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Corrective Action 101: Text Version

Module 1

Introduction

Scene note: Two narrators are standing on either side of a map that shows a hazardous waste cleanup site adjacent to a residential neighborhood. The map is divided down the middle. The left side of the map includes a manufacturing facility, a storage building, a monitoring well, an office building, and a tractor. There is also a treatment pond and sludge pile that are seeping contamination into the groundwater, which in turn feeds into a river flowing from the direction of the ABC facility into the residential neighborhood. The residential area includes three homes, several trees, and a child’s slide. The left side of the map shows cleanup activity and the right side shows community activity.

Reader note: If a word or term is linked, more information is provided after the narrator’s statement.

Narrator 1:
Sure looks like a lot of activity. What are all those people working on?

Narrator 2:
They’re working to clean up that facility under the RCRA Corrective Action Program.

Narrator 1:
What’s the RCRA Corrective Action Program?

Scene note: Added to the top of the map: “Protect Human Health and Environment”.

Narrator 2:
Under the RCRA Corrective Action Program, owners or operators of facilities who are subject to cleanup under the RCRA statute must evaluate releases of hazardous wastes and hazardous constituents, and implement cleanup actions to protect human health and the environment.

Links from this narrator statement:
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.

RCRA Orientation Manual (off-site link)

Facilities: “Facility” means:
(1) All contiguous land and structures, or 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).
(2) For the purpose of implementing corrective action under §264.101, all contiguous property under the control of the owner or operator seeking a permit under subtitle C of RCRA. This definition also applies to facilities implementing corrective action under RCRA Section 3008(h).
(3) Notwithstanding paragraph (2) of this definition, a remediation waste management site is not a facility that is subject to 40 CFR 264.101, but is subject to corrective action requirements if the site is located within such a facility.

Releases: The term “release” means any spilling, leaking, pumping, pouring, emitting, emptying, discharging, injecting, escaping, leaching, dumping, or disposing into the environment. It includes abandoned or discarded barrels, containers, and other closed receptacles containing hazardous waste or constituents.

Hazardous waste and hazardous constituents: Corrective action applies to releases of “hazardous waste and 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.

Narrator 1:
What are they going to do first?

Narrator 2:
In the short term, they are going to make sure that people aren’t being exposed to unacceptable levels of contamination. Also, if there is contaminated groundwater under the facility, they will make sure it is not spreading. The U.S. Environmental Protection Agency calls these two short-term goals the “Current Human Exposures Under Control” and “Migration of Contaminated Groundwater Under Control” environmental indicators. 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 and migration of contaminated groundwater to be under control at 70% of these facilities.

Links from this narrator statement:

RCRA Cleanup Baseline: EPA developed the RCRA Cleanup Baseline in conjunction with the States as a result of a mandate in the Government Performance and Results Act (GPRA) requiring EPA to measure and track program progress toward achieving clearly defined results. There are 1,714 facilities on the RCRA Cleanup Baseline.

Narrator 1:
I understand about protecting people, but why worry about groundwater?

Narrator 2:
We worry about groundwater because over half of our nation relies on groundwater for drinking water. (See public-supply groundwater map.) In most rural areas, all drinking water comes from groundwater sources. Groundwater also supports many billions of dollars worth of food production and industrial activities. So, clean groundwater is vital to our Nation’s health and economy.

Links from this narrator statement:
Public-supply groundwater map: This map of the United States illustrates how much groundwater is withdrawn in each state per day:
0 – 200 million gallons withdrawn per day: ME, NH, MA, RI, CT, VT, DE, MD, VA, WV, NC, KY, SC, AR, OK, KS, SD, ND, MT, WY, CO, NV, ID, OR, AK, HI, PR.
200 – 500 million gallons withdrawn per day: PA, NJ, OH, IN, MI, IL, WI, MN, IA, MO, TN, MS, AL, GA, LA, UT, AZ, NM, NE.
500 – 1,000 million gallons withdrawn per day: NY, WA.
1,000 – 2,000 million gallons withdrawn per day: FL, TX.
2,000 – 5,700 million gallons withdrawn per day: CA.

Narrator 1:
If clean groundwater is so important, why are they only focused on stopping the spread of contamination?

Narrator 2:
Well, once it has become polluted, groundwater is pretty difficult to clean up – so the first step is to stop the spread of contamination to keep clean groundwater from becoming contaminated. (See illustrations.) Note that the goal is to stop continued migration.

Links from this narrator statement:
Illustrations: Contaminant Migration in Groundwater
NAPLs are liquid contaminants that do not readily dissolve in water. NAPLs that are lighter (less dense) than water, like gasoline, are known as light non-aqueous phase liquids (LNAPLs). Dense NAPLs, such as the common solvent trichloroethylene, are more dense than water, and so are likely to sink in groundwater. NAPLs in the subsurface can cause long-term groundwater contamination, can be difficult to locate and, in many circumstances, may be technically impracticable to remove.

Release of Non-Aqueous Phase Liquids (NAPL) Contamination: This illustration uses arrows to show how the NAPL released from an industry site travels down into the ground. The residual DNAPL sinks through the groundwater to a fractured bedrock, and results in a plume of dense NAPL that moves back up through the ground to reach ground water.

Release of Dissolved Phase Contamination From Waste Water Through a Lagoon: This illustration shows how contaminated waste that is released through a wastewater treatment lagoon can filter down into the ground and pass through the groundwater.

Narrator 1:
I thought corrective action was a cleanup program. Shouldn’t they start by conducting extensive investigations and then cleanup?

Narrator 2:
The Corrective Action Program IS a cleanup program and they are working on investigations, but at the same time they’re taking steps to achieve some near-term goals to protect people and prevent the spread of contamination.

Narrator 1:
I am beginning to understand the short-term goals, but what are the long-term goals?

Scene note: Added to the top of the narrator’s map: “Achieve final cleanups that protect human health and the environment.”

Narrator 2:
In the long term, the goal is to achieve final cleanups that protect human health and the environment, attain media cleanup objectives, and control the sources of releases.

Links from this narrator statement:
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.

Media cleanup objectives: The concept of media cleanup objectives includes three components: cleanup levels, the point of compliance, and cleanup time frames.

Control the sources of releases: “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.

A source of releases is source material that includes or contains hazardous substances, pollutants, or contaminants that act as a reservoir (either stationary or mobile) for migration of contamination to groundwater, surface water, air, or other environmental media, or acts as a source for direct exposure.

Narrator 1:
It looks like a lot of people working on that facility. Does it really take all those people to meet corrective action goals?

Narrator 2:
It does take a lot of people working together to clean up a facility undergoing corrective action. Let’s meet some of them up close.

Scene note: Before the start of Module 2, you are asked to answer four questions that will assess your understanding about the important points in Module 1.

Short Quiz:
1. What are the main goals of the Corrective Action Program?
A. Issue permits.
B. Achieve final remedies that protect human heath and the environment.
C. Complete site investigations.
D. Achieve the environmental indicators by bringing human exposures under control and migration of contaminated groundwater under control.
E. Answers B and D.

Answer: E
YES, YOU GOT IT! The program goals are, in the short term, to achieve environmental indicators and, in the long term, to achieve final remedies that protect human health and the environment. And remember, there is no standard process used to reach these goals. Lead regulators should be flexible and tailor corrective action activities to site-specific circumstances.

2. True or false: the Corrective Action Program is a cleanup program?
A. True.
B. False.

Answer: True
YES, YOU GOT IT! The main goal of the Corrective Action Program is to achieve final remedies that protect human health and the environment. The Hazardous and Solid Waste Amendments (HSWA) of 1984 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. EPA refers to this cleanup of TSD facilities under these statutory authorities as RCRA Corrective Action.

3. Source control refers to:
A. Achieving environmental indicators.
B. Shutting down facilities that have leaked contaminants into the environment.
C. Removal, treatment, or containment of contamination that may migrate to groundwater, surface water, air, or other media.
D. Implementation of the final remedy at a RCRA Corrective Action site.
E. Both A and D.

Answer: C
YES, YOU GOT IT! Source control refers to removal, treatment, or containment of contamination that may migrate to groundwater, surface water, air, or other media. It is often an interim measure in reaching environmental indicators or achieving final remedies.

4. The RCRA Cleanup Baseline is:
A. The border of an area beyond which migration of contaminants is not permitted.
B. The level to which contaminated media must be restored in order to be called clean.
C. An arbitrary indication of progress.
D. 1,714 facilities where environmental indicators will be monitored to assess the success of RCRA Corrective Action.
E. States that have been authorized to issue permits containing corrective action requirements.

Answer: D
YES, YOU GOT IT! The RCRA Cleanup Baseline refers to the 1,714 facilities where environmental indicators will be monitored to assess the success of RCRA Corrective Action.

You have completed this quiz. Now let’s continue with the training.

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Module 2

Roles

Scene note: Six people are seated at a conference table. Each person at the table has a role in the corrective action program at the ABC facility. There is a whiteboard behind the table that asks: “Who is involved with corrective action?” Each person at the table will stand as they identify themselves and explain their role in the corrective action process. The facilitator now stands to introduce himself.

Reader note: If a word or term is linked, more information is provided after the speaker’s statement.

Facilitator:
Hi, we’re here today to talk about the cleanup at ABC facility. Let’s all introduce ourselves and talk about our roles and responsibilities.

EPA Headquarters person:
I’m Mike from EPA HQ, we’re out in the Region on an annual planning visit and they invited me to this meeting so I could get more of a sense for how things work in the field. My job is to work with the Regions, states, and the public to develop and monitor progress toward program goals, and to write corrective action regulations, policies, and guidance documents.

Lead regulator and state person:
Hi, I’m Susan from the State Department of Environmental Quality. I’m the lead regulator for ABC facility. I took over as the lead regulator from Mark earlier this year because the state is getting ready to submit our application for corrective action authorization. As the lead regulator, I’m responsible for reviewing and approving the site-specific work plans and other documents that the facility puts together, overseeing their implementation of corrective action in the field, and making decisions about corrective action issues. For example, right now we’re working with the facility to gather the information necessary to determine whether or not they have met the environmental indicators. I’m also responsible for making sure that there are meaningful opportunities for the public to be involved in corrective action decisions. Finally, when I’m not working as the lead regulator, I’m working on developing the state corrective action regulations and policies for our upcoming authorization.

Link from this speaker’s statement:
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.

EPA Regional Office person:
Hi, I’m Mark from the Regional Office. Susan and I have worked together on corrective action for a long time; before she became lead regulator for ABC facility, I was the lead regulator. I drafted the permit conditions that are governing corrective action at the facility. Now I support Susan in her role as lead regulator by offering technical assistance. I’m also working on overseeing Corrective Action Program implementation in the neighboring state and I’m serving on an EPA-HQ workgroup developing national corrective action policies and guidance.

Facility person:
Hi, I’m Emily from ABC facility. I’m responsible for carrying out corrective action at the facility. Right now, we are working to achieve the two environmental indicators —controlling human exposure and migration of contaminated groundwater. We plan to fill out the environmental indicator forms later this summer. Then we’ll recommend that Susan determine we have met them. Besides overseeing the day-to-day cleanup work at the facility, I’m also the liaison with the community. We meet with them about every quarter to get their input on the cleanup.

Community person:
Hi, I’m Teresa from the community action group. The public was involved in the cleanup at the ABC facility back when the permit was issued, a few years ago. Since then we’ve continued to monitor cleanup progress and to review and comment on important decisions. We also help ABC Company distribute information about the site to the entire community, not just people who are part of our action group. We’re excited about the upcoming environmental indicator decision and we’re even more interested in the decision about a final remedy, which we understand will be made in a year or so, after additional soil and groundwater data has been collected and analyzed.

Link from this speaker’s statement:
Public participation: Public participation provides people in the community with an opportunity to be involved in the corrective action process decisions that are made throughout the cleanup.

Facilitator:
Great! Thanks Teresa and everyone. We all should remember that even though Teresa is here from the community action group, it’s important for all of us to make sure the entire community has meaningful opportunities to participate in cleanup decisions. Now let’s review the main messages to keep in mind when thinking about roles and responsibilities during corrective action.

Scene note: A message board provides three important points to remember.

Main Messages:
States will be the primary implementers of the Corrective Action Program. States and regions should partner to share resources and lead regulators roles efficiently.

Facility owners/operators can and often should take on the responsibility of making recommendations about corrective action decisions.

Provide meaningful opportunities for the public to participate in corrective action decisions throughout cleanups.

Scene note: Before the start of Module 3, you are asked to answer three questions that will assess your understanding about the important points in Module 2.

Short Quiz:
1. The lead regulator for a corrective action facility can be:
A. An EPA Regional Office staff person.
B. A staff person from a corrective action authorized state.
C. A staff person from a state that is not authorized for corrective action.
D. A facility owner or operator.
E. Only A and B.
F. Only A, B, and C.

Answer F
YES! This is the most appropriate response. States will be the primary implementers of the RCRA Corrective Action Program. States and regions should partner to share resources and lead regulator responsibilities. While facility owners and operators are not considered “lead regulators” for corrective action sites since they don’t work for federal or state governments, they very typically only provide input that the state or EPA lead regulator uses to make investigation and cleanup decisions.

2. The only people who can fill out environmental indicator forms are:
A. The lead regulator.
B. EPA staff.
C. Facility owners or operators.
D. All of the above.
E. Only A and B.

Answer: D
YES, YOU’VE GOT IT! Staff from EPA or a state agency, as well as a representative from the facility, can fill out an environmental indicator form. However, remember that the facility makes recommendations and the lead regulator (state or EPA staff) makes the final decisions with respect to whether or not the facility has achieved one or both of the environmental indicators.

3. The public should be involved with corrective action:
A. Only at the beginning of corrective action.
B. Only when remedies are selected.
C. When cleanup is complete.
D. Throughout the cleanup.

Answer: D
YES! Citizens are our partners in implementing the Corrective Action Program; people living or working near corrective action facilities are the people who are most affected by lead regulator’s decisions. Remember the main message: provide meaningful opportunities for the public to participate in corrective action decisions throughout the cleanup.

You have completed this quiz. Now let’s continue with the training.

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Module 3

Timeline

Scene note: The two narrators are standing by the original map that is divided down the middle. The left side shows that cleanup activity continues at the ABC facility. A bulldozer is digging on the property; the treatment pond and sludge pile continue to seep contamination into the groundwater that feeds the river flowing from the direction of the ABC facility toward the community. A man is jogging and a young girl is skipping rope in the residential area.

Reader note: If a word or term is linked, more information is provided after the statement.

Narrator 1:
I’m the lead regulator for some corrective action facilities. If I’m going to have to make decisions about whether or not the Corrective Action Program goals are achieved, I guess I should know a little more about them. How were the goals developed?

Narrator 2:
The goals have been developed by EPA and its partners in state environmental programs as the Corrective Action Program has evolved since 1984. Let’s look at some of the major program milestones that contributed to the development of the program goals.

Scene note:
A vertical timeline titled “Corrective Action Milestones” lists several dates by year. Each year is presented in order, beginning at the top of the timeline and begins with the earliest: 1976, 1980, 1982, 1984, 1990, 1991, 1994, 1996, 1998, 1999, 2000, 2001, and current. An arrow points at 1976 and will move down the timeline, pointing at each subsequent date after the information is presented. The information that is provided for each date appears on a chalkboard to the right of the timeline.

1976 — RCRA Enacted
In 1976, Congress enacted the Resource Conservation and Recovery Act, or “RCRA,” as an amendment to the Solid Waste Disposal Act of 1965. The goals of the RCRA program are to:
· Protect human health and the environment from the hazards posed by waste disposal.
· Conserve energy and natural resources through waste recycling and recovery.
· Reduce or eliminate the generation of solid and hazardous wastes.
· Ensure that wastes are managed in an environmentally safe manner.

1980 — Initial Hazardous Waste Listed and Identified
In 1980, EPA established the general framework for listing and identifying hazardous wastes. Treatment, storage, or disposal of hazardous waste trigger RCRA permitting requirements.

1982 — Corrective Action Required for Regulated Units
In 1982, EPA established requirements for safe treatment, storage and disposal of hazardous wastes. As part of these requirements, EPA required corrective action for releases of hazardous wastes and hazardous constituents from regulated units.

Link from this statement:
Hazardous wastes and hazardous constituents: Corrective action applies to releases of “hazardous waste and 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 constituent”. 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.

1984 — Hazardous and Solid Waste Amendments
In 1984, Congress enacted the Hazardous and Solid Waste Amendments (HSWA) to RCRA, requiring corrective action for all releases of hazardous waste and hazardous constituents from solid waste management units at facilities seeking RCRA permits. The requirements applied regardless of the time at which waste was placed in the units. Congress also directed EPA to specify schedules of compliance in permits that are issued prior to completion of corrective action. (See Statutory language.)

Links from this statement:
Solid waste management units: Any discernible units at which solid wastes have been placed at any time, irrespective of whether the unit was intended for the management of solid or hazardous wastes. Such units include any area at a facility at which solid wastes have been routinely and systematically released.

Statutory language: The HSWA amendments added three new corrective action authorities to RCRA.

  1. RCRA Section 3004(u): Standards promulgated under this section shall require, and a permit issued after the date of enactment of the Hazardous and Solid Waste Amendments of 1984 for the Administrator or a State shall require, corrective action for all releases of hazardous waste or constituents from any solid waste management unit at a treatment, storage or disposal facility seeking a permit under this subtitle regardless of the time at which waste was placed in such unit. Permits issued under section 3005 shall contain schedules of compliance for such corrective action (where such corrective action cannot be completed prior to issuance of the permit) and assurances of financial responsibility for completing such corrective action.
  2. RCRA Section 3004(v): As promptly as practicable after the date of enactment of the Hazardous and Solid Waste Amendments of 1984, the Administrator shall amend the standards under this section regarding corrective action required at a facility for the treatment, storage or disposal of hazardous waste listed or identified under section 3001 to require that corrective action be taken beyond the facility boundary where necessary to protect human health and the environment unless the owner or operator of the facility concerned demonstrates to the satisfaction of the Administrator that, despite the owner’s or operator’s best efforts, the owner or operator was unable to obtain the necessary permission to undertake such action.
  3. RCRA Section 3008(h)(1): Whenever on the basis of any information the Administrator determines that there is or has been a release of hazardous wastes into the environment for a facility authorized to operate under section 3005(e) of this subtitle, the Administrator may issue an order requiring corrective action or such other response measures as the Administrator deems necessary to protect human health or the environment or the Administrator may commence a civil action in the United States District Court in the district in which the facility is located for appropriate relief, including a temporary or permanent injunction.

1990 — RCRA Implementation Study and Corrective Action Subpart S Proposal

The RCRA Implementation Study, published in 1990, included key recommendations for corrective action, emphasizing the need to prioritize resources and activities, and accelerating progress.

In 1990, EPA proposed implementing regulations for the Corrective Action Program. Known as Subpart S, the proposal established the risk-based remedial goals that corrective action cleanups must achieve. It also established a flexible framework of cleanup activities that could be used to achieve remedial goals. The Subpart S proposal was used as the primary guidance for implementing corrective action until it was replaced by the corrective action Advance Notice of Proposed Rulemaking in 1996.

1991 — National Corrective Action Prioritization System and Stabilization Initiative

In 1991, EPA established a system to prioritize corrective action sites based on risk and to focus resources on cleaning up the worst sites first.

Also in 1991, the Stabilization Initiative encouraged a flexible approach to corrective action. As situations warrant, program managers should look to near-term activities to control or reduce threats to human health and the environment, and prevent or minimize the further spread of contamination.

1994 — Established Two Corrective Action Environmental Indicators

In 1994, in response to concerns that the Corrective Action Program was too focused on process, EPA established two environmental indicators (control human exposures and control migration of contaminated groundwater). The indicators help focus program implementers away from process steps toward achievement of critical near-term environmental results at facilities.

1994 — RCRA Corrective Action Plan

Also in 1994, EPA published the RCRA Corrective Action Plan or CAP. The CAP establishes a menu of specific cleanup activities from which program implementers can choose to develop site-specific cleanup work plans.

1996 — Corrective Action Advance Notice of Proposed Rulemaking (ANPR)

In 1996, EPA issued the current main operating guidance for the Corrective Action Program — the corrective action Advance Notice of Proposed Rulemaking, or ANPR. The ANPR emphasizes the need to use flexible, inclusive approaches to achieve the goals of the Corrective Action Program.

1996 — RCRA Public Participation Manual

Also in 1996, EPA issued the RCRA Public Participation Manual. This user’s manual explains how public participation works during RCRA corrective action. It also establishes EPA’s expectation that citizens will have meaningful opportunities to participate in corrective action decisions throughout corrective action cleanups. Finally, it describes cooperative techniques that regulators, citizens, and the regulated community can use to make public participation more effective.

1996 — RCRA/CERCLA Parity Policy

Finally in 1996, EPA issued guidance on “Coordination between RCRA Corrective Action and Closure and CERCLA Site Activities” to discuss acceptance of decisions made by other remedial programs, deferral of activities to other programs, and coordination between cleanup programs at the Federal and the State level. This policy established the general principle that RCRA and CERCLA cleanup will achieve similar environmental results and that, therefore, cleanups under one program will be acceptable to the other program.

1998 — Management of Remediation Waste Under RCRA

The 1998 Remediation Waste guidance consolidates existing statutes, regulations, policies, and guidance that can be used to tailor application of RCRA hazardous waste requirements for hazardous remediation wastes. Examples of the eighteen approaches covered include: the area of contamination policy, permit waivers, contained-in policy, and land disposal restriction treatment variances.

1998 — Post-Closure Regulations

The Post-Closure regulations provide flexibility to EPA and authorized states by removing the requirement to obtain a permit for the post-closure period. They also allow EPA or authorized states to use other available authorities to address post-closure need under certain circumstances, thus removing impediments that have been encountered when one unit is subject to post-closure and other units are subject to corrective action.

1998 — Risk-Based Clean Closure Guidance

The Risk-Based Clean Closure Guidance provides guidance on risk-based clean closure and confirms that RCRA regulated units may be clean closed to protective, risk-based media cleanup levels.

Link from this statement:
Regulated units: “Regulated Units” are defined in 40 CFR 264.90 as surface impoundments, waste piles, land treatment units, and landfills that received hazardous waste after July 26, 1982.

1999 — Interim Final Guidance on Environmental Indicators

In 1999, EPA issued new guidance on the corrective action environmental indicators. The indicators “Current Human Exposures Under Control” and “Migration of Contaminated Groundwater Under Control” are the primary near-term goals of the Corrective Action Program. Meeting the environmental indicators at the 1,714 RCRA Cleanup Baseline facilities that warrant near-term attention is one of EPA’s highest priorities. The 1999 environmental indicator guidance establishes a series of questions and answers that program implementers use to assess site conditions and document site status.

1999 — Cleanup Reforms Round 1

Also in 1999, EPA launched a series of administrative reforms to further progress toward achieving the corrective action environmental indicators. Like the 1996 ANPR, the reforms encouraged program implementers to focus on cleanup results rather than cleanup processes, foster maximum use of program flexibility and practical approaches to achieving cleanup results, and enhance community involvement.

1999 — Withdrawal of the Subpart S Proposal

In 1999, EPA formally withdrew the majority of the 1990 Subpart S corrective action proposal. This withdrawal formalized EPA’s belief that detailed regulations are not necessary to implement corrective action requirements and could unnecessarily disrupt authorized state Corrective Action Programs. Withdrawal of the Subpart S proposal made it clear that the 1996 ANPR should be considered the primary implementation guidance for corrective action.

1999/2000 — National Results-Based Corrective Action Workshop Series

In 1999 and 2000 EPA conducted training in ten regional cities and in Washington, DC, at the RCRA National Meeting. The Results-Based Corrective Action Workshop was open to project managers from states and EPA Regions, and to representatives of the regulated, consulting and environmental communities, and the public. It reinforced the messages in the 1996 ANPR and in the corrective action reforms by providing attendees with specific tools and techniques to focus on cleanup results, use program flexibility, meet environmental indicators, and work together with all parties affected by a site to develop site-specific remedial approaches.

Link from this statement:
The Results-Based Corrective Action Workshop

2000 — Cleanup Reforms Round II

In 2000, EPA announced a second set of RCRA Corrective Action Program reforms. The first set of reforms was issued in 1999. Building on the reforms from 1999, the 2000 reforms are focused on piloting innovative approaches to cleanup, accelerating changes in the culture of the Corrective Action Program, connecting communities to cleanups, and capitalizing on redevelopment potential.

Link from this statement:
1999: In 1999, EPA launched a series of administrative reforms to further progress toward achieving the corrective action environmental indicators. Like the 1996 ANPR, the reforms encouraged program implementers to focus on cleanup results rather than cleanup processes, foster maximum use of program flexibility and practical approaches to achieving cleanup results, and enhance community involvement.

2001 — Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action

In 2001, EPA issued the Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action to clarify key groundwater related policies and to promote technically sound, reasonable, and consistent approaches to protecting and cleaning up groundwater. EPA also issued this Handbook to promote continued dialogues on groundwater issues so that groundwater protection and groundwater cleanups will continue to improve.

Current Activities:

EPA continues to develop policies, guidance, and other materials intended to improve program implementation and speed realization of program goals. More information on EPA’s latest activities and links to the guidance documents listed on the timeline can be found at the following off-site link.

Scene note: A message board provides five important points to remember.

Main Messages

The purpose of corrective action is to take actions to reduce risks — not to fulfill a standardized process.

Use the most appropriate tool — a Federal cleanup program or a state cleanup
program — to achieve cleanup goals.

Implementation is flexible and should be tailored to facility-specific circumstances.

Use interim actions and stabilization measures to reduce risk in advance of final remedies.

Provide meaningful opportunities for the public to participate in corrective action decisions throughout cleanups.

Scene note: Before completing Module 3, you are asked to answer three questions that will assess your understanding about the important ideas that have been discussed.

Short quiz:
1. What is the main implementing guidance for the Corrective Action Program?
A. The 1990 Subpart S Proposal.
B. The 1999 interim final guidance on environmental indicators.
C. The 1996 advance notice of proposed rulemaking.
D. The RCRA cleanup reforms.

Answer: C
YES! This is the appropriate response. And remember the main message from the ANPR: implementation should be flexible and tailored to facility-specific circumstances.

2. What types of cleanup authorities can be used to achieve the Corrective Action Program’s cleanup goals?
A. Federal RCRA enforcement orders.
B. RCRA permits.
C. State hazardous waste program orders.
D. State cleanup programs.
E. The Superfund program.
F. All of the above.
G. Only A, B, and C.

Answer: F
YES! This is the most appropriate response. This is one of the main messages from the 1996 ANPR and the RCRA / CERCLA Parity Policy: use the most appropriate tool — a Federal cleanup program or a state cleanup program — to achieve cleanup goals.

3. True or False: All the risk reduction in a corrective action cleanup occurs as part of a final remedy.
A. True
B. False

Answer: B
YOU GOT IT! Remember, meeting the Corrective Action Program’s two short-term goals of controlling human exposure and controlling migration of contaminated groundwater are also important steps toward reducing risk at corrective action facilities.

You have completed this quiz. Now let’s continue with module 3.

Scene note: The two narrators are standing on either side of the original map. Cleanup activities continue on the left side of the map where the ABC facility is located. Community activity continues on the right side of the map where the neighborhood is located.

Narrator 1:
That is a lot of stuff to remember. How do I know what’s really important?

Narrator 2:
What’s really important is meeting the goals of the Corrective Action Program: getting human exposures and migration of contaminated groundwater under control and choosing and implementing successful final remedies.

Narrator 1:
If the goals are the important thing, why do we have all this other stuff?

Narrator 2:
Everything we’ve talked about is just tools to help you meet the cleanup goals. To further emphasize the cleanup goals, EPA has recently instituted a series of reforms to the Corrective Action Program. These reforms encourage lead regulators and facility owners/operators to use program flexibility and partnerships to meet goals. The program implementation philosophy we’ve identified as part of this training is part of the corrective action reforms.

Link from this narrator statement:
Reforms to the Corrective Action Program (off-site link)

Narrator 1:
Program implementation philosophy?

Narrator 2:
You know! The main messages that have been listed on the white boards during the training and covered during the quizzes.

Scene note: A whiteboard lists the main messages from this module.

Main Messages

The purpose of the Corrective Action Program is not to fulfill a standardized process — it is to take actions to reduce risks.

States will be the primary implementers of the Corrective Action Program — states and Regions should partner to share resources efficiently.

Use the most appropriate tools — a Federal cleanup program or a state cleanup
program — to achieve cleanup goals.

Implementation is flexible and tailored to facility-specific circumstances.

Use interim actions and stabilization measures to reduce risks in advance of final remedies.

Facility owners/operators should take responsibility for making recommendations about corrective action decisions.

Provide meaningful opportunities for the public to participate in corrective action decisions throughout cleanup.

Scene note: Before the start of Module 4, you are asked to answer three questions that will assess your understanding about the important ideas in Module 3.

Short quiz:
1. True or false: The main responsibility of a lead regulator is to ensure that all the corrective action reference guidance is carefully followed?
A. True.
B. False.

Answer: B
YOU’VE GOT IT! The main responsibility of a lead regulator is to ensure that corrective action goals are achieved and to make decisions about how to achieve the corrective action goals. The guidance and references are meant to help lead regulators make these decisions.

2. What are the main goals of the Corrective Action Program?
A. Issue permits.
B. Achieve final remedies that protect human health and the environment.
C. Complete site investigations.
D. Achieve the environmental indicators by bringing human exposures under control and migration of contaminated groundwater under control.
E. Answers B and D.

Answer: E
You’ve got it! The program goals are, in the short term, to achieve environmental indicators and, in the long term, to achieve final remedies that protect human health and the environment. And remember, there is no standard process used to reach these goals. Lead regulators should be flexible and tailor corrective action activities to site-specific circumstances.

3. True or false: All waste managed during corrective actions must be managed as hazardous waste.
A. True
B. False

Answer: B
You’ve got it! And, for remediation wastes that are hazardous, EPA has created a number of opportunities (such as Corrective Action Management Units) to tailor RCRA requirements to the circumstances of remediation. Remember the main message: use program flexibility to manage remediation waste safely and efficiently.

You have completed this quiz. Now let’s continue to the next training module.

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Module 4

Corrective Action Activities

Scene note: The narrators are standing on either side of the map that shows the ABC facility and the residential area. The map is divided down the middle. The left side of the map shows the ABC manufacturing facility, storage building, monitoring well, office building, tractor, and treatment pond. The sludge pile is also present, but is now covered. There is no longer any seepage occurring from the treatment pond or sludge pile. The cleanup activity has stopped. Instead, a large sign at the ABC facility states “Digging Restricted.” Community activity continues on the right side of the map.

Reader note: If a word or term is linked, more information is provided after the statement.

Narrator 1:
Hey, the facility looks different. What’s changed?

Narrator 2:
The facility looks different because short-term controls have been put in place to prevent human exposures and to prevent further migration of contaminated groundwater. See, there are restrictions on digging in the contaminated soil where the load/unload area used to be. Also, the sludge pile has been fenced and covered, and the facility has installed a subsurface wall and a groundwater extraction/monitoring well network to bring migration of contaminated groundwater under control.

Narrator 1:
I guess that’s good, but there’s still a lot of contamination at the facility. What about that?

Narrator 2:
That’s why achieving the environmental indicators is only the short-term goal of the Corrective Action Program. It’s a major milestone, but a lot of work remains to put a final remedy in place for the facility.

Narrator 1:
I don’t completely understand all this talk about goals. If I’m the lead regulator for a facility, how do I get the information I need to make decisions about cleanup goals? And what about the cleanup process? You know, site characterization and evaluation of remedial alternatives. When do I work on those?

Narrator 2:
You will use activities like investigations and feasibility studies (if needed) to make cleanup decisions. So remember the purpose of corrective action is to take actions to reduce risks to human health and the environment — not to fulfill a standard process. Let’s look at some of the common elements that occur to gather information to make decisions about cleanup goals.

Scene note: Narrator 2 is standing on the right side of a table that is located in front of a chalkboard. On the table is a pyramid that is divided, starting at the top, into the following four sections: Sufficient understanding of site conditions (at the top), Actions to achieve results (middle left), Information collection when necessary (middle right), and Achieve results (covering the bottom).

Narrator 2:
EPA has emphasized that program implementers should use a flexible, facility-specific approach to implement corrective action. This is because few corrective action facilities are alike and no one process is likely to work effectively at each site. EPA also wants implementers to be creative and only do work that is needed to make decisions and ultimately to reduce risks to human health and the environment. At the same time, EPA has identified the common elements of gathering information, making decisions, and taking actions to achieve environmental results. These common elements occur to some degree during most corrective action projects.

Scene note: The pyramid changes color to draw the learner’s attention.

Narrator 2:
This pyramid illustrates an understandable way to see the common elements of gathering information, making decisions, and taking actions. One of the jobs of the lead regulator is to get the information you need to make decisions about correction action goals. Remember, there is no standard approach or set of steps — every site will be different. You will design a corrective action approach to efficiently meet cleanup goals. Let’s look in more detail at those common elements of most cleanups.

Link from the scene note: Achieve results

  1. Environmental indicators:
    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 and migration of contaminated groundwater to be under control at 70% of these facilities.
  2. 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.

Narrator 2:
Every corrective action approach should be focused on achieving results and there is no single approach that will work for every facility. For the Corrective Action Program, in the short-term the result we are targeting is to achieve the environmental indicators. Over the long-term, it is to achieve final remedies that protect human health and the environment. Click on each of the activities for more information.

Link from the scene note: Sufficient understanding of site conditions.

  1. Understand site conditions:
    The decision to be made will define the type (and degree) of understanding of site conditions you should have to support your decision-making. Remember, sometimes existing information will provide you with all you need to decide how to move forward. In other situations you will need to collect information to increase your understanding of site conditions.
  2. Make decisions:
    As a project manager your main responsibility is to make decisions about how to move forward to achieve corrective action goals.

Narrator 2:
Knowing what results you want to achieve, you will likely begin by working to understand the current site conditions and decisions that should be made in order to achieve results. Sometimes, existing information will provide you with the information you need to decide how to move forward. Other times, you will need to use tools like a conceptual site model to organize and understand the large amount of data that you have.

Link from narrator statement:
Conceptual site model: A conceptual site model is a three-dimensional picture of site conditions that conveys 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.

Narrator 2:
Existing information or site conditions may not be adequate to make remedy decision. In this case, additional information collection is required. There are a number of activities that may be incorporated into this step.

Link from scene note: Information collection when necessary.

  1. 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 owner/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.
  2. Site characterization:
    Before cleanup decisions can be made, a site characterization is conducted to determine the nature and extent of contamination and to support selection 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. Data Quality Objectives (DQO) refer 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. Sometimes individual releases require characterization. At other times, less characterization is needed. For example, if many releases are from the same source, or if the technology that will be used addresses all the releases, then the investigation can be streamlined.

Narrator 2:
Here a remedy is selected and put in place. Depending on the conditions at the site, a number of activities may be undertaken in order to achieve results.

Link from scene note: Actions to achieve results.

  1. Conduct interim measures:
    EPA has increasingly emphasized the use of interim actions and site stabilization in the Corrective Action Program. Many cleanup programs recognize the need for interim actions while site characterization is underway or before a final remedy is selected. Typically, interim or the environment in advance of final remedy selection. For example, actual or potential contamination of drinking water supplies might necessitate an interim action to provide alternate drinking water sources.
  2. Evaluation of remedial alternatives:
    Before choosing a cleanup approach, those involved will typically analyze one or more alternatives and evaluate their advantages and disadvantages relative to site-specific conditions. This evaluation does not necessarily have to address all potential remedies for every facility. EPA advises program implementers to focus these studies on realistic remedies and to tailor the scope and substance of the studies to the extent, nature, and complexity of releases and contamination at any given facility.
  3. Implement, operate, and monitor the remedy:
    Once a remedy is chosen, it should be implemented in accordance with its terms and conditions. Operation and maintenance of a remedy typically will be required whenever wastes are left in place at levels that are other than unrestricted exposure assumptions.

Scene note: The parts of the pyramid separate — moving up from the table. An arrow moves through each part, beginning at the top and curving through the middle parts from right to left and then toward the bottom.

Narrator 2:
RCRA activities do not need to happen in a single, specific order. Sometimes, all of the activities in the pyramid are required. If there is insufficient information to make a remedy decision, additional information is collected and the data show that actions should be taken to achieve results.

Scene note: The right, middle part of the pyramid shrinks away and the arrow moves from the top, through the remaining middle part, and then through the bottom.

Narrator 2:
If existing data are already adequate to support selection of an obvious remedy, further investigation is not needed. States, EPA, and facility owner/operators can work together to decide what data are required to make those flexible decisions.

Scene note: Both middle parts of the pyramid shrink away and the arrow moves from the top through the remaining part at the bottom.

Narrator 2:
At some facilities, a further evaluation of alternatives does not have to be submitted to an agency for review if adequate remedial goals have been developed. A review of existing data may show that the site has already achieved results.

Scene note: The four parts of the pyramid are rejoined on the table.

Narrator 2:
Remember the main messages. Be flexible, be creative, and look to get on with actual risk reduction activities, meeting environmental indicators, and selecting and implementing successful final remedies.

Scene note: Before you finish this module, you are asked to answer three questions that will assess your understanding about the important points in Module 4.

Short quiz:
1. True or false. Corrective action follows the same process at all facilities.
A. True
B. False

Answer: B
YES, YOU’VE GOT IT! One of the main goals of the CA Program is to reduce risks; not to fulfill a standardized process. Program implementation should be flexible and tailored to facility-specific circumstances.

2. Select the activities that must take place during a corrective action cleanup.
A. Site investigation, evaluation of remedial alternatives, and feasibility studies.
B. Site investigation.
C. Evaluation of remedial alternatives.
D. Feasibility studies.
E. It depends on site-specific conditions.

Answer: E
YES! YOU GOT IT! Although many corrective action facilities will require a formal investigation and evaluation of remedial alternatives, some facilities may already have information to support a sufficient understanding to make decisions about corrective action results. Remember the main message: conduct studies and activities if they help decide what reduction measures to take — but skip them if they are unnecessary.

3. True or false. All lead regulators need the same information to make a decision about remedy selection.
A. True
B. False

Answer: B
YES. YOU’VE GOT IT! The important thing for a lead regulator to have is a sufficient understanding to make a decision about remedy selection. The exact information needed to create that understanding will depend on site-specific circumstances.

You have completed this quiz. Now let’s continue with the training module.

Scene note: The two narrators are standing on either side of the original map. The map shows the changes made at the ABC facility. Community tennis courts and a recycling center have replaced the monitoring well, treatment pond, and sludge pile. There are two runners jogging along the river run jog path.

Narrator 1:
It looks like the facility is all cleaned up.

Narrator 2:
Yes, a final remedy is in place that required treatment and removal of waste and contaminated media to allow safe continued use of the facility. In this case, the land was suitable for community recycling and recreational uses.

Narrator 1:
I see. There is a lot of work to do to control human exposures and migration of contaminated groundwater and achieve final remedies.

Narrator 2:
Yes there is. There are 1,714 facilities on the RCRA Cleanup Baseline that warrant attention in the near term, and over 6,500 facilities that are subject to RCRA Corrective Action statutory authorities.

Link from this statement
6,500 facilities

Narrator 2:
But we have a clear vision of our goals and the main messages that we’ve looked at today form a set of guiding principles so I know we’ll make it.
Scene note: A message board provides nine important points to remember.

Main Messages

Narrator 1:
Okay. Let’s get started.

Scene note: The two narrators are standing on either side of a chalkboard that declares in large, bold letters: THE END.

Congratulations. You have successfully completed the Corrective Action 101 Training Module. Please take the time to provide feedback and let us know what you thought about this module, and give us additional feedback regarding the corrective action training in general.

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