The Challenge for Risk-Based Decisions
Non-technical issues
- the value of regulatory “No Further Action” letters and potential re-openers has to be accepted
- better defined language in “No Further Action” determinations
- identify the criteria relied on for the NFA
- include criteria for re-opener:
- change in land-use
- order of magnitude change in monitoring data
- define responsibility for re-opening the corrective action
- previous owner/operator
- current landowner