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ENV-16-11 New EPA Programs to Expedite RCRA Corrective Action

Lloyd Dunlap, Trihydro Corporation Tom Rinehart, Chevron Environmental Management Company

Format:
Electronic (digital download/no shipping)

Associate Member, International Member, Petrochemical Member, Refining Member - $0.00
Government, NonMember - $35.00

Description:

Completing Resource Conservation Recovery Act (RCRA) Corrective Action is typically a long and costly process. Three ways are presented to speed up or reduce costs in RCRA Corrective Action. A new program from the United States Environmental Protection Agency (USEPA) is called RCRA FIRST. This program greatly streamlines and optimizes the steps within RCRA Corrective Action. In addition, the USEPA has now included a new environmental indicator (EI) called CA550 OF. CA550 OF outlines a way to defer remedy construction at an operating facility if the remedy is within critical process units or manufacturing equipment. A third way to increase efficiency of the RCRA process is to perform a site-specific Strategy Review that evaluates new strategies resulting in the lowest life-cycle costs while achieving regulatory closure or an exit of the liability. RCRA FIRST is a new program from the EPA to expedite RCRA Corrective Action. The USEPA realizes that meeting their goals to have a remedy constructed at 95% of their RCRA baseline sites by the year 2020 will be challenging. RCRA FIRST initiates optimized communication between the regulators and the industry by setting up a Corrective Action Framework (CAF) meeting at the beginning of the RCRA phase. Hard issues are discussed and decided before any fieldwork or report writing is done. Having the critical discussions at the beginning allows for early mutual understanding and agreement of goals and expectations. The USEPA now has a new EI that can allow construction-remedy deferral at operating facilities for RCRA Corrective Action. The "Environmental Indicators Initiative" was started in 1997 to improve the agency's ability to report on the progress of achieving RCRA Corrective Action goals. As a result, the USEPA created EIs to track a select list of facilities called the Government Performance and Reports Act (GPRA) Baseline. The USEPA then established specific goals for those facilities to measure performance and progress in RCRA Corrective Action. The USEPA’s goal is to have a final remedy constructed by September 30, 2020 at 95% of the RCRA Corrective Action facilities on their GPRA baseline list. Due to the proximity of critical process or manufacturing equipment, along with safety concerns, constructing a remedy is difficult or impossible at portions of many operating or manufacturing facilities. As a result of years of negotiations and meetings, the USEPA now has a new final remedy-construction metric at operating facilities is called CA550-OF. A facility and the USEPA can achieve their 2020 goals for Remedy Construction by deferring remedy construction at critical locations within an operating site if certain conditions are met. Another way to expedite RCRA Corrective Action and CERCLA remediation at high-priority sites is to hold a Strategy Review. A Strategy Review is not simply a peer review of the current strategy or a review of various remedial options. The Strategy Review objective is to develop and evaluate a site-specific strategy, which, when implemented, will result in the lowest life-cycle costs while achieving regulatory closure or an exit of the liability. Attendees at the Review should consist of multiple disciplines so as to offer a wide view of perspectives and site-closure options. With this wide view of perspectives, alternative site-closure options and options to exit the liability at the site, including but not limited to remedial options, are brainstormed and scrutinized.

Product Details:

Product ID: ENV-16-11
Publication Year: 2016