New standards in UST cleanups lower costs
Newly promulgated Risk – Based Corrective Action (RBCA) guidelines will result in substantial savings in cleanup costs for states and property owners dealing with contaminated underground storage tank (UST) sites, according to Len Eder, president of Eder Associates, Locust Valley, N.Y., an environmental engineering firm active in UST remediation projects.
“By employing science-based risk assessments rather than non-scientific worst-case default assumptions, UST cleanup could be accomplished much faster and in a less costly manner,,” Eder says.
“In fact, according to a preliminary study conducted by the Washington-based National Environmental Policy Institute, use of risk-based assessments could cut cleanup costs by as much as 60 percent,” he adds.
The Emergency Standard Guide for RBCA, issued by the American Society for Testing and Materials (ASTM), was revised and issued in final form in September.
Developed for sites with leaking underground storage tanks, the guide promulgates the use of risk-based standards for tank remediation, routing its efficiency in targeting cleanup resources to actual site conditions.
The new policy taken by the U.S. Environmental Protection Agency (EPA) “agrees that cost control and reductions in the overall costs of remediation at leaking underground storage tanks sites are key components to the success of not only state assurance funds, but the UST program in general.”
The EPA is recommending that states consider using the RBCA standard and its concepts in their laws regulating leaking UST sites.
Once it is implemented, RBCA will be a tool focus remedial action on the most impacted sites.
More than 20 states have already acted on RBCA, Eder notes. For example, Michigan has taken the general guidelines and added its own specific regulations.
New Jersey has revised the ASTM standard in assessing risk factors for residential and commercial sites and institutional controls by developing classification exemption areas and deed restriction for higher levels of contamination. Other states currently taking action include Connecticut, Pennsylvania and Delaware.
Connecticut has proposed remediation standards incorporating risk-based elements including a flow diagram of steps to be taken in the review process and a table defining limits to contamination levels.
Pennsylvania enacted a law entitled the “Land Recycling and Environmental Remediation Standards Act.” As of July 1995, it allows responsible parties to choose from three standards in cleaning up contaminated areas, cleanup to background levels, to the state-wide health standard or to site-specific level that is essentially a risk-based level.
The act also provides for liability protection from third-party suits.
Delaware will probably adapt the ASTM risk-based approach to cleanup of underground storage tanks contamination. The possibility of applying this to Superfund sites is under discussion.
“The momentum behind the move to risk-based criteria is indeed impressive,” Eder says. “I suspect that within a very short period of time we will see these kinds of guidelines applied to other categories of remediation efforts as well.”