Many faces of RBCA
- Dames & Moore Group, Salem, NH (United States)
- Environmental Protection Agency, San Francisco, CA (United States)
A myriad of Risk-Based Corrective Action (RBCA) programs have recently been implemented or are under development by state regulatory agencies as well as the provincial agencies of our neighbors to the north. Collectively, RBCA programs represent the most important step forward in rational, environmental stewardship in the past several decades. The implementation and acceptance of RBCA reflects a shift in perspective from {open_quotes}How much of the contaminants of concern can we clean up?{close_quotes} to {open_quotes}What level of the contaminants of concern can we safely leave in place?{close_quotes}. The development of default, or Tier 1, risk-based cleanup criteria represent the foundations of RBCA programs. Inconsistencies in these criteria between RBCA programs can lead to confusion, however, as sites that would be considered {open_quotes}clean{close_quotes} under one agency`s program would seemingly pose unacceptable risks to human health and the environment under another. A review of background documents that describe the quantitative development each agency`s Tier 1 criteria reveals that these inconsistencies are due to differences in risk management decisions, models and modeling assumptions incorporated into the RBCA program. This is especially true for highly mobile contaminants, including petroleum related volatiles and solvents. Regardless of inconsistencies between RBCA programs, it is important that regulatory agencies have a clear and thorough strategy for implementing their program and that risk management policy decisions remain consistent across all tiers of the RBCA process. In this paper, we undertake a critical evaluation of the quantitative foundations of selected RBCA programs - their Tier 1 (Plan A, Method 1, etc.) lookup tables - and use this as a basis to examine differences in the risk management decisions that lie behind the development of RBCA programs.
- OSTI ID:
- 569957
- Report Number(s):
- CONF-971116--
- Country of Publication:
- United States
- Language:
- English
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