There has been some question as to whether ground water contaminated with restricted RCRA hazardous wastes, which is extracted during a RCRA corrective action or CERCLA response action, must meet the best demonstrated available technology (BDAT) identified for that waste under the RCRA land disposal restrictions (LDRs) prior to each reinjection, in a pump-and-treat reinjection remediation system. This memorandum explains EPA's interpretation of whether the LDRs are applicable or (under CERCLA response actions only) relevant and appropriate to such reinjections or to the remediation as a whole. |