Response actions

Specific response actions are specified for the different possible categories of ACBM. The five major response actions specified in the rule are operations and maintenance, repair, encapsulation, enclosure, and removal/ The LEA can select the least burdensome options among the various approved response actions so long as the response actions selected are sufficient to protect human 

Damaged or Sufficiently Damaged Thermal System Insulation 

Damaged Friable Sinfacing ACM or Damaged Friable Miscellaneous ACM 

Significantly Damaged Friable Smfacing ACM or Significantly Damaged Friable Miscellaneous ACM 

Friable Surfacing ACM, Thermal System Insulation ACM, or Friable Miscellaneous ACM, any one of which has a Potential for Damage 

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E. D. Schaumburg, "Banning Trichloroethylene Responsible Action or Overkill ," Environ. Sci. Technol 24(1), (1990). 

Cleanup actions taken to deal with a release or threat of release of a hazardous substance that could affect humans and/or the environment. The term "cleanup" is sometimes used interchangeably with the terms remedial action, removal action, response action, or corrective action. 

This section provides an overview of the engineering technologies and applications that are currently applicable to the study and remediation of releases of hazardous wastes and constituents from RCRA (Resource Conservation and Recovery Act) facilities and those sites which parallel Superfund sites. Activities which would be termed removal actions or expedited response actions under CERCLA (Comprehensive Environmental Recovery-Cleanup and Liability Act) are also covered in this section. Information presented in this section represent excerpts from document EPA/625/4-89/020 (September 1989). 

Figure 27. Houston Chemical Co. response actions (EPA/S40/2-84/002b, 1984).

To maintain adeqnate site control, the site safety and health snpervi-sor mnst have the anthority to enforce the SSAHP s rnles on any individ-nal present at the site, whether that individnal is an employee or an ontside contractor. If there is more than one SSAHP (i.e., if each contractor develops its own), OSHA considers it essential that the plans he integrated and enforced consistently to ensnre that on-site personnel have a clear nnder-standing of safety and health expectations, lines of anthority, and emergency response actions. 

The development of tlie emergency planning and response actions under CERCLA is based primarily on a national contingency plan that was developed under the Clean Water Act. Although the actions of CERCLA liave the capabilities to handle haziirdous and toxic releases, tlie act was primarily directed tow ard the cleanup of abandoned haztirdous waste sites. 

Different emergencies are likely to require different response actions. Specific steps for coping with four types of emergency situations are outlined. 

As soon as is practical afier the release, tliere must be a written followup emergency notice, updating the initial information and giving additional information on response actions already taken, known or anticipated healtli risks, and advice on medical attention. 

Both RCRA and CERCLA address hazards to the environment. However, CERCLA is the more comprehensive statute. CERCLA hazardous substances encompass RCRA hazardous wastes, as well as other toxic pollutants regulated by the CAA, the CWA, and the TSCA. Thus, all RCRA hazardous wastes may trigger CERCLA response actions when released into the environment. RCRA nonhazar-dous solid wastes, on the other hand, do not trigger CERCLA response actions unless they present an imminent and substantial danger as pollutants or contaminants (Figure 12.10). 

Remedial actions are longer-term response actions that ultimately represent the final remedy for a site and generally are more expensive and of a longer duration than removals. This is because the remedial actions are intended to provide permanent solutions to hazardous substance threats. It is possible that both removal and remedial actions may be taken at the same site. In the event that longer-term cleanup is necessary, the site is referred to the remedial program for further investigation and assessment. 

Following the implementation of the remedy, the state or the potentially responsible party (PRP) assumes responsibility for the operation and maintenance (O M) of the site, which may include activities such as groundwater pump and treat, and cap maintenance. Once U.S. EPA has determined that all appropriate response actions have been taken and cleanup goals have been achieved, the site is deleted from the NPL through a formal rulemaking process. 

The facility owner or operator implements RCRA corrective action. On the other hand, a number of different parties can implement a CERCLA remedial action in a number of different ways. For example, agreements may be reached that allow the PRPs, the State, or the federal government to assume the lead for certain portions of a response action. 

An emergency response action for handling major chemical spills or incidents requiring immediate action, usually only at the surface of a site (e.g., to avert an explosion, to clean up a hazardous waste spill, or to stabilize a site until a permanent remedy can be found) these action are limited to 12 months or USD 2 million in expenditure, although in certain cases these limits may be extended. 

The NCP requires that a detailed RI/PS be conducted for every site that is targeted for remedial response action under 104 of CERCLA. 

Developing preliminary remedial action alternatives. This involves initiating limited field investigations if available data are inadequate to develop a conceptual site model and adequately scope the project, and identifying preliminary remedial action objectives and likely response actions for the specific project. 

Developing general response actions for each medium of interest defining containment, treatment, excavation, pumping, or other actions, singly or in combination, that may be taken to satisfy the remedial action objectives for the site... 

Identifying volumes or areas of media to which general response actions might be applied, taking into account the requirements for protectiveness as identified in the remedial action objectives and the chemical and physical characterization of the site... 

Identifying and screening the technologies applicable for each general response action to eliminate those that cannot be implemented technically at the site and to specify remedial technology types... 

For practitioners of in situ technologies, note that U.S. EPA has issued a policy statement that reinjection of contaminated groundwater is allowed under Resource Conservation and Recovery Act (RCRA)35 36 as long as certain conditions are met. This policy is intended to apply to remedies involving in situ bioremediation and other forms of in situ treatment. Under this policy, groundwater may be reinjected if it is treated aboveground prior to reinjection. Treatment may be by a pump-and-treat system or by the addition of amendments meant to facilitate subsurface treatment. Also, the treatment must be intended to substantially reduce hazardous constituents in the groundwater (either before or after reinjection) the cleanup must be protective of human health and the environment and the injection must be part of a response action intended to clean up the environment.37... 

U.S. EPA has issued regulations and guidance primarily focusing on double liners and LCRSs.6 7 Several Federal Register notices and guidance documents have been published by U.S. EPA in this area.8-11 U.S. EPA also issued final regulations for double liners and for LDSs, including construction quality assurance (CQA) and response action plans.12-14... 

The significance of the exposure levels shown on the tables and figures may differ depending on the user s perspective. For example, physicians concerned with the interpretation of clinical findings in exposed persons or with the identification of persons with the potential to develop such disease may be interested in levels of exposure associated with "serious" effects. Public health officials and project managers concerned with response actions at Superfund sites may want information on levels of exposure associated with more subtle effects in humans or animals (LOAELs) or exposure levels below which no adverse effects (NOAELs) have been observed. Estimates of levels posing minimal risk to humans (Minimal Risk Levels, MRLs) are of interest to health professionals and citizens alike. 

The list of 8(e) notices as they have been published or otherwise made available by the EPA or trade press are followed closely by health and safety departments of companies in all types of industries. Industry in general has developed methods to not just acquire and evaluate information, but also take responsive action. 

So the industry has completed 5 years of life under TSCA. We are still in business. But we have changed. Some of the changes come from responding to the law. Some of our responses are to the "spirit of TSCA" — the public demands for responsive action that created the political atmosphere in which TSCA was originally conceived. From the EPA, we have seen several false starts in getting their act together. 

CERCLA, or Superfund, was enacted in 1980, and amended in 1986, for the basic purpose of providing funding and enforcement authority to clean up any site where there is a past unremedied release of a hazardous substance or hazardous substance spill. Such sites are typically characterized as areas where hazardous waste or materials have been disposed of improperly, with litde if any responsible action being taken to mitigate the situation. Standards for financial responsibility were promulgated by the SARA of 1986 which further amended Section 9003 of RCRA and mandated that the EPA establish financial responsibility requirements for UST owners and operators to guarantee cost recovery for corrective action and third-party liability caused by accidental releases of USTs containing petroleum products. 

Stage 1 Is the threat possible If a chemical facility is faced with a terrorism threat, it should evaluate the available information to determine whether or not the threat is possible (i.e., could something have actually happened). If the threat is possible, immediate operational response actions might be implemented, and activities such as site characterization would be initiated to collect additional information to support the next stage of the threat evaluation. 

Stage 3 Has the incident been confirmed Confirmation implies that definitive evidence and information have been collected to establish the presence of a threat to the chemical facility. Obviously, at this stage the concept of due diligence takes on a whole new meaning since authorities are now faced with death and destruction and a potential public health crisis. Response actions at this point include all steps necessary to protect public health, property, and the environment. 

At this point, response actions may be implemented to protect public health. However, if the threat is determined to be not credible, then samples may be collected, preserved and stored in the event that it becomes necessary to analyze them later. 

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