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
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