Engineering Overview of the Corrective Action Program

The technical differences between site problems at RCRA facilities and CERCLA sites sometimes may be difficult to distinguish, owing to similarities in present or past uses of the site, in hydrogeologic setting, and/or in the types of substances disposed, spilled, or otherwise managed at the site. Consequently, many technical aspects of the study and remediation of releases of hazardous wastes and constituents from RCRA facilities often will closely parallel those at Superfund sites, and cleanups under both statutes must achieve similar goals for protection of public health and the environment. Additionally, activities which would be termed removal actions or expedited response actions under CERCLA may be undertaken by owners and operators under RCRA. In the RCRA context, such actions are termed interim measures, as will be discussed in subsequent chapters. 

Actions at a RCRA facility may culminate in its return to normal operating status while at most Superfund sites (and at some RCRA facilities undergoing Corrective Action), these activities typically culminate in final cleanup or closure of the site. These and other factors might lead to selection and implementation of different corrective measures at otherwise similar RCRA and Superfund sites. 

114 Handbook of Emergency Response to Toxic Chemical Releases 

The Corrective Action Plan (CAP) relies on the sequential performance of activities which are conventional engineering practices. These activities include problem identification, development and evaluation of alternatives, and the implementation of the selected alternative. The three analogous phases identified in the CAP are as follows  

RCRA Facility Investigation (RFI) - site characterization and pre-investigation identification of possible containment/treatment technologies  

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