Region 4 Develops EI Strategy to Improve Schedules
Environmental Indicators (EIs) are measures being used by the RCRA Corrective Action program to go beyond programmatic activity measures to track changes in the quality of the environment. A positive "Current Human Exposures Under Control" EI determination indicates that there are no "unacceptable" human exposures to "contamination" (i.e., contaminants in concentrations in excess of appropriate risk-based levels) that can be reasonably expected under current land- and groundwater-use conditions at a facility site-wide. A positive "Migration of Contaminated Groundwater Under Control" EI determination indicates that the migration of "contaminated" groundwater has stabilized, and that monitoring will be conducted to confirm that contaminated groundwater remains within the original "area of contaminated groundwater"site-wide.
Defining a clear strategy for reaching positive EI determinations is important because many facilities have yet to reach a positive EI determination and the period of time in which a positive EI determination must be reached is short. Region 4's EI Strategy involves the development of an EI Project Schedule, with Milestones, for each facility. The EI Project Schedule for a facility estimates when human exposures and migration of groundwater contamination will be controlled AND outlines EI Interim Milestones. The EI Project Schedule is a planning tool - not an enforcement document.
The importance of establishing schedule dates for the completion of each EI Interim Milestone is that it allows for the periodic comparison to actual completion dates. Hence, each facility's (and EPA or State project manager's) progress toward a positive EI determination can be monitored and appropriate action can be taken to correct unacceptable project delays. In addition, accurately tracking and analyzing success in meeting positive EI determinations is particularly important given that the GPRA goals for the program are that by 2005, 70% of high priority RCRA sites will have toxic releases to groundwater controlled and 95% will have human exposure toxins controlled.
The RCRA Information System (RCRAInfo) will be used to track the EI Interim Milestones in the unauthorized states in Region 4 (TN, FL and MS). Specifically, a RCRAInfo area titled something similar to "Environmental Indicator Project Schedule" is to be established. RCRAInfo is also being used to identify which of the three (3) RCRA Branches within the Regional Office is responsible for the RCRA Cleanup Baseline Facility and/or responsible for tracking an authorized State's progress toward a positive EI determination.
For authorized states in Region 4 (AL, GA, KY, NC, SC), the Regional Office will obtain and track each State's estimates for attaining their GPRA Goals. As in unauthorized states, if problems are observed which might lead a State to not meet the annual or cumulative fiscal year goals which the regional office is measured against, then the problem can be identified and, where feasible, action can be taken to correct the delay.
Because of the relatively short amount of time given to meet these two EIs, Region 4 decided that these EI Project Schedules should not be unilaterally determined without input from the facilities. Therefore, each facility is receiving a copy of their draft EI Project Schedule. Comments/suggestions on the Interim Milestones and estimated completion dates can then be provided to the EPA or State Project Manager prior to finalization of the EI Project Schedule. The regional office maintains that active, ongoing and open communication with the RCRA facilities is essential if human health and the environment are to be protected and the EPA goals for GPRA are to be met in a timely manner.