- R6 Corrective Action Strategy (CAS)
- R3 and R7 RCRA Facilities Investigation Remedy Selection Track (FIRST)
- RCRA Tool Book
In 2004 the EPA Resource Conservation and Recovery Act (RCRA) Corrective Action (CA) Program set three milestone goals for their list of “baseline” facilities. The goals, and the projections for achievement by the end of 2020 are:
- Human Exposures Under Control (CA725) – projected to be met by 96% of facilities
- Migration of Contaminated Groundwater Under Control (CA750) – projected to be met by 91% of facilities
- Remedy Construction (CA550) – projected to be met by 79% of facilities
EPA recently released its RCRA Corrective Action Program
For 2030 including its Vision, Mission and Goals. In addition to developing a revised set of target facilities (“universe of cleanups”), five goals were established to be implemented in close coordination with the authorized states:
1. Complete Cleanups – ensure that RCRA CAs are initiated and completed efficiently, using flexible approaches that are visible to the public.
2. Impacts beyond facility boundaries including emerging risk issues (vapor intrusion, emerging contaminants etc.), will be addressed where practical.
3. Ensure that land within facility boundaries is safe for continued use or reasonably expected new uses.
4. Long-Term Stewardship (LTS) – develop procedures by 2025 for long-term stewardship for CAs and implement these in concert with the states.
5. Adjust the Pipeline – develop procedures by 2022 to regularly adjust the universe of CA facilities.
To proactively address RCRA CA Program 1-4 goals, consider the following actions/strategies:
Consider developing a virtual dashboard/interface for CA and LTS, through GIS or EQuIS. Use relational databases with access to data for contaminant trends, IC/EC footprints and requirements, e-records for key documents, and allow access to site data from one location that can be used by multiple people with the appropriate credentials.
- Ensure that sources are understood and addressed – develop working agreements with neighboring industries or other potentially responsible businesses
- Prioritize and address concerns in a teaming relationship with your regulators
- Develop a robust regulatory and community engagement plan
- Establish a buffer zone around the facility
- Institutional Controls (ICs) and Engineering Controls (ECs) – are they appropriate, up to date and implementable?
- Is the facility conducting and documenting ICs/ECs inspection/maintenance?
- Remedy maintenance and documentation
- Prepare for EPA requests to conduct a review (virtual or in-person)
- Do you have all the remedy development/implementation documentation?
- Do you have current proof of concept? (is it working?)
- Are your ICs still appropriate and being followed?
- Are your internal ECs being followed by facility operations?
- Have there been any changes in site conditions or regulations that warrant re-evaluation of risk exposure, cleanup standards or site controls?
- Is your Financial Assurance appropriate and backed up with cost information?
- Can you show documentation of Community Engagement?
Sharing Our Perspectives
Our practitioners share their insights and perspectives on the trends and challenges shaping the market.
Regulatory Updates
EPA Releases Clean Water Act Facility Response Plan Rule
June 19, 2024
This Regulatory Update is the first in a series summarizing the Rule and how it may affect your facility.
Regulatory Updates
PM2.5 Annual NAAQS Revised
May 7, 2024
The U.S. EPA issued a final rule based on its reconsideration of its 2020 decision to retain the primary and secondary National Ambient Air Quality Standards (NAAQS) for particulate matter (PM) without revision.
Regulatory Updates
What You Need to Know About MSHA’s Final Rule on Crystalline Silica Dust
April 8, 2024
Regulatory Changes Will Impact Mine Operators and Better Protect Employee Health and Safety.
Regulatory Updates
Changes to EPA’s Risk Management Program (RMP) Regulations Are Here
April 3, 2024
Changes to the Risk Management Program (RMP) regulations were signed into a final rule on February 27, 2024, by EPA Administrator Michael S. Regan.
Regulatory Updates
Changes to EPA’s Risk Management Program (RMP) Regulations Are Coming
April 14, 2023
Changes to the Risk Management Program (RMP) regulations were signed into a final rule on February 27, 2024, by EPA Administrator Michael S. Regan.
Regulatory Updates
Phase I ESA ASTM Standard Update: The Wait is Over
December 21, 2022
The USEPA published a Final Rule making the ASTM E1527-21 Phase I ESA standard AAI compliant.
Regulatory Updates
Proactive Enforcement is Key in the EPA FY2022-2026 Strategy
October 19, 2022
A core element of the EPA FY2022-2026 Strategic Plan focuses on environmental compliance.
Regulatory Updates
Preparing for EPA Inspections in Environmental Justice Communities
October 4, 2022
The EPA Office of Enforcement and Compliance Assurance Have Expanded Goals to Strengthen Enforcement and Protections Within EJ Communities
Regulatory Updates
New National Emerging Contaminants Research Initiative
September 12, 2022
The Executive Office of the President of the United States announced a National Emerging Contaminant Research Initiative
Insights
Climate Action and Environmental Justice are at the Forefront of EPA’s Strategic Plan
June 14, 2022
The EPA issued its Fiscal Year 2022-2026 Strategic Plan. Although the strategic plans emphases often change with administrations, we can be reasonably certain that the Plan reflects priorities through 2024.
Insights
CCR Removal and Its Effects on Soil and Groundwater Geochemistry
October 25, 2021
Many utilities are implementing corrective action at coal combustion residual (CCR) surface impoundments under Federal or State CCR Regulations, with implications for groundwater protection standards.
Regulatory Updates
NJDEP Implements New Jersey Environmental Justice Law Through Administrative Order
October 5, 2021
On September 22, 2021, the New Jersey Department of Environmental Protection (NJDEP) Commissioner announced the issuance of Administrative Order (AO) No. 2021-25 to implement New Jersey’s Environmental Justice (EJ) Law. This order is effective immediately, and applicants seeking to site new major source facilities, renew major source permits or expand existing facilities with major source permits (e.g., Title V air permits) in overburdened communities are affected. There are more than 4.5 million people that live within 331 municipalities that are overburdened communities in the state of New Jersey.
Regulatory Updates
OSHA’s Call for Comments on Mechanical Power Press Standard Changes
September 30, 2021
OSHA has recently published a call for comment regarding mechanical power presses. The reason behind OSHA’s request is that the American National Standards Institute (ANSI) consensus standard for mechanical power presses has been updated numerous times since the implementation of OSHA’s standard.
White Papers / Reports
Managing EHS & ESG Risks Through Integrated Systems Today and Beyond
July 22, 2021
It has been more than 50 years since the development and establishment of the federal Environmental Protection Agency (EPA) and the federal Occupational Safety & Health Administration (OSHA) which were formed to protect our environment and workplaces across the United States. Significant laws, policies and regulations followed to establish the “regulatory programs” that all applicable businesses and entities must address and meet to ensure these compliance-driven legislative programs would create a foundation to protect our society.
Regulatory Updates
EPA Resource Conservation & Recovery Act (RCRA) Corrective Action (CA)
January 11, 2021
The EPA RCRA Corrective Action (CA) Program recently provides a review and update on CA set in 2004 and new CA set for 2030.
Regulatory Updates
EPA continues to aggressively address PFAS wastewater with two new strategies
January 4, 2021
EPA takes steps toward PFAS wastewater and storm water permitting, and analytical methods for testing.
Regulatory Updates
2020 TSCA Chemical Data Reporting (CDR)
December 7, 2020
Earlier this year, EPA revised the CDR rule to reflect the 2016 amendments to TSCA, including changes for foreign-owned businesses and the reporting responsibilities of suppliers and contractors, as well as an exemption for small businesses.
Ecological Risk of PFAS from AFFF-Impacted Sites
June 30, 2020
The facts on evaluating exposure to wildlife
News
TRC Chosen to Provide Array of Integrated Services on Midship Pipeline Project
August 28, 2018
TRC has been awarded contracts for environmental consulting, engineering and field services and another for stem-to-stern Engineer, Procure and Construct (EPC) contract for three compressor stations.
