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Corrective Action 101- Key Terms
Community Involvement: The EPA's effort to establish two-way communication with the public to create understanding of EPA programs and related actions, to ensure public input into decision-making processes related to affected communities, and to make certain that the Agency is aware of and responsive to public concerns.
Conceptual Site Model: A conceptual site model is a three-dimensional picture of site conditions that coveys what is known or suspected about the sources, releases and release mechanisms, contaminant fate and transport, exposure pathways, potential receptors, and risks. The conceptual site model is based on the information available at any given point in time and will evolve as more information becomes available.
Corrective Action Authorization: EPA's authorization of a State Corrective Action Program is based on a determination that the State is capable of implementing corrective action equivalently to EPA, and in a manner consistent with applicable Federal statutes, regulations and guidance.
Corrective Action Management Unit (CAMU): An area within a facility that is used only for managing remediation wastes for implementing corrective action or cleanup at the facility.
Corrective Action Program: Accidents or other activities at facilities that treat, store or dispose of hazardous wastes have sometimes led to the release of hazardous waste or hazardous constituents into soil, ground water, surface water, or air. Prior to the Hazardous and Solid Waste Amendments (HSWA), cleanup of such releases focused primarily on protecting groundwater from special kinds of RCRA-regulated land disposal units that received hazardous wastes after July 1982. HSWA made it clear that owners or operators of treatment, storage or disposal (TSD) facilities are responsible for investigating and, as necessary, cleaning up releases at or from their facilities, regardless of when the releases occurred. EPA refers to this cleanup of TSD facilities under these statutory authorities as RCRA Corrective Action.
Data Quality Objectives (DQOs): Data Quality Objectives (DQO) refers to the overall degree of data quality or uncertainty that a decision maker is willing to accept for a decision. The DQO approach should apply to the entire measurement system (e.g., sampling locations, methods of collection and handling, field analysis, etc.), not just the laboratory analytical operations.
Environmental Indicators (EIs): Achieving the two environmental indicators-"Current Human Exposures Under Control" and "Migration of Contaminated Groundwater Under Control"-is the near-term goal of the Corrective Action Program. EPA has identified 1,714 facilities (called the RCRA Cleanup Baseline) that warrant attention in the near-term. By 2005, the Agency expects human exposures to be under control at 95% of these facilities and migration of contaminated groundwater to be under control at 70% of these facilities.
Facility: All contiguous land, and structures, other appurtenances, and improvements on the land, used for treating, storing, or disposing of hazardous waste. A facility may consist of several treatment, storage, or disposal operational units (e.g., one or more landfills, surface impoundments, or combinations of them).
Final Remedies: The long-term goal of the Corrective Action Program is to achieve final cleanups that protect human health and the environment, attain media cleanup objectives, and control the sources of releases at all facilities.
Hazardous Wastes/ Hazardous Constituents: EPA interprets "hazardous wastes" to include all wastes that are hazardous within the statutory definition in RCRA Section 1004(5), not just those hazardous wastes that are listed or identified by EPA pursuant to RCRA Section 3001.
Use of the term "hazardous constituents" is interpreted to indicate that, within the broad category of wastes that might be "hazardous" under RCRA Section 1004(5), corrective action should be focused on the specific subset of "hazardous constituents." It also means that corrective action is not limited to "hazardous wastes" but extends to hazardous constituents regardless of whether they were derived from hazardous wastes. This means that hazardous constituents that are (or were) contained in nonhazardous solid wastes are subject to corrective action.
Initial Site Assessment: Information is gathered on site conditions, releases, potential releases and exposure pathways to determine whether a cleanup may be needed and to identify areas of potential concern. Facility owners/operators may gather this information and submit it to EPA or a State for review. These assessments also confirm or reduce uncertainty about solid waste management units that may require further investigation.
Media Cleanup Objectives: The concept of media cleanup objectives includes three components: cleanup levels, the point of compliance, and cleanup time frames.
- Cleanup levels are chemical concentration regulators established for facility-specific cleanup goals.
- The point of compliance refers to where a facility should measure contaminant concentrations in environmental media and achieve media-specific cleanup levels.
- Cleanup time frames refer to both the schedule in which a cleanup measure will be implemented and the estimated time in which remedy will achieve cleanup levels.
Protect Human Health and the Environment: Protecting human health and the environment is the mandate from the RCRA statute and regulations, as well as being the mission of EPA. This goal is, therefore, the most important standard for final RCRA Corrective Action remedies.
Regulated Unit: Regulated units are defined as surface impoundments, waste piles, land treatment units, and landfills that received hazardous waste after July 26, 1982.
Releases: Any spilling, leaking, pumping, pouring, emitting, emptying, discharging, injecting, escaping, leaching, dumping or disposing into the environment. This includes abandoned or discarded barrels, containers, and other closed receptacles containing hazardous waste or constituents.
Remediation Waste: All solid and hazardous wastes, and all media (including groundwater, surface water, soils, and sediments) and debris that contain listed hazardous wastes or that themselves exhibit a hazardous characteristic and are managed for implementing cleanup.
Resource Conservation and Recovery Act (RCRA): RCRA is the Resource Conservation and Recovery Act, which was enacted by Congress in 1976 and in the subsequent Hazardous and Solid Waste Amendments of 1984. RCRA's primary goals are to protect human health and the environment from the potential hazards of waste disposal, to conserve energy and natural resources, to reduce the amount of waste generated, and to ensure that wastes are managed in an environmentally sound manner. For a more in-depth overview of RCRA and its programs, see the RCRA Orientation Manual.
Short-term Controls: Short-term controls are put into place at a facility to prevent human exposures and to prevent further migration of contaminated groundwater.
Site Characterization: Before cleanup decisions can be made, some level of characterization is necessary to ascertain the nature and extent of contamination at a site and to gather information necessary to support selection and implementation of appropriate remedies. Tools to support good site characterization include conceptual site models, innovative site characterization technologies, tailored data quality objectives, and use of existing information to streamline each investigation.
Solid Waste Management Units: Any discernible unit at which solid wastes have been placed at any time, irrespective of whether the unit was intended for the management of solid or hazardous waste. Such units include any are at a facility at which solid wastes have been routinely and systematically released.
Source Control: Source control refers to a range of actions (e.g., removal, treatment in place, containment) designed to protect human health and the environment by eliminating or minimizing migration of or exposure to significant contamination.
Staging Pile: An accumulation of solid, non-flowing remediation waste that is not a containment building and that is used only during remedial operations for temporary storage at a facility. Staging piles must be designated by EPA according to the requirements of 40 CFR 264.554.
Temporary Unit: For temporary tanks and container storage areas used to treat or store hazardous remediation wastes during remedial activities required under § 264.101 or RCRA 3008(h), or at a permitted facility that is not subject to § 264.101, the Regional Administrator may designate a unit at the facility, as a temporary unit. A temporary unit must be located within the contiguous property under the control of the owner/operator where the wastes to be managed in the temporary unit originated. For temporary units, the Regional Administrator may replace the design, operating, or closure standard applicable to these units with alternative requirements which protect human health and the environment.