Risk in remediation national rcra corrective action program perspective risk in remediation national rcra corrective action program perspective guy tomassoni, epa hq, office of solid waste corrective action programs branch tomassoni. Rcra corrective action for automotive manufacturing client site, mi weston resolved an array of client rcra corrective action obligations by providing comprehensive facility investigation, interim measures, and corrective measures solutions that reduced financial, ecological, and human health risks at an automotive manufacturer. If no releases to the environment are found, or if all unacceptable risks have been adequately removed andor managed, the corrective action completion determination process begins. Sparton performed the requirements of the order with oversight by epa. Federal register announcement of availability and request. The objective of the rfa is to identify potential and actual releases from swmusaocs and make rcra facility assessment rfa interim stabilization measures rcra facility. The rcra corrective action program, under the hazardous and solid waste amendments hswa to rcra, is a comprehensive cleanup program designed to investigate and, where necessary, remediate releases of hazardous waste or hazardous waste constituents from solid waste management units swmus at rcra facilities on a sitewide basis. Rcra, as amended by the hazardous and soli proposed 40 cfr part 264, subpart s 55 fr 30798, july 27,1990, 40 cfr part 270. Rcra corrective action plan the resource conservation and recovery act rcra corrective action plan cap is intended to aid regions and states in determining and directing the specific work that a permitteerespondent must perform as part of a complete corrective action program. On october 2, 2001, epa published a notice in the federal register requesting comment on a draft guidance document entitled recognizing completion of corrective action activities at rcra facilities see 66 fr 50195. Imposition of interim measures is typically written into the corrective action portion of the final rcra permit. Rcra corrective action determination of no further action. Epa possesses several corrective action authorities to compel cleanup.
At nonpermitted facilities where facilitywide corrective action is complete, and all other rcra obligations at the facility have been satisfied, epa or the authorized state may acknowledge completion of corrective action by terminating interim status through final administrative disposition of the facilitys permit application see 40 cfr. The resource conservation and recovery act rcra, an amendment to the solid waste disposal act, was enacted in 1976 to address the huge volumes of municipal and industrial solid waste generated nationwide. How can the public be involved in corrective action. The rcra corrective action program requires facilities that treat, store. Under the resource conservation and recovery act rcra corrective action program, epa has created a number of interim remedial measures for east. For access and information to nonenforcement, rcra corrective action program office documents, visit epas corrective action guidance website to locate a document within the rcra cleanup enforcement policy and guidance compendium choose from the search box, chronological. Guidance on implementing isms was provided in the original cap, the rcra corrective action interim measures guidance oswer directive 9902.
Materials found in this area address resource conservation and recovery act rcra cleanup enforcement topics. Interim measures im to control and abate the spread of hazardous waste. The waste must be accumulated in either tanks or containers. An opportunity for facilities and regulators to show meaningful progress that is achievable in the near future. This cleanup process is known as corrective action. Considerations for assessing ecological risks interim. Lucero, director, office of waste programs enforcement, and marcia williams, director, office of solid waste, on june 10, 1987, as the rcra 3008h corrective. Chronological list of rcra cleanup policy and guidance documents. Transmittal of interim guidance on financial responsibility for facilities subject to rcra corrective action 93003 provides guidance in the implementation of financial responsibility requirements to ensure that owners and operators provide evidence of financial responsibility for corrective action. Rcra corrective action summary montana environmental trust. Guidance on interim actions at corrective action sites epa. Nontsdfs where rcra corrective action has been imposed universe. What are some common reasons owners or operators of rcra facilities start corrective action. Examples of interim measures for various unit and release types an listed in the next chapter of this guidance document on page 4, integration with long term corrective action interim measures may be separate from the comprehensive corrective action plan but should anticipate integration with any longer term corrective action e.
Risk in remediation national rcra corrective action. Additional information about rcra corrective action is available on the. Epa has developed an interim guidance on site field work. Rcra corrective action in 2015 might not begin remedy construction until 2031. Corrective action program for hazardous waste facilities nys. When ics are used to supplement a corrective action remedy, whether it is part of an interim measure or the final corrective measure, the ic is usually considered during remedy selection, and commonly included in rcra decision documents permits, etc. Epas interim guidance applies to superfund cleanups, resource conservation and recovery act rcra corrective actions, toxic substances. Legally nonbinding guidance documents, adopted by the medical device coordination group mdcg in accordance with article 105 of regulation 7452017, pursue the objective of ensuring uniform application of the relevant provisions of the regulations within the eu. Rcra corrective action interim measures guidance interim final u. General description of illinois epas rcra corrective action. What rcra liability protections are available for purchasers of contaminated property. Permit writer instructions chapter 11 california department of. Nov 22, 2016 guidance on developing a rcra corrective action plan. Resultsbased approaches and tailored oversight pdf 18 pp, 587k.
Employ corrective measures that meet the threshold criteria and balancing. Rcra facility assessment rfa investigation rfi statement. Enforcement approaches for expediting corrective action. Corrective action or to address them through the corrective action cleanup requirements. In the near future epa will finalize a crossprogram guidance entitled. Managements implementation of the rcra corrective action program. Expectations for final remedies at rcra corrective action facilities pdf 2 pp, 12k final remedy selection for results based rcra corrective action pdf 10 pp. Currently, one is working with the usepa to transition the site from an interim remedy to a final remedy under the rcra corrective action program which consists of monitored natural attenuation mna and phytoremediation. However this rule was not intended as a way to bring wmus under the unitspecific closure standards.
Resource conservation and recovery act rcra corrective action. How do i know if im subject to a rcra closure or rcra. Key points as stated earlier in this course, land revitalization is a priority focus area for epa. General description of illinois epas rcra corrective.
Environmental indicators corrective action wastes us epa. Guidance internal market, industry, entrepreneurship and. Transmittal of interim guidance on financial responsibility for facilities subject to rcra corrective action pdf 17 pp, 295k september 30, 2003. Although the stabilization initiative is an approach that should be considered for all facilities subject to rcra corrective action, ohio epa emphasizes that the need for interim measures is determined on a site specific basis and may be identified at any point in the corrective action.
An owner or operator required to establish a corrective action program under this subpart must, at a minimum, discharge the following responsibilities. The rcra corrective action program, under the hazardous and solid waste. Protect human health and the environment from the hazards posed by waste disposal. Clarification to the 1994 revised interim soil lead guidance for cercla sites and rcra corrective action facilities pdf 16 pp, 127k top of page.
The rcra corrective measures study cms report berkeley lab, 2005a provided recommendations for the specific corrective measures that are required to eliminate or reduce potential risks to human health from contaminants in the soil and groundwater at berkeley lab, and protect the potential. Handlers are only included in this universe once theyve initiated corrective action through an rfi. Definition of environmental indicators for the rcra corrective action environmental indicators ei are measures being used by the rcra corrective action program to go beyond programmatic activity measures e. Generators of more than 1,000 kg 2,200 lbs of hazardous waste per month may accumulate their waste for up to 90. The purpose of this corrective measures study cms is to develop and evaluate the corrective action alternatives and to recommend the corrective measure s be taken at the facility. Epa memo to rcra senior policy advisors concerning office of inspector general recommendations pertaining to rcra corrective action environmental indicators september 25, 2002 pdf 2 pp, 18k oswer draft guidance for evaluating the vapor intrusion to indoor air pathway from groundwater and soils subsurface vapor intrusion guidance. Olq may require corrective action as a condition of a rcra permit, or by an enforcement action using indiana code 22. The design plan has been prepared in general accordance with epas guidance. A means of evaluating and reporting on the acceptability of current site conditions i. Rcra corrective action interim measures guidance interim final. Resource conservation and recovery act rcra cleanup. The resource conservation and recovery act rcra was enacted by congress in 1976, as an amendment to the 1965 solid waste disposal act. Chronological list of rcra cleanup policy and guidance. The actions discussed in this document include interim measures and performance standards, environmental indicators, stabilization practices.
Environmental protection agency epa was introduced on december 2, 1970 by president richard nixon. Rcra corrective action experience one environmental. Interim measures definition umbrella term for wide range of institutional and physical corrective action activities to achieve stabilization the goal of interim measures im and stabilization is to control or abate imminent threats to human health and the environment from releases at rcra facilities interim measures can be implemented at. If epa or the authorized state determines there has been a release of a hazardous waste or hazardous waste constituent at an interim status facility, rcra section 3008h1 authorizes epa or the authorized state to issue an administrative order requiring corrective action or other measures. The facility was constructed in 1963 and was specifically constructed for electroforming work. Corrective measures implementation cmi interim corrective measures icm focused cms atp group. This toolbox and its attachments are intended to provide guidance to epa personnel. The objective of the rfa is to identify potential and actual releases from swmusaocs and make rcra facility assessment rfa interimstabilization measures rcra facility. For both types, all of the following have been satisfied. Interim corrective measures icms to control or abate threats to human health andor the environment from releases andor to prevent or minimize the further.
Historical activities at permitted, interim status, and illegal rcra treatment, storage or. Rcra corrective action process rcra facility assessment rfa 1988 rcra facility investigation rfi 19902006 corrective measures study cms 2009 2010. Under the resource conservation and recovery act rcra epa requires the investigation and cleanup, or remediation, of the release of hazardous waste at rcra facilities. Resource conservation and recovery act rcra corrective action and closure programs. Tennessee was authorized by epa to oversee tennessee s corrective action program in 2000. Corrective action management unit means an area within a facility that is used only for managing. Rcra facility investigation rfi, corrective measures study cms, and. Environmental indicator determination interim final 2599. Rcra corrective action interim measures guidance interim. The us department of energy doe is involved in the remediation of environmental contamination at many of its facilities under the resource conservation and recovery act rcra. Facilities generally are brought into the rcra corrective action process through orders when there is an identified release of hazardous waste or hazardous constituents from waste management units wmu, or when ohio epa is considering a facilitys rcra permit application. Rcra corrective action environmental indicator ei rcris. A comparison of the rcra corrective action and the cercla.
If the need for interim measures is identified, ohio epa will require its implementation. Guidance on interim actions at corrective action sites. Chapter 4 demand for remediation of rcra corrective action. Interim corrective action guidance pdf 5 pp, 17 k, april 2, 2012 table that describes and references epas aim to use interim measures at facilities subject to rcra corrective action, since they are generally operating industrial facilities. Final guidance on completion of corrective action activities at. Rcra corrective action for automotive manufacturing client. Epa enforcement approaches for expediting rcra corrective. Interim final guidance for rcra corrective action environmental indicators, u. The intent of the attached document is to provide a comprehensive sidebyside comparison of the rcra corrective action and the cercla remedial action processes. The consent order, effective october 11, 1990, required conocophillips to perform facilitywide corrective action including interim measures, a rcra facility investigation, an environmental and human health risk assessment, and a corrective measures study. Fact sheet rcra corrective action program site name. Final guidance on completion of corrective action activities. The regional administrator will specify the groundwater protection standard in the. A site that does not hold rcra interim status or a rcra permit may accumulate hazardous waste for a short period of time before shipping it offsite.
Learn about corrective action hazardous waste us epa. Guidance on interim actions at corrective action sites us epa. The respondent shall furnish the personnel, materials, and services necessary to prepare the corrective measures study, except as otherwise specified. When may epa take enforcement action at a rcra corrective action facility. The agency is charged with protecting human health and the environment. The oepa has verbally agreed to revise the corrective measures program to reflect the revised remedial program as well. Consists of the rcra handlers that are not tsd facilities where corrective action has been imposed e. Resource conservation and recovery act rcra cleanup policies and guidance materials found in this area address resource conservation and recovery act rcra cleanup enforcement topics. Rcra corrective action process rcra facility assessment rfa 1988.
In response to the hswa mandate, epa established a program for the conduct of rcra corrective action. For more information on rcra corrective action, please go to the link for rcra closure guidance on derrs cleanup under rcra web site. This guidance document is a part of the reform effort, and describes a range of newer approaches that epa regions have developed to help expedite corrective action, which also helps in meeting our gpra goals and final cleanup. What are the rcra corrective action environmental indicators. Department of energy, off ice of environmental and assistance, rcrncercla division eh4, guidance manual, doueh0393, may 1993, 2. The rcra corrective action environmental indicators eis are.
Sep 30, 2003 clarification to the 1994 revised interim soil lead guidance for cercla sites and rcra corrective action facilities pdf 16 pp, 127k top of page. Figure a shows a flowchart of the corrective action process. Rcra facility assessment rfa often the first activity in the corrective action process is the rfa. Comparison of the rcra corrective action and cercla remedial action processes, prepared by the office of environmental guidance, rcracercla division eh231. A slurry wall containment system, an interim cover system, and groundwaterleachate collection, conveyance, and pretreatment system were installed. For access and information to nonenforcement, rcra corrective action program office documents, visit epas corrective action guidance website. While the use of interim measures, as described in the proposed subpart s rule, is designed to permit the implementation of shortterm actions to protect human health and the environment. Interim corrective measures 146 214 258 285 1,309 1,637 2,186 2,916 3,506 4,072 4,327 4,473. Congress amended the resource conservation and recovery act rcra in november 1984, expanding the acts cleanup provisions and prompting epa and its state partners to develop the rcra corrective action program. The essential stages of corrective action program and their objectives are as follows. Epa was clear that regional office decisions and followup steps must be. Resource conservation and recovery act rcra corrective.
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