EP 1110-1-19
30 Jun 01
f.
Operation and Maintenance. Operation and maintenance (O&M) are the activities
required to maintain the effectiveness or the integrity of a remedy. O&M is dependent on the
implemented remedy. O&M may not be necessary, may only be required for a defined
timeframe, or may be required to be performed indefinitely.4 For remedies that require active
on-site treatment, remedial system evaluation or optimization is an important component of
under NCP 300.435(f)(4), O&M measures are initiated after the remedy has achieved the
remediation objectives and cleanup goals listed in the ROD, and is operational and functional
(Paragraph 2-2.a). O&M starts when the RA is complete and the State or the PRP(s) assume
responsibility for all activities necessary to operate and/or maintain the long-term effectiveness
or integrity of the actions selected in the ROD. In the case of Fund-financed measures to restore
groundwater or surface waters, that extend beyond the ten-year long-term RA period (Paragraph
2-2.b), O&M is required to continue the operation of such measures until the cleanup goals are
achieved.
2-2. Remedial Action Process. Besides the RA and O&M phases, the RA process typically
includes the operation and functional period, long-term response, cleanup goals achieved
milestone, and five-year reviews. Exhibit 2-2 provides three different pipeline scenarios to help
illustrate when these periods occur in relation to preparation of the RA report. The following
paragraphs provide a brief description of each phase or milestone.
a.
Operational and Functional
(1)
Operational and functional (O&F) activities are conducted after the RA has been
constructed to ensure that it is operating as designed and functioning properly. The O&F period
is part of the RA and occurs during the last year of the RA. The NCP provides for a maximum
timeframe of one year for performing O&F activities, though EPA may extend the one-year
period, as appropriate. O&F determinations are made for containment (all media), groundwater
not go through an O&F determination.
(2)
A remedy becomes O&F either one year after O&F start, or when the remedy has
been determined, concurrently by EPA and the State agency, to be functioning properly and
performing as designed, whichever occurs first (40 CFR 300.435). O&F is considered to be
complete on the date that the designated Regional official approves, in writing, the interim RA
report (for sites with groundwater or surface water restoration remedies) or final RA report. This
4
Examples of remedies where O&M may have an indefinite period of performance are sites where waste is contained on-site
and the integrity of the cap must be maintained or sites where institutional controls must be maintained.
5
Additional information on
remedial
system
evaluation
or
optimization
is
available
on
the
web
at
6
Formal O&F determinations are made primarily for Fund-financed projects because the O&F milestone governs when O&M
or Long-Term RA (LTRA) begins under State authority. Federal facilities-lead projects go through determinations known as
"operating properly and successfully."
2-5
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