RCRA requires corrective action for releases of hazardous waste or hazardous waste constituents from solid waste management units (SWMUs) at permitted hazardous waste treatment, storage and disposal facilities (TSDFs), as well as facilities seeking a RCRA permit or approval of final closure. RCRA requires the owner or operator of a facility seeking a RCRA permit to institute corrective action as necessary to protect human health and the environment from all releases of hazardous waste and hazardous constituents from any SWMU at the facility and to implement corrective actions beyond the facility boundary if appropriate.
Through remedy selection, the corrective action process of RCRA consists of three components, and it is analogous in many ways to the CERCLA NCP process. These three components are the RCRA facility assessment (RFA), the RCRA facility investigation (RFI), and the corrective measures study (CMS).
The objective of the RFA is to identify the SWMUs or areas of concern (AOCs) where releases have occurred or have the potential to occur. The RFA evaluates existing data to determine whether further evaluation is required, or if an interim measure is necessary to address an imminent threat to human health or the environment. If the RFA identifies an actual or potential release but no imminent threat, then an RFI is initiated to characterize the nature and extent of the release and evaluate risks to human health and ecological resources. The results of the RFI are used to support one of the following decisions:
If a potential need for remediation is indicated, then a CMS is conducted to establish remedial goals and identify and evaluate potential remedial alternatives. In the CMS, a remedy is selected on the basis of degree of protection of human health and the environment (including ecological resources), attainment of media-specific cleanup standards, control of sources to eliminate continued harmful releases, and compliance with RCRA waste management and disposal requirements.
Note the similarity between the CERCLA and RCRA processes. Both include an initial phase in which existing data are evaluated to determine whether further investigation is necessary. In both processes, if an imminent human health or environmental threat is indicated, a mitigating action is authorized. Both processes include a thorough characterization of the nature and extent of contamination, together with an evaluation of risks to human health and the environment. Finally, each process includes a formal evaluation of potential remedies. The CERCLA and RCRA processes are compared in Figure 2.2.