Teresa Marks, Director
5301 Northshore Drive
North Little Rock, AR 72118-5317 
(501) 682-0744

---

Quick Links

• What is the Corrective Action Strategy (CAS) in Arkansas?
• What instrument is used to impose corrective action at the site not subject to RCRA permitting (LOA)?
• Where do I get a copy of the Letter of Agreement (LOA)?
• What instrument are you using to impose corrective action at permitted sites?
• Where can I get a copy of the CAS?
• Slides from Mr. Clanton's PowerPoint presentation at Region 6 Corrective Action Conference, June 2001
  • View with Internet Explorer 4.0 or higher*
  • Download this PowerPoint 2000 presentation (220kb)
    (You may need to "right-click" on the link and select "Save Target As" in order to download the file.)
    

    * Note: Internet Explorer users have the option of viewing the presentation in their browser or downloading the PowerPoint file for off-line viewing.
    Netscape users will have to download the PowerPoint file. (You do not need PowerPoint 2000 to view this file.
    There is a FREE PowerPoint Viewer available for download from the Microsoft Web site.)

What is the Corrective Action Strategy in Arkansas?

It is the implementation of the United States Environmental Protection Agency (U.S. EPA) Region 6 Corrective Action Strategy (CAS). Arkansas is using the CAS as a guidance document to implement three pilot projects. One pilot is corrective action at a site not subject to RCRA permitting; this is one that Region 6 will be involved closely with the project as it proceeds. We are piloting the strategy at two other facilities that currently have RCRA permits.

What instrument is used to impose corrective action at the site not subject to RCRA permitting (LOA)?

We are calling that document a Letter of Agreement (LOA). It is a very streamlined version of the Consent Administrative Order that we currently use to impose corrective action for site wide cleanup.

Where do I get a copy of the Letter of Agreement (LOA)?

Letter of Agreement (LOA) EXAMPLE (PDF)

What instrument are you using to impose corrective action at permitted sites?

We are planning to use enforcement discretion to suspend corrective action at permitted sites. The letter of suspension will state that the enforcement discretion will only continue as long as corrective action is proceeding successfully under the RMS and that the terms of the corrective action permitting module can be reactivated unilaterally at any time by the Department. The actual agreement that will be the implementing document will be similar to the LOA above. We do not plan at this time to issue a permit modification.

Where can I get a copy of the CAS?

The Corrective Action Strategy is available at Region 6's website at the following web address:
http://www.epa.gov/earth1r6/6pd/rcra_c/pd-o/riskman.htm