Who Needs RCRA Facility Investigations?
The Resource Conservation and Recovery Act (RCRA) is the public law that creates the framework for the proper management of hazardous/non-hazardous solid waste. Under this law, the EPA mandates a RCRA Facility Investigation (RFI) to determine the nature and extent of the releases of hazardous constituents at a facility. The RFI often accompanies a Corrective Measure Study (CMS), which provides the required actions for cleaning up the site.
The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), commonly known as Superfund, has provided a trust fund for cleaning up abandoned or uncontrolled hazardous waste sites. Superfund sites require comprehensive investigations to determine sources of contamination, identify Potential Responsible Parties (PRP), and allocate cost to each PRP.
With development of regulatory efforts on characterizing PFAS under CERCLA and RCRA, this will open a new realm of superfund sites that require extensive investigations and remediations.