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Community Relations Plan, December 2002

Appendix A - RCRA Corrective Action Process

Figure A1 shows the stages of a corrective action process and the documents required for each stage. Following is a brief summary of each stage.

RCRA Facility Assessment (RFA) - The RFA is often the first step in the corrective action process. An RFA is conducted prior to the issuance of a corrective action order. The RFA process is for identifying and gathering information on potential releases at RCRA facilities, and evaluating and identifying solid waste management units (SWMUs) and other areas of concern.

Interim Measures - Interim measures for corrective action may be initiated, when appropriate, prior to the initiation or completion of the RFI, Corrective Measures Study, or Corrective Measures Implementation. Decisions concerning interim measures are made based on the immediacy and magnitude of the potential threat to human health or the environment. It is not necessary to prepare a Statement of Basis or a public notice for Interim Measures implementation.

RCRA Facility Investigation (RFI) - If the regulatory agency determines that an RFI is necessary, the owner or operator will be required to perform an RFI either under a permit schedule of compliance or under an administrative order. The RFI generally includes the characterization/identification of the hydrogeological setting, the type and concentration of hazardous waste or hazardous constituents released, the rate and direction at which the releases are migrating, and the extent over which releases have migrated. A risk assessment can also be a part of the RFI. A risk assessment at CSSA will follow the Risk Reduction Rules (30 TAC � 335 Subchapter S) or the TRRP, depending on the current applicability. The risk assessment determines the potential threat to human health and the environment. The information generated during the RFI is used not only to determine the need for Corrective Measures Implementation, but also to aid in the selection and implementation of these measures. The findings of the RFI provide the rationale and basis for the Corrective Measures Study.

If no evidence of a release is observed (i.e., metals concentrations do not exceed background and organics are not detected), the site can be closed. The State of Texas or the EPA, depending on the jurisdiction of the particular site, will approve the closure using the appropriate regulations.

Corrective Measures Study - If the need for corrective measures is verified during the RFI process, the owner or operator is then responsible for performing a CMS. A CMS is required for closure under the Texas RRS3. During this step, the owner or operator will identify, evaluate, and recommend specific remedies that will remediate the release(s) based on a detailed engineering evaluation of the data and the corrective measure technologies.

Statement of Basis (SB) - The SB summarizes the information contained in the RFI/CMS reports. The SB is designated to facilitate public participation in the remedy selection by identifying the proposed remedy, explaining the reasons for the proposal, and soliciting public review and comment on all possible remedies considered in the RFI and CMS reports.

Public Comment Period for Selection of Remedy(ies) - The regulatory agency�s proposed remedy for a facility is presented to the public in a SB. The SB provides a brief summary of all the alternatives studied in the detailed analysis phase of the CMS, highlighting the key factors that lead to the identification of the proposed remedy.

Response to Comments (RTC) - Following receipt of public comments, the regulatory agency is required to prepare a RTC prior to the issuance of any final permit decision. A RTC should also be prepared after the public comment period but prior to those facilities undertaking corrective action pursuant to an administrative order. The RTC responds to comments received during or prior to the public comment period and describes the technical parameters of the selected remedy.

Corrective Measures Implementation (CMI) - The permit modification or corrective action order provides the framework for the transition into the next phase of the remedial process, CMI. The CMI program includes designing, constructing, operating, maintaining, and monitoring the performance of the remedy(ies) selected to protect human health and the environment.