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.
FACT SHEET #2
EXPECTATIONS FOR $ A t>
FINAL REMEDIES AT RCRA 1
CORRECTIVE ACTION FACILITIES \
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
Workshop.
WHAT IS THE PURPOSE OF THIS FACT SHEET?
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.
WHAT ARE THE AGENCY'S EXPECTATIONS FOR FINAL CORRECTIVE
ACTION REMEDIES?
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
facilities:
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
occur.
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
contamination.
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
environment.
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..
WHERE DO I GET MORE INFORMATION?
For more information about RCRA Corrective Action and the Results Based Site
Management Workshop, visit the Corrective Action Internet Home Page at
http://www.epa.gov/correctiveaction.
Notes:
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
------- |