United States                  RCRA Corrective Action Workshop On     EPA
Environmental Protection Agency    Results-Based Project Management:       March 2000
Office of Solid Waste            Fact Sheet Series                   www.	
EXPECTATIONS FOR                         $  A   t>
FINAL REMEDIES AT  RCRA                1
Congress, the general public, EPA, and State agencies believe the rate and pace of RCRA
cleanups should be increased. Tim Fields, Assistant Administrator of the Office of Solid
Waste and Emergency Response, recently indicated that Corrective Action was the RCRA
program's highest priority. One of the efforts designed to improve Corrective Action
progress is a new workshop titled, "RCRA Corrective Action Workshop on Results-Based
Project Management." This is the second in a series of fact sheets supporting the

This fact sheet1'2 conveys the Agency's general expectations for final remedies at RCRA
Corrective Action facilities.  EPA believes that an awareness of these expectations will help
focus facility investigations as well as the evaluation and selection of remedial alternatives.

Final remedies for RCRA Corrective Action facilities should be protective of human health
and the environment, and maintain protection over time.  In meeting this remedial goal,
EPA has learned that certain combinations of facility-specific circumstances are often
addressed by similar approaches. Based on this experience,  the Agency has developed
certain general expectations3 for remedies. Remedy expectations are not binding
requirements; rather, they should be  used to focus program implementors and facility
owner/operators on remedial alternatives that have the greatest likelihood of fulfilling the
statutory and regulatory intent of RCRA Corrective Action.  Currently, EPA has the
following remedial expectations for implementing final remedies at RCRA Corrective Action

      EPA expects to use treatment to address the principal threats posed by a  site
     whenever practicable and cost-effective. Contamination that represents principal
     threats for which treatment is  most likely to be appropriate includes contamination
     that is highly toxic, highly mobile, or cannot be reliably contained, and that would
      present a significant risk to human health and the environment should exposure
             RCRA Corrective Action Workshop on Results-Based Project Management
             Fact Sheet No. 2, Expectations for Final Corrective Action Remedies, Page 1

      EPA expects to return usable groundwaters to their maximum beneficial uses
      wherever practicable, within a time frame that is reasonable given the particular
      circumstances of the site. When restoration of groundwater is not practicable, EPA
      expects to prevent or minimize further migration of the plume, prevent exposure to
      the contaminated groundwater and evaluate further risk reduction. EPA also expects
      to control or eliminate surface and subsurface sources of groundwater

      EPA expects to use engineering controls, such as containment, for wastes and
      contaminated media which can be reliably contained, pose relatively low long-term
      threats, or for which treatment is impracticable.

      EPA expects to use a combination of methods (e.g., treatment, engineering and
      institutional controls), as appropriate, to achieve protection of human health and the

      EPA expects to use institutional controls such as water and land use restrictions
      primarily to supplement engineering  controls  as appropriate for short- and long-term
      management to prevent or limit exposure to hazardous wastes and constituents.
      EPA does not expect that institutional controls will often be the sole remedial action.

      EPA expects to consider using innovative technology when such technology offers
      the potential for comparable or superior treatment  performance or implementability,
      less adverse impact, or lower costs for acceptable  levels of performance when
      compared to more conventional technologies.

      EPA expects to remediate contaminated soils as necessary to prevent or limit direct
      exposure of human and environmental receptors and prevent the transfer of
      unacceptable concentrations of contaminants (e.g., via leaching, runoff or air borne
      emissions) from soils,  including subsurface soils, to other media..

For more information about RCRA Corrective Action and the Results Based Site
Management Workshop, visit the Corrective Action Internet Home Page at


1.     This document provides guidance to the public and the regulated community on how EPA intends to
      exercise its discretion in implementing its regulations.  The document does not, however, substitute
      for EPA's regulations, nor is it regulation itself. Thus, it cannot impose legally-binding requirements
      on EPA, States, or the regulated community, and may not apply to a particular situation  based upon
      the circumstances.  EPA may change this guidance in the future as appropriate.

2.     These expectations were taken from the May 1, 1996 Advance Notice of Proposed Rulemaking
      (ANPR) for RCRA Corrective Action Facilities (61 FR 19432). Many of these expectations were first
      articulated in the discussion of remedy selection at CERCLA sites in the National Oil and Hazardous
      Substances Pollution Contingency Plan (NCP) (40 CFR 430(a)(1)).
               RCRA Corrective Action Workshop on Results-Based Project Management
               Fact Sheet No. 2, Expectations for Final Corrective Action Remedies, Page 2