Hi Adam,
Nice to see your continuing the DQRA debate!!
The problem with CLEA is that you can't do much with it (although I believe
there are plans to change this). As such it leaves a large hole in
providing relevant SSTL's from a DQRA using UK policy.
Most LA's could accept modified RBCA etc as long as there isn't a more
suitable model available to use (CLEA, SNIFFER, RISC). As long as the
consultant has done his or her research and selected the relevant tox data
and applied it correctly then you should be OK to use it.
You are correct in stating that the US use a different way of determining
tox data and how those are interpreted, it's just unfortunate at the moment
that the UK hasn't caught up and we will just have to hold on for further
development of UK relevant tox data.
The two mains problems by doing so are:
firstly, a value a consultant comes up with now may be too high when the
CLEA SGV is produced, which could potentially lead to further remediation
and cost and possibly Part IIA action (We can move the goal posts if
necessary) (the flip side of the same case is also true).
Secondly, development can not stop due to lack of investment on the
Governments behalf (to fast track CLEA development)which puts the consultant
in a position of committing the first problem.
A catch 22.
Regards,
John Naylor
Environmental Protection Officer
Bury M.B.C.
*: 0161 253 5581
*: 0161 253 5563
*: [log in to unmask]
> -----Original Message-----
> From: Adam Czarnecki [SMTP:[log in to unmask]]
> Sent: 06 November 2003 17:41
> To: [log in to unmask]
> Subject: Re: Commercial Development on Hydrocarbon Contaminated Soils
>
> What do you mean not at the moment. Is it been modified for the UK
> legislative environment?
>
> Are you accepting RBCA output as part of human health and groundwater risk
> assessments?
>
> I can think of several large differences in the CLEA and RBCA
> methadologies and use of toxicological information.
>
> Many of the algorithms cannot be tweaked, i.e. indoor inhalation exposure
> pathway.
|