EPA's Proposed RCRA Corrective Action Program: Implications for the Pulp and Paper Industries, 1992 Environmental Conference Proceedings

The U.S. Environmental Protection Agency (EPA) has proposed regulations under the Resource Conservation and Recovery Act (RCRA) governing corrective action at hazardous waste management units. These rules, when implemented, will affect both RCRA Subtitle C regulated units, as well as solid waste management units (SWMUs), and will formalize EPA’s intent to use risk assessment to establish cleanup levels for releases of hazardous constituents at RCRA facilities. For the most part, this is a welcome change for the RCRA-regulated community, which has consistently petitioned EPA to adopt an approach to developing site cleanup criteria this is more realistic that the "cleanup to background" standard previously used.

The corrective action rule, first proposed in the July 27, 1990 Federal Register, is designed to address releases of hazardous constituents from SWMUs present at RCRA-regulated facilities. EPA has estimated that there are currently 5,700 facilities affected by this rule. EPA’s proposed approach relies on the RCRA permitting and closure process as the impetus for SWMU investigation and cleanup, with provisions for a series of specific steps to streamline the remediation process. This paper describes the proposed corrective action process and evaluates its impacts on the pulp and paper industries, with emphasis on industry-specific applicability, corrective action implementation considerations, and EPA estimated costs for program implementation. Environmental management strategies to minimize compliance requirements and liabilities are also presented.