Environmental Protection Plan.

EP 1110-1-18

24 Apr 00

(e) The Work Plan will be placed in the Administrative Record for the project. The PM

and project team members should also maintain a current copy of the Work Plan.

(f) Any changes to the approved Work Plan will be reviewed by the OE project team and

approved by the OE Design Center and CO prior to implementation. Changes to the Work Plan

should be incorporated within 21 days.

(2) SSHP. As a part of the Work Plan, the A-E will also prepare a SSHP in accordance

with the guidance provided in Chapter 20.

(3) Environmental Protection Plan.

(a) The A-E will prepare an Environmental Protection Plan as a part of the Work Plan.

This plan should include an assessment of ARARs, which must be identified during the EE/CA

planning process. ARARs are defined in paragraph 1-3g of this pamphlet.

(b) ARARs are identified on a chemical-specific, location-specific, and action-specific

basis. ARARs require an analysis for applicability, relevance, and appropriateness. First, the

determination is made whether a requirement is applicable. If it is not applicable, then a

determination is made whether it is both relevant and appropriate. When this analysis concludes

that a requirement is both relevant and appropriate, then the requirement must be complied with

to the same extent as if it were an applicable requirement.

(c) Non-promulgated advisories or guidance documents issued by Federal or state

governments do not have the status of potential ARARs. However, these "to be considered"

criteria may be used in determining the necessary level of cleanup for human safety and

protection of the environment.

(4) Real Estate and Regulatory Requirements. During the EE/CA planning and

coordination process, the PM must ensure that all applicable real estate and regulatory

requirements, as discussed in Chapter 3, have been satisfied. The PM should also ensure that the

public involvement requirements discussed in Chapter 4 have been satisfied. Additionally, the

applicable safety and training requirements, as specified in Chapters 20 and 24 respectively, must

be fulfilled. The PM may also consider the establishment of an Anomaly Review Board (ARB).

ARBs are only used in exceptional circumstances (e.g., an ARB may be used during an EE/CA

investigation at a highly contaminated site in a heavily urbanized area). Information on ARB

procedures is provided in Appendix E.

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