Corrective action program

The CAP can serve as the technical framework for a Corrective Action program. The CAP provides a "menu" of activities or information requirements that may be necessary for each phase of the process. Site-specific conditions and the nature and extent of the contamination will determine which tasks will be necessary. The necessary tasks will be enforceable through permit conditions or by an administrative order or judicial action. The (TAP can serve as a flexible engineering guide for the regulatory community in implementing their own Corrective Action Program. 

For the environmental consultant, an extensive overview of corrective action technologies is provided. Topics covered are the general concepts of corrective action programs, facility investigation principles, treatment technologies for wastes and waste streams, post treatment technologies and engineering considerations for corrective measures implementation. 

For off-site land disposal of wastes resulting from a CERCLA activity, the program contains two additional requirements. First, the unit in which the wastes are to be disposed must not be releasing hazardous wastes or constituents into groundwater, surface water, or soil. Second, any releases from other units of the facility must be under an approved RCRA corrective action program. This policy assures that wastes shipped off-site from CERCLA sites are sent to environmentally sound waste management facilities. 

When action level excursions or frequent alert excursions are identified, a corrective action program, resolution deadline, and preventive plan shall be implemented. Risk analysis shall be performed to determine the probability of one or more causes of errors occurring, as well as to identify the potential consequences of excursions. (See attachment nos. 1700.80(1), 1700.80(J), and 1700.80(K), and 1700.80(L) for excursion of air, surface, personnel, and visual inspection report during the visit to plant by the microbiologist responsible.)... 

Martino, L. and Kaszynski, G., A comparison of the CERCLA response program and the RCRA corrective action program, Hazardous Waste Hazardous Mater., 8(2), 1991. 

The Corrective Action program requires corrective action (e.g., removal, stabilization, engineering controls) for all releases of hazardous waste or chemical constituents from any solid waste management unit at a facility seeking a permit under Subtitle C,... 

Drivers who continue to submit logs with excessive violations will be placed in Phase 2 of The Company s corrective action program. 

Phase 3 is the final stage of The Company s hours-of-service corrective action program. Drivers who reach this stage are demonstrating inability or unwillingness to conform to the company s Log Auditing Policy and federal regulations. 

If a motor carrier has an efficient and timely audit and feedback process in place, along with a strong corrective action program, there is really no reason why its drivers should incur hours-of-service violations during company auditing or roadside inspections ... 

The Company reserves the right to impose more stringent consequences based on circumstances and severity of a preventable accident. Accidents will be judged on a case-by-case basis before the following phased corrective action program is initiated. 

If the driver successfully completes the 90-day period without any further preventable accidents, the driver will be taken off Phase-1 status. However, if the driver is involved in another preventable accident while still within the 90 days, the driver will be escalated to Phase-2 of the corrective action program. 

This line of reasoning will explain why the occurrence was not prevented and what corrective actions will be most effective. This reasoning should be kept in mind during the entire root cause process. Effective corrective-action programs include the following ... 

A successful corrective action program requires that management be involved at the appropriate level, be willing to take responsibility, and allocate adequate resources for corrective actions. Additional specific questions and considerations in developing and implementing corrective actions include... 

The intent of the investigation should be to learn from the incident and help prevent similar incidents. A corrective action program should be established based on the findings of the investigation in order to analyze incidents (e.g., uncontrolled release or non-compliant pollution incident) for common root causes. The corrective action prc ram is a followup system to the incident analysis procedures. The investigation should be expedited and findings and recommendations resolved in a timely manner. 

Public service electric and gas company corrective action program related to reactor trip breaker failures on February 22 and 25, 1983 Unit No.l Salem Generating Station", Docket No. 50-272, Public Service Electric and Gas Company (PSE G), April 7,1983. 

Phase 5—Corrective Action Program Develop Corrective Action Program... 

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