The allocation of limited resources (for example, time, money, regulatory oversight, qualified professionals) to any one petroleum release site necessarily influences corrective action decisions at other sites. This has spurred the search for innovative approaches to corrective action decision making, which still ensures that human health and the environment are protected.
The RBCA process presented in this guide is a consistent, streamlined decision process for selecting corrective actions at petroleum release sites. Advantages of the RBCA approach are as follows:
Decisions are based on reducing the risk of adverse human or environmental impacts,
Site assessment activities are focussed on collecting only that information that is necessary to making risk-based corrective action decisions,
Limited resources are focussed on those sites that pose the greatest risk to human health and the environment at any time,
The remedial action achieves an acceptable degree of exposure and risk reduction,
Compliance can be evaluated relative to site-specific standards applied at site-specific point(s) of compliance,
Higher quality, and in some cases faster, cleanups than are currently realized, and
A documentation and demonstration that the remedial action is protective of human health, safety, and the environment.
Risk assessment is a developing science. The scientific approach used to develop the RBSL and SSTL may vary by state and user due to regulatory requirements and the use of alternative scientifically based methods.
Activities described in this guide should be conducted by a person familiar with current risk and exposure assessment methodologies.
In order to properly apply the RBCA process, the user should avoid the following:
Use of Tier 1 RBSLs as mandated remediation standards rather than screening levels,
Restriction of the RBCA process to Tier 1 evaluation only and not allowing Tier 2 or Tier 3 analyses,
Placing arbitrary time constraints on the corrective action process; for example, requiring that Tiers 1, 2, and 3 be completed within 30-day time periods that do not reflect the actual urgency of and risks posed by the site,
Use of the RBCA process only when active remediation is not technically feasible, rather than a process that is applicable during all phases of corrective action,
Requiring the user to achieve technology-based remedial limits (for example, asymptotic levels) prior to requesting the approval for the RBSL or SSTL,
The use of predictive modelling that is not supported by available data or knowledge of site conditions,
Dictating that corrective action goals can only be achieved through source removal and treatment actions, thereby restricting the use of exposure reduction options, such as engineering and institutional controls,
The use of unjustified or inappropriate exposure factors,
The use of unjustified or inappropriate toxicity parameters,
Neglecting aesthetic and other criteria when determining RBSLs or SSTLs,
Not considering the effects of additivity when screening multiple chemicals,
Not evaluating options for engineering or institutional controls, exposure point(s), compliance point(s), and carcinogenic risk levels before submitting remedial action plans,
Not maintaining engineering or institutional controls, and
Requiring continuing monitoring or remedial action at sites that have achieved the RBSL or SSTL.
1.1 This is a guide to risk-based corrective action (RBCA), which is a consistent decision-making process for the assessment and response to a petroleum release, based on the protection of human health and the environment. Sites with petroleum release vary greatly in terms of complexity, physical and chemical characteristics, and in the risk that they may pose to human health ......
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