation and Maintenance Procedures

       G. Replacement Schedule for Equipment and Installed Components

       H. Waste Management Practices

       I. Sampling and Analysis

       J. Corrective Measure Completion Criteria

       K.  Operation and Maintenance Contingency Procedures

       L. Data Management and Documentation Requirements

Section III:    Intermediate Plans and Specifications (30, 50, 60, 90 and/or 95%
              Design Point)

Section IV:    Final Plans and Specifications (100% Design Point)

Section V:     Construction Workplan

       A.  Introduction/Purpose

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       B. Project Management

       C. Project Schedule

       D. Construction Quality Assurance/Quality Control
       Programs

       E. Waste Management Procedures

       F. Sampling and Analysis

       G. Construction Contingency Procedures

       H. Construction Safety Procedures

       I. Documentation Requirements

       J. Cost Estimate/Financial Assurance

Section VI:    Construction Completion Report

Section VII:   Corrective Measure Completion Report

Section VIII:   Health and Safety Plan

Section IX:    Public Involvement Plan

Section X:     Progress Reports

Section XI:    Proposed Schedule
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Section I:  Conceptual Design (15% Design Point)

   The Permittee/Respondent shall prepare a Conceptual Design (CD) that clearly
   describes the size, shape, form, and content of the proposed corrective measure;
   the key components or elements that are needed; the designer's vision of the
   corrective measure in the form of conceptual drawings and schematics; and the
   procedures and schedules for implementing the corrective measure(s).  It should be
   noted that more that one conceptual design may be needed in situations where
   there is a complex site with multiple technologies being employed at different
   locations. The implementing agency may require approval of the CD prior to
   implementation.  The CD must, at a minimum, include the following elements:

   A.     Introduction/Purpose: Describe the purpose of the document and provide
          a summary description of the project.

   B.     Corrective Measures Objectives: Discuss the corrective measure objectives
          including applicable media  cleanup standards.

   C.     Conceptual Model of Contaminant Migration:  Present a conceptual model
          of the site and contaminant migration. The conceptual model consists of a
          working hypothesis of how the contaminants may move  from the release
          source to the receptor population. The  conceptual model is developed by
          looking at the applicable physical parameters (e.g., water  solubility,
          density, Henry's Law Constant, etc.) for each contaminant and assessing
          how the contaminant may  migrate given the existing site  conditions
          (geologic features, depth to groundwater, etc.).  Describe the phase (water,
          soil, gas, non-aqueous) and  location where contaminants are likely to be
          found. This analysis may have already been done as part  of earlier work
          (e.g., Current Conditions Report). If this is the case,  then provide a
          summary of the conceptual model with  a reference to the earlier document.

   D.     Description of Corrective Measures:  Considering the conceptual model of
          contaminant migration, qualitatively describe what the corrective measure
          is supposed to do and how  it will  function at the facility.  Discuss the
          feasibility of the corrective measure and its  ability to  meet the corrective
          measure objectives.

          1.      Data Sufficiency: Review existing data needed to  support the
                 design effort and establish whether or not there is sufficient
                 accurate data available for this purpose.  The Permittee/Respondent
                 must summarize the assessment  findings and specify any additional
                 data needed to complete the corrective measure design.  The
                 implementing agency may require or the Permittee/Respondent
                 may propose that sampling and analysis plans and/or treatability
                 study workplans be developed to obtain the additional data.
                 Submittal times for any new sampling and analysis plans and/or
                 treatability study workplans  will be determined by the
                 implementing agency and will be included in  the project schedule.

   E.     Project Management:  Describe the management approach including levels
          of authority and responsibility (include  organization  chart), lines of
          communication and the qualifications of key personnel who will direct the

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       corrective measure design and the implementation effort (including
       contractor personnel).

F.     Project Schedule: The project schedule must specify all significant steps in
       the process and when all CMI deliverables (e.g., Operation and
       Maintenance Plan, Corrective Measure Construction Workplan, etc.) are to
       be submitted to the implementing agency.

G.     Design Criteria: Specify performance requirements for the overall
       corrective measure and for each major component. The
       Permittee/Respondent must select equipment that meets the performance
       requirements.

H.     Design Basis: Discuss the process and methods for designing all major
       components of the corrective measure. Discuss the significant assumptions
       made and possible sources of error.  Provide justification for the
       assumptions.

       1.      Conceptual Process/Schematic Diagrams.

       2.      Site plan showing preliminary plant layout and/or treatment area.

       3.      Tables listing number and type of major  components with
              approximate dimensions.

       4.      Tables giving preliminary mass balances.

       5.      Site safety and security provisions (e.g., fences, fire control, etc.).

I.      Waste Management Practices: Describe the wastes generated by the
       construction of the corrective measure and how they will be managed.
       Also discuss drainage and indicate how rainwater runoff will be managed.

J.      Required Permits: List and describe the permits  needed to construct and
       operate the corrective measure.  Indicate on the project schedule when the
       permit applications will be submitted to the applicable agencies  and an
       estimate  of the permit issuance date.

K.     Long-Lead Procurement Considerations: The Permittee/Respondent shall
       prepare a list of any elements or components of the corrective measure  that
       will require custom fabrication or for some other reason must be
       considered as long-lead procurement items.  The list must include the
       reason why the items are considered long-lead items, the length  of time
       necessary for procurement, and the recognized sources of such
       procurement.

L.     Appendices including:

       1.      Design Data  -Tabulations of significant data used in the design
              effort;

       2.      Equations -List and describe the source of major equations used in

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                 the design process;

          3.      Sample Calculations -Present and explain one example calculation
                 for significant or unique design calculations; and

          4.      Laboratory or Field Test Results.

Section II:  Operation and Maintenance Plan

   The Permittee/Respondent shall prepare an Operation and Maintenance (O&M)
   Plan that outlines procedures for performing operations, long term maintenance,
   and monitoring of the corrective measure.  A draft Operation and Maintenance
   Plan shall be submitted to the implementing agency simultaneously with the draft
   Plans and Specifications (see Section III).  A final Operation and Maintenance Plan
   shall be submitted to the implementing agency simultaneously with the final Plans
   and Specifications.  The O&M plan shall, at a  minimum, include the following
   elements:

   A.     Introduction/Purpose: Describe the purpose of the document and provide
          a summary description of the project.

   B.     Project Management:  Describe the management approach including levels
          of authority and responsibility  (include organization chart), lines of
          communication and the qualifications of key personnel who will operate
          and maintain the corrective measures (including contractor personnel).

   C.     System Description:  Describe the corrective measure and identify
          significant equipment.

   D.     Personnel Training: Describe the training process for O&M personnel.
          The Permittee/Respondent shall prepare, and include in the technical
          specifications governing treatment systems, the contractor requirements for
          providing: appropriate service visits by experienced personnel to supervise
          the installation, adjustment, start up and operation of the treatment
          systems, and training covering appropriate operational procedures once the
          start-up has been successfully accomplished.

   E.     Start-Up Procedures:  Describe system  start-up procedures including any
          operational testing.

   F.     Operation and Maintenance Procedures:  Describe normal operation and
          maintenance procedures including:

          1.      Description of tasks for operation;
          2.      Description of tasks for maintenance;
          3.      Description of prescribed  treatment or operation conditions; and
          4.      Schedule showing frequency  of each O&M task.

   G.     Replacement Schedule for Equipment and Installed Components.

   H.     Waste Management Practices:  Describe the wastes generated by operation
          of the corrective measure and how they will be managed. Also discuss

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       drainage and indicate how rainwater runoff will be managed.

I.      Sampling and Analysis:  Sampling and monitoring activities may be needed
       for effective operation and maintenance of the corrective measure.  To
       ensure that all information, data and resulting decisions are technically
       sound, statistically valid, and properly documented, the
       Permittee/Respondent shall prepare a Quality Assurance Project Plan
       (QAPJP) to  document all monitoring procedures, sampling, field
       measurements and sample analyses performed during these activities.  The
       Permittee/Respondent shall use quality  assurance, quality control,  and
       chain-of-custody procedures approved by the implementing agency. These
       procedures are described in the soon to be released EPA  Requirements for
       Quality Assurance Project Plans for Environmental Data Operations (EPA
       QA/R-5), which will replace Interim Guidelines and Specifications for
       Preparing Quality Assurance Project Plans. QAMS-005/80, December 29,
       1980.

J.      Corrective Measure Completion Criteria:  Describe the process and criteria
       (e.g., groundwater cleanup goal met at all compliance points for 1 year)  for
       determining when corrective measures have achieved media cleanup goals.
       Also describe the process and criteria for determining when maintenance
       and monitoring may cease.  Criteria for  corrective measures such as a
       landfill cap must reflect the need for long-term monitoring and
       maintenance.  Satisfaction of the completion criteria will trigger
       preparation  and submittal of the Corrective Measures Completion  Report.

K.     O&M Contingency Procedures:

       1.      Procedures to address system breakdowns and operational problems
              including a list of redundant and emergency back-up equipment and
              procedures;

       2.      Alternate procedures to be implemented if the corrective measure
              suffers complete failure.  The alternate procedures must be able to
              prevent release or threatened releases of hazardous wastes or
              constituents which may endanger human health  and/or the
              environment or exceed media cleanup standards;

       3.      The O&M Plan must specify that, in the event of a major
              breakdown and/or complete failure of the corrective measure
              (includes emergency situations),  the Permittee/Respondent will
              orally notify the implementing agency within 24 hours of the event
              and will notify the implementing agency in writing within  72 hours
              of the event. Written notification must, at a minimum, specify
              what happened, what  response action is being taken and/or is
              planned,  and any potential impacts on human health and/or the
              environment; and

       4.      Procedures to be implemented in the event that the corrective
              measure is experiencing major operational problems, is not
              performing to design specifications and/or will not achieve the
              cleanup goals in the expected time frame.  For example, in certain

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                 circumstances both a primary and secondary corrective measure
                 may be selected for the Facility. If the primary corrective measure
                 were to fail, then the secondary would be implemented. This
                 section would thus specify that if the primary corrective measure
                 failed, then design plans would be developed for the secondary
                 measure.

   L.     Data Management and Documentation Requirements:  The O&M Plan
          shall specify that the Permittee/Respondent collect and maintain the
          following information:

          1.     Progress Report Information
          2.     Monitoring and laboratory data;
          3.     Records of operating costs; and
          4.     Personnel, maintenance and inspection records.

   This data and information should be used to prepare Progress Reports and the
   Corrective Measure Completion Report.

   [NOTE-  See Section Xfor guidance on what kind of inform ation  may be required
   in progress reports^

Section III:  Intermediate Plans and Specifications (30, 50, 60, 90 and/or 95% Design
Point)

[NOTE- The Permittee/Respondent m ay propose or the implem enting agency m ay require
the submittal of several interm ediate plans and specifications (e.g., at the 60% Design Point)
or none at all.}

   The Permittee/Respondent shall  prepare draft Plans and Specifications that are
   based on the Conceptual Design but include additional design  detail. A  draft
   Operation and Maintenance Plan and Construction Workplan shall be submitted
   to the  implementing agency simultaneously with the draft Plans and
   Specifications. The draft design package must include drawings and specifications
   needed to construct the corrective measure. Depending on the nature of the
   corrective measure, many different types of drawings  and specifications may be
   needed.  Some of the elements that may be  required are:

          •      General Site Plans
          •      Process Flow Diagrams
          •      Mechanical Drawings
          •      Electrical Drawings
          •      Structural Drawings
          •      Piping and Instrumentation  Diagrams
          •      Excavation and Earthwork Drawings
          •      Equipment Lists
          •      Site Preparation and Field Work Standards
          •      Preliminary Specifications for Equipment and Material

   General  correlation between drawings and  technical specifications is a basic
   requirement of any set of working construction plans and specifications.  Before
   submitting the project specifications to the implementing agency, the

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   Permittee/Respondent shall:

          •      Proofread the specifications for accuracy and consistency with the
                 conceptual design and

          •      Coordinate and cross-check the specifications and drawings.

Section IV: Final Plans and Specifications (100% Design Point)

   The Permittee/Respondent shall prepare Final Plans and Specifications that are
   sufficient to be included in a contract document and be advertised for bid. A final
   Operation and Maintenance Plan and Construction Workplan shall be submitted
   to the implementing agency simultaneously with the final Plans and Specifications.
   The final design  package must consist of the detailed drawings and specifications
   needed to construct the corrective measure.  Depending on the nature of the
   corrective measure, many  different types of drawings and specifications may be
   needed. Some of the elements that may  be required are:

          •      General Site Plans
          •      Process Flow Diagrams
          •      Mechanical Drawings
          •      Electrical Drawings
          •      Piping and Instrumentation Diagrams
          •      Structural Drawings
          •      Excavation and Earthwork Drawings
          •      Site Preparation and Field Work Standards
          •      Construction Drawings
          •      Installation Drawings
          •      Equipment Lists
          •      Detailed Specifications for Equipment and Material

   General correlation between drawings and technical specifications is a basic
   requirement of any set of working construction plans and specifications.  Before
   submitting the final project specifications to the implementing agency, the
   Permittee/Respondent shall proofread the  specifications for accuracy and
   consistency  with the preliminary design; and coordinate and cross-check the
   specifications and drawings.

Section V:  Construction Workplan

   The Permittee/Respondent shall prepare a Construction Workplan which
   documents the overall management strategy, construction quality assurance
   procedures and schedule for constructing the corrective measure. A draft
   Construction Workplan shall be submitted to the implementing agency
   simultaneously with the draft Plans and Specifications  and draft Operation and
   Maintenance Plan. A final Construction Workplan shall be submitted to the
   implementing agency simultaneously with the final Plans and Specifications  and
   final Operation and Maintenance Plan.  Upon receipt of written approval  from the
   implementing agency, the Permittee/Respondent shall commence the construction
   process and implement the Construction Workplan in accordance with the
   schedule and provisions contained therein.  The Construction Workplan must be
   approved by the implementing agency prior to the start of corrective measure

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construction. The Construction Workplan must, at a minimum, include the
following elements:

A.     Introduction/Purpose: Describe the purpose of the document and provide
       a summary description of the project.

B.     Project Management:  Describe the construction management approach
       including levels of authority and responsibility (include organization
       chart), lines of communication and the qualifications of key personnel who
       will direct the corrective measure construction effort and provide
       construction quality assurance/quality control (including contractor
       personnel).

C.     Project Schedule:  The project schedule must include  timing for key
       elements of the bidding process, timing for initiation and completion of all
       major corrective measure construction tasks as specified in the Final Plans
       and Specifications, and specify when the Construction Completion Report
       is to be submitted to the implementing agency.

D.     Construction Quality Assurance/Quality Control Programs:  The purpose
       of construction quality assurance is to ensure, with a  reasonable degree of
       certainty, that a completed corrective measure will meet  or exceed all design
       criteria, plans, and specifications. The Construction Workplan must
       include a complete Construction Quality Assurance Program  to be
       implemented by the Permittee/Respondent.

E.     Waste Management Procedures:  Describe the wastes  generated by
       construction of the corrective measure and how they  will be managed.

F.     Sampling and Analysis: Sampling and monitoring activities may be needed
       for construction quality assurance/quality  control and/or other
       construction related purposes. To ensure that all information, data and
       resulting decisions are technically sound, statistically  valid, and properly
       documented, the Permittee/Respondent shall prepare a Quality Assurance
       Project Plan (QAPJP)  to document all monitoring procedures, sampling,
       field measurements and sample analysis performed during these activities.
       The Permittee/Respondent shall use quality assurance, quality control, and
       chain-of-custody procedures approved by the implementing agency.  These
       procedures are described in  the soon to be  released EPA Requirements for
       Quality Assurance Project Plans for Environmental Data Operations (EPA
       QA/R-5), which replaces Interim Guidelines and Specifications for
       Preparing Quality Assurance Project Plans. QAMS-005/80, December 29,
       1980.

G.     Construction Contingency  Procedures:

       1.      Changes to the design and/or specifications may  be needed during
              construction to address unforeseen problems  encountered in  the
              field.  Procedures to address such circumstances, including
              notification of the implementing agency, must be included in the
              Construction Workplan;
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          2.     The Construction Workplan must specify that, in the event of a
                 construction emergency (e.g. fire, earthwork failure, etc.), the
                 Permittee/Respondent will orally notify the implementing agency
                 within 24 hours of the event and will notify the implementing
                 agency in writing within 72 hours of the event. The written
                 notification must, at a minimum, specify what happened, what
                 response action is being taken and/or is planned, and any potential
                 impacts on human health and/or the environment; and

          3.     Procedures to be implemented if unforeseen events prevent
                 corrective measure construction.  For example, in certain
                 circumstances both a primary and secondary corrective measure
                 may be selected for the Facility.  If the primary corrective measure
                 could not be constructed, then the secondary would be
                 implemented. This section would thus specify that if the primary
                 corrective measure could not be constructed, then design plans
                 would be developed for the secondary measure.

   H.    Construction Safety Procedures: Construction safety  procedures should be
          specified in a separate Health and Safety  Plan.  [See Section VIII]

   I.      Documentation Requirements

          The Permittee/Respondent shall describe how analytical data and results

                               will be evaluated, documented, and managed.
          (Se e App e n dix BJ

   ].      Cost Estimate/Financial Assurance

          [NOTE- See 40 CFK § 264.101]

          Financial assurance for corrective measure construction and operation may
          be required by an enforcement order, facility permit, or permit
          modification.  The Construction Workplan must include a cost estimate
          and specify which financial mechanism will be used and when the
          mechanism will be established.  The cost estimate shall include both
          construction and operation and maintenance costs. An initial cost  estimate
          shall be included in the draft Construction Workplan  and a final cost
          estimate shall be included in the final Construction Workplan. The
          financial assurance mechanism may  include a performance or surety bond,  a
          trust fund, a letter of credit, financial test and corporate guarantee
          equivalent to that in 40 CFR. § 265.143 or any other mechanism acceptable
          to the implementing agency.

          Financial assurance mechanisms are used to assure the implementing agency
          that the Permittee/Respondent has adequate financial  resources to
          construct and operate the corrective measure.

Section VI:  Construction Completion Report

The Permittee/Respondent shall prepare a Construction Completion (CC) Report

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which documents how the completed project is consistent with the Final Plans and
Specifications.  A CC Report shall be submitted to the implementing agency when the
construction and any operational tests have been completed. The CC Report shall, at
a minimum, include the following elements:

    1.     Purpose;

    2.     Synopsis of the corrective measure, design criteria, and certification that the
          corrective measure was constructed in accordance with the Final Plans and
          Specifications;

    3.     Explanation and description of any modifications to the Final Plans and
          Specifications and why these were necessary for the project;

    4.     Results of any  operational testing and/or monitoring, indicating how
          initial operation of the corrective measure compares to the design criteria;

    5.     Summary of significant activities that occurred during construction.
          Include a discussion  of problems encountered and how they were
          addressed;

    6.     Summary of any inspection findings (include copies of key inspection
          documents in appendices);

    7.     As built drawings or photographs; and

    8.     Schedule indicating when any treatment systems will begin full scale
          operations.

Section VII:  Corrective Measure Completion Report

The Permittee/Respondent shall prepare a Corrective Measure Completion (CMC)
Report when the Permittee/Respondent believes that the corrective measure
completion criteria have been satisfied.  The purpose of the CMC Report is to fully
document how the corrective measure completion criteria have been satisfied and to
justify why the corrective measure and/or monitoring may  cease. The CMC Report
shall, at a minimum, include the following elements:

    1.     Purpose;

    2.     Synopsis of the corrective measure;

    3.     Corrective Measure  Completion Criteria:  Describe the process and criteria
          for determining when corrective measures, maintenance and monitoring
          may cease.  Corrective measure completion criteria were given in the final
          Operation and Maintenance (O&M) Plan;

    4.     Demonstration that the completion criteria have been met. Include results
          of testing and/or monitoring, indicating how operation of the corrective
          measure compares to the completion criteria;

    5.     Summary of work accomplishments (e.g., performance levels achieved,

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          total hours of treatment operation, total treated and/or excavated volumes,
          nature and volume of wastes generated, etc.);

   6.     Summary of significant activities that occurred during operations.  Include
          a discussion of problems encountered and how they were addressed;

   7.     Summary of inspection findings (include copies of key  inspection
          documents in appendices); and

   8.     Summary of total operation and maintenance costs.

Section VIII: Health and Safety Plan

   The Permittee/Respondent shall submit a Health and Safety Plan for all field
   activity, although it does not require review and approval by the implementing
   agency.  The Health and Safety Plan shall be developed as a stand alone document
   but may be submitted with the CMI Workplan. The Health and Safety Plan must,
   at a minimum, include the following elements:

          1.      Objectives:  Describe the goals and objectives of the health and
                  safety program (must apply to on-site personnel and visitors). The
                  health  and safety plan must be consistent with the Facility
                  Contingency Plan, OSHA Regulations, NIOSH Occupational
                  Safety  and Health Guidance Manual for Hazardous Waste Site
                  Activities (1985), all  state and local regulations and other
                  implementing agency guidance as provided.

          2.      Hazard Assessment:  List and describe the potentially hazardous
                  substances that could be encountered by field personnel during
                  construction and/or operation and maintenance activities.  Discuss
                  the following:

                  •      Inhalation Hazards
                  •      Dermal Exposure
                  •      Ingestion Hazards
                  •      Physical Hazards
                  •      Overall Hazard Rating

                  Include a table that,  at a minimum, lists:  known contaminants,
                  highest observed concentration, media, symptoms/effects of acute
                  exposure.

          3.      Personal Protection/Monitoring Equipment

                  •      Describe personal protection levels and identify all
                        monitoring equipment for each operational task.

                  •      Describe any  action levels and corresponding response
                        actions (i.e., when will levels of safety be upgraded).

                  •      Describe decontamination procedures and areas.
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          4.     Site Organization and Emergency Contacts

                 List and identify all contacts (include phone numbers).  Identify the
                 nearest hospital and provide a regional map showing the shortest
                 route from the facility to the hospital. Describe site emergency
                 procedures and any site safety organizations.  Include evacuation
                 procedures for neighbors (where applicable).

                 Include a facility map showing emergency station locations (first
                 aid, eyewash areas, etc.).

Section EX:  Public Involvement Plan

    [NOTE- It is strongly recommended that the implementing agency over see the
    Permittee's I Respondent's public involvem ent activities. Public involvem ent is an
    important part ofRCRA corrective action.  The public must be notified of significant
    changes to permits and orders regarding corrective action. In some cases, they also must
    be provided with the opportunity to review and com m ent on the changes. Further
   guidance on this process is in  the docum ent entitled RCRAPub/ic Involvem ent Manual
    (EPA/530-R-93-006, September 1993).]

    All Public  Involvement Plans prepared by the Permittee/Respondent shall be
    submitted to the implementing agency for comment and approval prior to use.
    Permittees/Respondents must never appear to represent or speak for the
    implementing agency before the public, other government officials, or the media.

    Public Involvement activities that may be required of the Permittee/Respondent
    include, the following:

          1.     Conducting  an open house or informal meeting (i.e., availability
                 session) in a  public location where people can talk to agency
                 officials and  Permittee/Respondent on a one-to-one basis;

          2.     Preparing fact sheets summarizing current or proposed corrective
                 action activities (all fact sheets should be reviewed by the
                 implementing agency prior to public distribution);

          3.     Communicating effectively with people who have vested interest in
                 the corrective action activities, (e.g., providing written or verbal
                 information  in the foreign language of a predominantly  non-
                 English-speaking community); and

          4.     Maintaining an easily accessible repository (such as a town hall or
                 public library or the facility itself, in some limited circumstances) of
                 information  on the facility-specific corrective action program,
                 including the order or permit, approved workplans, and/or other
                 reports.

          A schedule for community relations activities shall be included in the
    Public Involvement Plan.
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Section X:  Progress Reports

   The Permittee/Respondent will, at a minimum, provide the implementing
   agency with signed [monthly, bimonthly, or quarterly] progress reports during
   corrective measure design, construction, operation and maintenance. The
   implementing agency may adjust the frequency of progress reporting to address
   site-specific needs. For example, more frequent progress reports may be needed
   to track critical activities such as corrective measure construction and start-up.
   Progress reports must, at a minimum, include the following elements:

   1.     A description of significant activities (e.g., sampling events, inspections,
          etc.) and work completed/work accomplishments (e.g., performance levels
          achieved, hours of treatment operation, treated and/or excavated volumes,
          concentration of contaminants in treated and/or excavated volumes, nature
          and volume of wastes generated, etc.) during the reporting period;

   2.     Summary of system effectiveness.  Provide a comparison of system
          operation to  predicted performance levels (applicable only during operation
          of the corrective measure);

   3.     Summaries of all findings (including any inspection results);

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

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

   6.     Actions being taken and/or planned to rectify problems;

   7.     Changes in personnel during the reporting period;

   8.     Projected work for the next reporting period; and

   9.     If requested by the implementing agency, the results of any sampling tests
          and/or other data generated during the reporting period.

Section XI:  Proposed Schedule

   The Permittee/Respondent will provide the implementing agency with CMI
reports according to the following schedule:
   Facility Submission          Due Date

   Conceptual Design          [DATE]
   (Section I)

   Operation and Maintenance  [ DATE]
   Plan (Section II)

   Intermediate Plans and      [NUMBER ] days after

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Specifications
(Section III)

Final Plans and
Specifications
(Sections IV)
                            Conceptual Design Approval
                            [NUMBER] days after
                            the implementing agency
                            comments on Intermediate Plans and Specifications
                            (date of approval may be tied to submittal of the
Construction Workplan
(Section V)

Construction Completion
Report (Section VI)

Corrective Measure
Completion Report
(Section VII)

Health and Safety Plan
(Section VIII)

Public Involvement Plan
(Section IX)

Progress Reports on
Sections I through IX
[see Section X above for guidance on progress reports.]
                            CMI Workplan, if required)

                            Concurrent with Final Plans and Specifications
                            (or approval thereof)

                            [DATE]
                            [DATE]
                            (based on when completion criteria are believed to
                            have been satisfied)

                            [DATE]


                            [DATE]
                            [ MONTHLY, BI-
                            MONTHLY, other ]
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