Primary steps in RCRA corrective actions and their relationship to the Triad.
RCRA, as amended by the HWSA legislation, addresses the environmental release of hazardous material at active facilities. While waste generators, underground storage tanks (UST) and treatment, storage, or disposal facilities (TSDFs) fall specifically under RCRA's domain, all operating facilities are potentially subject to RCRA rules. RCRA establishes a minimum set of requirements, with many states imposing more stringent requirements as part of their state-led programs. As a result, most state RCRA programs are at least somewhat unique.
Facilities in the RCRA program are guided by rule 55 FR 30798, which proposed the procedures and technical requirements for conducting a corrective action in response to an environmental release. This rule proposed aspects of the Subpart S, Corrective Action for Solid Waste Management Units at Hazardous Waste Management Facilities. Subpart S created a four step approach to RCRA corrective actions analogous to CERCLA's process. These four steps include:
By the middle to late 1990s, a number of factors reducing the effectiveness of RCRA corrective actions were identified by stakeholders, the regulated community, and state regulators. In an effort to address these impediments, EPA embarked on what is referred to as "RCRA cleanup reforms." Some of the reforms meant to streamline RCRA cleanups are stressing results-based approaches that eliminate unnecessary process steps, focusing on environmental indicators (e.g., current human exposure under control) as metrics to gauge progress in achieving risk reduction, piloting innovative approaches, enhancing community involvement, and capitalizing on redevelopment potential. As early as 1996, EPA was recommending that work strategies now included within the Triad framework (the use of a CSM, flexible work strategies, real-time data collection using modern tools) be integrated into routine RCRA programs (see http://www.epa.gov/docs/fedrgstr/EPA-WASTE/1996/May/Day-01/pr-547.pdf, pages 19444-19446).
The Triad approach has the possibility for playing a significant role in each of the RCRA corrective action steps. Systematic planning focuses attention on what decisions need to be made and identifies the CSM data gaps that prevent confident decisions from being made. Data collection will usually be required to address CSM data gaps and manage decision-making uncertainty. The most efficient way to gather data and move on to the next step is laid out during systematic planning. Generally the most cost-effective options will involve real-time data gathering and dynamic work strategies for part or most of the work.