2.4 Corrective Action Process Under the Resource Conservation and Recovery Act
The corrective action process under RCRA is similar to that under CERCLA. It generally consists of the
following three steps:
- RCRA facility investigation (RFI) — An RFI is similar to a CERCLA remedial investigation and includes the assessment of both active and inactive solid waste management units. The RFI identifies releases that require corrective action when contamination levels exceed action levels established under the state regulations.
- Corrective measures study (CMS) — A CMS has an objective similar to that of a feasibility study under CERCLA; it is intended to evaluate appropriate cleanup alternatives for eliminating or reducing the risks posed by releases discovered during the RFI.
- Corrective measures implementation (CMI) — The CMI phase involves constructing and operating the remedy (or remedies) selected after completion of the CMS.
A company should contemplate each step when evaluating its environmental liabilities. As information
becomes available during assessments, the company should continually reevaluate in a manner consistent with the guidance in ASC 450-20 whether it is
probable that subsequent corrective actions will be required and whether the costs of such actions are
reasonably estimable.