RCRA Permitting Risk Assessment

EPA’s hazardous waste permitting program established by RCRA helps ensure the safe treatment, storage, and disposal of hazardous wastes by establishing specific requirements that must be followed when managing hazardous wastes. Human health is an integral part of risk based closure of permitted units, developing groundwater remediation goals or permit limits, and for evaluating operating permits, including permit issuance, annual monitoring and closure, for 40 CFR 264 Subparts O (incinerators)  and X (miscellaneous units)  facilities and for 40 CFR 266 Subpart H facilities (boilers and industrial furnaces).

Risk assessment for hazardous waste  facilities, including closures in conjunction with DEQ’s Risk Based Closure Guidance, was conducted using 'Guidance for Development of Health Based Cleanup Goals Using Decision Tree/REAMS Program”,  November 1, 1994,  and subsequent updates as prepared by Old Dominion University developed by DEQ. DEQ has developed a new tool using the latest EPA Risk Screen Level (RSL) data called Virginia Unified Risk Assessment Model (VURAM). While the overall approach and assumptions provided in DEQ’s risk based closure guidance and REAMS manual remain valid and applicable, VURAM replaces and supersedes the risk assessment module of the REAMS software but does NOT replace the fate and transport modules of REAMS. Thus going forward, REAMS software must not be used for quantitative risk assessment. VURAM does not include fate and transport based modeling for soil-to-groundwater transfer, for which the facility may choose to use the SESOIL module of REAMS. Please contact DEQ for more details on fate and transport modeling. In places where risk assessment assumptions are conflicting between risk based closure guidance and VURAM, VURAM will supersede. Please include all the results of the screening level risk assessment as well as the VURAM report (output) in its ENTIRETY. For VURAM Risk Assessment questions please contact the DEQ Risk Assessment staff.

Refer to the VURAM User’s Guide for instruction on how to install and use VURAM. The latest version of VURAM supersedes all previous versions. It is the facility’s responsibility to ensure that the most current version of VURAM is used in risk assessments regardless of whether the DEQ’s web-based risk assessment guidance pages have been updated. 

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Virginia Department of
Environmental Quality
P.O. Box 1105
Richmond, VA 23218
(804) 698-4000

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