RCRA facility assessments

The Hazardous and Solid Waste Amendments of 1984 (HSWA) broadened the authorities of the Resource Conservation and Recovery Act (RCRA) by requiring corrective action for releases of hazardous wastes and hazardous constituents at treatment, storage, and disposal (TSD) facilities. The goal of the corrective action process is to ensure the remediation of hazardous waste and hazardous constituent releases associated with TSD facilities. Under Section 3004(u) of RCRA, operating permits issued to TSD facilities must address corrective actions for all releases of hazardous waste and hazardous constituents from any solid waste management unit (SWMU) regardless of when the waste was placed in such unit. Under RCRA Section 3008(h), the Environmental Protection Agency (EPA) may issue administrative orders to compel corrective action at facilities authorized to operate under RCRA Section 3005(e) (i.e., interim status facilities). The process of implementing the Corrective Action program involves the following, in order of implementation; (1) RCRA Facility Assessment (RFA); (2) RCRA Facility Investigation (RFI); (3) the Corrective Measures Study (CMS); and (4) Corrective Measures Implementation (CMI). The RFA serves to identify and evaluate SWMUs with respect to releases of hazardous wastes and hazardous constituents, and to eliminate from further consideration SWMUs that do not pose a threat to human health or the environment. This Information Brief will discuss issues concerning the RFA process