Savannah River Site plan for performing maintenance in Federal Facility Agreement areas (O and M Plan)

The Savannah River Site was placed on the National Priority List (NPL) in December 1989 and became subject to comprehensive remediation in accordance with CERCLA. The FFA, effective August 16, 1993, establishes the requirements for Site investigation and remediation of releases and potential releases of hazardous substances, and interim status corrective action for releases of hazardous wastes or hazardous constituents. It was determined that further direction was needed for the Operating Departments regarding operation and maintenance activities within those areas listed in the FFA. The Plan for Performing Maintenance (O and M Plan) provides this additional direction. Section 4.0 addresses the operation and maintenance activities necessary for continued operation of the facilities in areas identified as RCRA/CERCLA Units or Site Evaluation Areas. Certain types of the O and M activity could be construed as a remedial or removal action. The intent of this Plan is to provide direction for conducting operation and maintenance activities that are not intended to be remedial or removal actions. The Plan identifies the locations of the units and areas, defines intrusive O and M activities, classifies the intrusive activity as either minor or major, and identifies the requirements, approvals, and documentation necessary to perform the activity in a manner that is protective of human health and the environment; and minimizes any potential impact to any future removal and remedial actions