ASTM D5745-95(1999)
(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
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 1999)
Standard Guide for
Developing and Implementing Short-Term Measures or Early
Actions for Site Remediation
This standard is issued under the fixed designation D 5745; 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 (e) indicates an editorial change since the last revision or reapproval.
1. Scope Corrective Action or Solid Waste Management Units at
Hazardous Waste Management Facilities, Proposed Rule,
1.1 The purpose of this guide is to provide guidance for
27July1990,40CFRParts264,265,270,and271(55FR
assisting in the development, selection, design, and implemen-
30797)
tation of partial, short-term, or early action remedies under-
CorrectiveAction Management Units andTemporary Units;
taken at sites of waste contamination for the purpose of
Corrective Action Provisions; Final Rule, 16 February
managing, controlling, or reducing risk posed by environmen-
1993, 58 FR 8658
tal site contamination. Early action remedies and strategies are
National Oil and Hazardous Substances Pollution Contin-
applicable to the management of other regulatory processes
gency Plan, Final Rule, 8 March 1990, 40 CFR Part 300
(for example, state UST programs are equally applicable) in
2.3 EPA Documents
additiontotheComprehensiveEnvironmentalResponse,Com-
CERCLA, Compliance with Other Laws Manual, Part I
pensation and Liability Act (CERCLA)/NCP process. this
(Interim Final), August 1988, EPA/9234.1-01
guide identifies and describes a standard process, technical
CERCLA, Compliance with Other Laws Manual, Part II:
requirements, information needs, benefits, and strategy for
CleanAirAct and Other Environmental Statutes and State
early actions.
Requirements, August 1989, EPA/9234.1-02
1.2 This guide is applicable to both nonhazardous and
Guidance for Performing Preliminary Assessments under
hazardous sites of contamination as defined by CERCLA as
CERCLA, September 1991, EPA/9345.0-01A
amended by the Superfund Amendments and Reauthorization
Guidance for Performing Site Inspections under CERCLA,
Act of 1986 (SARA) and the Resource Conservation and
September 1992, EPA/9345.1-05
RecoveryAct(RCRA)asamendedbytheHazardousandSolid
Data Quality Objectives for Remedial Response Activities:
Waste Amendments (HSWA) of 1986.
Development Process, EPA/540/G-87/003
1.3 To the extent that this guide may be used for hazardous
Guidance for Conducting Remedial Investigations and Fea-
materials actions operations, it does not address the applica-
sibility Studies (RI/FS) under CERCLA, October 1988,
bility of regulatory limitations and local requirements.
EPA/9355.3-01
1.4 This standard does not purport to address all of the
RCRA Corrective Action Interim Measures Guidance, In-
safety concerns, if any, associated with its use. It is the
terim Final, June 1988, EPA/9902.4
responsibility of the user of this standard to establish appro-
priate safety and health practices and determine the applica-
3. Terminology
bility of regulatory limitations prior to use.
3.1 Definitions:
2. Referenced Documents 3.1.1 applicable or relevant and appropriate requirements
(ARAR)—those requirements, cleanup standards, standards of
2.1 ASTM Standards:
control, and other substantive environmental protection re-
E 1528 Practice for Environmental SiteAssessment: Trans-
quirements, criteria, or limitations promulgated under federal
action Screen Process
or state law that show either a direct correspondence or address
2.2 Code of Federal Regulations:
problems or situations sufficiently similar at a site to show that
they are well suited for application.
This guide is under the jurisdiction of ASTM Committee D-34 on Waste
3.1.2 conceptual site model, n—a mental or physical repre-
Management and is the direct responsibility of Subcommittee D34.05 on Site
sentation of the physical system and the iterative characteriza-
Remediation.
tion of the physical and chemical processes and conditions that
Current edition approved June 15, 1995. Published August 1995.
affect the transport of contaminants from sources through
Annual Book of ASTM Standards, Vol 11.04.
Available from Superintendent of Documents, U.S. Government Printing
environmental media to receptors or potential receptors.
Office, Washington, DC 20402.
Copyright © ASTM International, 100 Barr Harbor Drive, PO Box C700, West Conshohocken, PA 19428-2959, United States.
D5745
3.1.3 contaminant, n—any substance potentially hazardous effortstoprovideabasisforthefollowing:(1)thedevelopment
to human health or the environment and present in the of a conceptual site model (CSM), (2) the selection and design
environment above background concentration. of a site remediation plan, or (3) the measuring point against
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
of a release or threatened release of a hazardous substance in to
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
4.1 The basic activities associated with implementing an
information and an off-site reconnaissance, if appropriate, to
early action are as follows: (1) construction of a CSM and
determine whether a release may require additional investiga-
estimation of risk(s); (2) identification of exposure control
tionoraction.Apreliminaryassessmentmayincludeanon-site
pathways amenable to engineered control; (3) development of
reconnaissance, if appropriate. SeeASTM Guidance forTrans-
interim or partial solutions, estimation of engineered risk, and
action Screen Questionnaire (Practice E 1528).
identification and negotiation of required action levels; (4)
3.1.11 receptor, n—humans or other species potentially at
selection of the desired solution(s); (5) attainment of legal
risk from exposure to contaminant(s) at the point(s) of expo-
authority for implementation of the planned solution(s); (6)
sure.
design and execution of the selected solution(s); and (7)
3.1.12 release, n—any spilling, leaking, pumping, emitting,
post-implementation monitoring of the conceptual site model.
emptying, discharging, injecting, escaping, leaching, dumping,
4.2 Five common objectives for an early action are to
and disposing into the environment (including the abandon-
achieve the following: (1) minimize the human or environmen-
ment or discarding of barrels, containers, and other closed
tal risk exposure, or both; (2) minimize the time required to
receptacles) of any hazardous chemical, extremely hazardous
implement a final remedy; (3) protect resources (for example,
substance, or CERCLA hazardous substance.
financial, mineral, and ecological); (4) minimize the complex-
3.1.13 removal, n—the cleanup or removal of released
ity of a final remedy; or (5) provide a solution-oriented project
hazardous substances from the environment; such actions as
focus, or combination thereof.
may be necessary to take in the event of the threat of release of
4.3 There are three basic types of partial, short-term or early
hazardous substances into the environment; such actions as
action remedies: (1) source control remedies, (2) pathway
may be necessary to monitor, assess, and evaluate the release
control remedies, and (3) receptor control remedies. It is more
or threat of release of hazardous substances; the disposal of
common for early actions to be of the source or receptor
removedmaterial;orthetakingofsuchotheractionsasmaybe
control type since pathway controls usually require a sophis-
necessary to prevent, minimize, or mitigate damage to the
ticated understanding of the dynamics of a conceptual site
public health or welfare or to the environment, which may
model.
otherwise result from a release or threat of release.
4.4 The development of a final remedy is often an iterative
3.1.14 short-term measure, n—an early action designed to
process that evolves frequently with the compilation of new
have an authorized duration of less than one year for the
data in the CSM. The development and implementation of
effective control or management of a contaminant released to
early actions that support the final remediation objectives of a
the environment.
project provides maximum benefit when performed as
3.1.15 size characterization, n—the process by which infor- promptly as practical.
mation relating to the nature, extent, potential migration 4.5 Early actions, short-term remedies, or interim remedial
pathways, and receptors of environmental contaminants is measures are effective risk management tools when designed
gathered, interpreted, and documented. Site characterization and executed properly. Some common benefits derived from
D5745
early actions are as follows: (1) human, ecological, and guide should be used to supplement existing regulatory guid-
financialresourcesareprotected;(2)theactualtimerequiredto ance and to focus remedial efforts toward final remedy solu-
remediate an unacceptable environmental condition is mini- tions.
mized or reduced; (3) the geometric magnitude or scale of an
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
developing a successful early action remedy. At a minimum,
implementation of early action.
the following source characteristics should be measured or
4.6.7 Preparation and finalization of the early action reme-
estimated for a site:
dial plan.
6.2.3.1 Source location, boundaries, volume, and mass;
4.6.8 Implementation and documentation of early action
6.2.3.2 Hazardous constituents and their concentration at a
activities.
source;
4.6.8.1 Validating early action results in comparison to the
6.2.3.3 Time, duration, rate o
...
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