Standard Guide for Remedy Selection Integrating Risk-Based Corrective Action and Non-Risk Considerations

SIGNIFICANCE AND USE
4.1 This guide is intended for use within a RBCA process or other risk-based framework for protection of human health and the environment that is based on an evaluation of sources, exposure pathways, and receptors.  
4.2 This guide is intended to identify the factors that should be considered in the selection and implementation of an appropriate remedial action to address COCs present in environmental media at the site at concentrations above the remedial action levels. The specific process used to select the remedial action will vary widely from site to site. However, in all cases, the selected remedial action should be both a protective remedial action (that is, achieves the risk-based remedial action objectives) and an acceptable remedial action (that is, satisfies the non-risk remedial action objectives).
SCOPE
1.1 This guide covers the selection of appropriate remedial actions at sites where a release of chemicals (for example, vapor-phase, dissolved-phase, or non-aqueous phase liquids (NAPL)) into the environment has occurred. This overall remedy selection process is illustrated in Fig. 1. The guide is intended to be applied within a risk-based corrective action (RBCA) framework.
FIG. 1 Remedy Selection Process  
1.2 The purpose of this guide is to facilitate the selection of acceptable remedial actions and to minimize bad decisions leading to the selection of remedial actions that do not satisfy both the risk-based remedial action objectives and the non-risk remedial action objectives.  
1.3 This guide is intended to be applied at sites that require a remedial action to address unacceptable human heath or ecological risks, other regulatory requirements, and/or other unacceptable site conditions. Prior to use of this guide, a site assessment should be completed resulting in: (1) the establishment of remedial action objectives, (2) a determination that a remedial action is required to achieve the remedial action objectives, (3) an identification of site areas requiring a remedial action, and (4) a conceptual site model that reflects the results of the site assessment. The risk-based remedial action objectives are assumed to have been established using RBCA or another risk-based assessment method that results in the identification of appropriate remedial action objectives based on an evaluation of sources, exposure pathways, and potential receptors. Remedial action objectives may be established using Guide E1739, Guide E2081, and/or Guide E2205. In addition, applicable federal, state, and local regulations, statutes, and policies should be followed and should form the basis for determining risk-based and non-risk remedial action objectives. The remedial action objectives may include resource protection standards and the prevention of aesthetic or nuisance impacts in addition to protection of human health and the environment.  
1.4 Each risk-based remedial action objective for an exposure pathway will typically include numeric remedial action levels for each chemical of concern (COC). Remedial action levels may also be developed for non-risk remedial action objectives such as resource protection standards. The non-risk remedial action levels may include thickness or mobility criteria for NAPL. The selected remedy must be effective and timely for each remedial action objective based on the consideration of the associated exposure pathway or resource protection standard.  
1.5 To facilitate the selection of acceptable remedial actions, this guide establishes a process for remedy selection (Fig. 2) that involves:
FIG. 2 Remedy Selection Flowchart  
FIG. 2 Remedy Selection Flowchart (continued)  
1.5.1 Development of risk-based remedial action objectives that includes identification of complete exposure pathways and numeric remedial action levels (Section 5).  
1.5.2 Development of non-risk remedial action objectives based on resource protection and other non-risk considerations...

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31-Oct-2020
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This international standard was developed in accordance with internationally recognized principles on standardization established in the Decision on Principles for the
Development of International Standards, Guides and Recommendations issued by the World Trade Organization Technical Barriers to Trade (TBT) Committee.
Designation: E2616 − 09 (Reapproved 2020)
Standard Guide for
Remedy Selection Integrating Risk-Based Corrective Action
and Non-Risk Considerations
This standard is issued under the fixed designation E2616; the number immediately following the designation indicates the year of
original adoption or, in the case of revision, the year of last revision.Anumber in parentheses indicates the year of last reapproval.A
superscript epsilon (´) indicates an editorial change since the last revision or reapproval.
1. Scope 1.4 Each risk-based remedial action objective for an expo-
sure pathway will typically include numeric remedial action
1.1 This guide covers the selection of appropriate remedial
levels for each chemical of concern (COC). Remedial action
actions at sites where a release of chemicals (for example,
levels may also be developed for non-risk remedial action
vapor-phase, dissolved-phase, or non-aqueous phase liquids
objectives such as resource protection standards. The non-risk
(NAPL)) into the environment has occurred. This overall
remedial action levels may include thickness or mobility
remedy selection process is illustrated in Fig. 1. The guide is
criteria for NAPL. The selected remedy must be effective and
intended to be applied within a risk-based corrective action
timely for each remedial action objective based on the consid-
(RBCA) framework.
eration of the associated exposure pathway or resource protec-
1.2 The purpose of this guide is to facilitate the selection of
tion standard.
acceptable remedial actions and to minimize bad decisions
1.5 Tofacilitatetheselectionofacceptableremedialactions,
leading to the selection of remedial actions that do not satisfy
this guide establishes a process for remedy selection (Fig. 2)
both the risk-based remedial action objectives and the non-risk
that involves:
remedial action objectives.
1.5.1 Development of risk-based remedial action objectives
1.3 This guide is intended to be applied at sites that require
thatincludesidentificationofcompleteexposurepathwaysand
a remedial action to address unacceptable human heath or
numeric remedial action levels (Section 5).
ecological risks, other regulatory requirements, and/or other
1.5.2 Development of non-risk remedial action objectives
unacceptable site conditions. Prior to use of this guide, a site
basedonresourceprotectionandothernon-riskconsiderations.
assessment should be completed resulting in: (1) the establish-
Resource protection objectives typically include numeric re-
ment of remedial action objectives, (2) a determination that a
medial action levels while other non-risk criteria are typically
remedial action is required to achieve the remedial action
non-numeric and may include: remediation timeframe,
objectives, (3) an identification of site areas requiring a
implementability, cost effectiveness, regulatory compliance,
remedial action, and (4) a conceptual site model that reflects
property use requirements, liability control, and community
the results of the site assessment. The risk-based remedial
concern (Section 5).
action objectives are assumed to have been established using
1.5.3 Evaluation of protectiveness to identify protective
RBCAor another risk-based assessment method that results in
remedial actions that will be effective and timely for each
the identification of appropriate remedial action objectives
risk-based remedial action objective for the site (Section 6).
based on an evaluation of sources, exposure pathways, and
potential receptors. Remedial action objectives may be estab-
1.5.4 Evaluation of the retained remedies using the non-risk
lished using Guide E1739, Guide E2081, and/or Guide E2205.
remedial action objectives to identify acceptable remedial
In addition, applicable federal, state, and local regulations,
actions that satisfy the minimum level for each non-risk
statutes, and policies should be followed and should form the
criterion (Section 7).
basis for determining risk-based and non-risk remedial action
1.5.5 Remedial action selection to select the acceptable
objectives. The remedial action objectives may include re-
remedial action to be implemented at the site (Section 8).
source protection standards and the prevention of aesthetic or
1.5.6 Remedy design and implementation to ensure that the
nuisanceimpactsinadditiontoprotectionofhumanhealthand
selected remedy is effectively implemented at the site and
the environment.
satisfies the remedial action objectives (Section 9).
1.6 This guide is intended for use in the selection of final
ThisguideisunderthejurisdictionofASTMCommitteeE50onEnvironmental
Assessment, Risk Management and CorrectiveAction and is the direct responsibil-
remedial actions. This guide may also be used in the selection
ity of Subcommittee E50.04 on Corrective Action.
of interim measures provided that risk-based remedial action
Current edition approved Nov. 1, 2020. Published November 2020. Originally
objectivesandnon-riskremedialactionobjectivesareavailable
approvedin2009.Lastpreviouseditionapprovedin2014asE2616–09(2014).DOI:
10.1520/E2616-09R20. for the evaluation of these interim measures.
Copyright © ASTM International, 100 Barr Harbor Drive, PO Box C700, West Conshohocken, PA 19428-2959. United States
E2616 − 09 (2020)
FIG. 1 Remedy Selection Process
1.7 The values stated in SI units are to be regarded as 1.8 This guide is not intended to specifically address con-
standard. No other units of measurement are included in this tractor health and safety issues. It is the responsibility of the
standard. user of this guide to ensure that Occupational Safety and
E2616 − 09 (2020)
FIG. 2 Remedy Selection Flowchart
E2616 − 09 (2020)
FIG. 2 Remedy Selection Flowchart (continued)
E2616 − 09 (2020)
Health Administration (OSHA) regulatory requirements are 3.1.2 site assessment—The characterization of a site to
met, and appropriate industry practices are consulted for determinewhetherareleasehasoccurred,theconcentrationsof
guidance.
the COCs in environmental media, and the distribution of the
COCs. The site assessment collects data on soil, groundwater,
1.9 This standard does not purport to address all of the
air,andsurfacewaterquality;sitecharacteristics(forexample,
safety concerns, if any, associated with its use. It is the
subsurface geology, geochemistry, soil properties and
responsibility of the user of this standard to establish appro-
priate safety, health, and environmental practices and deter- structures, hydrology and surface characteristics), land and
resource use, and potential receptors, and generates informa-
mine the applicability of regulatory limitations prior to use.
1.10 This international standard was developed in accor- tion to develop a conceptual site model to support risk-based
dance with internationally recognized principles on standard- decision making.The results of the site assessment are used to
ization established in the Decision on Principles for the
(1) establish remedial action objectives, (2) determine whether
Development of International Standards, Guides and Recom-
a remedial action is required to achieve the remedial action
mendations issued by the World Trade Organization Technical
objectives, (3) identify site areas requiring a remedial action,
Barriers to Trade (TBT) Committee.
and (4)developaconceptualsitemodelthatreflectstheresults
of the site assessment. The site assessment may be conducted
2. Referenced Documents
using Practice D6235 or Guide E1912.
2.1 ASTM Standards:
3.1.3 complete exposure pathway—The route a COC takes
D6235Practice for Expedited Site Characterization of Va-
from the source area(s) to a human or ecological receptor. A
dose Zone and Groundwater Contamination at Hazardous
complete exposure pathway describes a mechanism by which
Waste Contaminated Sites
an individual or population is or could be exposed to COCs
D7294Guide for CollectingTreatment Process Design Data
originating from the site. Each exposure pathway is associated
at a Contaminated Site—A Site Contaminated With
withasource,apointofexposure,andanexposureroute.Ifthe
Chemicals of Interest
exposure point is not at the source, a transport/exposure
E1689Guide for Developing Conceptual Site Models for
mechanism is included.
Contaminated Sites
E1739Guide for Risk-Based Corrective Action Applied at
3.1.4 conceptual site model—The integrated representation
Petroleum Release Sites
of the physical and environmental context, the complete and
E1912Guide forAccelerated Site Characterization for Con-
potentially complete exposure pathways and the potential fate
firmed or Suspected Petroleum Releases (Withdrawn
and transport of chemicals(s) of concern at a site. The site
2013)
conceptual model should include both the current understand-
E1943Guide for Remediation of Ground Water by Natural
ing of the site and the understanding of the potential future
Attenuation at Petroleum Release Sites
conditions and uses for the site. It provides a method to
E2081Guide for Risk-Based Corrective Action
conduct the exposure pathway evaluation, inventory the expo-
E2091Guide for Use of Activity and Use Limitations,
sure pathways evaluated, and determine the status of the
Including Institutional and Engineering Controls
exposure pathways as incomplete, potentially complete, or
E2205Guide for Risk-Based Corrective Action for Protec-
complete.
tion of Ecological Resources
E2435Guide for Application of Engineering Controls to
3.1.5 risk-based remedial action objectives—Aset of objec-
Facilitate Use or Redevelopment of Chemical-Affected
tivesbasedonprotectionofhumanhealthandtheenvironment
Properties
developed for the site that identifies the COCs, affected
E2531Guide for Development of Conceptual Site Models
environmental media, complete exposure pathways, and risk-
and Remediation Strategies for Light Nonaqueous-Phase
based remedial action levels.
Liquids Released to the Subsurface
3.1.6 non-risk remedial action objectives—A set of objec-
3. Terminology tives based on non-risk considerations for current and future
site management. These objectives may include action levels
3.1 Conceptual Model Terms:
based on aesthetic criteria or other resource protection stan-
3.1.1 site—The area(s) defined by the likely physical distri-
dards with non-risk remedial action levels. In addition, these
bution of the COCs from a source area. A site could be an
objectives not directly based on COC concentrations such as:
entirepropertyorfacility,adefinedareaorportionofafacility
remediation timeframe, implementability, cost effectiveness,
or property, or multiple facilities or properties. One facility
regulatory compliance, property use requirements, liability
maycontainmultiplesites.Multiplesitesatonefacilitymaybe
control, and community concern.
addressed individually or as a group.
3.1.7 remedial action levels—Concentrations of COCs in
the source media and/or receptor media below which remedial
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
actions are not required in order to satisfy the remedial action
Standards volume information, refer to the standard’s Document Summary page on
objectives. Non-risk remedial action levels may include re-
the ASTM website.
3 source protection standards not linked to a complete exposure
The last approved version of this historical standard is referenced on
www.astm.org. pathway (that is, the application of drinking water standards to
E2616 − 09 (2020)
water resources not currently used for drinking water). Non- 3.4.9 IC—institutional control
risk remedial action levels may also include thickness or
3.4.10 ITRC—Interstate Technology & Regulatory Council
mobility criteria for NAPL.
3.4.11 NAPL—non-aqueous phase liquids
3.2 Types of Remedial Action Technologies:
3.4.12 NAVFAC—Naval Facilities Engineering Command
3.2.1 removal—A remedial action technology to take envi-
3.4.13 OSHA—OccupationalHealthandSafetyAdministra-
ronmental media away from the site to another location for
tion
storage, processing, or disposal in accordance with all appli-
3.4.14 RBCA—risk-based corrective action
cable requirements.
3.2.2 decontamination—A remedial action technology
4. Significance and Use
based on permanent and irreversible treatment processes to an
4.1 ThisguideisintendedforusewithinaRBCAprocessor
environmental medium so that the threat of release of COCs at
otherrisk-basedframeworkforprotectionofhumanhealthand
concentrations above the remedial action levels is eliminated.
the environment that is based on an evaluation of sources,
3.2.3 activity and use limitation (AUL)—A remedial action
exposure pathways, and receptors.
technology that relies on institutional controls (ICs) or engi-
4.2 This guide is intended to identify the factors that should
neeringcontrols(ECs)(collectively,ICsandECsareknownas
be considered in the selection and implementation of an
“activity and use limitations”) to prevent exposure to COCs
appropriate remedial action to address COCs present in envi-
present in environmental media at concentrations above the
ronmental media at the site at concentrations above the
remedial action levels. An AUL technology can be used to
remedial action levels. The specific process used to select the
eliminateacompleteorpotentiallycompleteexposurepathway
remedial action will vary widely from site to site. However, in
by eliminating the receptor or by preventing transport of the
all cases, the selected remedial action should be both a
COCs to the receptor. AUL measures must be combined with
protective remedial action (that is, achieves the risk-based
appropriate maintenance, monitoring, and any necessary fur-
remedial action objectives) and an acceptable remedial action
ther remedial action to satisfy the remedial action objectives
(that is, satisfies the non-risk remedial action objectives).
and be protective of human health and the environment.
5. Remedial Action Objectives
3.3 Remedy Selection:
3.3.1 remedial action—One or more technologies imple-
5.1 Conceptual Model—Aconceptualmodelisanimportant
mented at a site to address environmental media containing
tool that is utilized in the risk-based remedy selection process.
COCs at concentrations exceeding the remedial action levels
The conceptual model provides a systematic method for use of
defined for the site. A remedial action for a s
...

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