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Accomplishment Description
What Does "Having Approved Controls in Place" Mean?
The following list contains situations that indicate accomplishment of the GPRA goal of having approved controls in place to prevent dangerous releases.
Permitted Units
- The unit is under a permit. (This is the option to get operating units under control.)
Post-Closure Units Without Permits, But Following Other Enforceable Documents
- The facility (including all units) has complied with the post-closure rule.
- The unit has properly closed with waste in place, as verified by the lead regulatory agency, and an approved post closure plan, or similar enforceable document (such as a consent order), covers appropriate post closure obligations including part 264 subpart F groundwater monitoring requirements. (This is similar to the part of the post-closure rule that deals with alternate authorities in lieu of permits.) or
- The unit is situated among solid waste management units, closure and any dangerous releases at the unit are covered by a corrective action order or a similar enforceable document. (This is similar to the part of the post-closure rule that addresses cleanup of commingled releases.)
- The unit is under an approved post-closure plan which contains standards consistent with §264 subpart F and G monitoring and cap maintenance.
Units Are Being Handled By a Cleanup Program
- The original source is removed (or controlled to standards of §264 subpart F and G groundwater monitoring and cap maintenance) and the cleanup of any residual contamination caused by the unit has been referred to either EPA or State cleanup authorities.
- Note: facilities that are also on the 2008 corrective action baseline should have at least met the corrective action environmental indicator (EI) for human health exposures. (Facilities referred to CERCLA are to be removed from the baseline.)
Units That Have No Waste to Pose a Threat
- The unit has achieved clean closure, as verified by the lead regulatory agency.
- The unit is proposed and has not yet been built (therefore there is no potential for release since the unit will have a permit issued before it is built and manages hazardous waste).
- The unit never managed hazardous waste and does not have permitting or closure obligations (they should not have been selected for baseline initially).
Case-by-Case Verification
- The EPA region makes a case-by-case determination that approved controls are in place that prevent dangerous releases to air, soil, and groundwater and sends in a verification (states can also make that determination if an arrangement is made with the region). This should apply only to non-operating facilities.
- Note: These verifications will be processed and added into RCRAInfo as accomplishments. If the RCRAInfo facility data can be updated by the implementer to show the accomplishment, they should not use this verification process. (amended 3-16-06)
Baseline Units Have to Be Under Control for the Facility to Be Under Control
- A hazardous waste facility in the GPRA Operating Permit Baseline Universe is considered to have met the GPRA goal when all units identified as part of this baseline have approved controls in place. Likewise, a hazardous waste facility on the GPRA Post-Closure Baseline Universe is considered to have met the GPRA goal when all units identified as part of this baseline universe have approved controls in place.
Criteria to Be in the GPRA Permitting Baseline
- The permitting baseline is based on the operating permit baseline plus the post-closure permit baseline. The baseline was updated in 2005. Facilities were added that started on the permit track since the baseline was set, superfund facilities were removed and other corrections were made. The GPRA Operating Permit Baseline includes only those hazardous waste facilities which had at least one unit that had or needed an operating permit as of 10/1/97. This baseline universe excludes units that needed an operating permit prior to 10/1/97, but the permits were subsequently terminated or expired and the unit(s) clean closed prior to 10/1/97 or were in the closure workload at that time, or did not need a permit prior to or on 10/1/97.
- The GPRA Post-Closure Baseline includes any hazardous waste facilities that had at least one land disposal unit that ceased operating before 10/1/97 and had not clean-closed or was not in the operating or closure workload.
