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RCRA Cleanup Baseline

As part of EPA's RCRA CleanUp Reforms initiative, a Baseline of 1700+ RCRA facilities nationwide was published on July 8, 1999.

2008 RCRA Clean-Up Baseline (Table of Environmental Indicators)

GPRA (Government Performance Results Act)

In an effort to accelerate corrective action at RCRA facilities, the GPRA has set a goal of having 95% of these facilities to have human exposures controlled, and 70 % to have groundwater releases controlled by the year 2005. These goals will provide a measurement of the progress of corrective action for all RCRA facilities and will be represented by the following environmental indicators: CA 725 for Human Exposures Controlled, and CA 750 for Groundwater Releases Controlled. These codes will be entered into the RCRA Information System (RCRIS) database by EPA and the States when RCRA facilities have reached these goals.

Background

The Baseline was developed from the National RCRA Corrective Action Priorities Initiative and input from the States. This initiative was in 1991 and initial rankings for most facilities were generated in 1991 through 1993. Corrective action is required for releases of hazardous waste or constituents from solid waste management units (SWMUs) at hazardous waste treatment, storage, or disposal facilities. Most facilities were ranked based on information in the RCRA Facility Assessment (RFA) report. The ranking took into account: 1) type and design of the waste management unit, 2) volume of waste, 3) waste toxicity, and 4) likelihood of a release to the environment. Other factors included: 1) depth to groundwater, 2) groundwater use, 3) distance to surface water, 4) nearest drinking water intake, 5) nearest sensitive environment, and 6) nearby population. The RCRA Baseline was then checked against a list of facilities in the corrective action workload universe in RCRIS. This universe is calculated using the status of regulated units and corrective action activities which have occurred.

Current Status

Many RCRA facilities are in the process of conducting corrective action. Some facilities have made substantial progress in their cleanup efforts, and may have met the environmental indicator measures (CA725/CA750). Determinations were made based on information provided on the CA725/CA750 forms in PDF format. (To get a free copy of the PDF Reader click here. After downloading the PDF reader to your computer, click on any pdf file, and tell the browser the path to the acroread.exe file that was downloaded from Adobe's Web Page). Other facilities that have not yet met the environmenal indicators may have made substantial progress through stabilization. For further information on the current status of RCRA facilities in Region 6, see attached table.

Questions and Answers

1. What are these facilities and how did EPA develop the RCRA Cleanup Baseline?

EPA developed the RCRA Cleanup Baseline in conjunction with the states as a result of a mandate in the Government Performance & Results Act (GPRA) requiring EPA to measure and track program progress. The purpose of the baseline is to track our workload and progress in corrective action. Most of the 1714 facilities were identified in the early 1990's when EPA and the states were prioritizing their corrective action workload, and were identified as facilities where early cleanup progress was appropriate.

Since being included in the early 1990's, many facilities have made progress in their cleanup efforts. 791 facilities have met both environmental indicators (CA 725/Human Exposures Controlled, and CA750/Groundwater Releases Controlled), and at some of these facilities cleanup is complete. Many of the facilities that have not yet met the environmental indicator measures have still made substantial progress by stabilizing problems or in some cases beginning final remedies. At other facilities, corrective action has either not begun or is proceeding at varying rates. To find out the actual status and situation at a given facility, we strongly encourage the public to contact the authorized state or EPA Region.

2. How did EPA and the states determine that these facilities were a priority?

The National Corrective Action Prioritization System (NCAPS) is the principal mechanism EPA used in the early 1990's to determine the relative priority for facility cleanup. This system is a management tool that takes multiple factors into account, including: whether there has been an observed release; toxicity of contaminants; contaminant characteristics that relate to fate and transport; aquifer, surface water and rainfall parameters; characteristics of waste management units, amount of waste; and receptor characteristics (e.g., whether groundwater is being used). This scoring allows the oversight agencies to assess the relative potential of facilities to pose a threat to human health or the environment. The oversight agency then categorizes each facility as being of High, Medium, or Low priority for focusing Agency oversight.

The NCAPS system is different than the Hazard Ranking System used in Superfund, but it does consider many of the same factors. NCAPS scores do not equate to the Superfund Hazard Ranking System (HRS).

3. How is the RCRA Corrective Action Program different from the Superfund Program?

The RCRA Corrective Action program addresses facilities that at one time or another treated, stored, or disposed of hazardous wastes and, therefore, were subject to RCRA permitting requirements. There are approximately 3500 industrial sites nationwide that must undergo cleanup to satisfy the RCRA corrective action program. EPA and the states have identified approximately 1700 facilities for the RCRA Cleanup Baseline from this 3500.

EPA's Superfund has much broader authority to address both regulated facilities as well as hazardous substance releases from abandoned and inactive facilities, spills, illegal dumping, etc. The Agency's policy is to use Superfund to complement regulatory programs, focusing Superfund resources on problems that are not otherwise being addressed. There are currently about 1,300 proposed and final sites on the Superfund National Priorities List.

4. How many of the facilities nationwide have met the environmental indicators?

Of the 1714 facilities nationwide on the RCRA Cleanup Baseline: 1018 have met the Human Exposure Environmental Indicator 875 have met the Groundwater Migration Environmental Indicator, 791 facilities have met both of the environmental indicators.

5. Can there be more than one regulatory authority at these facilities?

Yes. We have noted that at some of these facilities there are areas where both Superfund and RCRA Corrective Action authorities are being used in the cleanup. Also, many of these facilities also must comply with the Clean Air Act, Clean Water Act, Toxic Substances Control Act, and other state or local authorities. Federal facilities may have to comply with their own authorities.

6. How can facilities get off the baseline?

This baseline is a tool for tracking EPA/State workload and progress and therefore must remain consistent to have value for this purpose. Therefore, facilities will not be "removed" from the baseline. However, when it is verified that a facility meets both environmental indicators, they will be added to a separate grouping of facilities that have met their near-term Corrective Action obligations. There are 791 such facilities nationwide in this grouping now.

7. Why did EPA and the States choose these 2 environmental indicators?

The RCRA Program developed the Environmental Indicators (EIs) guidance to help focus program activities on observable, near term improvements in environmental conditions (i.e., Results) that were site-wide and to de-emphasize procedural (i.e., the Process), document-based, or partial-facility milestones of program progress. These EIs are being used to measure program progress under the Government Performance and Results Act.

These indicators address two of the program's highest near-term priorities.

The protection of human health by preventing current exposures to contamination (via cleanup of contaminated media and/or the use of exposure controls to prevent unacceptable exposures) is clearly one of the Corrective Action Program's highest near-term priorities.

The protection of environmental resources by preventing the further spread of contamination, in the most significantly contaminated and mobile media (i.e., groundwater), is also one of the highest near-term priorities of the Corrective Action Program.

8. Does Superfund use these same indicators?

The Superfund program is currently using several performance measures and three environmental indicators to document its progress in protecting people and the environment. Each is a set of indicators to measure 1) Populations protected from immediate threats, 2) Attainment of incremental clean up goals, and 3) Volumes of waste handled by treatment and containment technologies. Two additional Superfund indicators are being developed to provide more specific information on risk reduction and ecological protection. The two programs are working together to determine which environmental indicators both programs can use for the same purpose.

9. Do you have any environmental indicators concerning the protection of ecosystems, endangered species, wetlands, etc.?

We are considering developing additional indicators. We would like to get additional feedback from our stakeholders on developing additional measures to assess our protection of ecosystems, etc.

10. The GPRA goals are in terms of stabilizing the situation at sites. Why isn't EPA pursuing final cleanup at each of these sites? Are these sites ever going to be completely cleaned up?

Final cleanup is the ultimate goal at all RCRA Corrective Action sites, but it makes sense from an environmental and human health standpoint to make sure that human exposures and groundwater migration are under control at as many sites as possible before moving on to final cleanup.

791 sites nationwide have moved beyond stabilization and have met the environmental indicators and are on their way to final cleanup.

11. Why is EPA releasing the RCRA Cleanup Baseline at this time?

The public has a right to know what we are doing to address the cleanup of these facilities.

12. How accurate is the baseline?

We believe that the RCRA Cleanup Baseline information is as accurate as possible, given that by definition this information is constantly changing to reflect changes in cleanup status and program progress. EPA regions and the states recently completed a significant upgrading and updating of the Baseline information so we are confident that it is a reasonably accurate SNAPSHOT of environmental indicator status at the baseline facilities. At the same time, one of the purposes of this announcement is to encourage more activity by regulators and industry to document and verify that the environmental indicators (EI) have been met, so we hope that the EI information will change at a rapid rate.

For Further Information, Contact:

EPA: Cathy Gilmore - Enforcement - 214.665.6766 or Email at: gilmore.cathy@epa.gov
EPA: Cathy Carter - RCRA Permitting - 214.665.6792 or Email at: carter.cathy@epa.gov

State Contacts:
Arkansas Department of Environmental Quality: Daniel Clanton - 501.682.0834
Louisiana Department of Environmental Quality: Narendra Dave - 225.765.0361
Oklahoma Department of Environmental Quality: Don Barrett - 405.702.5142
New Mexico Environment Department: James Bearzi - 505.827.1567
Texas Natural Resource Conservation Commission: Ata Rahman - 512.239.2276