Regulations promulgated under the authority of Subtitle C of the Resource Conservation and Recovery Act (RCRA), include provisions regarding the post-closure care of hazardous waste land disposal units. The Subtitle C regulations establish a 30-year post-closure care period as the default requirement (See 40 CFR § 264.117). The 2022 position paper highlights key issues and recommends that EPA either revise the RCRA regulations for post-closure or issue supplemental guidance on the implementation of the post-closure regulations under Subtitle C of RCRA congruent with the key issues raised.
Articles with the Tag RCRA
Modernizing Public Notice for RCRA Hazardous Waste Permitting and Other Actions
The Corrective Action and Permitting Task Force within the Hazardous Waste Subcommittee provided comments on February 11, 2022 regarding EPA’s Modernizing Public Notice for RCRA Hazardous Waste Permitting and Other Actions.
ASTSWMO RCRA Corrective Action Webinar Series: Michigan’s Long-Term Stewardship Program and Its Use of Drones
The State of Michigan’s Department of Environment, Great Lakes, and Energy (EGLE) Hazardous Waste Program (HWP) conducts a Corrective Action Monitoring and Maintenance (CAMM) program that involves inspecting all RCRA Treatment, Storage, and Disposal (TSD) facilities that have completed corrective action. The CAMM program helps ensure facility compliance with the requirements of legal agreements in place. The presentation also discusses how Drone Photometry tools have assisted the CAMM program to the benefit of the Department and the facility.
ASTSWMO RCRA Corrective Action Webinar Series: Pharmacia & Upjohn Company LLC Site: Case-Study
The 78-acre Pharmacia & Upjohn Company LLC site had a long history of industrial use, including the manufacturing of products used in dyes and pigments, photographic chemicals, consumer products and pharmaceuticals, among others. For more than a decade, investigations and interim measures were performed under Resource Conservation and Recovery Act (RCRA) 3013 and 3008(h) Administrative Orders. Prior to 1995, limited progress and minimal stakeholder outreach led to community frustration, distrust and legal entanglements.
This presentation focused on the stakeholder-driven approach to corrective measures that successfully turned public opinion around, achieved full community support for the remedy, and addressed site impacts in a sustainable manner. Remedy construction was deemed complete on September 30, 2019.
Today, all that remains is long-term operation, maintenance and monitoring of the final remedy. The Connecticut Department of Energy and Environmental Protection, following a 45-day public comment period, where public support and appreciation of the future vision of land-use for the property was heard, issued a Stewardship Permit, a form of RCRA Corrective Action post-remedy permit to ensure long-term stewardship at the property, on March 9, 2021.
Director – Environmental Engineering, Remediation & Transactions
Odor Control at RCRA Subtitle D Landfills
The ASTSWMO Solid Waste Disposal and Conversion Task Force has prepared this compendium providing an overview of the common landfill odors; meteorological conditions and operational impacts affecting the development and perception of landfill odors; and many options for landfill odor controls with corresponding case studies.
Webinar – RCRA Subtitle C Corrective Action 2020 and The Road Ahead Webinar Series: GenX and related PFAS in North Carolina
The North Carolina Department of Environmental Quality has been working to assess and mitigate PFAS emissions from the Chemours facility in Fayetteville, NC, for several years. PFAS compounds were first discovered in the Cape Fear River by EPA researchers. Various PFAS compounds, including HFPO Dimer Acid, or “GenX,” have since been discovered in surface water, rain, soil, sediment, fish, foam on surface water, and in private drinking water wells more than 12 miles from the facility. Join staff from the NC DEQ to learn more about the PFAS investigation in the area and how impacted resources are being addressed to protect human health and the environment.
2020 RCRA Corrective Action Conference – Webinars
The 2020 ASTSWMO RCRA Corrective Action Conference was held on September 1-3, 2020 as a virtual event. The Conference featured the theme, “RCRA Corrective Action: 2020 and The Road Ahead”, to acknowledge 2020 as the milestone year for achieving RCRA corrective action goals and the work that remains beyond 2020.
On the first two days, two sessions were separated by a break. There was a continuous session on the last day.
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EPA RCRA Corrective Action Program Vision / Mission / Goals for 2030
EPA Hazardous Waste Corrective Action webpage
ASTSWMO Position Paper on RCRA Subtitle C Hazardous Waste Program Information and RCRAInfo Database Operation and Maintenance
Since the enactment of the Resource Conservation and Recovery Act (RCRA) in 1976 and subsequent amendments, the U.S. Environmental Protection Agency (EPA) has developed and maintained several information systems. These evolving information management systems are necessary for tracking and maintaining information pertaining to the multitude of sites around the country involved in the generation, transportation, and management of hazardous waste.
ASTSWMO Position Paper on Federal Regulation of Coal Combustion Residuals
On April 17, 2015, the U.S. Environmental Protection Agency (EPA) published the final rule, Hazardous and Solid Waste Management System; Disposal of Coal Combustion Residuals From Electric Utilities (80 FR 21301). This Position Paper is a brief update from ASTSWMO to comment on current developments in the regulation of coal combustion residuals (CCR).
ASTSWMO Position Paper on Coal Combustion Residuals
This publication has been replaced by this document here.
On June 21, 2010, the U.S. Environmental Protection Agency (EPA) proposed the rule, Hazardous and Solid Waste Management System; Identification and Listing of Special Wastes; Disposal of Coal Combustion Residuals From Electric Utilities (75 FR 35127). In this rulemaking, EPA co-proposed two options for regulation of coal combustion residuals (CCRs). Under one option, EPA would reverse its August 1993 and May 2000 Bevill Regulatory Determinations regarding CCRs and list CCRs as a special waste subject to regulation under Subtitle C of the Resource Conservation and Recovery Act (RCRA) when they are destined for disposal in landfills or surface impoundments. The other option would leave the Bevill determination in place and regulate disposal of CCRs under RCRA Subtitle D, with EPA issuing national minimum criteria under 40 CFR part 257 Criteria for Classification of Solid Waste Disposal Facilities and Practices. The proposal did not address the placement of CCRs in mines, or non-minefill uses of CCRs at coal mine sites. The proposal also did not change the May 2000 Regulatory Determination for beneficially used CCRs, which as EPA noted are currently exempt from the hazardous waste regulations under Section 3001(b)(3)(A) of RCRA. However, EPA did indicate that it was clarifying the determination and seeking comment on potential refinements for certain beneficial uses. This position paper is based in large part upon comments that ASTSWMO provided to EPA on November 19, 2010 in response to the proposal.