Corrective Action Program for Hazardous Waste Facilities
Contamination of the environment may occur when waste materials are improperly stored, treated, or disposed resulting in the release of hazardous constituents to the land, air, surface water, or groundwater. In order to address known or suspected environmental releases at hazardous waste management facilities, the federal law known as the "Resource Conservation and Recovery Act" (RCRA) was amended in 1984 to create Corrective Action requirements. Subsequently, New York State has received authorization from the Federal Government to implement this program. The focus of Corrective Action is upon "solid waste management units" or "SWMUs" which includes any unit at a facility where solid and/or hazardous waste was or is now managed, regardless of whether such management was intended.
The objective of a Corrective Action Program at a hazardous waste management facility is to evaluate the nature and extent of the releases of hazardous waste or hazardous constituents; to evaluate facility characteristics; and to identify, develop, and implement an appropriate corrective measure or measures to protect human health and the environment.
The five main components of the Department's RCRA Corrective Action Program and their objectives are as follows:
- RCRA Facility Assessment (RFA) - to evaluate SWMU information by reviewing all available records, conducting a visual site inspection to observe the SWMUs, and, if necessary, requiring the facility to perform a sampling visit when releases are suspected.
- Interim Corrective Measures (ICMs) - to control or abate threats to human health and/or the environment from releases and/or to prevent or minimize the further spread of contamination while long-term remedies are pursued.
- RCRA Facility Investigation (RFI) - to evaluate thoroughly the nature and extent of the releases of hazardous waste and hazardous constituents and to gather necessary data to support the Corrective Measures Study and/or interim corrective measures.
- Corrective Measures Study (CMS) - to develop and evaluate a corrective measure alternative or alternatives and to recommend the final corrective measure(s).
- Corrective Measures Implementation (CMI) - to design, construct, operate, maintain, and monitor the performance of the corrective measure(s) selected.
The Department establishes the requirements of the Corrective Action Program for a facility through the issuance of a hazardous waste management permit or an administrative enforcement action, such as a negotiated consent order.