RCRA REVISION CHECKLIST 121

Corrective Action Management Units and Temporary Units
58 FR 8658-8685
February 16, 1993
(RCRA Cluster III, HSWA provisions)

Note:  The final rule addressed by this checklist reduces the regulatory requirements for certain types of waste management conducted during correction action; thus authorized States are not required to adopt the changes addressed by this rule.  As such, this checklist is designated as optional.  However, EPA strongly encourages States to adopt the checklist as soon as possible in order to expedite hazardous waste remediation at RCRA corrective action facilities.

	FEDERAL REQUIREMENTS	FEDERAL RCRA CITATION	ANALOGOUS STATE CITATION	STATE ANALOG IS:				
				EQUIV-ALENT	LESS
STRIN-
GENT	MORE STRIN-GENT	BROADER IN SCOPE	
	PART 260 - HAZARDOUS WASTE MANAGEMENT SYSTEM:  GENERAL							
	SUBPART B - DEFINITIONS							
†	DEFINITIONS							
	add "corrective action management unit"	260.10 "corrective action management unit"						
	add sentence excluding a corrective action management unit into which remediation wastes are placed from definition 	260.10 "disposal facility"						
	designate existing definition as "(1)"; add second definition numbered "(2)" for the purpose of implementing correction action under 264.101	260.10 "facility"						
	replace "or a cave" with "a cave, or a corrective action management unit" 	260.10 "landfill"						
	add "corrective action management unit," after "containment building, "	260.10 "miscellaneous unit"						
	add "remediation waste"	260.10 "remediation waste"						
	PART 264 - STANDARDS FOR OWNERS AND OPERATORS OF HAZARDOUS WASTE TREATMENT, STORAGE, AND DISPOSAL FACILITIES							
	SUBPART A - GENERAL							
†	RELATIONSHIP TO INTERIM STATUS STANDARDS							
	add ", except as provided under 40 CFR part 264 subpart S" at end of paragraph	264.3						
	SUBPART F - RELEASES FROM SOLID WASTE MANAGEMENT UNITS							
†	CORRECTIVE ACTION FOR SOLID WASTE MANAGEMENT UNITS							
	add "in accordance with this section and subpart S of this part" after "in the permit"	264.101(b)						
	SUBPART S - CORRECTIVE ACTION FOR SOLID WASTE MANAGEMENT UNITS							
†	CORRECTIVE ACTION MANAGEMENT UNITS (CAMU)							
	Regional Administrator may designate one or more areas at a facility as CAMUs for purpose of implementing remedies under 264.101 or RCRA 3008(h)	264.552(a)						
	placement of remediation wastes in CAMU does not constitute land disposal	264.552(a)(1)						
	consolidation or placement of remediation wastes in CAMU does not constitute creation of a unit subject to minimum technology requirements	264.552(a)(2)						
	Regional Administrator may designate a regulated unit as a CAMU or include a regulated unit in a CAMU; criteria	264.552(b)(1)						
		264.552(b)(1)(i)						
		264.552(b)(1)(ii)						
	Subparts F, G, and H and unit-specific Parts 264 or 265 requirements that applied to regulated unit continue to apply to that portion of CAMU after incorporation	264.552(b)(2)						
	criteria by which Regional Administrator shall designate CAMU:	264.552(c)						
	CAMU shall facilitate implementation of reliable, effective, protective, and cost-effective remedies	264.552(c)(1)						
	associated waste management activities shall not create unacceptable risks to humans or the environment	264.552(c)(2)						
	CAMU shall include uncontaminated areas only if including such areas for purpose of managing remediation waste is more protective than managing such wastes at contaminated areas	264.552(c)(3)						
	CAMU areas where waste will remain after closure shall be managed and contained to minimize future releases, to the extent practicable	264.552(c)(4)						
	CAMU shall expedite remedial activity implementation when appropriate and practical	264.552(c)(5)						
	CAMU shall enable use of treatment technologies, when appropriate, to enhance long-term effectiveness of remedial actions	264.552(c)(6)						
	CAMU shall, to the extent practicable, minimize land area where wastes will remain after closure	264.552(c)(7)						
	owner/operator shall provide sufficient information to enable Regional Administrator to designate CAMU in accordance with 264.552	264.552(d)						
	Regional Administrator shall specify CAMU requirements in permit or order, including:	264.552(e)						
	areal configuration of CAMU	264.552(e)(1)						
	requirements for remediation waste management, including applicable design, operation and closure requirements	264.552(e)(2)						
	requirements for ground water monitoring sufficient to:	264.552(e)(3)						
	continue to detect and characterize existing releases from sources within CAMU	264.552(e)(3)(i)						
	detect and characterize releases from areas of the CAMU in which wastes will remain after closure	264.552(e)(3)(ii)						
	closure and post-closure requirements:	264.552(e)(4)						
	CAMU closure shall:	264.552(e)(4)(i)						
	minimize need for further maintenance	264.552(e)(4)(i)(A)						
	control, minimize, or eliminate post-closure escape of hazardous waste, hazardous constituents, leachate, contaminated runoff, or hazardous waste decomposition products to ground, surface waters, or atmosphere	264.552(e)(4)(i)(B)						
	requirements for closure of CAMU shall include, as appropriate and deemed necessary by the Regional Administrator:	264.552(e)(4)(ii)						
	excavation, removal, treatment or containment of wastes	264.552(e)(4)(ii)(A)						
	capping of areas in which wastes will remain after CAMU closure	264.552(e)(4)(ii)(B)						
	removal and decontamination of equipment, devices, and structures used in remediation waste management activities within CAMU	264.552(e)(4)(ii)(C)						
	in establishing specific 264.552(e) closure requirements, Regional Administrator shall consider:	264.552(e)(4)(iii)						
	CAMU characteristics	264.552(e)(4)(iii)(A)						
	volume of wastes which remain in place after closure	264.552(e)(4)(iii)(B)						
	potential for releases from CAMU	264.552(e)(4)(iii)(C)						
	physical and chemical characteristics of the waste	264.552(e)(4)(iii)(D)						
	hydrogeological and other relevant environmental conditions which may influence migration of potential or actual releases	264.552(e)(4)(iii)(E)						
	potential for exposure of human and environmental receptors if releases occur	264.552(e)(4)(iii)(F)						
	post-closure requirements as necessary to protect human health and the environment; for areas where wastes will remain, monitoring and maintenance activities and frequency 	264.552(e)(4)(iv)						
	Regional Administrator shall document rationale for CAMU designation; make documentation available to public	264.552(f)						
	incorporation of CAMU into existing permit approved by Regional Administrator under 270.41 or 270.42 procedures	264.552(g)						
	CAMU designation does not change EPA's existing authority to address clean-up levels, media-specific points of compliance, or other remedy selection decisions	264.552(h)						
†	TEMPORARY UNITS (TU)							
	Regional Administrator may determine alternative design, operating, or closure standards for temporary tanks and container storage areas for treatment or storage of hazardous remediation wastes under 264.101 or RCRA 3008(h); must protect human health and environment	264.553(a)						
	temporary unit to which alternative requirements are applied shall be:	264.553(b)						
	located within facility boundary	264.553(b)(1)						
	used only for treatment or storage of remediation wastes	264.553(b)(2)						
	factors Regional Administrator shall consider in establishing temporary unit standards:	264.553(c)						
	length of time unit will be in operation	264.553(c)(1)						
	type of unit	264.553(c)(2)						
	volumes of wastes to be managed	264.553(c)(3)						
	physical and chemical characteristics of wastes to be managed	264.553(c)(4)						
	potential for releases from the unit	264.553(c)(5)						
	hydrogeological and other relevant environmental conditions which may influence migration of potential releases	264.553(c)(6)						
	potential for exposure of humans and environmental receptors if releases occur	264.553(c)(7)						
	Regional Administrator shall specify in permit or order length of time, up to a year, the temporary unit will be allowed to operate; design, operating, and closure requirements for the unit	264.553(d)						
	Regional Administrator may extend operational period of temporary unit once for no longer than one year beyond period specified in permit or order, if:	264.553(e)						
	continued operation of unit will not threaten human health and environment	264.553(e)(1)						
	continued operation of unit is necessary to ensure timely and efficient implementation of remedial actions	264.553(e)(2)						
	incorporation of a temporary unit or time extension for temporary unit in an existing permit shall be:	264.553(f)						
	approved in accordance with 270.41 permit modification procedures	264.553(f)(1)						
	requested by owner/operator as Class II modification in accordance with 270.42	264.553(f)(2)						
	Regional Administrator shall document rationale for temporary unit designation; documentation made available to public	264.553(g)						
	PART 265 - INTERIM STATUS STANDARDS FOR OWNERS AND OPERATORS OF HAZARDOUS WASTE TREATMENT, STORAGE, AND DISPOSAL FACILITIES							
	SUBPART A - GENERAL							
†	PURPOSE, SCOPE, AND APPLICABILITY							
	add ", and of 40 CFR 264.552 and 40 CFR 264.553," after "standards of this part"	265.1(b)						
	PART 268 - LAND DISPOSAL RESTRICTIONS							
	SUBPART A - GENERAL							
†	DEFINITIONS APPLICABLE IN THIS PART							
	add ", except in a corrective action management unit," after "on the land"	268.2(c)						
	PART 270 - EPA ADMINISTERED PERMIT PROGRAMS:  THE HAZARDOUS WASTE PERMIT PROGRAM							
	SUBPART A - GENERAL INFORMATION							
†	DEFINITIONS							
	add  "corrective action management unit"	270.2						
	add sentence excluding a corrective action management unit into which remediation wastes are placed from definition 	270.2 "disposal facility"						
	SUBPART D - CHANGES TO PERMIT							
†	PERMIT MODIFICATION AT THE REQUEST OF THE PERMITTEE							
	add new section N. to table	270.42 Appendix I