What are some common reasons owners or operators of RCRA facilities start corrective action?
EPA or an authorized state issues a permit containing corrective action requirements (as well as schedule for implementing those requirements) for investigating and, if necessary, cleaning up contamination at or from a RCRA-regulated facility. EPA issues an administrative order to address various circumstances, such as where EPA or an authorized state has not yet issued a permit, there are potential imminent and substantial risks, or investigations are needed. A State issues an order under their own cleanup or brownfields redevelopment authorities. EPA and states are working to ensure that cleanups conducted under these alternative state authorities satisfy RCRA obligations. A facility owner/operator voluntarily performs corrective action by either conducting investigations and cleanups in advance of regulatory oversight, or by entering into a “voluntary agreement” with EPA or a State cleanup program.
