RCRA facilities

The EPA I.D. Number is a 12-digit number assigned to facilities covered by hazardous waste regulations under the Resource Conservation and Recovery Act (RCRA). Facilities not covered by RCRA are not likely to have an assigned I.D. Number. If your facility is not required to have an I.D. Number, enter not applicable. NA, in box a. If your facility has been assigned EPA Identification Numbers, you must enter those numbers in the spaces provided in Section 3.8. 

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. 

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

Where there is an imminent threat to human health and the environment, as well as in some nonemergency situations, the regulatory agency may ascertain that a response is appropriate prior to the completion of the RCRA Facility Investigation or the Corrective Measures Study. Hence, the decision for interim measures can be made based on the immediacy as well as the magnitude of the potential threat to human health or the environment the nature of appropriate Corrective Action the implications of deferring Corrective Action until the RCRA Facility Investigation and Corrective Measure Study is complete and other factors. 

If the RFA or other information has indicated a release of hazardous constituents, then from the owner/operator s perspective, the Corrective Action process truly begins. The first step in the process, the RCRA Facility Investigation (RFI), is directed toward development of the engineering information about the site necessary to permit selection and evaluation of remedial alternatives. The main engineering thrust of the RFI is the characterization of site conditions by defining the nature and extent of the problem. 

Most treatment options for detoxifying the hazardous constituents from RCRA facilities must have a uniform feed to the process. However, the media in which hazardous constituents are located are not generally homogeneous. Thus, some form of pretreatment of the waste or waste medium will probably be required to prepare the waste for further treatment by chemical, biological or thermal means. 

Guidance Manual for Conducting RCRA Facility Assessments at Publicly Owned Treatment Works, September 1987 ERIC W830 NTIS PB95-157715. 

Once hazardous wastes are transported from a CERCLA site, they are subject to full RCRA regulation. Therefore, all transportation and TSD requirements under RCRA must be followed. This means that off-site shipments must be accompanied by a manifest. In particular, the off-site disposal of hazardous wastes can occur only at an RCRA facility in a unit in full compliance with the requirements. U.S. EPA policy requires that the disposal facility be inspected six months prior to receiving the waste. 

Agent Degradation Products Listed in the RCRA Facility Investigation Sampling and Analysis Work Plan, 19... 

DTRA Defense Threat Reduction Agency REA RCRA facility assessment... 

In conducting sampling for preclosure activities (such as the RCRA facility investigation (RFI)) and for closure activities, the Army must either follow accepted published... 

On or within any other area or structure deemed to be included in the JACADS Closure Campaign (JCC) through the RCRA Facility Assessment (RFA) or other means. 

The USEPA estimates that over 6000 facilities are currently operated as treatment, storage, or disposal facilities (TSDFs) regulated under the Resource Conservation and Recovery Act (RCRA), which assigns the responsibility of corrective action to facility owners and operators and authorizes the USEPA to oversee corrective actions. Unlike the Superfund, RCRA responsibility is delegated to states. The USEPA and authorized states have completed initial assessment of potential environmental contamination at over 70% of RCRA facilities, as required by statute to address corrective action. Environmental contamination at many RCRA facilities is expected to be less severe than at Superfund sites however, the total number of RCRA facilities exceeds the number of Superfund sites. The USEPA developed a computer-based system known as the RCRA National Corrective Action Prioritization System (NCAPS) to help establish priorities for corrective action activities. Among the factors considered in NCAPS are the history of hazardous waste releases, the likelihood of human and environmental exposure, and the type and quantity of waste handle at the facility. 

Weston, Inc (1994) RCRA Facility Investigation - Phase I report, vol I. Elf Atochem North America, East Plant, Wyandotte, Michigan... 

Okrent and Xing (1993) analyzed the cancer risk resulting from inadvertent intrusion into a RCRA facility for hazardous chemical waste. The facility was assumed to contain waste from production of veterinary pharmaceuticals and other wastes that resulted in concentrations of 1,000 mg kg-1 of arsenic and 100 mg kg 1 of beryllium, cadmium, chromium, and nickel. A scenario for inadvertent intrusion involving permanent site occupancy similar to the scenario used by NRC to develop the Class-A, -B, and -C limits for near-surface disposal of radioactive waste (NRC, 1982b) was used to estimate the human health consequences of the postulated intrusion. 

Law Environmental (1994) Phase II RCRA Facility Investigation Work Plan, Alabama, pp 242... 

All three classes of modifications require that the permittee send a notice of the modification to all persons on the facility mailing list. Inclusion on a RCRA facility mailing list is typically accomplished by submitting a written request. Class 2 and 3 permit modifications trigger requirements for public notice, solicitation of comments, and, in some cases, a public meeting. 

Actions taken pursuant to CERCLA removal authority may be taken at any location, even at RCRA facilities, by the... 

Mandated by the Hazardous and Solid Waste Amendments to RCRA in 1984, RCRA corrective action requires cleanup of releases of hazardous waste or hazardous constituents from solid waste management units at RCRA facilities (RCRA Section 3004 (u) and (v)). Similar to the CERCLA program, RCRA corrective action pertains specifically to cleanup at RCRA facilities. 

Mason and Hanger Corporation/Battelle Pantex. Risk Reduction Rule Guidance for Pantex Plant RCRA Facility Investigations. Final, 1996. 

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