Financial Assurance Data Entered into RCRAInfo
As a reminder, the financial assurance (FA) module is a critical component of RCRAInfo that is used by EPA (HQ and Regions) and the States to ascertain what financial assurance a facility has submitted and to cross-verify submissions across Regions/States. Financial assurance information is not captured in any other RCRA database and EPA has responded to the Inspector General and the GAO that EPA would collect this data in a useable format to assist in compliance and enforcement.
During past financial assurance reviews we did find instances of facilities that did not disclose the extent of financial test obligations to all states. The cross verification also assists reviewing a facility's ability to cover all of its obligations. OECA also uses the FA reports from RCRAInfo when it learns about issues related to the financial health of owners/operators, bankruptcies of specific companies, or compliance concerns with specific FA instruments. Information from the FA report is used to track the usage of instruments across Regions/States and to inform and coordinate efforts among the Regions/States to check compliance with FA requirements.