Cost-Effective Management Of The RCRA Corrective Action Process, 1998 Environmental Conference Proceedings

Michael E. Resch Scott Snyder

Senior Program Manager

RCRA Programs

ENSR Consulting and Engineering Union Camp Corporation

The authors have managed or directed more than a dozen RCRA Corrective Action programs across the country. These projects have been performed in accordance with the requirements of several EPA Regions and State regulatory agencies. In performing these efforts, numerous ideas and strategies have been developed that have aided in streamlining the overall RCRA Corrective Action process at these facilities. Armed with the lessons learned from these programs, the authors have distilled these streamlining strategies into an orchestrated listing of potential approaches that can result in the completion of the RCRA Corrective Action process in a very cost-effective manner. Part 1 of this paper discusses eight proactive strategies TSD personnel can implement to reduce their liability before Corrective Action investigations begin. The principal strategies in these activities consist of eliminating solid waste management units (SWMUs) or areas of concern (AOCs) from formal Corrective Action investigations and reducing the scope of investigations at those units that cannot be eliminated. Part 2 details Corrective Action strategies to employ after the Corrective Action order or RCRA permit has been received to ensure investigations and remediation efforts are completed in the most cost-effective manner.