Engineering Considerations in the Facility Investigation

If the RFA or other information has indicated a release of hazardous constituents, then from the owner/operator s perspective, the Corrective Action process truly begins. The first step in the process, the RCRA Facility Investigation (RFI), is directed toward development of the engineering information about the site necessary to permit selection and evaluation of remedial alternatives. The main engineering thrust of the RFI is the characterization of site conditions by defining the nature and extent of the problem. 

Identification of what contaminants are in what media is only part of the objectives of the RFI. In 

118 Handbook of Emergency Response to Toxic Chemical Releases 

Early in the Corrective Action process, a decision may be made concerning whether or not containment is necessary to protect human health and the environment (HHE). If the release or threatened release presents danger to HHE, immediate action must be taken to halt migration. Under these circumstances, actions termed Interim Measures may be required, and excavation or containment measures may be directed by the regulatory agency. However, the Owner/Operator will be responsible for their implementation. In the event that containment is not required as an interim measure, containment may still be needed as part of the overall Corrective Action to halt the pollution migration if wastes or contaminants are to be left on-site. 

Based on the existent site information, the questions which need to be answered to determine if containment is needed are  

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