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
in
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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;
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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;
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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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