RCRA Corrective Action, Closure, and Stewardship

Connecticut is authorized for Resource Conservation and Recovery Act (RCRA) Closure and Corrective Action. RCRA requires facility owners and operators to clean up properties that have treated, stored, or disposed of hazardous waste at their facility. This requirement is implemented through a permit, order, or in the case of land disposal facilities, by regulation. Such clean-up work may be coordinated with work performed pursuant to other clean-up authorities in Connecticut.

RCRA Corrective Action

RCRA facilities must investigate all areas of concern sitewide.  If any investigation and remediation activities are not completed by the time of a facility's permit issuance then such environmental investigation and remediation will be included in the permit.  

• Corrective Action at RCRA Land Disposal Facilities Fact Sheet [22a-449(c)-105(h)] of RCSA
• Corrective Action and Financial Assurance Links
• Corrective Action History  EPA Fact Sheet
• RCRA Stewardship Permits   Presentation that  explains the use of Stewardship Permits ("RCRA Part B Post-Closure Permits") to implement RCRA Corrective Action and Long-Term Stewardship Obligations
• RCRA Orientation Training for Remediation Staff - PowerPoint slides for DEEP Training on the provisions of RCRA that apply to site cleanup, including the requirements relating to RCRA closure, post-closure, and corrective action.
• Environmental Indicators (EIs) - EIs measure progress in environmental terms rather than by the administrative process steps that were previously monitored. Measuring and recording progress toward these goals will be a top priority for EPA and the States over the next several years. EPA's Environmental Indicator forms for Human Health - CA725 and Groundwater - CA750.
• Connecticut RCRA's "Contained-In" Policy  Explains how to determine whether to manage environmental media depending on whether it contains or does not contain hazardous waste
• Site Characterization - Investigation, or site characterization, is expected to be conducted in accordance with prevailing standards and guidelines.
• The Site Characterization webpage provides resources that assist the environmental professional in understanding the standard of care expected when characterizing a site under various Connecticut cleanup programs.

Ecological Risks

• Considerations for Assessing Ecological Risks (EPA, RCRA, March 2015)
• RCRA Corrective Action Ecological Receptor Exposure Pathway Scoping Checklist - This checklist is a screening tool developed by EPA to aid project managers in determining whether there is the potential for complete exposure pathways between RCRA facility contaminants and ecological receptors.
• EPA Ecological Risk Assessment Guidance Ecological risk evaluation is required for all RCRA Corrective Action sites. This guidance provides the key elements expected to be included  in the submittal of ecological risk assessment documents to the CTDEEP and EPA, including conceptual site model and the proper approach to assessing ecological risk.
• EPA Contaminated Sediments: Guidance and Technical Support Numerous documents regarding remediation of sediments.

RCRA Closure

RCRA requires operators to remove hazardous waste from treatment and storage areas and to either remove waste from land disposal units or close such units as a land disposal facility.  Once wastes are removed, facilities and generators must decontaminate the area and any equipment that was used for managing hazardous wastes. Any releases to the environment must be remediated.

• RCRA Closure Guidance for Treatment, Storage, and Disposal Facilities - Container Storage Areas and Tanks Systems
• Guidance For Implementing and Documenting Closure (Waste Removal And Decontamination) For Indoor RCRA Hazardous Waste Storage Areas  This is a supplement to the RCRA Closure Guidance for Generators Who Store Less Than 90 days (above).
• RCRA Closure Guidance for Generators Who Store Less Than 90 days - Container Storage Areas and Tanks Systems 

RCRA Stewardship Permits for Corrective Action Facilities

If You Own or Operate a Resource Conservation and Recovery Act (RCRA) Hazardous Waste Facility:

• Do you want to move from interim status to permitted status and reduce future permitting and enforcement uncertainty?
• Do you want to start on the road to clean-up?
• Do you want to memorialize the clean-up work completed to date?
• Do you want a "certificate of stewardship" to provide to the bank or the insurance company to show you are on the road to clean-up?

The answer: Apply for a Stewardship Permit.  

A Stewardship Permit:

• Defines the long-term obligations for the permit holder;
• Is transferrable to future owners;
• Provides public participation during the cleanup process;
• Documents cleanup as it is completed; and
• Imposes financial assurance, possibly in phases, for the proposed cleanup work.

Additional Information

Remediation Stewardship Permit Fact Sheet

Examples of Stewardship Permits Issued

Proposed Individual Permits

Permit application forms and instructions

Permit Application for Remediation Stewardship Permit  (DEP-STWD-APP-100)

Contact Information:

DEEP.REMStewardship@ct.gov  Remediation Division, Water Protection and Land Reuse Bureau