Significance and Use
The risk-based corrective action (RBCA) process presented in this guide is a consistent, streamlined decision process for selecting corrective actions at chemical release sites.
Risk assessment is a developing science. The scientific approach used to develop the RBSL and SSTL may vary by regulatory agency and by user due to regulatory requirements, guidance and use of alternative scientifically-based methods.
Activities described in this guide should be conducted by persons familiar with current site characterization techniques, remedial action science and technology, current human health risk and exposure assessment methodologies, toxicology, and current ecological evaluation methodologies.
In order to properly apply the RBCA process, the user should AVOID the following:
Prescribing Tier 1 RBSL or RESC as remedial action standards for all sites rather than screening levels,
Limiting use of the RBCA process to Tier 1 evaluation only and not continuing with Tier 2 or Tier 3 analyses for sites where further tier evaluation is appropriate,
Placing arbitrary time constraints on the corrective action process; for example, requiring that Tiers 1, 2, and 3 be completed within time periods that do not reflect the actual urgency of and risks posed by the site,
Using the RBCA process only when active remedial action is not technically feasible, rather than as a process that is applicable during all phases of corrective action,
Conducting active remedial action to achieve only technology-based remedial limits (for example, asymptotic levels) prior to determining applicable corrective action goals,
Using predictive modeling that is not supported by available data or knowledge of site conditions,
Limiting remedial action options to a single class of remedial actions for all sites,
Using unjustified or inappropriate exposure factors,
Using unjustified or inappropriate toxicity parameters,
Failing to consider cumulative risks and additive effects when evaluating multiple chemicals,
Excluding the evaluation of options for activity and use limitations, point(s) of exposure, point(s) of demonstration, sequencing remedial action activities at multiple sites on the same facility, or risk levels,
Excluding the maintenance and monitoring of activity and use limitations,
Failing to consider the long-term effectiveness and reliability of potential remedial action options,
Failing to evaluate potential risks to the public, to workers and to relevant ecological receptors and habitats that may be created by proposed remedial actions or assessment methods and
Continuing monitoring or remedial action at sites that have achieved the corrective action goals (unless monitoring is specifically required for an activity and use limitation or another regulatory requirement). Achievement of corrective action goals is predicated on sufficient monitoring to substantiate the site conditions.
The RBCA process described in this guide includes several features that are only examples of standardized approaches to addressing the objectives of the particular activity, for example, the response action evaluation table and the exposure scenario evaluation flowchart. These elements should be customized by the user based on the constraints of the site or group of sites being addressed and the appropriate technical policy decisions. The objectives of the analyses are identified in this guide.
Scope
1.1 This is a guide for conducting risk-based corrective action (RBCA) at chemical release sites based on protecting human health and the environment. The RBCA is a consistent decision-making process for the assessment and response to chemical releases. Chemical release sites vary greatly in terms of complexity, physical and chemical characteristics, and in the risk that they may pose to human health and the environment. The RBCA process recognizes this diversity by using a tiered approach that integrates site assessment and response actions with human health and ecological risk assessment to determine the need for remedial action and to tailor corrective action activities to site-specific conditions and risks. The evaluations and methods used in the RBCA process begin with simple analyses in Tier 1 and move to more complex evaluations in either Tier 2 or Tier 3, as applicable. The process of gathering and evaluating data is conducted in a scaled fashion. Consequently, only the data that are necessary for a particular tier's decision-making are collected at that tier.
1.2 This guide describes an approach for risk-based corrective action. It is intended to help direct and streamline the corrective action process and to complement but not to supersede federal, state and local regulations. It can be employed at sites where corrective action is being conducted including sites where there may not be a regulatory framework for corrective action, or where the user wishes to conduct corrective action such as sites in voluntary cleanup programs or under Brownfields initiatives. In addition, it can also be used as a unifying framework when several different agency programs affect the site. Furthermore, the user should be aware of the federal, state and local corrective action programs that are applicable for the site and, regardless of the program, federal, state and local agency approvals may be required to implement the processes outlined in this guide. Finally, regardless of whether a corrective action is specifically governed by a regulatory program, the user should consult the regulatory agency requirements to identify the appropriate technical policy decisions prior to implementing the RBCA process.
