Managing Risk
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Risk-Based Corrective ActionFeedback
Risk-based decision-making is a mechanism for identifying necessary and appropriate action throughout the cleanup process. Depending on known or anticipated risks to human health and the environment, appropriate action may include: site closure, monitoring and data collection, active or passive remediation, engineering or institutional controls. In all cases, the objective is the same: to ensure that adequate protection of human health and the environment is provided.
The availability of options such as excavating contaminated soils or allowing contamination to remain and be subject to institutional controls to prevent exposure will depend on a number of factors. These include the types and amounts of hazardous substances present at a site, potential exposed populations, and the calculated health risks. With regard to revitalization of potentially contaminated sites, risk management decision-making also evaluates potential reuse of a site.
A major component in the risk based corrective action (RBCA) process is establishment of cleanup standards based on the selected future land use. Under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), contaminated sites must meet cleanup standards or applicable or relevant and appropriate requirements (ARARs). CERCLA infers that the remedial action either eliminates or reduces contaminants to the level specified in the ARARs for each contaminant. In addition, risk-based target levels can be developed for contaminants at a site for applicable media of concern (sometimes referred to as site-specific target levels) based on the contaminants’ potential to reach human receptors.
The cost of meeting such stringent standards can make a contaminated revitalization site economically infeasible to developers. At least one not-for-profit organization, ASTM INTERNATIONAL (ASTM) developed a risk-based corrective action (RBCA) framework that incorporates a step approach to risk assessment in which risk levels and other variables, including exposures anticipated at the site based on expected future uses, can be used to determine sufficiently protective cleanup standards and corresponding remedial actions on a site-specific basis. This approach is favorable for brownfield sites under VCPs due to the specific nature of the programs and site specific reuse scenarios; however, some states have their own standards that must be followed. The ASTM Risk Management Guidance Document Exhibit presents a standard guidance document that ASTM has published for use in site revitalization. This resource, and additional applicable resources, can be purchased through ASTM’s Web Site. At this time, the ASTM website is the only known official source for purchasing ASTM methods, and there is no known “free” source.
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Topic
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Document Title
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Summary
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Risk-Based Corrective Action (RBCA)
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(ASTM E1739-95e1)
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Defines RBCA as a process for assessing and responding to a petroleum release in a manner that ensures the protection of human health and the environment. The guide will assist brownfields decision makers who wish to become familiar with another approach that can be used to assess environmental risk at a site, in conformity with applicable federal, state, local, and tribal regulations. The diversity and flexibility of a RBCA approach is defined and discussed, and the tiered approach of the process is summarized. Although the RBCA process is not limited to a particular site, the guide emphasizes the use of RBCA in response to releases of petroleum.
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Some State environmental agencies have developed their own information on RBCA. This information is freely available from the following websites:
Finally, the USEPA Office of Underground Storage Tanks provides some information on risk-based decision-making for underground storage tanks.