Standard Guide for Risk-Based Corrective Action Applied at Petroleum Release Sites

SIGNIFICANCE AND USE
The allocation of limited resources (for example, time, money, regulatory oversight, qualified professionals) to any one petroleum release site necessarily influences corrective action decisions at other sites. This has spurred the search for innovative approaches to corrective action decision making, which still ensures that human health and the environment are protected.
The RBCA process presented in this guide is a consistent, streamlined decision process for selecting corrective actions at petroleum release sites. Advantages of the RBCA approach are as follows:
Decisions are based on reducing the risk of adverse human or environmental impacts,
Site assessment activities are focussed on collecting only that information that is necessary to making risk-based corrective action decisions,
Limited resources are focussed on those sites that pose the greatest risk to human health and the environment at any time,
The remedial action achieves an acceptable degree of exposure and risk reduction,
Compliance can be evaluated relative to site-specific standards applied at site-specific point(s) of compliance,
Higher quality, and in some cases faster, cleanups than are currently realized, and
A documentation and demonstration that the remedial action is protective of human health, safety, and the environment.
Risk assessment is a developing science. The scientific approach used to develop the RBSL and SSTL may vary by state and user due to regulatory requirements and the use of alternative scientifically based methods.
Activities described in this guide should be conducted by a person familiar with current risk and exposure assessment methodologies.  
In order to properly apply the RBCA process, the user should avoid the following:
Use of Tier 1 RBSLs as mandated remediation standards rather than screening levels,
Restriction of the RBCA process to Tier 1 evaluation only and not allowing Tier 2 or Tier 3 analyses,
Placing arbitrary time constraints ...
SCOPE
1.1 This is a guide to risk-based corrective action (RBCA), which is a consistent decision-making process for the assessment and response to a petroleum release, based on the protection of human health and the environment. Sites with petroleum release vary greatly in terms of complexity, physical and chemical characteristics, and in the risk that they may pose to human health and the environment. The RBCA process recognizes this diversity, and uses a tiered approach where corrective action activities are tailored to site-specific conditions and risks. While the RBCA process is not limited to a particular class of compounds, this guide emphasizes the application of RBCA to petroleum product releases through the use of the examples. Ecological risk assessment, as discussed in this guide, is a qualitative evaluation of the actual or potential impacts to environmental (nonhuman) receptors. There may be circumstances under which a more detailed ecological risk assessment is necessary (see Ref (1).  
1.2 The decision process described in this guide integrates risk and exposure assessment practices, as suggested by the United States Environmental Protection Agency (USEPA), with site assessment activities and remedial measure selection to ensure that the chosen action is protective of human health and the environment. The following general sequence of events is prescribed in RBCA, once the process is triggered by the suspicion or confirmation of petroleum release:
1.2.1 Performance of a site assessment;
1.2.2 Classification of the site by the urgency of initial response;
1.2.3 Implementation of an initial response action appropriate for the selected site classification;
1.2.4 Comparison of concentrations of chemical(s) of concern at the site with Tier 1 Risk Based Screening Levels (RBSLs) given in a look-up table;
1.2.5 Deciding whether further tier evaluation is warranted, if implementation of interim remedial action...

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Publication Date
31-Aug-2010
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NOTICE: This standard has either been superseded and replaced by a new version or withdrawn.
Contact ASTM International (www.astm.org) for the latest information
´1
Designation: E1739 − 95 (Reapproved2010)
Standard Guide for
Risk-Based Corrective Action Applied at Petroleum Release
Sites
This standard is issued under the fixed designation E1739; 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.
´ NOTE—The units of measurement were editorially revised in November 2010.
1. Scope 1.2.4 Comparison of concentrations of chemical(s) of con-
cern at the site with Tier 1 Risk Based Screening Levels
1.1 This is a guide to risk-based corrective action (RBCA),
(RBSLs) given in a look-up table;
which is a consistent decision-making process for the assess-
1.2.5 Deciding whether further tier evaluation is warranted,
ment and response to a petroleum release, based on the
if implementation of interim remedial action is warranted or if
protection of human health and the environment. Sites with
RBSLs may be applied as remediation target levels;
petroleumreleasevarygreatlyintermsofcomplexity,physical
1.2.6 Collection of additional site-specific information as
andchemicalcharacteristics,andintheriskthattheymaypose
necessary, if further tier evaluation is warranted;
to human health and the environment. The RBCA process
1.2.7 Developmentofsite-specifictargetlevels(SSTLs)and
recognizes this diversity, and uses a tiered approach where
point(s) of compliance (Tier 2 evaluation);
corrective action activities are tailored to site-specific condi-
1.2.8 Comparison of the concentrations of chemical(s) of
tions and risks. While the RBCA process is not limited to a
concern at the site with the Tier 2 evaluation SSTL at the
particular class of compounds, this guide emphasizes the
determined point(s) of compliance or source area(s);
applicationofRBCAtopetroleumproductreleasesthroughthe
use of the examples. Ecological risk assessment, as discussed 1.2.9 Deciding whether further tier evaluation is warranted,
in this guide, is a qualitative evaluation of the actual or ifimplementationofinterimremedialactioniswarranted,orif
potential impacts to environmental (nonhuman) receptors.
Tier 2 SSTLs may be applied as remediation target levels;
There may be circumstances under which a more detailed
1.2.10 Collection of additional site-specific information as
ecological risk assessment is necessary (see Ref (1).
necessary, if further tier evaluation is warranted;
1.2.11 Development of SSTL and point(s) of compliance
1.2 The decision process described in this guide integrates
(Tier 3 evaluation);
risk and exposure assessment practices, as suggested by the
1.2.12 Comparison of the concentrations of chemical(s) of
United States Environmental Protection Agency (USEPA),
concern at the site at the determined point(s) of compliance or
with site assessment activities and remedial measure selection
source area(s) with the Tier 3 evaluation SSTL; and
to ensure that the chosen action is protective of human health
1.2.13 Developmentofaremedialactionplantoachievethe
andtheenvironment.Thefollowinggeneralsequenceofevents
is prescribed in RBCA, once the process is triggered by the SSTL, as applicable.
suspicion or confirmation of petroleum release:
1.3 The guide is organized as follows:
1.2.1 Performance of a site assessment;
1.3.1 Section 2 lists referenced documents,
1.2.2 Classification of the site by the urgency of initial
1.3.2 Section 3 defines terminology used in this guide,
response;
1.3.3 Section 4 describes the significance and use of this
1.2.3 Implementation of an initial response action appropri-
guide,
ate for the selected site classification;
1.3.4 Section 5 is a summary of the tiered approach,
1.3.5 Section 6 presents the RBCAprocedures in a step-by-
step process,
ThisguideisunderthejurisdictionofASTMCommitteeE50onEnvironmental
1.3.6 Appendix X1 details physical/chemical and toxico-
Assessment, Risk Management and CorrectiveAction and is the direct responsibil-
logical characteristics of petroleum products,
ity of Subcommittee E50.04 on Corrective Action.
Current edition approved Sept. 1, 2010. Published November 2010. Originally
1.3.7 Appendix X2 discusses the derivation of a Tier 1
published as ES38–94. Last previous edition E1739–95 (2002). DOI: 10.1520/
RBSL Look-Up Table and provides an example,
E1739-95R10.
1.3.8 Appendix X3 describes the uses of predictive model-
Theboldfacenumbersinparenthesesrefertothelistofreferencesattheendof
this guide. ing relative to the RBCA process,
Copyright © ASTM International, 100 Barr Harbor Drive, PO Box C700, West Conshohocken, PA 19428-2959. United States
´1
E1739 − 95 (2010)
1.3.9 AppendixX4discussesconsiderationsforinstitutional 3.1.7 engineering controls—modifications to a site or facil-
controls, and ity (for example, slurry walls, capping, and point of use water
1.3.10 Appendix X5 provides examples of RBCA applica- treatment) to reduce or eliminate the potential for exposure to
tions. a chemical(s) of concern.
1.4 This guide describes an approach for RBCA. It is 3.1.8 exposure—contact of an organism with chemical(s) of
concern at the exchange boundaries (for example, skin, lungs,
intended to compliment but not supersede federal, state, and
local regulations. Federal, state, or local agency approval may and liver) and available for absorption.
be required to implement the processes outlined in this guide.
3.1.9 exposure assessment—the determination or estimation
(qualitative or quantitative) of the magnitude, frequency,
1.5 The values stated in SI units are to be regarded as
duration, and route of exposure.
standard. No other units of measurement are included in this
standard.
3.1.10 exposure pathway—the course a chemical(s) of con-
cern takes from the source area(s) to an exposed organism.An
1.6 This standard does not purport to address all of the
exposure pathway describes a unique mechanism by which an
safety concerns, if any, associated with its use. It is the
responsibility of the user of this standard to establish appro- individualorpopulationisexposedtoachemical(s)ofconcern
originating from a site. Each exposure pathway includes a
priate safety and health practices and determine the applica-
bility of regulatory limitations prior to use. source or release from a source, a point of exposure, and an
exposure route. If the exposure point differs from the source, a
2. Referenced Documents transport/exposure medium (for example, air) or media also is
3 included.
2.1 ASTM Standards:
3.1.11 exposure route—the manner in which a chemical(s)
E1599Guide for Corrective Action for Petroleum Releases
of concern comes in contact with an organism (for example,
(Withdrawn 2002)
ingestion, inhalation, and dermal contact).
2.2 NFPA Standard:
3.1.12 facility—the property containing the source of the
NFPA 329Handling Underground Releases of Flammable
chemical(s) of concern where a release has occurred.
and Combustible Liquids
3.1.13 hazard index—the sum of two or more hazard quo-
3. Terminology
tientsformultiplechemical(s)ofconcernormultipleexposure
pathways, or both.
3.1 Definitions of Terms Specific to This Standard:
3.1.1 active remediation—actions taken to reduce the con-
3.1.14 hazard quotients—the ratio of the level of exposure
centrations of chemical(s) of concern. Active remediation
of a chemical(s) of concern over a specified time period to a
could be implemented when the no-further-action and passive
reference dose for that chemical(s) of concern derived for a
remediation courses of action are not appropriate.
similar exposure period.
3.1.2 attenuation—the reduction in concentrations of
3.1.15 incremental carcinogenic risk levels—the potential
chemical(s) of concern in the environment with distance and
for incremental carcinogenic human health effects due to
timeduetoprocessessuchasdiffusion,dispersion,absorption,
exposure to the chemical(s) of concern.
chemical degradation, biodegradation, and so forth.
3.1.16 indirect exposure pathways—an exposure pathway
3.1.3 chemical(s) of concern—specific constituents that are
withatleastoneintermediatereleasetoanymediabetweenthe
identified for evaluation in the risk assessment process.
source and the point(s) of exposure (for example, chemicals of
3.1.4 correctiveaction—thesequenceofactionsthatinclude concern from soil through ground water to the point(s) of
site assessment, interim remedial action, remedial action, exposure).
operation and maintenance of equipment, monitoring of
3.1.17 institutional controls—the restriction on use or ac-
progress, and termination of the remedial action.
cess (for example, fences, deed restrictions, restrictive zoning)
3.1.5 direct exposure pathways—an exposure pathway
to a site or facility to eliminate or minimize potential exposure
where the point of exposure is at the source, without a release to a chemical(s) of concern.
to any other medium.
3.1.18 interim remedial action—the course of action to
3.1.6 ecological assessment—a qualitative appraisal of the
mitigate fire and safety hazards and to prevent further migra-
actual or potential effects of chemical(s) of concern on plants
tion of hydrocarbons in their vapor, dissolved, or liquid phase.
and animals other than people and domestic species.
3.1.19 maximum contaminant level (MCL)—a standard for
drinking water established by USEPAunder the Safe Drinking
WaterAct, which is the maximum permissible level of chemi-
For referenced ASTM standards, visit the ASTM website, www.astm.org, or
cal(s) of concern in water that is delivered to any user of a
contact ASTM Customer Service at service@astm.org. For Annual Book of ASTM
public water supply.
Standards volume information, refer to the standard’s Document Summary page on
the ASTM website.
3.1.20 Monte Carlo simulation—aproceduretoestimatethe
The last approved version of this historical standard is referenced on
value and uncertainty of the result of a calculation when the
www.astm.org.
result depends on a number of factors, each of which is also
Available from National Fire Protection Association (NFPA), 1 Batterymarch
Park, Quincy, MA 02169-7471, http://www.nfpa.org. uncertain.
´1
E1739 − 95 (2010)
3.1.21 natural biodegradation—the reduction in concentra- 3.1.34 risk-based screening level/screening levels
tion of chemical(s) of concern through naturally occurring (RBSLs)—risk-based site-specific corrective action target lev-
els for chemical(s) of concern developed under the Tier 1
microbial activity.
evaluation.
3.1.22 petroleum—including crude oil or any fraction
3.1.35 site—thearea(s)definedbytheextentofmigrationof
thereof that is liquid at standard conditions of temperature and
the chemical(s) of concern.
pressure (15.5°C and 10335.6 kg/m ). The term includes
petroleum-based substances comprised of a complex blend of
3.1.36 site assessment—an evaluation of subsurface
hydrocarbons derived from crude oil through processes of
geology, hydrology, and surface characteristics to determine if
separation,conversion,upgrading,andfinishing,suchasmotor
areleasehasoccurred,thelevelsofthechemical(s)ofconcern,
fuels, jet oils, lubricants, petroleum solvents, and used oils.
and the extent of the migration of the chemical(s) of concern.
The site assessment collects data on ground water quality and
3.1.23 point(s) of compliance—a location(s) selected be-
potential receptors and generates information to support reme-
tween the source area(s) and the potential point(s) of exposure
dial action decisions.
where concentrations of chemical(s) of concern must be at or
below the determined target levels in media (for example,
3.1.37 site classification—a qualitative evaluation of a site
ground water, soil, or air). basedonknownorreadilyavailableinformationtoidentifythe
need for interim remedial actions and further information
3.1.24 point(s) of exposure—the point(s) at which an indi-
gathering. Site classification is intended to specifically priori-
vidualorpopulationmaycomeincontactwithachemical(s)of
tize sites.
concern originating from a site.
3.1.38 site-specific target level (SSTL)—risk-basedremedial
3.1.25 qualitative risk analysis—a nonnumeric evaluation
action target level for chemical(s) of concern developed for a
of a site to determine potential exposure pathways and recep-
particular site under the Tier 2 and Tier 3 evaluations.
tors based on known or readily available information.
3.1.39 site-specific—activities,information,anddataunique
3.1.26 reasonable maximum exposure (RME)—the highest
to a particular site.
exposure that is reasonably expected to occur at a site. RMEs
3.1.40 source area(s)—either the location of liquid hydro-
are estimated for individual pathways or a combination of
carbons or the location of highest soil and ground water
exposure pathways.
concentrations of the chemical(s) of concern.
3.1.27 reasonable potential exposure scenario— a situation
3.1.41 target levels—numeric values or other performance
with a credible chance of occurence where a receptor may
criteria that are protective of human health, safety, and the
become directly or indirectly exposed to the chemical(s) of
environment.
concern without considering extreme or essentially impossible
circumstances.
3.1.42 Tier 1 evaluation—a risk-based analysis to develop
non-site-specific values for direct and indirect exposure path-
3.1.28 reasonably anticipated future use—future use of a
ways utilizing conservative exposure factors and fate and
site or facility that can be predicted with a high degree of
transport for potential pathways and various property use
certainty given current use, local government planning, and
categories(forexample,residential,commercial,andindustrial
zoning.
uses).ValuesestablishedunderTier1willapplytoallsitesthat
3.1.29 receptors—persons, structures, utilities, surface
fall into a particular category.
waters, and water supply wells that are or may be adversely
3.1.43 Tier 2 evaluation—arisk-basedanalysisapplyingthe
affected by a release.
direct exposure values established under a Tier 1 evaluation at
3.1.30 reference dose—a preferred toxicity value for evalu-
the point(s) of exposure developed for a specific site and
ating potential noncarcinogenic effects in humans resulting
developmentofvaluesforpotentialindirectexposurepathways
from exposure to a chemical(s) of concern.
at the point(s) of exposure based on site-specific conditions.
3.1.31 remediation/remedial action—activitiesconductedto
3.1.44 Tier 3 evaluation—a risk-based analysis to develop
protect human health, safety, and the environment. These values for potential direct and indirect exposure pathways at
activities include evaluating ris
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