Learn about Corrective Action
On this page:
- What is Corrective Action?
- What are Corrective Action Facilities?
- The Corrective Action Process
- Program Oversight
- General Resources
Corrective action is a requirement under the Resource Conservation and Recovery Act (RCRA) that facilities that treat, store or dispose of hazardous wastes investigate and clean up hazardous releases into soil, ground water, surface water and air. In 1984, Congress passed the Hazardous and Solid Waste Amendments, which granted EPA expanded authority to require corrective action at permitted and non-permitted treatment, storage and disposal facilities (TSDFs).
Rather than creating a rigid regulatory framework for corrective action, EPA developed guidance and policy documents to assist facilities conducting cleanups. Some of the resources are broad in scope, while others are more process or media specific.
Corrective action is principally implemented through RCRA permits and orders. RCRA permits issued to TSDFs must include provisions for corrective action as well as financial assurance to cover the costs of implementing those cleanup measures. In additional to EPA, 44 states and territories are authorized to run the Corrective Action program. Corrective action is largely enforced through statutory authorities established by RCRA.
RCRA Corrective Action facilities vary significantly. They include current and former chemical manufacturing plants, oil refineries, lead smelters, wood preservers, steel mills, commercial landfills, federal facilities, and a variety of other types of entities. Size, type and extent of contamination, media affected, environmental characteristics, and geology also differ greatly between facilities. Facilities are generally brought into the RCRA Corrective Action process when:
- there is an identified release of hazardous waste or hazardous constituents, or
- when EPA is considering a treatment, storage and disposal facility (TSDF) RCRA permit application.
The RCRA Corrective Action program, comprised of EPA and its state partners, oversees almost 4,000 cleanups across the country, including many facilities with risks comparable to Superfund Sites. Information on these individual facilities is available from the Corrective Action Sites Around the Nation regional page and in Cleanups in My Community.
EPA's Corrective Action program works closely with facilities during the investigation and cleanup process.
- Learn how EPA measures progress at corrective action facilities.
- Gather facility-specific information from EPA's regional programs.
The RCRA corrective action cleanup process focuses on results rather than specific steps, and is flexible, depending on site-specific conditions. A typical cleanup may include steps such as: initial site assessment, site characterization, interim actions, evaluation of remedial alternatives, and implementation of the selected remedy.
Because no one approach is likely to be appropriate for all corrective action facilities, these five elements should not be viewed as prescribed steps in the corrective action process. Instead, they serve as evaluations necessary to make good cleanup decisions within a flexible program. The five elements are described below in more detail. Additional elements of corrective action to keep in mind, and which are also described below, are tracking progress and long-term care.
Select the clean-up step to learn more about its function in the RCRA corrective action process. EPA provides links to guidance documents and other information to help the regulated community and program implementers learn about and enforce the corrective action process.
- Initial Site Assessment
The first element in most cleanup programs is an initial site assessment. During the initial site assessment, state or EPA technicians gather information on site conditions, releases, potential releases, and exposure pathways to determine whether a cleanup may be needed and to identify areas of potential concern. In the corrective action program, this step is commonly referred to as RCRA Facility Assessment (RFA). Overseeing agencies may also use initial site assessments to set relative priorities among facilities and allocate resources. EPA issued the Initial Site Assessment guidance to assist in this process.
- Site Characterization
Before cleanup decisions can be made, some level of characterization is necessary to ascertain the nature and extent of contamination of a site and to gather information necessary to support selection and implementation of appropriate remedies. This step is often referred to as the RCRA Facility Investigation (RFI). A successful RFI will identify the presence, movement, fate, and risks associated with environmental contamination at a site and will explain the chemical and physical properties of the site likely to influence contamination migration and cleanup. Information collected during the RFI can be used by the owner or operator to formulate and implement appropriate corrective measures. Such corrective measures may range from a) stopping the release through the application of a source control technique to b) a full-scale cleanup of the affected area. EPA issued Site Characterization documents to assist in this process.
- Interim Actions
While site characterization is underway or before a final remedy is selected, corrective action facilities often need interim actions. Interim actions are used to control or abate ongoing risks to human health and the environment in advance of the final remedy selection. For example, actual or potential contamination of drinking water supplies may necessitate an interim action to provide alternative drinking water sources. EPA issued Interim Actions documents to assist in this process.
- Evaluation of Remedial Alternatives
Before choosing a cleanup approach, program implementers and facility owners/operators will typically analyze a range of alternatives and evaluate their advantages and disadvantages relative to facility-specific conditions. Such a study is called the Corrective Action Measures Study (CMS). EPA issued Evaluation of Remedial Alternatives documents to assist in this process.
- Remedy Implementation
Remedy implementation typically involves detailed remedy design, remedy construction, remedy operation and maintenance and remedy completion. In the corrective action program, this step is often referred to as Corrective Measures Implementation (CMI). EPA issued Remedy Implementation Documents to assist in this process.
- Tracking Progress
Corrective Action Event Code documents provide information on tracking cleanup progress at RCRA facilities. EPA developed a series of event codes from the first facility assessment until the corrective action is terminated. These codes provide important information, such as when the state or EPA determine the remedy for a facility to achieve corrective action goals, as well as when the facility completes the remedy, and major corrective action milestones. EPA also developed the National Corrective Action Prioritization System (NCAPS), a menu-driven, computer-based system, which prioritizes events. The NCAPS assists EPA in focusing corrective action resources on those facilities which present the greatest risk to human health and the environment. The system is intended to provide a nationally consistent approach to assessing site-specific factors that potentially affect or drive corrective action decisions.
- Long-Term Care
The Corrective Action Program strives to ensure long-term protection after a facility cleanup has established institutional and engineering controls. This protects the integrity of the remedy by preventing or limiting exposure to remaining hazardous waste on the facility. EPA defines institutional controls as "non-engineered instruments, such as administrative and legal controls, that help to minimize the potential for human exposure to contamination and protect the integrity of the remedy." Such controls provide information and/or restrictions that help modify or guide human behavior at facilities and properties where hazardous wastes and contamination prevent unlimited use and unrestricted exposure. Common examples of institutional controls include permits and orders, zoning, building or excavation permits, well drilling prohibitions, and easements and restrictive covenants. EPA developed Long-Term Care documents for identifying and selecting institutional controls at corrective action cleanups.
the U.S. Government Accountability Office (GAO) and the Office of Inspector General (OIG) independently monitor the Corrective Action Program. The GAO is an independent, non-partisan agency that works for Congress to investigate how the federal government spends taxpayer dollars. OIG monitors and tracks the use of taxpayer dollars through audits, inspections, evaluations, and investigations. The OIG seeks to improve the efficiency and effectiveness of select government programs and operations.
For additional information and guidance on program oversight of the RCRA Corrective Action program, view:
- EPA's response to the OIG Audit, "Superfund Sites Deferred to RCRA" (PDF)(59 pp, 125 K, About PDF)
- GAO Report on the Corrective Action Program (PDF)(32 pp, 452 K, About PDF)
|RCRA Corrective Action Plan||
The purpose of the RCRA Corrective Action Plan (CAP) is to aid Regions and States in determining and directing the specific work that a permittee/respondent must perform, as part of a complete Corrective Action Program. The CAP assists the Regions and States in developing Corrective Action requirements in permits under RCRA §3004(u) and (v) and §3005(c)(3) (omnibus) and Corrective Action orders under RCRA §3008(h) and §7003.
|Guidance for Corrective Action Management Units (CAMUs)||This information is regarding the regulations governing CAMUs concerning: the types of wastes that may be managed in a CAMU, the design standards that apply to CAMUs, the treatment requirements for wastes placed in CAMUs, information submission requirements for CAMU applications, responses to releases from CAMUs, and public participation requirements for CAMU decisions.|
|RCRA/Comprehensive Environmental Response, Compensation, and Liability Act (CERLCA) Coordination Memo (PDF)(11 pp, 49.6 K, About PDF)||
This memo discusses three areas: acceptance of decisions made by other remedial programs; deferral of activities and coordination among EPA RCRA, EPA CERCLA and state/tribal cleanup programs; and coordination of the specific standards and administrative requirements for closure of RCRA regulated units with other cleanup activities. The memo also announces a revision to the EPA’s policy on the use of fate and transport calculations to meet the "clean closure" performance standard under RCRA.
|Results-Based Approaches and Tailored Oversight||
This document describes how EPA implements the statutory and regulatory provisions that concern RCRA Corrective Action. The purpose of the Corrective Action Program is to address releases of hazardous waste and hazardous constituents at RCRA facilities in a timely and protective manner. Results-based approaches emphasize outcomes, or results, in cleaning up releases and strive to tailor process requirements to the characteristics of the specific Corrective Action. Tailored oversight is an oversight plan developed based on facility-specific conditions such as site complexity, compliance history, and financial and technical capability of the facility.
|Handbook of Groundwater Protection and Cleanup Policies for the RCRA Corrective Action||
This handbook is designed to help regulators, members of the regulated community, and members of the public find and understand EPA policies on protecting and cleaning up groundwater at facilities subject to corrective action under subtitle C of RCRA.
EPA developed the following trainings to explain various aspects of the corrective action program.
- Strategies for Meeting the 2020 Vision – these training materials were designed to develop and enhance the skills of qualified personnel who will implement corrective actions for their sites by the year 2020 that are protective of human health and the environment while encouraging revitalization.
- Environmental Indicator Forum 2000 Exit- This page consists of presentations from EPA’s EI Forum from August 15-17, 2000. The purpose of the EI Forum was to bring together public and private stakeholders to hear presentations and discuss issues associated with achieving two EIs at facilities subject to RCRA Corrective Action.