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Complying Action Types (July 2005 REVISED)

THIS DOCUMENT REPLACES:

      ICIS Complying Action Types (June 2004 ARCHIVE)

 

The three categories are defined in the Guide to Calculating Environmental Benefits of Enforcement Cases: FY 2005 CCDS Updateas:

1) Actions with Direct Environmental Benefits/Response/Corrective Actions;

2) Preventative Actions to Reduce the Likelihood of Future Releases; and

3) Facility/Site Management and Information Practices. 

 

The preventative actions were added to ICIS in FY 2005 to capture the preventive benefits of the following programs: Spill Prevention and Countermeasures Control Plans (SPCC), Public Water System Supervision (PWSS) Program, underground injection, RCRA Subtitle C, underground storage tanks, lead-based paint and asbestos, and FIFRA.  Note: several programs areas can report both preventive and direct environmental benefits.  Amounts can only be reported for direct and preventive complying actions.

 

Actions with Direct Environmental Benefits/Response/Corrective Action are those actions that treat, reduce, or eliminate a pollutant or emission/discharge stream to reduce/eliminate human health exposure or environmental impact (e.g., source reduction, emissions/discharge change, implementing best management practices, removal).  These include CERCLA and RCRA-corrective actions.  OC measures the direct environmental benefits in terms of quantity, volume, area, and people protected.

 

Preventative Actions to Reduce the Likelihood of Future Releases are those actions that properly manage a waste stream or prevent a release or exposure.  Preventative actions may reduce the likelihood of future human health risk or environmental impact by maintenance of proper controls prior to a release or waste stream being generated (e.g., plug and abandon wells, develop spill prevention plans, secondary containment, asbestos removal training) or after it has been generated as a waste (e.g., RCRA labeling, storage change, disposal change).  OC measures the environmental benefits of these actions in terms of quantity, volume, area, schools/housing/building units, wells, and people notified.

 

Facility/Site Management and Information Practices (FMIP) are those actions that a facility conducts to better manage their environmental program and to inform the public/permitting authority of the toxicity, quantity, and location of their chemicals, waste streams, and emissions (e.g., auditing, environmental management review, site assessment, testing, recordkeeping, reporting).  OC does not try to quantify the environmental benefits of FMIPs.

 

A complete list of the complying action types for each category are shown below.

(See attachment)

See Also 

FY 2005 Guide to Calculating Environmental Benefits of Enforcement Cases: FY 2005 CCDS Update

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