Who We Are

Background

What We Do

Watershed Approach

Statutory and Regulatory Framework

Structure

Resource Conservation and Recovery Act

RCRA regulates LANL's Remediation Services project. As enacted in 1976, RCRA's hazardous waste management provisions govern the day-to-day operations of hazardous waste generation, treatment, storage, and disposal facilities.

Under RCRA, LANL qualifies as a treatment and storage facility and has a permit to operate regulated hazardous waste treatment and storage units.

Hazardous and Solid Waste Amendments

In 1984, Congress amended RCRA by passing the Hazardous and Solid Waste Amendments (HSWA). Sections 201, 202, 203, 206, 207, 212, 215, and 224 of HSWA modified the permitting sections of RCRA (Sections 3004 and 3005). In accordance with these provisions of HSWA, LANL's permit to operate hazardous waste treatment and storage units includes a section (called the HSWA Module) that prescribes a specific corrective action program for LANL, which focuses primarily on the investigation and cleanup, if required, of inactive sites.

The fundamental unit to which these requirements apply is the solid waste management unit (SWMU). The US Environmental Protection Agency (EPA) defines in the HSWA Module as "...any discernible unit at which solid wastes have been placed at any time, irrespective of whether it was intended for the management of solid or hazardous waste. Such units include any area at or around a facility at which solid wastes have been routinely and systematically released."

The HSWA Module specifies the following three-step corrective action process:

1. RCRA Facility Investigation (RFI). An RFI identifies the nature and extent of contamination at its source and the environmental pathways along which contaminants could travel to human and environmental receptors. This step characterizes the extent of contamination in the detail necessary to determine which corrective measures, if any, are needed. Characterization focuses on answering questions relevant to determining further actions in a cost-effective manner.
2. Corrective measures study (CMS). If characterization indicates that corrective measures are needed, a CMS evaluates potential alternatives. These alternatives are evaluated based on their projected ability to reduce risks to human and environmental health and safety in a cost-effective manner.
3. Corrective measures implementation (CMI). A CMI implements the selected remedy, verifies its effectiveness, and establishes ongoing control and monitoring requirements, if needed.

Statutory and Regulatory Framework