Implementation of Interim/Stabilization Measures

1. Purpose

Interim/Stabilization Measures are implemented so as to mitigate a current or potential threat to human health and/or the environment.  Interim/Stabilization Measures must be consistent with and integrated into any long term remedy at the Facility.  Where applicable, Respondent may provide information on existing interim measures and their effectiveness.

2. Scope

The Interim/Stabilization Measures to be implemented at the Facility consist of the following tasks:

1. Development of the Interim/Stabilization Measures Work Plan

2. Interim/Stabilization Measures Implementation

3. Preparation of Reports

3. Implementation of Interim/Stabilization Measures

The Respondent shall submit an Interim/Stabilization Measures (IM) Workplan, and implement the interim/stabilization measures contained in the IM Workplan, as described below and in accordance with Section VI.1 of the Order.  The information may be provided in the CSSA Environmental Encyclopedia.

1. Interim/Stabilization Measures Workplan 

The IM Workplan shall include, but not be limited to, the following:

1. A description of on-going and planned interim measures;

2. A statement of the objectives of each interim/stabilization measure, including how the measure mitigates a potential threat to human health and the environment and is consistent with and integrated into any long term remedy for the Facility; and

3. Proposed location, design plans and specifications, construction, operation, and maintenance requirements of the interim measures, including a sampling and analysis plan.

2. Interim/Stabilization Measures Implementation

Interim/Stabilization Measures shall include, but not be limited to, the following:

1. The off-site monitoring wells that were sampled in 1996 shall be resampled to determine if the wells have become impacted by the ground water plume.  All facility potable water wells and ground water monitoring wells shall be sampled in order to provide a current baseline for ground water contamination delineation.

2. Respondent shall locate and map all off-site water wells, located within one-quarter mile of the facility boundary, which have the potential to be impacted by activities from the Facility.

3. Respondent shall evaluate the interim measures (IMs) necessary to control the further spread of contamination from the oxidation pond (SWMU O-1).  At a minimum, the following interim measures shall be evaluated and implemented, as appropriate:

1. In-situ treatment or excavation and removal of the contaminated soil and/or sludge; and/or

2. Mitigate the migration of contamination from the oxidation pond.

4. Respondent shall expedite the closure of the oxidation pond under State closure requirements.  In order to expedite closure of the oxidation pond, previous investigation data and results shall be used.

5. CSSA shall determine the proper disposition, and then implement the action, for the soil piles at the previously sifted SMWUs (B-8, 20, 24, 28, and Demo Dud Area).

3. Reports

The Respondent shall prepare plans, specifications, and reports according to the requirements as set forth above to document the design, construction, operation, maintenance, and monitoring of the interim measures.  In addition the documentation shall include, but not be limited to the following:

1. Progress Reports

The Respondent shall provide the State and EPA with signed, quarterly IM progress reports containing, but not limited to, the following information. 

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

2. Summaries of all findings determined during the course of IM actions;

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

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 to rectify problems;

7. Projected work for the next reporting period; and

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

2. Interim/Stabilization Measure Report

No later than sixty (60) days after data validation for the completion of the construction of the IM (except for long term operation, maintenance and monitoring), the Respondent shall submit a Final IM Report to EPA for approval, or modification and approval, by EPA.  The Report shall document whether the project is consistent with the design specifications, and whether the interim/stabilization measures are performing adequately.  The report shall include, but not be limited to, the following elements:

1. Synopsis of the interim/stabilization measures and certification of the design and construction;

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

3. Listing of the criteria, established before the interim measures were initiated, for judging the functioning of the interim measures, and also an explanation of any modification to these criteria;

4. Results of monitoring activities at the Facility, and an evaluation of the extent to which the interim/stabilization measures will meet or exceed the performance criteria; and

5. Description of the operation and maintenance (including monitoring) to be undertaken at the Facility.

The IM Report shall include, but not be limited to, copies of the inspection summary reports, inspection data sheets, problem identification and corrective measure reports, block evaluation reports, photographic reporting data sheets, design engineers' acceptance reports, deviations from design and material specifications (with justifying documentation) and as-built drawings. 

4. Facility Submission Summary

A summary of the information reporting requirements contained in the Interim Measures Scope of Work is present below: