ASTM E2205-02
(Guide)Standard Guide for Risk-Based Corrective Action for Protection of Ecological Resources
Standard Guide for Risk-Based Corrective Action for Protection of Ecological Resources
SCOPE
1.1 This is a guide to risk-based corrective action for the protection of ecological resources and supplements the RBCA process (Guide E 2081). The primary objective of the Eco-RBCA process is to provide a flexible framework for a tiered approach to ERA and risk management decision making at chemical release sites. To this end, available guidance documents from various federal and state agencies were reviewed and their common attributes incorporated into this guide, where possible. The Eco-RBCA process complements existing technical and regulatory ecological risk guidance (see 4.2). In particular, it is intended to be compatible with the USEPA programmatic guidelines for ERA (1), guidance for the Superfund program (2), and other USEPA (3) risk assessment and corrective-action programs. Eco-RBCA might also be used in conjunction with corrective action strategies that include human health issues (for example, Guide E 2081).
1.2 Chemical release sites vary greatly in terms of complexity, physical and chemical characteristics, and the risk that they might pose to ecological resources. The Eco-RBCA process, as described in Guide E 2081, recognizes this variability and incorporates a tiered approach that integrates site assessment, response actions, and remedial actions with ERA. The process begins with relatively simple analyses in Tier 1 and, if necessary, proceeds to more detailed evaluations in Tier 2 or Tier 3. The process of gathering and evaluating data is conducted in such a manner that only those data that are necessary for a given tier's decision making are collected at each tier. Hence, this can facilitate effective use of resources and reduce initial data requirements.
1.3 Eco-RBCA is intended to provide a framework for sites not covered under regulatory programs and for sites under regulatory programs that lack specific guidance. Eco-RBCA may also provide a useful framework to help merge several possible approaches into a single approach when multiple regulatory programs apply. The user should be aware of the federal, state, and local corrective action programs and policies that are applicable for the site and, regardless of the program, that agency approvals might be required to implement the process for completing ERAs.
1.4 Various TPDs will need to be made regarding the aspects of Eco-RBCA. These TPDs may cover both the philosophical and methodological aspects, from what values to protect to exactly how the Eco-RBCA process will be performed. TPDs may affect every stage of the process, from the initial site assessment to development and monitoring of the remedy. It is the responsibility of the user to identify the appropriate TPDs. Section 7, Appendix X2, and Guide E 2081 provide more detail regarding TPDs in the Eco-RBCA process.
1.5 The general performance standard for this document requires that:
1.5.1 Applicable TPDs be identified, beginning at the initiation of the Eco-RBCA process, and as appropriate, at later stages;
1.5.2 Data used in the Eco-RBCA process be of sufficient quantity and quality to answer the questions and support the decisions made at the tier of investigation;
1.5.3 Site assessments be distinguished into tiers of appropriate levels of evaluation;
1.5.4 Actions taken should integrate the Eco-RBCA process for the protection of relevant ecological receptors and habitats and RBCA for the protection of human health (see Guide E 2081), as appropriate;
1.5.5 Applicable federal, state, and local laws and regulations be followed; and
1.5.6 Potential adverse effects on relevant ecological receptors and habitats be considered when selecting remedial action alternatives. The remedial action alternatives should be consistent with the TPDs and the RBCA process (see Guide E 2081).
1.6 Ecological resources are the focus of this guide; risks to human health are addressed for petroleum releases and chemical releases in other ASTM RBCA standards (Guides E 1739 and E 2081). There are ...
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Designation: E 2205 – 02
Standard Guide for
Risk-Based Corrective Action for Protection of Ecological
1
Resources
This standard is issued under the fixed designation E 2205; 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.
INTRODUCTION
This guide for risk-based corrective action for the protection of ecological resources (Eco-RBCA)
provides a flexible framework for a tiered approach to ecological risk assessment (ERA) and risk
management decision-making at chemical release sites. The framework of the Eco-RBCA guide
parallels the framework in Guide E 2081 with respect to the tiered approach for data gathering,
evaluationanddecision-making,andshould,whenpossible,beconductedconcurrentwiththebroader
RBCAprocess activities.The Eco-RBCAguide directs the user to Guide E 2081 for development and
implementation of a corrective action program. This guide supplements Guide E 2081 and was
developed after careful consideration of the peer-reviewed published literature and existing federal,
regional, and state ecological risk–assessment guidance. The user of this guide, as defined in 3.1.44,
needs to be familiar with Guide E 2081 and the overall RBCA process. The RBCA process provides
a flexible, technically defensible framework for corrective action that has applicability to a wide range
of sites and chemicals of concern.
ASTM guides are not federal or state regulations; rather, they are consensus standards that can be
followed voluntarily. It is not within the scope of this standard to provide the details of specific
regulatory requirements. Collectively, the Eco-RBCA and RBCA guides provide an integrated
framework to corrective action. Eco-RBCA is intended to complement rather than replace the
decision-making structures of regulatory programs. In addition, Eco-RBCA is intended to provide a
framework for sites not covered under regulatory programs, for sites under regulatory programs that
lackguidance,orforsitesunderprogramswithguidancethatlackdetail.Eco-RBCAmayalsoprovide
a useful framework to help merge an approach when multiple regulatory programs apply. Even when
a site is not currently governed by a regulatory program, consultation with the appropriate regulatory
agency(ies) will ensure regulatory compliance and provide technical guidance.
TheEco-RBCAprocessisintendedtoaccommodateadiversityofsitesandconditionsbyproviding
a framework that can address site-specific needs. The appendixes provide useful technical details and
case study examples, although the application of this guide does not require their use. Eco-RBCA is
a process for evaluating ecological risk and decision making. To facilitate the implementation of
Eco-RBCA, the framework is organized into ten steps and three risk assessment tiers that begin with
relatively simple analyses and progress to more complex assessments as site conditions warrant (see
Fig. 1).Although organized into steps and tiers, the user should recognize that Eco-RBCAprogresses
conceptually in a linear manner, but may not be implemented in a linear manner.The objective should
be to conduct the evaluation in the manner that most appropriately meets the needs and goals of the
assessment. Each tier includes five types of activities that increase in complexity and level of effort
as the evaluation progresses through the RBCAprocess.These activities are (1) planning and scoping,
(2) data and information acquisition, (3) analysis and evaluation, (4) decision making, and (5)
remedial actions. The details of the activities and how they are implemented can vary, depending on
the nature and complexity of the site and the tier level. Early in the Eco-RBCAprocess, assumptions
are biased toward being overly protective (that is, “conservative”) because of uncertainties inherent in
non–site-specificdata.Typically,asthesiteprogressesthroughthetieredevaluation,moresite-specific
information is collected and uncertainty decreases; therefore, less-conservative assumptions can be
used in the evaluation.As understanding of site conditions improves, confidence often increases. The
progression of the evaluation through the tiered process is accompanied by an increasing degree of
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E2205–02
FIG. 1 Eco-RBCA Process Flowchart—Adapted from the RBCA Flowchart (Guide E 2081)
formalization that could include the documentation of a screening-level assessment or the use of
formal ecological risk assessment (ERA) methods. As additional site-speci
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