RCRA
The Resource Conservation and Recovery Act (RCRA) was enacted in 1976 and gives the USEPA the authority to control hazardous and non-hazardous waste from generation to final destruction or disposal. In 1986, amendments to RCRA also gave the USEPA control over management of environmental issues that could arise from underground storage tanks (USTs). It should be noted that many states have been granted RCRA authority by the USEPA, and RCRA programs may be implemented at the state rather than the Federal level.
The RCRA rule and associated regulations drive or affect remediation in four major areas. These include RCRA Facility Investigation/Corrective Action, RCRA Closure, management of UST issues, and remedial waste management. RCRA Facility Investigation (RFI) and Corrective Action (CA) are typically performed in conjunction with obtaining a RCRA permit. As a condition of an interim permit, the facility investigates and remediates former solid waste management units. RCRA closure specifies the procedures necessary for termination of a RCRA permit, including remediation of areas used to store hazardous wastes. USTs are installed, monitored, and closed in accordance with RCRA requirements. In the event that a UST leaks during the course of its life, RCRA specifies the cleanup requirements. Finally, solid and hazardous wastes generated during any remedial activity are subject to RCRA waste management requirements.
RCRA Experience
I have extensive consulting experience supporting clients remediating sites under the RCRA Corrective Action Process, RCRA Closure, and UST release incidents. My experience includes characterization of sites in accordance with RFI requirements, preparation of RCRA Remedial Investigation Work Plans/Reports, Quality Assurance Project Plans, Risk Assessment Reports, Corrective Measures Studies, and Remedial Work Plans/Reports. I have led negotiations with RCRA regulators and support agencies, and provided public communication on behalf of PRPs. Additionally, I have extensive experience characterizing wastes for disposal under RCRA rules, including determination of Listed and Characteristic wastes.
