The Hazardous and Solid Waste Amendments of 1984 revised RCRA to include new provisions requiring certain facilities to take corrective action to clean up their sites. EPA data show that as of the end of fiscal year 2010, about 6,000 facilities were subject to corrective action; that is, they were required to undertake corrective action in response to a release of hazardous waste or constituents. Facilities that may be required to undertake corrective action include, among others, operating or closed treatment, storage, or disposal facilities that are permitted or have interim status—during which the owner or operator of a treatment, storage, or disposal facility is considered to have been issued a RCRA permit even though a final determination on the permit has not yet been made by the regulator. Permitted and interim-status facilities generally incur an obligation for continued corrective action even after closure. Facilities generally come into the corrective action program when (1) EPA or an authorized state is considering a facility’s RCRA permit application, (2) a release of hazardous waste or constituent has been identified, or (3) a facility volunteers to perform corrective action by entering into an agreement with EPA or an authorized state. First, when a facility is seeking a permit or when a permit is already in place, EPA or an authorized state can incorporate corrective action into the permit’s requirements. EPA or the state may use this process to address both on- site releases and releases that have migrated beyond a facility’s boundary. Second, EPA or the state may issue a corrective action order that is not contingent on a facility’s permit status, for example, when immediate action is necessary to address a release or threat of release of a solid or hazardous waste that may present an imminent and substantial endangerment to human health or the environment, including at an interim-status facility. Third, facilities may volunteer to take corrective action before they are required to do so by the terms of the permit or corrective action order. There are no comprehensive cleanup regulations under RCRA. Instead, EPA and authorized states primarily use guidance to implement corrective action and impose requirements at individual facilities through their permits or orders. The agency emphasizes the flexible nature of the program, but several elements are common to most, although not all, corrective action cleanups: Initial facility assessment. EPA or an authorized state first assesses a facility to characterize the risk posed and determine the need for immediate action.  Facility investigation. If it is determined that information beyond initial facility assessment is needed, EPA or the authorized state requires the company owning or operating the facility to conduct a more detailed investigation to establish the nature and extent of contamination released to groundwater, surface water, air, and soil. Depending on a facility’s particular circumstances, this phase may be complex and take years to complete. The process is monitored by the agency overseeing the correction action, and the outcome is subject to that authority’s approval. While facility investigation is under way, interim measures may be needed to control or abate ongoing risks to human health and the environment. According to EPA, interim measures may take place any time during the corrective action process. In some cases, such actions may be enough to complete the corrective action process.  Remedy study and selection. If further corrective action is deemed necessary, facility owners and operators analyze a range of cleanup options. A company may complete a study of corrective measures describing the advantages, disadvantages, and costs of various options. The scope of the effort required for such a study depends on the risks posed at the facility: a study can be relatively restricted in scope if the risks and cleanup option are readily identifiable. EPA or the authorized state solicits public comments on the selected option and approves a final cleanup method.  Remedy construction and implementation. Facility owners and operators design and construct and, as necessary, operate, maintain, and monitor the selected remedy. EPA has undertaken a number of initiatives over the years to manage the corrective action program by making decisions on the basis of the level of the risk to public health and the environment and to improve the cleanup process. In 1991, EPA decided to focus its resources on facilities it ranked as high priority for corrective action because of the relatively high risk they posed. It also decided to first control or abate immediate threats to human health and the environment at these facilities, instead of diverting resources to push for final cleanup actions. In 1994, EPA established two environmental indicators: controlling exposures to humans and controlling the migration of contaminated groundwater. In 1998, EPA took steps to remove some barriers to cleanups, such as providing for more flexible treatment of contaminated soil that may temporarily accumulate during cleanups. In 1999 and 2001, EPA implemented a set of administrative reforms to promote faster and more flexible cleanup. These reforms called for new results-oriented cleanup guidance, promoting program flexibility through training and outreach, and enhancing community involvement. As part of its effort to focus and streamline the RCRA corrective action program, EPA has since 1997 set a series of progressively more ambitious performance goals and identified which facilities must meet them. The agency also issued guidance to expedite cleanup. Goals set by EPA for the corrective action program have encompassed progressively more facilities and longer time frames. In response to GPRA, the agency first set performance goals to be achieved by fiscal year 2005, which focused on high-risk facilities deemed to have potentially unacceptable levels of contaminants. EPA then began focusing on longer-term concerns by setting goals to be achieved by fiscal year 2008. EPA also began to establish a long-range vision for the program, which included a larger universe of facilities and goals for fiscal year 2020. In addition, the agency has also issued guidance to expedite cleanup. In 1997, in response to GPRA, EPA established its first set of performance goals for the corrective action program. The goals were to be achieved by the end of fiscal year 2005 and targeted 1,714 facilities at high risk of causing potentially unacceptable public exposure to pollutants, having high levels of groundwater contamination, or both. The performance goals to be met by fiscal 2005 were as follows: controlling human exposures to contaminants at 95 percent of these high-priority facilities and controlling the migration of contaminated groundwater at 70 percent of the 1,714 facilities. Importantly, these goals did not explicitly address final cleanup of sites but rather sought to control contamination at high-risk sites first. Previously, we and others reported that EPA had not established long- term goals for final cleanup. In our August 2000 report, we noted that focusing only on controlling contamination and not on implementing final cleanup actions could postpone cleanups well into the future, and we recommended that EPA establish long-term and annual goals delineating the number or portion of facilities that are to implement final cleanup actions. In response to our recommendation, EPA agreed that implementing final remedies was important but decided at the time to use its limited resources to focus on controlling contamination at the worst sites. EPA also stated that the corrective action program did not have the resources to focus concurrently on containing contamination and implementing final cleanup actions. EPA’s next set of performance goals, for 2008, began to address longer- term concerns. EPA continued the goals to control human exposures to contaminants and contain the spread of groundwater contamination, but it added two new goals. These two longer-term goals directed that a portion of high-priority facilities were to decide upon and construct a final cleanup remedy. EPA defined the completion of final remedy construction as the time when the physical components of a final corrective action remedy for a facility were in place and functioning correctly. EPA also increased the total number of high-priority facilities that must address the goals from 1,714 to 1,968. The performance goals to be met by fiscal year 2008 were as follows: controlling human exposures to contaminants at 95 percent of 1,968 high-priority facilities, controlling the migration of contaminated groundwater at 80 percent of these high-priority facilities, selecting final remedies at 30 percent of these facilities, and completing final remedy construction at 20 percent of these facilities. While directing attention to high-priority facilities, EPA was also working to establish what it considered a long-range vision for the corrective action program—that by the year 2020, cleanup of contamination at an expanded universe of RCRA facilities would be largely complete. In developing this vision, EPA issued a memorandum asking the regions and authorized states to include in this universe facilities that, as of October 1997, had RCRA permits for actively managing waste, as well as treatment and storage facilities that had been closed and had postclosure obligations. The regions and states had discretion to add facilities they agreed were important to address through the program. According to an EPA official, this group of facilities includes the majority of facilities ultimately expected to need corrective action, including those that had previously been considered as medium or low priority. Beginning in fiscal year 2009, EPA shifted its focus from the 1,968 high- priority facilities to tracking and reporting progress among the expanded universe of 3,747 facilities targeted in the 2020 goals. In September 2010, EPA issued new fiscal year 2015 performance goals for this expanded universe. These goals were as follows: controlling human exposures to contaminants at 84 percent of the 3,747 facilities, containing migration of contaminated groundwater at 78 percent of these facilities, and completing final remedy construction at 56 percent of these facilities. The agency also set long-range goals for 2020: controlling human exposures to contaminants at 95 percent of 3,747 facilities, controlling the migration of contaminated groundwater at 95 percent of these facilities, and completing final remedy construction at 95 percent of these facilities. Figure 1 depicts the goals set for the corrective action program for fiscal years 2005, 2008, 2015, and 2020. (App. III contains a map illustrating the number of facilities covered by the fiscal year 2020 goals in each EPA region and each state.)