Corrective Action and Permitting Program Update

4 3/27/2019 RCRA State Directors Meeting CORRECTIVE ACTION MEASURES<br>

5 3/27/2019 RCRA State Directors Meeting At the end of the 2018 calendar year, EPA requested monthly targets for RAU from R4 states.

EPA state coordinators sent an email to each state suggesting when the RAU should be submitted during the remaining months of FY19.

R4 made this request because the RAU measure is reported monthly within the division and region’s Bowling charts.

RAU is a strategic measure and it is also tracked on the Administrator’s Bowling Chart and OLEM’s Bowling Chart. In FY19 and going forward, CA550 will also be tracked on both OLEM and the Administrator’s Bowling Chart.

A conference call was held (last February) between EPA and the states to discuss EPA’s request. CORRECTIVE ACTION MEASURES<br>

6 3/27/2019 RCRA State Directors Meeting During the conference call, all of the states similarly identified three main concerns with meeting the Region’s request:

EPA’s request that asked for the states to specify when RAU will be achieved within a specific month when work will be accomplished is a challenge for the states.

States have already provided commitments through the Annual Workplan Negotiation process, but moving to quarterly goals and now monthly goals present a moving target.

EPA’s request for monthly submittal of measures being made outside of the Annual Workplan Negotiation process changes the goal post. CORRECTIVE ACTION MEASURES<br>

Generally, all the states would like to work with EPA and agreed to make their best efforts in FY19.

The states also agreed that as long as EPA’s request was made during the Annual Workplan Negotiation process, then the states could plan accordingly.

The states agreed that targeting a specific quarter that they would achieve RAU was more feasible than planning to achieve the target during a specific month.

It was also agreed that EPA would share the current language that is included Annual Workplan Negotiation Process (for Program Element IV: Corrective Action) to determine what modifications need to be made in FY20 workplan guidance. 7 3/27/2019 RCRA State Directors Meeting CORRECTIVE ACTION MEASURES<br>

EPA started in FY18 going towards a management system that looked for monthly/quarterly reporting of accomplishments. In FY19, states will need to focus on entering accomplishments in RCRAInfo on a monthly basis which is consistent with the EPA/State MOA, “For data entered directly into RCRAlnfo, the State agrees to enter the previous month's activities no later than the 20th of every month.” 8 3/27/2019 RCRA State Directors Meeting FY2020 WORKPLAN GUIDANCE Current Language<br>

During FY18, EPA implemented the EPA Lean Management System (ELMS) which uses measures to track and identify performance. As we continue to deploy ELMS in FY20, EPA will continue to track our accomplishments using various management systems that utilize both monthly and quarterly reporting of accomplishments.

Specifically, in the case of CA550 and RAU, EPA and the states will collaboratively implement strategies identified to achieve the measures such as quarterly targeting for both CA550 and RAU submittal within the workplan.

In FY20, states will need to focus on entering accomplishments in RCRAInfo on a monthly basis which is consistent with the EPA/State MOA, “For data entered directly into RCRAlnfo, the State agrees to enter the previous month's activities no later than the 20th of every month.” 9 3/27/2019 RCRA State Directors Meeting Proposed Language FY2020 WORKPLAN GUIDANCE<br>

RCRA 2020 CORRECTIVE ACTION BASELINE PROGRESS At the end of FY18, the Region’s progress toward meeting the percentage goals within the RCRA 2020 Corrective Action Baseline represents the outstanding work our States have done implementing their RCRA programs. 


CA725, 97.5% complete of 546/560*, where the national average is 94% (3rd only behind R9 and R8)

CA750, 94% complete or 527/560*, where the national average is 88% (we are first in the country)

CA550, 73% complete or 410/560*, where the national average is 70% (3rd only behind R6 and R3) 

*R4 has the second largest universe of facilities on the RCRA 2020 Corrective Action Baseline behind R5. 10 3/27/2019 RCRA State Directors Meeting<br>

IMPORTANT TRAINING DATES RCRA Permit Writers Training Course
Region 7
June 26, 27, and 28
Jefferson City, MO (Missouri Department of Natural Resources)
RCRA Permit Writers’ is a 3-day training course for permit writing and targets new permit writers and experienced permit writers providing an introduction to permits and condition writing as well as updates to permitting, RCRA administration and application of RCRA standards to operating and post closured RCRA facilities requiring a hazardous waste management permit.

FACTT Training– Financial Assurance Compliance Tracking Tool Training
August 27 and 28
Region 4
Atlanta, GA
The first day of the training is financial assurance 101 discussing each of the six traditional financial assurance instruments. The discussion includes how each instrument works, regulatory requirements, challenges and tips for how to manage those challenges.
Day 2 focuses on FACTT - how to enter data, how to use FACTT to monitor FA and identify 'at-risk' regulated entities and how to create reports. 11 3/27/2019 RCRA State Directors Meeting<br>

IMPORTANT TRAINING DATES RCRA Organic Air Emission Standards 2-Day Workshop
Summer/Fall
Columbia, SC
This is a Workshop that targets the application and demonstration of RCRA Organic Air Emission Standards at RCRA facilities, overlap with CAA Subparts, inspection, monitoring, permitting and Standards legal and enforcement issues. 12 3/27/2019 RCRA State Directors Meeting<br>