ASTM D5745-95(2005)
(Guide)Standard Guide for Developing and Implementing Short-Term Measures or Early Actions for Site Remediation
Standard Guide for Developing and Implementing Short-Term Measures or Early Actions for Site Remediation
SIGNIFICANCE AND USE
This guide is intended to provide a systematic approach for the application and execution of early actions for purposes of remediating sites of both hazardous and non-hazardous contamination. Fundamental to the use of this guide is the iterative development of a CSM.
Anticipated users of this guide are owners or operators at sites of environmental contamination; technical professionals involved in the field of environmental site characterization and remediation; environmental regulators, property owners, employees, and residents adjacent to sites of environmental contamination; and lenders, sureties, and persons of general interest within an affected community.
This guide is not intended to replace legal requirements for remediating sites of environmental contamination. This guide should be used to supplement existing regulatory guidance and to focus remedial efforts toward final remedy solutions.
SCOPE
1.1 The purpose of this guide is to provide guidance for assisting in the development, selection, design, and implementation of partial, short-term, or early action remedies undertaken at sites of waste contamination for the purpose of managing, controlling, or reducing risk posed by environmental site contamination. Early action remedies and strategies are applicable to the management of other regulatory processes (for example, state UST programs are equally applicable) in addition to the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA)/NCP process. This guide identifies and describes a standard process, technical requirements, information needs, benefits, and strategy for early actions.
1.2 This guide is applicable to both nonhazardous and hazardous sites of contamination as defined by CERCLA as amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA) and the Resource Conservation and Recovery Act (RCRA) as amended by the Hazardous and Solid Waste Amendments (HSWA) of 1986.
1.3 To the extent that this guide may be used for hazardous materials actions operations, it does not address the applicability of regulatory limitations and local requirements.
1.4 This standard does not purport to address all of the safety concerns, if any, associated with its use. It is the responsibility of the user of this standard to establish appropriate safety and health practices and determine the applicability of regulatory limitations prior to use.
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Designation:D5745–95 (Reapproved 2005)
Standard Guide for
Developing and Implementing Short-Term Measures or Early
Actions for Site Remediation
This standard is issued under the fixed designation D5745; the number immediately following the designation indicates the year of
original adoption or, in the case of revision, the year of last revision. A number in parentheses indicates the year of last reapproval. A
superscript epsilon (´) indicates an editorial change since the last revision or reapproval.
1. Scope 2.2 Code of Federal Regulations:
Corrective Action or Solid Waste Management Units at
1.1 The purpose of this guide is to provide guidance for
Hazardous Waste Management Facilities, Proposed Rule,
assisting in the development, selection, design, and implemen-
27July1990,40CFRParts264,265,270,and271(55FR
tation of partial, short-term, or early action remedies under-
30797)
taken at sites of waste contamination for the purpose of
CorrectiveAction Management Units andTemporary Units;
managing, controlling, or reducing risk posed by environmen-
Corrective Action Provisions; Final Rule, 16 February
tal site contamination. Early action remedies and strategies are
1993, 58 FR 8658
applicable to the management of other regulatory processes
National Oil and Hazardous Substances Pollution Contin-
(for example, state UST programs are equally applicable) in
gency Plan, Final Rule, 8 March 1990, 40 CFR Part 300
additiontotheComprehensiveEnvironmentalResponse,Com-
2.3 EPA Documents
pensation and Liability Act (CERCLA)/NCP process. this
CERCLA, Compliance with Other Laws Manual, Part I
guide identifies and describes a standard process, technical
(Interim Final), August 1988, EPA/9234.1-01
requirements, information needs, benefits, and strategy for
CERCLA, Compliance with Other Laws Manual, Part II:
early actions.
CleanAirAct and Other Environmental Statutes and State
1.2 This guide is applicable to both nonhazardous and
Requirements, August 1989, EPA/9234.1-02
hazardous sites of contamination as defined by CERCLA as
Guidance for Performing Preliminary Assessments under
amended by the Superfund Amendments and Reauthorization
CERCLA, September 1991, EPA/9345.0-01A
Act of 1986 (SARA) and the Resource Conservation and
Guidance for Performing Site Inspections under CERCLA,
RecoveryAct(RCRA)asamendedbytheHazardousandSolid
September 1992, EPA/9345.1-05
Waste Amendments (HSWA) of 1986.
Data Quality Objectives for Remedial Response Activities:
1.3 To the extent that this guide may be used for hazardous
Development Process, EPA/540/G-87/003
materials actions operations, it does not address the applica-
Guidance for Conducting Remedial Investigations and Fea-
bility of regulatory limitations and local requirements.
sibility Studies (RI/FS) under CERCLA, October 1988,
1.4 This standard does not purport to address all of the
EPA/9355.3-01
safety concerns, if any, associated with its use. It is the
RCRA Corrective Action Interim Measures Guidance, In-
responsibility of the user of this standard to establish appro-
terim Final, June 1988, EPA/9902.4
priate safety and health practices and determine the applica-
bility of regulatory limitations prior to use.
3. Terminology
2. Referenced Documents 3.1 Definitions:
3.1.1 applicable or relevant and appropriate requirements
2.1 ASTM Standards:
(ARAR)—those requirements, cleanup standards, standards of
E1528 Practice for Limited Environmental Due Diligence:
control, and other substantive environmental protection re-
Transaction Screen Process
quirements, criteria, or limitations promulgated under federal
orstatelawthatshoweitheradirectcorrespondenceoraddress
problems or situations sufficiently similar at a site to show that
This guide is under the jurisdiction of ASTM Committee D34 on Waste
they are well suited for application.
Management and is the direct responsibility of Subcommittee D34.05 on Site
3.1.2 conceptual site model, n—a mental or physical repre-
Remediation.
Current edition approved April 1, 2005. Published May 2005. Originally
sentation of the physical system and the iterative characteriza-
approved in 1995. Last previous approved in 1999 as D5745-95(1999) DOI:
tion of the physical and chemical processes and conditions that
10.1520/D5745-95R05.
For referenced ASTM standards, visit the ASTM website, www.astm.org, or
contact ASTM Customer Service at service@astm.org. For Annual Book of ASTM
Standards volume information, refer to the standard’s Document Summary page on Available from Superintendent of Documents, U.S. Government Printing
the ASTM website. Office, Washington, DC 20402.
Copyright © ASTM International, 100 Barr Harbor Drive, PO Box C700, West Conshohocken, PA 19428-2959, United States.
D5745–95 (2005)
affect the transport of contaminants from sources through pathways, and receptors of environmental contaminants is
environmental media to receptors or potential receptors. gathered, interpreted, and documented. Site characterization
effortstoprovideabasisforthefollowing:(1)thedevelopment
3.1.3 contaminant, n—any substance potentially hazardous
to human health or the environment and present in the of a conceptual site model (CSM), (2) the selection and design
of a site remediation plan, or (3) the measuring point against
environment above background concentration.
which the effectiveness of a remedy can be evaluated, or some
3.1.4 early action, n—any remedial plan initiated in ad-
combination thereof.
vance of a complete or final characterization of a contaminated
3.1.16 site inspection (SI), n—an on-site investigation to
site.
determine whether a release or potential release exists and the
3.1.5 final remedy, n—site restoration.
nature of the associated threats. The purpose is to augment the
3.1.6 interim remedial measure, n—a remedial action that
data collected in the preliminary assessment and to generate, if
implements a partial solution prior to the selection of a final
necessary, sampling and other field data to determine whether
complete remedy. Interim remedial measures may be early
further action or investigation is appropriate.
actions, but they are often not.
3.1.17 site remediation, n—those actions taken in the event
3.1.7 migration, n—the movement of contaminant(s) away
ofareleaseorthreatenedreleaseofahazardoussubstanceinto
fromasourcethroughpermeablesubsurfacemedia(suchasthe
the environment, to prevent or minimize the impact of the
movement of a groundwater plume of contamination) or the
release, or to mitigate a substantial hazard to present or future
movement of contaminant(s) by a combination of surficial and
environmental conditions. This early action may or may not
subsurface processes.
lead to ultimate restoration of the site.
3.1.8 partial remedy, n—an interim or incomplete solution
3.1.18 source, n—the location at which contamination has
intended to be consistent with the expected permanent remedy
entered the natural environment.
for treatment, control, elimination, or management of risk
3.2 Description of Terms Specific to This Standard:
associated with the release of a contaminant to the environ-
3.2.1 significantly above background, adj—the mean con-
ment.
centration of a site contaminant can be shown (by statistical
3.1.9 potential migration pathway, n—the route that may be
analysis of other methods) to be greater than nearby back-
taken by contaminants in the environment as they move or are
ground samples from the same pathway.
transported from the source(s), usually in a downgradient
direction.
4. Summary of Guide
3.1.10 preliminary assessment (PA), n—a review of existing
information and an off-site reconnaissance, if appropriate, to
4.1 The basic activities associated with implementing an
determine whether a release may require additional investiga-
early action are as follows: (1) construction of a CSM and
tionoraction.Apreliminaryassessmentmayincludeanon-site
estimation of risk(s); (2) identification of exposure control
reconnaissance, if appropriate. SeeASTM Guidance forTrans-
pathways amenable to engineered control; (3) development of
action Screen Questionnaire (Practice E1528).
interim or partial solutions, estimation of engineered risk, and
3.1.11 receptor, n—humans or other species potentially at
identification and negotiation of required action levels; (4)
risk from exposure to contaminant(s) at the point(s) of expo-
selection of the desired solution(s); (5) attainment of legal
sure.
authority for implementation of the planned solution(s); (6)
3.1.12 release, n—any spilling, leaking, pumping, emitting, design and execution of the selected solution(s); and (7)
emptying, discharging, injecting, escaping, leaching, dumping,
post-implementation monitoring of the conceptual site model.
and disposing into the environment (including the abandon-
4.2 Five common objectives for an early action are to
ment or discarding of barrels, containers, and other closed
achieve the following: (1) minimize the human or environmen-
receptacles) of any hazardous chemical, extremely hazardous
tal risk exposure, or both; (2) minimize the time required to
substance, or CERCLA hazardous substance.
implement a final remedy; (3) protect resources (for example,
3.1.13 removal, n—the cleanup or removal of released
financial, mineral, and ecological); (4) minimize the complex-
hazardous substances from the environment; such actions as ity of a final remedy; or (5) provide a solution-oriented project
may be necessary to take in the event of the threat of release of
focus, or combination thereof.
hazardous substances into the environment; such actions as
4.3 There are three basic types of partial, short-term or early
may be necessary to monitor, assess, and evaluate the release
action remedies: (1) source control remedies, (2) pathway
or threat of release of hazardous substances; the disposal of
control remedies, and (3) receptor control remedies. It is more
removedmaterial;orthetakingofsuchotheractionsasmaybe
common for early actions to be of the source or receptor
necessary to prevent, minimize, or mitigate damage to the
control type since pathway controls usually require a sophis-
public health or welfare or to the environment, which may
ticated understanding of the dynamics of a conceptual site
otherwise result from a release or threat of release.
model.
3.1.14 short-term measure, n—an early action designed to
4.4 The development of a final remedy is often an iterative
have an authorized duration of less than one year for the
process that evolves frequently with the compilation of new
effective control or management of a contaminant released to
data in the CSM. The development and implementation of
the environment.
early actions that support the final remediation objectives of a
3.1.15 size characterization, n—the process by which infor- project provides maximum benefit when performed as
mation relating to the nature, extent, potential migration promptly as practical.
D5745–95 (2005)
4.5 Early actions, short-term remedies, or interim remedial contamination; and lenders, sureties, and persons of general
measures are effective risk management tools when designed interest within an affected community.
and executed properly. Some common benefits derived from 5.3 This guide is not intended to replace legal requirements
early actions are as follows: (1) human, ecological, and for remediating sites of environmental contamination. This
financialresourcesareprotected;(2)theactualtimerequiredto guide should be used to supplement existing regulatory guid-
remediate an unacceptable environmental condition is mini- ance and to focus remedial efforts toward final remedy solu-
mized or reduced; (3) the geometric magnitude or scale of an tions.
unacceptable environmental condition is reduced; (4) the
6. Procedure
complexity and scope of a final remedial solution is reduced;
6.1 Assembling Required Information—Assemble all avail-
and (5) environmental projects become “solution” oriented.
able information, including the following: historical records,
4.6 Asuccessful strategy for the application of early actions
interviews, previous studies, environmental analytical data,
has been developed. The strategy consists of phases or steps
permits, regulatory guidance and requirements, maps, geologic
that are as follows:
cross sections, engineering infrastructure as-built plans, and
4.6.1 Development of a list of potential proactive early
drawings. At least one site visit by technical personnel tasked
action remedies.
with the responsibility of designing and implementing an early
4.6.2 Identification of candidate sites for early action.
action is required prior to the development of a remedial plan.
4.6.3 Identification of site-specific and easily definable
6.2 Development of the Conceptual Site Model—An initial
CSM components(s).
concept of the site(s) conceptual site model should be devel-
4.6.3.1 Establishing and prioritizing early action objectives
oped using all assembled information. The quality and accu-
for each CSM component.
racy of all information should be assessed both quantitatively
4.6.3.2 Identifying early action alternatives to address each
and qualitatively, and the use of the information should be
objective and identifying anticipated or expected results and
focused on the following:
their impact on final regulations and remedy.
6.2.1 Identification of Contaminants—Identify the environ-
4.6.3.3 Seeking regulatory and public comment, as appro-
mental contaminants for all pathways of a conceptual site
priate.
model. Particular emphasis should be placed on identifying the
4.6.4 Establishmentoffundingavailabilityforearlyactions.
contaminants for any suspected exposure pathways of concern.
4.6.5 Prioritization of early action solutions consistent with
6.2.2 Characterization of Background Conditions—The
the objectives, public response, expected results, and funding
natural and secondary (modified) background concentration of
availability.
contaminants in all conceptual site model pathways must be
4.6.6 Selection and integration of early action solutions.
characterized or estimated in order to design a useful early
4.6.6.1 Selecting criteria for management and measurement
action. This information is necessary in order to develop
of the results and progress of early action.
appropriate action levels, identify possible synergism, estimate
4.6.6.2 Establishing documentation and recording proce-
environmental risk, and identify and design remedial solutions.
dures and requirements for early action implementation and
6.2.3 Contaminant Source Characterization—An under-
effective final remedy implementation.
standing of contaminant source characteristics is essential in
4.6.6.3 Analyzing the validation approach prior to the
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