United States             Office of Solid Waste           E ??£  \
                     Environmental Protection      and Emergency Response      R«vised Marcn
                     Agency                (OS-305)             Supersedes January 1993


                     Office of Solid Waste                                  	
&ER&         Environmental
                     Fact  Sheet
                     EPA Issues Final Rules for Corrective

                     Action Management Units and Temporary

                     Units

                     EPA has revised the corrective action-related regulations under Subtitle C of the
                     Resource Conservation and Recovery Act (RCRA). The revised regulations
                     address the difficulties associated with management of remediation wastes
                     during corrective actions. EPA is introducing the concepts of Corrective Action
                     Management Units (CAMUs) and Temporary Units for remediation wastes to
                     provide facilities with a wider range of remediation alternatives, while assuring
                     reliable, protective, and cost-effective remedies. This flexibility will help to
                     promote more expeditious dean-ups at many sites.


   EPA's Corrective Action Program

        Subtitle C of the 1976 Resource Con-       The actual cleanup of these facilities,
   servation and Recovery Act (RCRA) created  as with Superfund sites, often involves ex-
   a comprehensive program for the safe man-  cavating and managing large volumes  of
   agement of hazardous wastes. In  1984,  hazardous wastes, including contaminated
   Congress passed the Hazardous and Solid  soils,  debris, sludges and other wastes.
   Waste Amendments (HSWA), which man-  These cleanup wastes are  subject to the
   dated even stricter standards  for the  same set of RCRA regulations that apply to
   regulation of hazardous wastes. One of the  management of newly generated hazardous
   key provisions of HSWA was the authority  wastes.  However. EPA's experience with
   provided to EPA to compel "corrective ac-  implementing the corrective action program
   tiorf for environmental problems that have  has shown that application of these uni-
   resulted from historic waste management  form,  national standards has often been
   practices at hazardous waste facilities.     counterproductive when applied to the

                                         alternative rmedles that c     otherwise
   eventually need some type of corrective   havebeenavaflable.Foreicampleitreatment
   action.

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                     United States             Office of Solid Waste           E ^  u
                     Environmental Protection      and Emergency Response      R«vised Marcn
                     Agency                (OS-305)             Supersedes January 1993

                     Office of Solid Waste                                    	
SEPA         Environmental
                     Fact  Sheet
                     EPA Issues Final Rules for Corrective

                     Action Management Units and Temporary

                     Units

                     EPA has revised the corrective action-related regulations under Subtitle C of the
                     Resource Conservation and Recovery Act (RCRA). The revised regulations
                     address the difficulties associated with management of remediation wastes
                     during corrective actions. EPA is introducing the concepts of Corrective Action
                     Management Units (CAMUs) and Temporary Units for remediation wastes to
                     provide facilities with a wider range of remediation alternatives, while assuring
                     reliable, protective, and cost-effective remedies. This flexibility will help to
                     promote more expeditious clean-ups at many sites.


   EPA's Corrective Action Program

        Subtitle C of the 1976 Resource Con-       The actual cleanup of these facilities,
   servation and Recovery Act (RCRA) created  as with Superfund sites, often involves ex-
   a comprehensive program for the safe man-  cavating and managing large volumes  of
   agement of hazardous wastes.  In  1984,  hazardous wastes, including contaminated
   Congress passed the Hazardous and Solid  soils,  debris, sludges and other wastes.
   Waste Amendments (HSWA), which man-  These cleanup wastes are  subject to the
   dated even stricter standards for the  same set of RCRA regulations that apply to
   regulation of hazardous wastes. One of the  management of newly generated hazardous
   key provisions of HSWA was the authority  wastes.  However. EPA's experience with
   provided to EPA to compel "corrective ac-  implementing the corrective action program
   tion" for environmental problems that have  H^Q shown that application of these uni-
   resulted from historic waste management  form,  national standards has often been
   practices at hazardous waste facilities.     counterproductive when applied to the







   **!!• Z11^  ™ ^^FSrS alternative remedies that oSdd otherwise
   eventually need  some type of corrective nayebeenavaflable.Forerampleitreatment
   action.

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                                       -2-
standards requiring incineration often
preclude the use of other effective treatment
technologies that could be used in achiev-
ing a protective cleanup for a site.

Action Being Taken
      In order to address these problems,
EPA has finalized regulations that provide
for the use of corrective action management
units (CAMUs) when cleaning up sites
under RCRA and Superfund.  Use of the
CAMU  concept under these regulations
will ensure cleanups that are fully protec-
tive, yet  better tailored  to actual site
conditions. Under the rule, appropriate
treatment requirements will be determined
as  part of the overall cleanup plan for a
particular site. This is expected to result in
more expeditious cleanups, and will pro-
mote the use of new, innovative treatment
technologies.   The use of  CAMUs should
decrease  the  volumes of cleanup wastes
that must be incinerated, and increase the
use of alternative treatment technologies
that are appropriate for actual site and
waste characteristics.  In addition, EPA
expects the new rule to result in less waste
being hauled  off-site, and overall, more
treatment of greater volumes of cleanup
wastes
      Hie CAMU regulations contain im-
portant restrictions and safeguards that
ensure the rule will be used to achieve
more protective and effective cleanups. For
example, newly generated process wastes
cannot be managed in CAMUs, nor can
wastes that originate from other clean-up
 sites. Technical requirements for ground-
 water monitoring, closure, and post-closure
 are also  specified. In addition, the rule
 requires  thorough public  review and
 comment on CAMU decisions.
       Based  on the  Regulatory Impact
 Analysis conducted for this rule, the use of
   Glossary fln
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                                          -3-
 the CAMU concept Is also expected to result
 In billions of dollars of cost savings  for
 industry and Federal agencies.

        In addition to the CAMU provisions,
 the  final  rule also will allow regulatory
 agencies to approve "temporary units" for
 remedial purposes. This provision will al-
 low regulatory agencies to modify design
 standards for tanks and container storage
 units that are used for short-term treat-
 ment or management of remediation wastes.

 Example 1
State Applicability

      This rule will take effect shortly after
publication, in .States where EPA is imple-
menting the  RCRA  corrective  action
program. In other States, the rules will not
take effect until they are adopted by the
State legislatures. Since the rule is con-
sidered "less stringent" adopting the CAMU
rules will not be mandatory.   However,
EPA strongly encourages States to adopt
these regulations.
 Before Remedial Activities
 The remedial goal at this facility is to  1) treat and
 contain contaminated surface sofl Jrom. the site, and
 (2) to stabilize and contain sludge wastes Jrom the
 leaking sludge lagoon. In this case, the two waste
 streams have very different characteristics and re-
 quire efferent treatment processes. In addition, they
 wiR require different ultimate containment methods.
After Designating CAMUs
(A) To allow for these differing waste characteristics
and to minimize further contamination, the regula-
tory officials have designated two separate CAMUs
to deal with the two remediation waste streams.

(B) Remediation wastes Jrom the contaminated sur-
face son of the facility wOl be treated in treatment
unit* I and remediation wastesjrom the laaoonurfD
be treated in unit f 2. Both wiits may be temporary
units authorized specfficaUy for the remediation
process.

(C) Treatment residuals can be placed in each CAMU
without triggering the Land Disposal Restrictions.
Each CAAfU must beprotectiueo/human health and
the environment For the sludge lagoon (now CAMU
*2j, this may mean retrofitting the unit euen though
it mould not necessarily need to meet minimum
technology requirements.
r
Pacify Boundary
    Solid Waste
  I  MgmntUnit
                   Surface Soil
                   Contamination
                                                I a on ~"|
                                                DD  oD
                                             I  Process Area
                                Sludge
                                Lagoon
                  Surface SoTT
                             _
   rDcess^Arc£ __ . ____________ |

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