Remedial Design and Construction
New York State's Inactive Hazardous Waste Disposal Site Remedial Program begins with the discovery of a potential hazardous waste site and follows a path of investigation, remedy selection, design, construction and monitoring. This fact sheet highlights the Design and Construction phase of the program.
Design and Construction
The remedial design spells out the technical requirements of construction.
The remedial design details the size, scope and character of a site's remediation - the planned action that will, at a minimum, protect public health and the environment. It translates information from the Remedial Investigation/Feasibility Study, the Record of Decision and additional data gathered during design preparation into clear, precise facts and numbers.
Key participants are Responsible Parties (RPs), state and federal agencies.
RPs are legally responsible for site remediation. For many sites, remedial work is carried out by RPs under DEC oversight. The RPs are responsible for completion and long-term performance of the remedy. For other sites, remedial work is carried out by DEC or EPA.
DEC ensures that all remedial designs effectively protect the environment and conform to the recommendations of the Records of Decision and consent orders.
The NYS Department of Health (DOH) ensures that all remedial designs effectively protect the public and contain community health and safety considerations that must be implemented during construction.
Design elements include quality control, assurance and contingency plans.
Construction Quality Control (CQC)
A planned system of inspections that is used to directly monitor and control the quality of a construction project. CQC, usually carried out by the contractor, is necessary to achieve quality in the constructed system.
Construction Quality Assurance (CQA)
A planned system of activities to provide assurance to the owner and the permitting agency that all aspects of remedial construction meet design requirements. CQA includes inspections, verifications, audits, tests and evaluations of materials and workmanship to determine and document the quality of the remedial construction.
The contingency plan protects the local community in the instance of an accident or emergency caused by remedial activities. Contingency plans may include:
- Name of person responsible for responding in an emergency.
- Schedule for meeting with local, state and federal agencies, the community, local emergency agencies and hospitals.
- First aid and medical information.
- Air monitoring plan if a human health risk exists through inhalation of specified pollutants.
- Spill control and countermeasures plan to prevent contamination of soil, water, air, structures, equipment or material from the discharge of wastes due to spills. Also, to contain the spill and remove and properly dispose of media contaminated from the spill.
Citizen participation activities, which begin when the site is identified, continue through the Design and Construction phases.
When the remedial design is finalized, a fact sheet describing the proposed remedial action is distributed to the community and other interested people. The fact sheet also contains a construction schedule, explanations of the roles of the RP and DEC, details of the contingency plan and descriptions of potential inconveniences, such as excess traffic and noise. A public meeting or availability session may also be held to discuss schedules, changes in traffic patterns, location of monitoring equipment and how the public will be kept informed on progress. DEC staff ensure that all relevant documents about the site remediation are placed in repositories for public review.
At the completion of construction, another fact sheet announcing the end of construction and describing any Operation and Maintenance activities that may have been specified in the Record of Decision (ROD) is distributed to the community.
Remedial construction is carefully monitored.
DEC's remedial project manager attends progress meetings to discuss the status of and changes in the project, test results, other findings and upcoming activities. The manager ensures that construction is not endangering public health, monitors quality assurance, coordinates remedial activities and promotes citizen participation.
The RP's or DEC's consulting engineer and inspectors test and inspect the constructor's work and confirm that test data are properly recorded and validated. Their main responsibility is to verify that construction conforms to the approved design documents.
DEC oversight ensures that the construction meets all the requirements of the approved design.
No work is performed at a site until DEC has approved the work plan. Oversight consists of two types - office and field. Office oversight includes the review, evaluation and comment on all submittals, reports, data, etc. generated by remedial activities. Field oversight is site dependent and includes consent order requirements, construction according to approved plan, public health and environmental concerns, public sensitivity and the potential for pollutant migration.
Final inspection ensures that all aspects of the design have been met by the construction.
Acceptance of the remedial work signals the next step in the remedial program - site reclassification.
Sites are often reclassified after remedial construction. Site reclassification signals the conclusion of the remedial construction.
Following remediation, a site usually is reclassified from Class 2, which calls for remedial action to protect public health or the environment, to:
- Class 4, requiring continued operation, maintenance and monitoring, or
- Class 5, requiring no operation, maintenance and monitoring.
If all hazardous wastes have been removed, the site may be removed (delisted) from the Registry of Inactive Hazardous Waste Sites.
Operation and Maintenance may be included in the remedial program.
Included in some remedies are monitoring requirements, which are included in Operation and Maintenance (O&M) Plans. O&M includes visual inspections and upkeep and can include sampling.