Establishing a regulatory framework for a RCRA corrective action program

Recently, the environmental community has become keenly aware of problems associated with integration of the demanding regulations that apply to environmental restoration activities. Once can not attend an EPA-sponsored conference on Superfund without hearing questions concerning the Resource, Conservation, and Recovery Act (RCRA) and the applicability of the National Contingency Plan (NCP) to sites that do not qualify for the National Priorities List (NPL). In particular, the U.S. Department of Energy (DOE) has been greatly criticized for its inability to define a comprehensive approach for cleaning up its hazardous waste sites. This article presents two decision flowcharts designed to resolve some of this confusion for DOE. The RCRA/CERCLA integration diagram can help the environmental manager determine which law applies and under what conditions, and the RCRA corrective action decision flowchart can guide the manager in determining which specific sections of RCRA apply to a RCRA-lead environmental restoration program