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HAZWOPER and RCRA Corrective Action

If your facility has a Resource Conservation and Recovery Act (RCRA) Part B permit for the treatment, storage, and/or disposal of hazardous waste, any remedial action will come under the purview of RCRA Corrective Action. If you do not have a RCRA Part B permit (or interim status) your remedial efforts will be regulated by the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). There is a world of difference in how newly generated wastes are handled and managed under these two regulations.

drums of RCRA hazardous waste

Under CERCLA, you will have to meet Applicable or Relevant and Appropriate Requirements (ARARS) for the various regulations at your facility. There is some latitude if you are working with CERCLA and ARARs when it comes to dealing with solid/hazardous waste. Under RCRA Corrective Actions, you must meet all regulatory requirements.

For example, if your facility has contaminated groundwater and the contaminant originated from a "listed" hazardous waste, your entire groundwater plume is now a listed hazardous waste. Anything that comes into contact with the groundwater is now considered a listed hazardous waste. So, if you have tools and other items being used in the remediation effort, these are now a listed hazardous waste. HAZWOPER training at these contaminated sites would fall under 29 CFR 1910.120 (e) General Site Personnel. If your facility is in one of the 27 OSHA Plan States, you would have to comply with your state regulatory agency. State regulatory agencies must be as least as stringent as the Federal OSHA standards and can be more stringent.  

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