
The proposed rules would expand the RCRA Corrective Action regime to PFAS and potentially other emerging contaminants. They may complicate ongoing compliance efforts as well as lead to significant value chain impacts.
By Gary P. Gengel, Julia A. Hatcher, Thomas C. Pearce, and Guy Jack Mathews
The Resource Conversation and Recovery Act (RCRA) mandates a two-part “corrective action” regime:
- Permits for any “solid waste management unit” (SWMU) at a “treatment, storage or disposal facility” (TSDF) must require