Integration of Risk Management and Project Management for Efficient RCRA Corrective Action

There is a continuing debate concerning the efficiency of the Resource Conservation and Recovery Act (RCRA) corrective action process. Responsible parties and the regulatory agencies at both the state and federal levels have been at odds over the process, technology, endpoints and timing of corrective action for many years. The objective of the regulatory agencies is often remedial action to the extent technically practical whereas the objective of the responsible parties is often minimal financial expenditures for corrective action and only to the extent that there is an adverse impact to human health and the environment. These conflicting objects have resulted in a process that is tedious and time consuming and have generated considerable debate between the agency and the responsible party at individual sites. Furthermore, there are often other competing state and federal regulatory programs with different and sometimes conflicting objectives and processes. This paper discusses an alternative approach for corrective action that integrates risk assessment and risk management concepts into the corrective action process. In addition, this paper identifies the significant risk management decisions that must be resolved in order for this risk-based decision making process to be successful. The process has a role in corrective action and property environmental lifecycle management. Effective implementation of the integrated risk-based approach for corrective action will require that traditional processes, technologies and science are challenged and that an effective collaboration between responsible parties, the regulatory agencies and other stakeholders with an interest in the corrective action process is created.