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United States Environmental Protection Agency
Region 10: The Pacific Northwest
Serving the people of Alaska, Idaho, Oregon, Washington and 270 Native Tribes

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Corrective Action
Resource Conservation and Recovery Act (RCRA)


Region 10 Environmental Indicator (EI) Progress

Overview of the Corrective Action Program

Corrective Action is an EPA program designed to investigate and guide the cleanup of any contaminated air, groundwater, surface water, or soil from hazardous waste management of spills or releases into the environment. These releases of hazardous waste and hazardous constituents are a result of the past and present activities at RCRA-regulated facilities.

    Enforcement of corrective action

    The EPA enforces corrective action through statutory authorities established by the 1984 Hazardous and Solid Waste Amendments (HSWA). Through HSWA, Congress expanded EPA's corrective action authority to initiate corrective action at both RCRA permitted facilities and facilities operating under interim status. When a facility is obtaining a permit, or when a facility has an existing permit, EPA can incorporate corrective action into the permit requirements through:

    • Section 3004(u) which addresses releases from solid waste management units (SWMUs) in a facility's permit. A SWMU is any unit where solid or hazardous wastes have been placed at any time, or any area where solid wastes have been routinely and systematically released.
    • Section 3004(v) which addresses releases that have migrated beyond the facility boundary.
    • Section 3005(c)(3) also known as the "Omnibus Permitting Authority" allows EPA or an authorized state agency to include any requirements deemed necessary in a permit, including the requirement to perform corrective action.
Regional Information

    Additional authorities to order corrective action

    • Section 3008(h) which is an administrative enforcement order or lawsuit that addresses releases at interim status facilities.
    • Section 7003 which applies to all facilities, whether or not they have a RCRA permit, that may present an imminent and substantial endangerment to health or the environment. Under this provision, EPA can waive other RCRA requirements (e.g., a permit) to expedite the cleanup process.
    • Corrective action does not always involve permit requirements or an enforcement order. Owners and operators of RCRA-regulated facilities may also volunteer to perform corrective action. Some activities which may be necessary to achieve corrective action goals at a facility, may require formal approval by EPA or the authorized state. EPA strongly encourages owners and operators to work closely with EPA and authorized state agencies to obtain oversight during voluntary cleanup activities.


    Corrective Action Process

    Cleanup at a RCRA-regulated facility will depend on site-specific conditions. The corrective action process is highly flexible and focuses on results than specific steps. The six components of this process are:

    • RCRA Facility Assessment (RFA), to compile existing information on environmental conditions at a given facility, including information on actual or potential releases.
    • Phase I RCRA Facility Investigations (RFIs) also known as Release Assessment (RA), to confirm or reduce uncertainty about areas of concern or potential releases identified during the RFA.
    • RCRA Facility Investigation (RFI), to assess the nature and extent of contamination of releases identified during the RFA or Phase I RFI.
    • Interim Measures (IM), short-term actions to control ongoing risks while site characterization is underway or before a final remedy is selected.
    • Corrective Measures Study (CMS), to identify and evaluate different alternative measures to remediate the site.
    • Corrective Measures Implementation (CMI), includes detailed design, construction, operation, maintenance, and monitoring of the chosen remedy.

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Unit: Resources Mgmt. & State Programs Unit
Point of contact: Jeff Hunt
E-Mail: hunt.jeff@epa.gov
Phone Number: (206) 553-0256
Last Updated: 08/21/2007

 

 
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