RCRA Corrective Action 2030 Goals and Outcome of 2020 Goals Announced


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RCRA Corrective Action 2030 Goals and Outcome of 2020 Goals Announced

By: George Colvin, CPG, CHMM

On September 1, 2020, US EPA Office of Land and Emergency Management (OLEM) Assistant Administrator Peter Wright, announced the 2030 vision, mission, and goals for the Resource Conservation and Recovery Act (RCRA) Corrective Action hazardous waste facility cleanup program.  The announcement of the RCRA cleanup goals for the next 10 years was provided as part of the Association of State and Territorial Solid Waste Management Officials (ASTSWMO) 2020 RCRA Corrective Action Virtual Conference.  The ASTSWMO 2020 Corrective Action Conference was the first national Corrective Action conference since 2008.  The presentations from the virtual conference can be accessed through the ASTSWMO website.

The 2030 vision and goals replace the 2020 goals established in 2004.  The prior goals targeted achieving 95% completion of the following three milestones at 3,779 baseline facilities by 2020:

  • Human exposure under control (aka the Human Health Environmental Indicator [EI] or CA 725)
  • Migration of contaminated groundwater under control (aka Groundwater Environmental Indicator or CA 750)
  • Remedy Construction (aka CA 550)

As part of Peter Wright’s keynote speech, EPA formally stated for the first time that, although close, they would not likely meet all the 2020 Corrective Action goals by the end of the EPA’s 2020 fiscal year.  According to Wright, EPA is projected to meet the Human Health EI goal, achieving the human health under control determination at 96% of the baseline facilities, but would come up short of the goals for the Groundwater EI and the Remedy Construction milestone, achieving 91% and 79%, respectively.

For 2030, EPA has developed a new vision, mission, and goals for the Corrective Action program as follows.

Vision

“RCRA Corrective Action cleanups support healthy and sustainable communities where people and the environment are protected from hazardous contamination today and into the future.”

Mission

“EPA, states, and tribal partners work together to ensure that owners and operators of hazardous waste treatment, storage, and disposal facilities conduct effective and efficient cleanups to protect human health and the environment, support continued use, and make land ready for reuse including, if necessary, placement of controls to protect communities into the future.”

Goals (emphasis added to get to the heart of the goal):

1. Through 2030, the RCRA Corrective Action Program will ensure that RCRA cleanups are initiated and completed efficiently and expeditiously. Commitments regarding what work is planned and what progress is made will be visible to the public. An ambitious universe of cleanups will be identified for completion by 2030.

2. By 2030, the RCRA Corrective Action Program will eliminate or control adverse impacts beyond facility boundaries at RCRA Corrective Action facilities wherever practicable and the program will focus attention on cleanups that will not meet this target.

3. By 2030, the RCRA Corrective Action Program will ensure or confirm that land within facility boundaries at RCRA Corrective Action facilities will be safe for continued use or reasonably foreseeable new uses wherever practicable and the program will focus attention on cleanups that will not meet this target.

4. By 2025, the RCRA Corrective Action Program will identify the key elements of effective Long Term Stewardship for Corrective Action cleanups, and regions and states will have approaches in place to ensure implementation of the key elements.

5. By 2022, program procedures will be in place to regularly adjust the universe of facilities in the cleanup pipeline to reflect current program priorities.

The generally vague vision\mission statements and goals provide little in the way of specifics.  The next step for EPA will be the preparation of a program plan to be completed in four to six months from the announcement.   The program plan should hopefully provide specific details.  But for now, here are the takeaways:

  • From the perspective of the owner/operator, I cannot find fault with the mission statement. EPA claims to have put considerable effort into the crafting of the specific language and it is likely to please most stakeholders.
  • Corrective Action will focus on controlling or eliminating adverse impacts beyond the facility boundaries.
  • EPA has clearly moved beyond investigation of most sites and is focused on remedies and long-term stewardship of the numerous facilities that will rely on land use controls as they wrap up RCRA Corrective Action.
  • Additional scrutiny and better tracking of long-term stewardship of land use controls are likely in the future.
  • Opportunities for public sharing of site information and public involvement in key Corrective Action site decisions are likely to continue to increase.
  • EPA will be reprioritizing the baseline of individual facilities, bringing in those facilities subject to RCRA Corrective Action which were not included in the 2020 baseline of 3,778 of facilities and potentially removing those facilities which have completed Corrective Action.
  • The universe of facilities in the cleanup pipeline will be regularly adjusted to reflect program priorities as opposed to the relatively static baseline of facilities subject to the 2020 goals.

Published in October 2020 Focus on the Environment Newsletter.


George H. Colvin is a hydrogeologist with over 30 years of consulting experience. Much of his experience has focused on RCRA Corrective Action, RCRA closure, and groundwater investigation, monitoring, and cleanup. He holds a BS in Geology from Ohio University and MS in geology and hydrology from Vanderbilt University. He is a Certified Professional Geologist with the American Institute of Professional Geologists, a registered geologist in Kentucky, Pennsylvania, and Tennessee, and a Certified Hazardous Materials Manager.