The United States Environmental Protection Agency (“EPA”) issued a December 19, 2024 Resource Conservation Recovery Act (“RCRA”) guidance document titled:
Improved Procedures for Facility/Site Transfers Between RCRA Hazardous Waste Cleanup and CERCLA Cleanup Authorities (“Guidance”)
See OLEM Directive #9932.2.
The Guidance is transmitted from Caroline Hoskinson, EPA office of Resource Conservation Recovery to the following:
- Land, Chemicals, and Redevelopment Division Directors, Regions 1-10
- Superfund and Emergency Management Division Directors. Regions 1-10
The Guidance describes its purpose as providing updated procedures for processing program transfers of facilities/Sites between the RCRA Hazardous Waste Cleanup Program and the Comprehensive Environmental Response, Compensation, and Liability Act (“CERCLA”) Program. The described procedures include documenting and tracking transfer-related information in the following databases:
- RCRA Info
- Superfund Enterprise Management System
The intent is to:
- Help ensure that facilities/sites transferred between the programs follow consistent and complete process.
- Enable Program Managers to accurately identify facility/site’s administrative program management lead, transfer status in real time and improve overall project management at the state, regional, and national levels.
Components of the guidance include:
- Background
- Implementation
- Terms
- Applicability
- Updated RCRA-to-Superfund Referral Process
- Updated Superfund-to-RCRA deferral process
- Timeline for processing proposed transfers
- Database Reporting Requirements and related updates
- Conclusion
- Appendix
A copy of the guidance can be downloaded here.
