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RCRA Corrective Action Background

RCRA Corrective Action

Corrective Action Implementation

Corrective Action requirements are found in the 1984 Hazardous and Solid Waste Amendments (HSWA) to the Resource Conservation and Recovery Act (RCRA). Facilities which receive a hazardous waste treatment, storage or disposal permit are subject to RCRA Corrective Action. RCRA Corrective Action Orders may also be issued to facilities which treat, store or dispose hazardous waste or handle solid or hazardous waste in a manner constituting imminent or substantial endangerment. RCRA Corrective Action is the process through which areas at a hazardous waste facility are evaluated and, if necessary, are cleaned up. The areas covered under the corrective action provisions of RCRA include solid waste management units (SWMUs) and areas of concern (AOC).

RCRA comprises the Federal Regulations (FR) found in 40 CFR §260 - §279. The regulations relating specifically to RCRA Corrective Action are found in 40 CFR §264.101.

In Region 4, implementation of the Resource Conservation and Recovery Act (RCRA), including the RCRA Corrective Action program, is performed by the following entities:

The EPA Region 4 RCRA Programs Branch manages all issues regarding RCRA facility permits for which a state is not authorized to implement in lieu of EPA, including RCRA Corrective Action pursued through a permit. Currently, seven (7) of the eight (8) states are authorized to implement RCRA Corrective Action. The first Region 4 State to become authorized for RCRA Corrective Action was Georgia. In 2000, Florida and Tennessee become the latest Region 4 States to be authorized to implement RCRA Corrective Action. In authorized States, EPA's main roles include transmission of national priorities and oversight of State actions. Only Mississippi has yet to apply for authorization to implement RCRA Corrective Action. Therefore, the Region 4 RCRA Programs Branch is responsible for RCRA Corrective Action in Mississippi.

The EPA Region 4 Enforcement and Compliance Branch implements or oversees compliance assurance measures in the eight (8) Region 4 states. These measures include facility inspections, compliance assistance efforts, RCRA Corrective Action pursued through orders, as well as initiating federal enforcement actions for violations of RCRA. The Region 4 Enforcement and Compliance Branch may issue RCRA Corrective Action orders in any State, regardless of authorization status.

The EPA Region 4 Federal Facilities Branch monitors and provides assistance to federal facilities to ensure compliance with environmental regulations and policies under the Comprehensive Environmental Response, Compensation Liability Act (CERCLA), the Superfund Amendments & Reauthorization Act (SARA) and implementation (after permit or order issuance) of RCRA Corrective Action at federally-owned facilities. Because every State but Mississippi is authorized to implement the RCRA Corrective Action Provisions, the Region 4 Federal Facilities Branch is only responsible for implementing RCRA Corrective Action through permits in Mississippi. However, the Federal Facilities Branch can implement RCRA Corrective Action Orders issued by the Region 4 Enforcement and Compliance Branch. Region 4's Federal Facilities Branch also has ongoing responsibilities under CERCLA.

Since 1984, EPA and authorized states have made considerable progress in implementing the RCRA Corrective Action requirements. Despite the progress made, states, environmental groups and the regulated community have raised concerns, including: slow progress in achieving cleanup or other environmental results; an emphasis on process and reports over actual work in the field; unrealistic, impractical or overly conservative cleanup goals; and lack of meaningful public participation. In response to these concerns, EPA entered into a series of reforms, RCRA Reforms I and RCRA Reforms II. These Reforms compliment and support the Agency's efforts at meeting GPRA.

EPA Headquarters on RCRA Corrective Action
Further information and explanations on RCRA Corrective Action can be found at the Office of Solid Waste.

Additional Information on RCRA Corrective Action
Region 4 RCRA Guidance provides further regional guidance on the RCRA Corrective Action Program.

National RCRA Corrective Action Guidance provides a selection of key national RCRA Corrective Action Guidance.

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