Interim measures

The technical differences between site problems at RCRA facilities and CERCLA sites sometimes may be difficult to distinguish, owing to similarities in present or past uses of the site, in hydrogeologic setting, and/or in the types of substances disposed, spilled, or otherwise managed at the site. Consequently, many technical aspects of the study and remediation of releases of hazardous wastes and constituents from RCRA facilities often will closely parallel those at Superfund sites, and cleanups under both statutes must achieve similar goals for protection of public health and the environment. Additionally, activities which would be termed removal actions or expedited response actions under CERCLA may be undertaken by owners and operators under RCRA. In the RCRA context, such actions are termed interim measures, as will be discussed in subsequent chapters. 

At this writing, the Interim Final guidance for the regulatory community with regard to interim measures is available (U.S. EPA, 1988). Based on this guidance, the general concepts for the application of interim measures can be identified. 

Where there is an imminent threat to human health and the environment, as well as in some nonemergency situations, the regulatory agency may ascertain that a response is appropriate prior to the completion of the RCRA Facility Investigation or the Corrective Measures Study. Hence, the decision for interim measures can be made based on the immediacy as well as the magnitude of the potential threat to human health or the environment the nature of appropriate Corrective Action the implications of deferring Corrective Action until the RCRA Facility Investigation and Corrective Measure Study is complete and other factors. 

Once a decision is made that interim measures are needed, then the next question is what interim measures might be required for this particular situation. Examples of interim measures for various RCRA treatment, storage and disposal facilities, and for various release types are listed in Table 1. Note that these are examples their inclusion does not infer either guidance or approval. 

Interim measures may be separate from the comprehensive Corrective Action plan but should be consistent with, and integrated with, any longer-term Corrective Action (e.g., corrective measure through an order, an op erating permit, a post-closure permit or interim status closure requirements). To the extent possible, interim measures should not seriously complicate the ultimate physical management of hazardous wastes or constituents, nor should they present or exacerbate a health or environmental threat. Interim measures may add additional costs or work to the comprehensive Corrective Action. Such added costs or work do not preclude implementation of an interim measure. 

The following is a list of possible interim measures for various units and release types. This list is not considered to be all-inclusive. More information is available through the Interim Measures Guidance Interim Final (U.S. EPA, 198ab). 

Model language not included in Interim Measures Guidance - Interim Final. 

U.S. EPA. 1988b. RCRA Corrective Action Interim Measures Guidance - Interim Final EPA/530-SW-88-029, OSWER 9902.4, Office of Solid Waste and Emergency Response, Washington, D.C., June 1988. 

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. 

The cleanup of a site with hazardous waste contamination may be handled under either CERCLA, as described above, or RCRA. RCRA authorizes U.S. EPA to require corrective action (under an enforcement order or as part of a permit) whenever there is, or has been, a release of hazardous waste or constituents at TSDFs. The RCRA statute also provides similar corrective action authority in response to releases at interim status facilities. Further, RCRA allows U.S. EPA to require corrective action beyond the facility boundary. U.S. EPA interprets the term corrective action to cover the full range of possible actions, from studies and interim measures to full cleanups. Anyone who violates a corrective action order can be fined up to 27,500/d of noncompliance and runs the risk of having their permit or interim status suspended or revoked. 

Pharmacologic therapy is appropriate for patients with moderately severe BPH and as an interim measure for patients with severe BPH. 

Natural attenuation should not be perceived as a permanent remedy or as a means to achieve certain cleanup levels, but rather as (1) an interim measure until future technologies are developed, (2) a managerial tool for reducing site risks, and (3) a bridge from active engineering (i.e., pump-and-treat, vapor extraction, etc.) to no further action. 

There have been three main approaches to protecting plants from air pollution. Several researchers are including pollutant stress in standard breeding programs and thus are breeding for tolerance. Interim measures involve the use of chemical sprays. Such sprays are not now economically feasible but they are being tested, and some are protective. Cultural and land-use practices may also be used to control pollution effects, especially on a short-term basis. 

The use of allelochemicals may overcome one of many long-term drawbacks of synthetic agrochemicals, namely the unnatural excessive application of these chemicals. Such an application can be counterproductive at times, in that the process of exogenously applying a high selection pressure of chemicals can cause rapid selection for organisms resistant to these agrochemicals, and thereby defeat the objective. However, such interim measures are, at times, necessary. 

We must also be prepared to enforce a standard if it is important enough. It is inappropriate to use such measures to achieve what is, in effect, a permanent reduction in a standard. For example, if exceedances of a standard routinely occur and are simply accepted, then what the public might think is that compliance with an annual average concentration of 10 mg L-1 is in fact only compliance with a concentration of 20 mg L"1. If the latter is environmentally acceptable, then it should have been used as a standard in the first place. Only if they are steps on a path toward full compliance should such interim measures be tolerated (e.g., for particular hot spots or problem periods). 

Interim measures are additional controls applied in relation to computer functionality that support critical quality-related activities. They are implemented where compliance gaps are considered to exist, to provide added assurance of control, and to justify the continued use of a computer system. Interim measures are used to supplement or replace defined computer functionality. Examples of interim measures include ... 

The type of interim measure implemented should be appropriate to the computer functionality being addressed. Computer funetionality being addressed should be mapped so that appropriate interim measures ean be identified. The mapping should include both a workflow analysis and a dataflow analysis. Controls that are already in place may provide the basis for the interim measures. Critieal aetivities that should be given particular consideration for interim measures include ... 

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