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Corrective Action Overview

Introduction

Though historically RCRA has been a prevention program, a corrective action program has evolved to address the cleanup of hazardous waste releases at RCRA-regulated sites. The corrective action program is one of the primary mechanisms to facilitate cleanup of contamination at treatment, storage, and disposal sites (TSDFs).

EPA can issue an administrative order to compel an owner/operator to undertake corrective action, or EPA can sue (i.e., bring a civil action) to have the court order the owner/operator to clean up. The authority for requiring corrective action at permitted sites is found in Sections 3004(u) and (v) of the Resource Conservation and Recovery Act (RCRA). EPA uses Section 3008(a) to enforce at permitted sites the corrective action requirements found in Sections 3004(u) and (v).

The RCRAInfo Corrective Action Module is used to track the specific corrective action information needed to regulate sites found to have hazardous waste releases. RCRA sites usually fall under corrective action during the permitting process or when a release justifying action is identified. The process usually begins with an Agency-conducted RCRA Facility Assessment (RFA). If the RFA finds that a release may exist then the corrective action process continues, otherwise the process stops.

Information tracked by RCRAInfo's Corrective Action Module includes the specific authority driving the corrective action activities such as permits or corrective action orders, the areas affected by the release, and the events that track the progress of the corrective action. The authority is the legal force driving the corrective action. The area tracked in corrective action is defined geographically; areas are physical areas that can be part of the site or the entire site. The events in corrective action are designed to track the different phases of the corrective action implementation from the RFA to the clean-up of the release.