Standard Guide for Risk-Based Corrective Action Applied at Petroleum Release Sites
4.1 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.
4.2 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:
4.2.1 Decisions are based on reducing the risk of adverse human or environmental impacts,
4.2.2 Site assessment activities are focussed on collecting only that information that is necessary to making risk-based corrective action decisions,
4.2.3 Limited resources are focussed on those sites that pose the greatest risk to human health and the environment at any time,
4.2.4 The remedial action achieves an acceptable degree of exposure and risk reduction,
4.2.5 Compliance can be evaluated relative to site-specific standards applied at site-specific point(s) of compliance,
4.2.6 Higher quality, and in some cases faster, cleanups than are currently realized, and
4.2.7 A documentation and demonstration that the remedial action is protective of human health, safety, and the environment.
4.3 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.
4.4 Activities described in this guide should be conducted by a person familiar with current risk and exposure assessment methodologies.
4.5 In order to properly apply the RBCA process, the user should avoid the following:
4.5.1 Use of Tier 1 RBSLs as mandated remediation standards rather than screening levels,
4.5.2 Restriction of the RBCA process to Tier 1 evaluation only and not allowing Tier 2 or Tier 3 analyses,
4.5.3 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,
4.5.4 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,
4.5.5 Requiring the user to achieve technology-based remedial limits (for example, asymptotic levels) prior to requesting the approval for the RBSL or SSTL,
4.5.6 The use of predictive modelling that is not supported by available data or knowledge of site conditions,
4.5.7 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,
4.5.8 The use of unjustified or inappropriate exposure factors,
4.5.9 The use of unjustified or inappropriate toxicity parameters,
4.5.10 Neglecting aesthetic and other criteria when determining RBSLs or SSTLs,
4.5.11 Not considering the effects of additivity when screening multiple chemicals,
4.5.12 Not evaluating options for engineering or institutional controls, exposure point(s), compliance point(s), and carcinogenic risk levels before submitting remedial action plans,
4.5.13 Not maintaining engineering or institutional controls, and
4.5.14 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 and the environment. The RBCA process recognizes this diversity, and uses a tiered approach where corrective action activities are tailored to site-specific conditions and risks. While the RBCA process is not limited to a particular class of compounds, this guide emphasizes the application of RBCA to petroleum product releases through the use of the examples. Ecological risk assessment, as discussed in this guide, is a qualitative evaluation of the actual or potential impacts to environmental (nonhuman) receptors. There may be circumstances under which a more detailed ecological risk assessment is necessary (see Ref (1).2
1.2 The decision process described in this guide integrates risk and exposure assessment practices, as suggested by the United States Environmental Protection Agency (USEPA), with site assessment activities and remedial measure selection to ensure that the chosen action is protective of human health and the environment. The following general sequence of events is prescribed in RBCA, once the process is triggered by the suspicion or confirmation of petroleum release:
1.2.1 Performance of a site assessment;
1.2.2 Classification of the site by the urgency of initial response;
1.2.3 Implementation of an initial response action appropriate for the selected site classification;
1.2.4 Comparison of concentrations of chemical(s) of concern at the site with Tier 1 Risk Based Screening Levels (RBSLs) given in a look-up table;
1.2.5 Deciding whether further tier evaluation is warranted, if implementation of interim remedial action is warranted or if RBSLs may be applied as remediation target levels;
1.2.6 Collection of additional site-specific information as necessary, if further tier evaluation is warranted;
1.2.7 Development of site-specific target levels (SSTLs) and point(s) of compliance (Tier 2 evaluation);
1.2.8 Comparison of the concentrations of chemical(s) of concern at the site with the Tier 2 evaluation SSTL at the determined point(s) of compliance or source area(s);
1.2.9 Deciding whether further tier evaluation is warranted, if implementation of interim remedial action is warranted, or if Tier 2 SSTLs may be applied as remediation target levels;
1.2.10 Collection of additional site-specific information as necessary, if further tier evaluation is warranted;
1.2.11 Development of SSTL and point(s) of compliance (Tier 3 evaluation);
1.2.12 Comparison of the concentrations of chemical(s) of concern at the site at the determined point(s) of compliance or source area(s) with the Tier 3 evaluation SSTL; and
1.2.13 Development of a remedial action plan to achieve the SSTL, as applicable.
1.3 The guide is organized as follows:
1.3.1 Section 2 lists referenced documents,
1.3.2 Section 3 defines terminology used in this guide,
1.3.3 Section 4 describes the significance and use of this guide,
1.3.4 Section 5 is a summary of the tiered approach,
1.3.5 Section 6 presents the RBCA procedures in a step-by-step process,
1.3.6 Appendix X1 details physical/chemical and toxicological characteristics of petroleum products,
1.3.7 Appendix X2 discusses the derivation of a Tier 1 RBSL Look-Up Table and provides an example,
1.3.8 Appendix X3 describes the uses of predictive modeling relative to the RBCA process,
1.3.9 Appendix X4 discusses considerations for institutional controls, and
1.3.10 Appendix X5 provides examples of RBCA applications.
1.4 This guide describes an approach for RBCA. It is intended to compliment but not supersede federal, state, and local regulations. Federal, state, or local agency approval may be required to implement the processes outlined in this guide.
1.5 The values stated in SI units are to be regarded as standard. No other units of measurement are included in this standard.
1.6 This standard does not purport to address all of the safety concerns, if any, associated with its use. It is the responsibility of the user of this standard to establish appropriate safety and health practices and determine the applicability of regulatory limitations prior to use.
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