Risk-Based Decision Making Basics
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RBDM is used more and more to facilitate effective and appropriate characterization and cleanup of UST releases. According to the Environmental Protection Agency (EPA), RBDM “is a process that utilizes risk and exposure assessment methodology to help UST implementing agencies make determinations about the extent and urgency of corrective action and about the scope and intensity of their oversight of corrective action by UST owners and operators.”
First introduced into the UST corrective action program in 1995, RBDM is a means of providing flexibility while adhering to requirements of the Resource Conservation and Recovery Act (RCRA), the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), state groundwater protection programs, and environmental justice and brownfields initiatives. As a result of EPA’s acceptance of RBDM, many states have adopted its use within their UST programs, making it one of the essential tools to help clear the national backlog of LUST corrective actions.
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RBDM can be used throughout the corrective action process. However, the EPA cites three principal uses of RBDM:
1) To categorize or classify sites—Contaminant levels at UST release sites can be compared with risk-based criteria to rank sites in categories with prescribed initial response actions and/or subsequent steps in the corrective action program using a standardized approach appropriate for that category of risk. For example, at low-risk sites, UST owners and operators may not be required to develop site-specific corrective action plans, but would undertake the prescribed steps without constant oversight by the implementing agency. At high-risk sites, however, submission of corrective action plans and agency oversight would also be incorporated in the implementing agencies’ policies, again in response to the level of risk.
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2) To aid in establishing cleanup goals—Risk-based cleanup goals can be either generic or site-specific. Generic goals based on conservative assumptions about factors influencing human and environmental exposures can be developed to provide adequate protection of human health and the environment in the majority of corrective action cases for contaminants generally present at UST release sites. Using generic goals will lower the need for site-specific data collection and analysis, expediting the corrective action. At some sites, it may be more cost-effective to gather site-specific data and set site-specific cleanup goals based on exposure and risk assessment methodology. Where conditions are similar to those of the applicable generic cleanup goals, however, site-specific goals may not be significantly different, and the costs of the additional data collection and analysis may negate any savings associated with site-specific goals.
3) To decide on levels of agency oversight of UST owners and operators—Where allowed by state and/or federal law, both the reporting requirements imposed on UST owners and operators and the extent of oversight by the regulatory agency can be varied in accordance with varying risk levels. Categorizing sites based on level of risk can facilitate different levels of oversight, as well as the frequency and content of reporting by UST owners and operators. Other aspects that can be linked to categorization include whether and how often corrective action sites are inspected and whether and how UST implementing agencies review technical reports coming from UST owners and operators. The result is corrective action requirements that are appropriate and protective while allowing regulators to focus compliance inspection and evaluation resources on those sites where human health and environmental risks are highest.