Christopher Black, RCRA CA PM November 18, 2014

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Presentation transcript:

Christopher Black, RCRA CA PM November 18, 2014 RCRA Corrective Action vs. CERCLA or The Top 5 Misconceptions about RCRA Corrective Action Christopher Black, RCRA CA PM November 18, 2014

#1 RCRA Corrective Action is a Compliance Program Misconceptions #1 RCRA Corrective Action is a Compliance Program

REALITY

RCRA Corrective Action = Cleanup

“We are doing the same thing” Statement of Basis/Final Decision Proposed Plan/Record of Decision

RCRA Corrective Action Authorities Pre-HSWA Statutory Enforcement Authorities 1976 – Section 7003 provides judicial authority to compel any person to abate conditions that present an imminent and substantial endangerment to human health or the environment (CERCLA 106) 1980 – Section 3013 added - provides administrative authority to compel investigations

1984 RCRA HSWA Corrective Action Authorities Can happen through an Order or a Permit: Statutory Authority in RCRA - for Interim Status facilities – 3008(h) ~ Usually an Administrative Order on Consent (AOC) RCRA Permits issued after 11/8/84 include CA for releases from Solid Waste Management Units (SWMUs) at the facility - 3004(u) Requires the Owner/Operator (O/O) to perform CA on releases beyond the facility’s boundaries - 3004(v)

Similarities w/ CERCLA Both Cleanups Both Stepped Approach Similar Technical Guidance NPL vs. NCAPS NCP vs. 1996 ANPR

Differences w/ CERCLA Operating/Owned facilities (RCRA CA) vs. Abandoned (CERCLA) Cost Recovery in CERCLA/ NO Cost Recovery in RCRA CA RCRA CA – facility pays for cleanup – No PRPs Training, Support, Contractor & FTE Resources greater in CERCLA

#2 It just deals with RCRA Regulated Units Misconceptions #2 It just deals with RCRA Regulated Units

REALITY

It’s Sitewide Remediation

Misconceptions #3 It’s a small program

REALITY

National Numbers More than 6000 facilities subject to RCRA Corrective Action 3,747 (2020 List) facilities have Corrective Action already underway 1322 sites on the NPL (Final Sites)

Location of RCRA Corrective Action 2020 Sites 1/3/2019 U.S. Environmental Protection Agency

#4 It’s all based on regulations Misconceptions #4 It’s all based on regulations

REALITY

Streamlined Approaches Results Based Orders (negotiate the process) Interim Measures, Short term and Long term goals for the remedies Environmental Indicators for Human Health and Groundwater under Control

Misconceptions #5 It doesn’t affect us

REALITY

Mixed Plumes Overlap of Cleanups Program Differences can confound shared goals

U.S. Environmental Protection Agency We can see some of these RCRA Corrective Action and Superfund overlapping Issues at the Solutia Site 1/3/2019 U.S. Environmental Protection Agency