1. June 20, 2001EPA Region 6 Corrective Action Conference1 Corrective Action Strategy in Arkansas Daniel Clanton Engineering Supervisor Arkansas Department of Environmental Quality

2. June 20, 2001EPA Region 6 Corrective Action Conference 2 Criteria For Success Trust for all parties is an imperative. If the facility doesn’t trust the state and the state doesn’t trust the facility, the CAS will not work. Commitment by management of both state and facility to quick document turn around. Delegation for decision making to those parties directly involved in the project.

3. June 20, 2001EPA Region 6 Corrective Action Conference 3 Commitment by the Facility Facility must be cooperative. Facility must make commitment in resources, both in time and money, to accelerate characterization and clean-up.

4. June 20, 2001EPA Region 6 Corrective Action Conference 4 Commitment by the State State must commit to quick document turn around, frequent conference calls, and delegation of approval to those available for calls. State must agree to make decisions during meetings and document those decisions in writing.

5. June 20, 2001EPA Region 6 Corrective Action Conference 5 Three Sites Are Currently Working With Us Using the CAS REMINGTON ARMS GREAT LAKES CHEMICAL KOPPER’S/BEAZER EAST

6. June 20, 2001EPA Region 6 Corrective Action Conference 6 Remington Arms Company Formerly a subsidiary of Dupont. Dupont is directly involved with the current company in the investigation. The CAS pilot project with EPA Region 6. A letter of agreement is the implementing document.

7. June 20, 2001EPA Region 6 Corrective Action Conference 7 Remington Arms Company No investigation had begun at the time of the Letter of Agreement. Scoping meeting held January 23, 2001. Jamie VanBuskirk from Dupont will elaborate on the site and discuss progress under the Corrective Action Strategy.

8. June 20, 2001EPA Region 6 Corrective Action Conference 8 Great Lakes Chemical Company Corrective Action started as the result of a Consent Administrative Order in the late 1980s. Corrective Action merged with permit when issued in 1994. Extensive work done, i.e., closures, etc. No remedial action decision was on the horizon. Not an official pilot but is benefiting from EPA’s assistance.

9. June 20, 2001EPA Region 6 Corrective Action Conference 9 Great Lakes Chemical Company Entering the process at RFI workplan approved. Scoping meeting held January 31 – February 1, 2001. Major contaminates are bromine related.

10. June 20, 2001EPA Region 6 Corrective Action Conference 10 Koppers/Beazer East Corrective Action started with a RCRA 3008 (h) Administrative Order on Consent issued by EPA Region 6. Post Closure Permit issued in July 1995 with provision for corrective action to go under the permit, and therefore state control, on approval of the Corrective Measures Study by EPA Region 6. 3008 (h) order terminated early on approval of the CMS Workplan.

11. June 20, 2001EPA Region 6 Corrective Action Conference 11 Koppers/Beazer East Site originated in 1906, and has been treating railroad ties ever since. Koppers Industries owns the site. Beazer East is responsible for the corrective action. Major contamination is from a sludge impoundment that leaked; major pool of creosote on and offsite. One high efficiency recovery well on site with others to follow.

12. June 20, 2001EPA Region 6 Corrective Action Conference 12 Koppers/Beazer East Ground water contamination offsite. Subdivisions on two sides of facility. Public Participation important in decision making. Scoping meeting held February 22, 2001.

13. June 20, 2001EPA Region 6 Corrective Action Conference 13 Some parting thoughts We are planning to use the CAS for at least one other major facility on the GPRA list this year. We are contemplating using it on a more wide spread basis. Again, it is not a replacement for enforcement orders for some facilities. CAS is a good way to get to “yes” faster for environmental indicators.

14. June 20, 2001EPA Region 6 Corrective Action Conference 14 Visit Our Website on CAS Arkansas Department of Environmental Quality. Go to www.adeq.state.ar.us.www.adeq.state.ar.us Click on Divisions & Sections. Click on Hazardous Waste Division. Click on Active Sites Branch. Click on Arkansas Corrective Action Strategy.

15. June 20, 2001EPA Region 6 Corrective Action Conference 15 Questions?