Correction Action Process
Figure 1: Corrective Action Process Chart
(PDF document, requires Adobe Acrobat Reader to view.)
The corrective action process generally comprises six activities. These activities are not always undertaken as a linear progression towards final facility cleanup, but can be implemented
flexibly to most effectively meet site-specific corrective action needs. These six activities are:
- RCRA Facility Assessment (RFA): Often the first activity in the corrective action process is the RFA. The objective of the RFA is to identify potential and actual releases from
SWMUs/AOCs and make preliminary determinations about releases, the need for corrective action, and interim measures.
- Interim/Stabilization Measures: Interim/stabilization measures are short-term actions taken to respond to immediate threats to human health or prevent damage or contaminant
migration to the environment. Interim or stabilization measures may be taken at any time in the corrective action process.
- Corrective Measures Study (CMS): After the RFI is completed and the regulatory agency determines that cleanup is necessary, the regulatory agency may request the owner and
operator to conduct a CMS. The purpose of the CMS is to identify and evaluate cleanup alternatives, called corrective measures, for releases at the facility. The recommended measures are
reviewed by regulatory agency. The regulatory agency then selects the best remedy, given the site-specific considerations. When a remedy is selected, the facility's permit is modified to include
the remedy and is subject to public review and comment.
- Statement of Basis: This document describes the basis for remedy selection and provides the public with an opportunity to comment on the remedy. When selecting a remedy the
short- and long-term reliability and effectiveness; reduction of toxicity, mobility or volume of hazardous constituents; implementability; and costs are taken into consideration. In addition,
proposed remedies must satisfy the following criteria:
- Be protective of human health and the environment;
- Control the sources of releases thereby reducing or eliminating, to the maximum extent practicable, further releases posing a threat to public health and the environment;
- Attain media clean-up standards; and
- Comply with applicable waste management standards.
Corrective Measures Implementation (CMI): Once a remedy has been selected, the facility enters the CMI phase of corrective action. During the CMI, the owner and operator of the facility implement
the chosen remedy.
