The Facility Lead program provides an opportunity for companies not currently under a permit or an order to initiate corrective action using a streamlined agreement to investigate and clean up a facility. After being invited into the program by EPA, the facility sends EPA a letter of commitment acknowledging the requirements of the facility agreement which includes, but is not limited to, a workplan, a site investigation schedule, a data quality assurance plan, time frames for achieving EPA's Environmental Indicators, a discussion of any proposed interim measures, a plan for public participation, and schedule for reporting. The major advantages in participating in this program include reduced administrative burden, scheduling flexibility, reduced costs and less emphasis on process. One disadvantage of participating in this program is that the Facility Lead Agreement will not survive a property transfer or bankruptcy. In some cases the current operator of the property is not responsible for the contamination and may want the responsible party under an enforceable document.
Some facilities prefer an enforceable document based on corporate policy.
The goals established in Facility Lead Agreement are the same as the goals in EPA s Orders and Permits. This program is not for facilities which already have a Permit or Order for Corrective Action. However, opportunities for streamlining the corrective action process are also available for facilities with Permits or Orders. No, but EPA may choose to issue a Permit or Order at any time. Yes, a facility may withdraw out of the program at any time.