The use of risk assessment during selection of off-site response actions

ABSTRACT This paper addresses the need for incorporating risk assessment procedures into the decision making for off-site response actions under the Comprehensive Environmental Response, Compensation and Liability Act of 1980 (CERCLA or "Superfund") and the Resource Conservation and Recovery Act (RCRA). Differences in regulatory approaches of the CERCLA and RCRA programs as well as inherent deficiencies in implementation of RCRA have led to problems from past off-site responses. EPA's 1985 "Procedures for Planning and Implementing Off-Site Response Actions" do not provide for adequate risk assessment practices to overcome these historical deficiences. EPA can act as a role model for industry and engender public support by selecting the best off-site facilities. Developing guidance under CERCLA and RCRA addresses the need for risk assessments in the regulation of hazardous waste. The so-called Off-Site Policy should articulate a strategy for use of risk assessment during implementation of off-site response...