How do I address plumes of contaminated groundwater that originate from off-site sources in making a Migration of Contaminated Groundwater under Control EI determination at a RCRA facility?
As stated in the February 5, 1999 guidance from the Office of Solid Waste, OSW (renamed Office of Resource Conservation and Recovery, ORCR, on January 18, 2009) on how to determine if a facility has met the RCRA Environmental Indicators, the Migration of Contaminated Groundwater under Control EI determination apples site-wide for all contaminated groundwater “subject to corrective action at or from the identified facility.” Therefore, plumes that originate from off-site sources would not be subject to a RCRA groundwater EI determination for the RCRA facility in question. The overseeing agency, however, should ensure that such plumes are addressed as necessary through other regulatory actions.
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