Corrective Action Enforcement

The Region 6 RCRA Corrective Action Enforcement program protects human health and the environment by enforcing against those responsible for operating a contaminated RCRA hazardous waste site and pursue getting the site cleaned up. The Technical Section uses a number of RCRA cleanup authorities independently and in combination to address specific cleanup situations. These clean-up operations are similar in nature to a PRP-Lead Superfund Enforcement Remedial Action. Corrective Action is simply the RCRA way of saying clean-up or take remedial action.

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The Compliance Assurance and Enforcement Division, Hazardous Waste Enforcement, Technical Section deals with all aspects of corrective action enforcement from targeting and case development to oversight of the corrective action activities under an enforcement instrument. Our workload is made up of interim status facilities requiring clean-up, facilities with a potential imminent and substantial endangerment to human health or the environment, and facilities where the condition or status is unknown. We find out about these facilities in a number of ways including referrals from other EPA programs, referrals from state programs, or even referrals from the public. For those of you who speak RCRA, we use the following authorities to accomplish RCRA Corrective Action:

• Section 3008(h) for corrective action at interim status facilities,
• Section 3013 for sampling, analysis, reporting, & remedial plan development at RCRA facilities
• Section 7003 for facilities with a potential imminent and substantial endangerment to human health or the environment
• Letter Orders/Agreements which may implement any of these authorities, and;
• prospective purchaser agreements or orders with prospective purchasers.

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The cleanup of contaminated property, including brownfields, and environmental cleanup liability, are the building blocks to the sustainable reuse of previously-used property.

By the year 2020, EPA and the authorized states plan to have largely completed the work of implementing final remedies at all facilities requiring Corrective Action. (See Goal 3 of the Office of Solid Waste's 2020 Vision for more details.) While working toward the 2020 goal, EPA decided to ensure that sites presenting the greatest risk to human health and the environment are dealt with first. Accordingly, the Corrective Action Program had pledged to select a final remedy at 30% and put a final remedy in place at 20% of 1,968 highest-priority sites by 2008. Those goals have been raised, however, to better reflect progress made through 2006. Now, the Corrective Action Program has pledged to select a final remedy at 36% and put a final remedy in place at 27% of 1,968 highest-priority sites by 2008.