RCRA Corrective Action Program

Corrective action is a requirement under the Resource Conservation and Recovery Act (RCRA) that facilities that treat, store or dispose of hazardous wastes investigate and clean up hazardous releases into soil, ground water, surface water and air. In 1984, Congress passed the Hazardous and Solid Waste Amendments, which granted EPA expanded authority to require corrective action at permitted and non-permitted treatment, storage and disposal facilities (TSDFs). The following specific sections of the RCRA statute that regulators use to require corrective action (or aspects of corrective action) include: §§3004(u)&(v), 3005(c)(3), 3008(h), 3013, and 7003. EPA’s regulatory provisions for corrective action at permitted facilities are found primarily in 40 CFR Part 264 Subpart F. EPA provides additional direction on corrective action through guidance, policy directives, and related regulations. The most recent and comprehensive guidance issued for RCRA corrective action is in Section III (pages 19440 – 19455) of the May 1, 1996 Advance Notice of Proposed Rulemaking (ANPR; EPA, 1996a; see also EPA, 1997a).

More recently, in 2024, EPA issued a memorandum with recommendations for EPA regions and RCRA authorized states about how to work with RCRA facility owners and operators to integrate climate change adaptation considerations into the RCRA corrective action process. 

Rather than creating a rigid regulatory framework for corrective action, EPA developed guidance and policy documents to assist facilities conducting cleanups. Some of the resources are broad in scope, while others are more process or media specific.

EPA’s Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action is designed to help regulators, members of the regulated community, and members of the public find and understand EPA policies on protecting and cleaning up groundwater at facilities subject to corrective action under subtitle C of RCRA. This Handbook contains EPA’s latest interpretation of policies on such topics as cleanup goals, the role of groundwater use, point of compliance, source control, and monitored natural attenuation. It ties 15 different topics together with an overall Groundwater Protection and Cleanup Strategy that emphasizes a phased, results-based appraoch to cleaning up contaminated groundwater.

The Handbook of Growndwater Protection provides guidance to EPA regional and State RCRA Corrective Action Program implementers, as well as to owners and operators of facilities subject to RCRA corrective action requirements, and to the general public. More specifically, this Handbook conveys how EPA generally expects to exercise its discretion in implementing RCRA statutory and regulatory provisions that concern RCRA corrective action. EPA designed this guidance to explain and clarify national policy on issues related to the protection and cleanup of groundwater at RCRA corrective action facilities. The statutory provisions and EPA regulations discussed in this Handbook contain legally binding requirements. This Handbook itself does not substitute for those provisions or regulations, nor is it regulation itself. Thus, this Handbook does not impose legally binding requirements on EPA, States, or the regulated community, and may not apply to a particular situation based upon the specific circumstances of the corrective action facility. EPA and State regulators retain their discretion to use approaches on a case-by-case basis that differ from this Handbook where appropriate. EPA and State regulators base their corrective action decisions on the statute and regulations as applied to the specific facts of the corrective action facility.

See EPA’s Resources on Public Participation in the Hazardous Waste Permitting and Corrective Action Processes webpage for resources regarding public participation in hazardous waste management issues. EPA is committed to involving the public in the development and implementation of solid and hazardous waste decisions. One of the Agency’s central goals is to provide equal access to information and an equal opportunity to participate. EPA regards public participation as an important activity that empowers communities to become involved in local Resource Conservation and Recovery Act (RCRA) related activities.

One area in which RCRA requires public participation is the hazardous waste permitting process. The public interaction occurs during pre-application meetings, public comment and response periods, and public hearings. RCRA includes specific provisions to involve the public in all stages of the hazardous waste treatment, storage and disposal facility (TSDF) permitting process: prior to the initial permit application; after draft permit issuance; and during permit modifications, permit renewals, post-closure permits, and trial burns.

Also see EPA’s RCRA Public Participation Tools and Resources webpage.

See EPA’s Corrective Action Process webpage for a description of the cleanup process, which focuses on results rather than specific steps, and is flexible, depending on site-specific conditions. A typical cleanup may include steps such as: initial site assessment, site characterization, interim actions, evaluation of remedial alternatives, and implementation of the selected remedy. Because no one approach is likely to be appropriate for all corrective action facilities, these five elements should not be viewed as prescribed steps in the corrective action process. Instead, they serve as evaluations necessary to make good cleanup decisions within a flexible program. The five elements are described in more detail at EPA’s Corrective Action Process webpage. Additional elements of corrective action to keep in mind are tracking progress and long-term care.

EPA’s Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action is designed to help regulators, members of the regulated community, and members of the public find and understand EPA policies on protecting and cleaning up groundwater at facilities subject to corrective action under subtitle C of RCRA. This Handbook contains EPA’s latest interpretation of policies on such topics as cleanup goals, the role of groundwater use, point of compliance, source control, and monitored natural attenuation. It ties 15 different topics together with an overall Groundwater Protection and Cleanup Strategy that emphasizes a phased, results-based appraoch to cleaning up contaminated groundwater. Training on this Handbook is available through CLU-IN. 

To learn more about RCRA facilities, see EPA’s Hazardous Waste Management Facilities and Units webpage and EPA’s RCRA Training Module about Treatment, Storage and Disposal Facilities.

Explore EPA’s Hazardous Waste Data for helpful articles and interactive maps on hazardous waste topics. An article of interest is: Hazardous Waste Generation on Federal and Tribal Lands: Looking at the types of owners of hazardous waste facilities on federal and tribal lands.

Faster Cleanup and Faster Reuse at PCB and RCRA Corrective Action Sites webinar was recorded in October 2018 and describes new cleanup tools and recent experiences under RCRA Corrective Action and TSCA PCB cleanups to expedite the investigation, cleanup, and reuse of contaminated properties. The panel will provide an introduction to RCRA FIRST and PCB FAST tools developed to remove roadblocks on the way to completion of corrective action and cleanups. Stories of this approach will be shared to demonstrate its success at several sites.

The following resources provide information on addressing RCRA sites with brownfields funding:

• How Communities Can Address RCRA Sites with Brownfields Funding Fact Sheet
• Brownfields and Land Revitalization Initiatives
• Guidance: Comfort/Status Letters for RCRA Brownfields Properties