Corrective action management unit application for the Environmental Restoration Disposal Facility

The Environmental Restoration Disposal Facility (ERDF) is to accept both CERCLA (EPA-regulated) and RCRA (Ecology-regulated) remediation waste. The ERDF is considered part of the overall remediation strategy on the Hanford Site, and as such, determination of ERDF viability has followed both RCRA and CERCLA decision making processes. Typically, determination of the viability of a unit, such as the ERDF, would occur as part of record of decision (ROD) or permit modification for each remediation site before construction of the ERDF. However, because construction of the ERDF may take a significant amount of time, it is necessary to begin design and construction of the ERDF before final RODs/permit modifications for the remediation sites. This will allow movement of waste to occur quickly once the final remediation strategy for the RCRA and CERCLA past-practice units is determined. Construction of the ERDF is a unique situation relative to Hanford Facility cleanup, requiring a Hanford Facility specific process be developed for implementing the ERDF that would satisfy both RCRA and CERCLA requirements. While the ERDF will play a significant role in the remediation process, initiation of the ERDF does not preclude the evaluation of remedial alternatives at each remediation site. To facilitate this, the January 1994 amendment to the Tri-Party Agreement recognizes the necessity for the ERDF, and the Tri-Party Agreement states: ''Ecology, EPA, and DOE agree to proceed with the steps necessary to design, approve, construct, and operate such a ... facility.'' The Tri-Party Agreement requires the DOE-RL to prepare a comprehensive ''package'' for the EPA and Ecology to consider in evaluating the ERDF. The package is to address the criteria listed in 40 CFR 264.552(c) for corrective action management unit (CAMU) designation and a CERCLA ROD. This CAMU application is submitted as part of the Tri-Party Agreement-required information package