Interim Remedial Measures (IRM)
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 Interim Remedial Measure (IRM), a remedial action.
Interim Remedial Measures
An IRM is a discrete set of planned actions for both emergency and non-emergency situations that can be conducted without the extensive investigation and evaluation of a Remedial Investigation/Feasibility Study (RI/FS).
An IRM can be part of or the full remediation of a site.
An IRM is designed to be a permanent part of the final remedy. Sometimes, an IRM achieves the remedial goal for a site and no further action is required. When an IRM constitutes the entire remedy, DEC drafts a Proposed Remedial Action Plan (PRAP) that proposes no further action at the site and solicits public comment.
An IRM provides a quick solution to a defined problem.
An IRM is extremely adaptable. It covers a variety of activities, large and small, to remediate an array of diverse, well-defined problems at a site. Some of these problems may be contaminated soils, surface and groundwater, debris, sediments, drinking water supplies, buried and abandoned drums of waste and bulk storage tanks.
Remedial activities carried out under an IRM include:
- Removing wastes and contaminated materials, including contaminated soil, sediments and groundwater.
- Erecting access controls such as fences.
- Removing drums of waste and bulk storage tanks.
- Constructing diversion ditches, groundwater collection systems, leachate collection systems, and gas venting systems.
- Pumping and treating contaminated groundwater.
- Treating contaminated soil on-site using innovative technologies such as soil vapor extraction.
- Installing individual drinking water filter systems.
- Demolishing and removing contaminated buildings.
IRMs provide better protection of public health and the environment.
Because of their versatility and the relative speed with which they are applied, IRMs accelerate remedial projects. The sooner sites are remediated, the sooner the public and the environment are protected. In addition, accelerated remedial projects often mean reduced remedial costs.
DEC discusses IRMs with the affected communities.
In emergencies, IRMs must be implemented quickly to be most effective, making it impractical to hold public meetings and comment periods prior to the IRM actions. For time-critical IRMs, the Project Manager prepares a fact sheet describing the IRM for distribution to local officials. The fact sheet is sent to interested parties and residents adjacent to the site. If time does not permit mailing the fact sheet prior to implementation of the IRM, DEC staff may telephone the information to local officials and conduct door-to-door notifications of residents.
For non-time-critical IRMs, the Project Manager conducts an availability session or public information meeting to explain the proposed IRM and listen to comments from local officials and the public.
State and federal agencies and RPs carry out IRMs.
DEC carries out IRMs at State-funded sites. Responsible Parties (RPs) perform IRMs at their sites under consent orders. EPA (the federal Environmental Protection Agency) carries out IRMs, calling them Emergency Response Actions, at sites on the National Priorities List.
DEC also carries out emergency actions at non-registry sites.
DEC's emergency response actions, such as drum removals, are carried out to prevent, mitigate or remedy environmental damage at sites not listed in the registry of inactive hazardous waste disposal sites.