A Toolbox for Corrective Action: Resource Conservation and Recovery Act Facilities Investigation Remedy Selection Track

The Resource Conservation and Recovery Act (RCRA) Facilities Investigation Remedy Selection Track (FIRST) Toolbox for Corrective Action distills practical lessons learned and experiences contributed by federal, state, and regulated community representatives involved with investigation and remedy selection worldwide.

On this page:

• The RCRA FIRST Approach
• The RCRA FIRST Toolbox

The RCRA FIRST Approach

EPA designed the RCRA FIRST approach to improve the efficiency of RCRA facility investigations and remedy selection at RCRA Corrective Action Facilities. The RCRA FIRST approach:

• Addresses the root causes of delay, such as
  • Unclear or non-specific investigation or cleanup objectives and
  • Lack of specific opportunity and process to elevate differences among stakeholders early in the process.
• Starts with multi-party understanding of the objectives in investigation and remedy selection phases.
• Enhances communication among project stakeholders.
• Promotes the principle of “done right the first time” and avoids re-do loops.
• Advances critical decision-making through rapid elevation to resolve disputes.
• Stays within the technical and regulatory framework of the corrective action program.

The RCRA FIRST Toolbox

The RCRA FIRST toolbox and associated tools will help EPA Regional staff and their partners to take advantage of the efficiency and quality gains from the RCRA FIRST approach. The toolbox includes a how-to guide, process flow maps, and tools and templates to make it easier to complete different parts of the FIRST approach and monitor its effectiveness. Project teams can customize the resources to meet each region or state’s specific needs. The tools are also downloadable in individual files.

• Memo from Barnes Johnson, Office Director, Office of Resource Conservation and Recovery, Regarding RCRA FIRST (pdf) (630.19 KB)
• A Toolbox For Corrective Action: Resource Conservation and Recovery Act Facilities Investigation Remedy Selection Track (RCRA FIRST) (pdf) (6.82 MB)
• Tool 1: Model Corrective Action Framework (CAF) Meeting Agenda (pdf) (113.85 KB)
  The CAF Meeting Agenda is the most important tool in the Toolbox. This is the initial entry to the RCRA FIRST process and the measurable RFI objectives that come from this meeting will anchor all subsequent activity and define the successful completion of the RCRA Facilities Investigation (RFI).
• Tool 2: Corrective Action Framework Template (pdf) (164.44 KB)
  Use this model CAF Template as a tool for drafting the facility-specific CAF. The CAF is a tool generally intended to summarize the goals and expectations for the RFI process.
• Tool 3: Elevation Process (pdf) (112.21 KB)
  This tool provides the steps required to engage in an elevation and lays out nine specific points in the process where project teams should use it to raise an impasse to the next level of management for resolution.
• Tool 4: RCRA Facility Investigation Data Sufficiency Evaluation (pdf) (157.95 KB)
  This tool is a flow chart that helps project teams assess RCRA Facility Investigation Data Sufficiency in three steps: (1) Compile and jointly review all existing data that might affect Current Conceptual Site Model; (2) Consider Qualitative Assessment Questions: and; (3) Assess if project data quality objectives have been satisfied.
• Tool 5: Conceptual Site Model Iterative Evaluation Update Tool (pdf) (155.48 KB)
  This tool is a flow chart that helps project teams evaluate and update the conceptual site model.
• Tool 6: Template Agenda for Remedy Selection Process Meeting (pdf) (115.63 KB)
  Project teams may use this strategically designed agenda to facilitate agreement on a set of Corrective Action Objectives (CAOs) that guide the proposed remedy(ies) for all contaminated media or other areas identified in the RFI and the Site Conceptual Model. The agenda also guides project teams to choose an approach to the development of the proposed remedy among the following: no corrective measures study (CMS), modified CMS, or full CMS.
• Tool 7: Developing Corrective Action Objectives (pdf) (146.76 KB)
  This tool provides information on developing effective objectives and provides a format to document corrective actions objectives based on the environmental media, sources, pathways, and receptors relevant to a facility.
• Tool 8: Post-Remedial Care Considerations (pdf) (197.01 KB)
  This tool provides project managers with a summary of RCRA Post-Remedial Care policy, tools, and examples that can bear on establishing CAOs during the Remedy Selection Process Meeting.
• Tool 9: Remedy Selection Process Document (pdf) (136.59 KB)
  This tool is for regulators and facilities wishing to utilize the RCRA FIRST approach to remedy selection. Project teams may use this model Remedy Selection Process Document (RSPD) as a tool for drafting the facility-specific RSPD.
• Tool 10: Control Plan (pdf) (138.51 KB)
  This tool outlines a control plan to track process improvements with RCRA FIRST. The control plan outlines the metric for each step in the facility investigation and remedy selection processes, the unit of measure for tracking, and the target measure of performance. Project managers can track progress in the “Current Quarter Status” column and take the suggested recovery actions where necessary.
• Tool 11: Communications Plan (pdf) (137.86 KB)
  This tool provides a table to outline a systematic communications approach for the RCRA FIRST processes, including the purpose of each meeting, the participants, the documents needed in advance, and applicable RCRA FIRST Tools.
• Tool 12: Project Manager Transition Checklist (pdf) (129.41 KB)
  This transition checklist defines the steps and associated activities needed to facilitate seamless on boarding and/or transition of a new RCRA corrective action project manager within the EPA, Industry, and Consultants.
• Example CAF Meeting Agenda for Restarting a Stalled RFI (pdf) (167.8 KB)
• Example CAF for a New RFI (pdf) (318.95 KB)
• Example Corrective Action Agenda for Remedy Selection (pdf) (196.52 KB)