EPA’s new methods for speeding up your RCRA Corrective Action process
Do you manage a RCRA Corrective Action facility?
You may be in luck. Completing Resource Conservation Recovery Act (RCRA) Corrective Action is typically a long and costly process.  However, EPA recently announced two new updates to the RCRA process that may speed things up for you.

A little background
EPA’s current goal is to have a final remedy constructed at 95% of the RCRA Corrective Action facilities on the Government Performance and Reports Act (GPRA) baseline list by September 30, 2020.  EPA realizes that meeting this goal is challenging and has therefore defined a new program and a new environmental indicator (EI) to speed up or reduce costs in RCRA Corrective Action. These two new developments are, 1) RCRA FIRST, and 2) EI CA550 OF.  

RCRA FIRST is a new EPA program that greatly streamlines and optimizes the steps within RCRA Corrective Action.  RCRA FIRST initiates optimized communication between the regulators and industry by setting up a Corrective Action Framework (CAF) meeting at the beginning of the Corrective Action phase your site is approaching, such as the investigation or remedy design.  Challenging issues are discussed and decided before any fieldwork or report writing is done, which allows for early mutual understanding and agreement on goals and expectations. That equals serious cost savings in the long run.  

What is CA550 OF?
Constructing a remedy can be difficult or impossible at portions of many operating or manufacturing facilities due to the proximity of critical process or manufacturing equipment and related safety concerns. CA550 OF is a new EPA EI which outlines a way to defer remedy construction at an operating facility if the remedy would cause undue interruption of a critical process or destruction of an integral portion of the operating area(s).

How do I decide if RCRA FIRST or CA550 OF are right for me and my facility?
RCRA FIRST: The new RCRA FIRST process is designed to take years off completing RCRA Corrective Action, thus reducing remediation costs for your facility.  If you want to save time and money, this may be a great option to explore – just be prepared to invest some upfront time in pushing through and achieving agreement on complex issues like cleanup levels and future land use. 

CA550 OF: A facility and EPA can achieve their EI 2020 goals for Final Remedy Construction by deferring remedy construction at critical locations within an operating site if certain conditions are met.  The deferral is for a specified period of time and it cannot extend beyond the active life of the critical process or integral component that is the basis for the deferral.  Your facility must be able to demonstrate that there are safety and/or physical limitations that cannot be overcome by engineering and/or scheduling considerations, and then be able to show that those factors inhibit reasonable efforts to construct and implement remedies during a specified time-period or operation.  

Have questions or want more information? 
Our team of RCRA remediation experts have been partnering with facility managers since we opened our doors more than 32 years ago. We know how complex large facility remediation efforts can be, and we take pride in making your job easier. It’s the reason we do business.


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