ASTM E2081-00(2010)e1

Standard Guide for Risk-Based Corrective Action

SIGNIFICANCE AND USE
The risk-based corrective action (RBCA) process presented in this guide is a consistent, streamlined decision process for selecting corrective actions at chemical release sites.
Risk assessment is a developing science. The scientific approach used to develop the RBSL and SSTL may vary by regulatory agency and by user due to regulatory requirements, guidance and use of alternative scientifically-based methods.
Activities described in this guide should be conducted by persons familiar with current site characterization techniques, remedial action science and technology, current human health risk and exposure assessment methodologies, toxicology, and current ecological evaluation methodologies.
In order to properly apply the RBCA process, the user should AVOID the following:
Prescribing Tier 1 RBSL or RESC as remedial action standards for all sites rather than screening levels,
Limiting use of the RBCA process to Tier 1 evaluation only and not continuing with Tier 2 or Tier 3 analyses for sites where further tier evaluation is appropriate,
Placing arbitrary time constraints on the corrective action process; for example, requiring that Tiers 1, 2, and 3 be completed within time periods that do not reflect the actual urgency of and risks posed by the site,
Using the RBCA process only when active remedial action is not technically feasible, rather than as a process that is applicable during all phases of corrective action,
Conducting active remedial action to achieve only technology-based remedial limits (for example, asymptotic levels) prior to determining applicable corrective action goals,
Using predictive modeling that is not supported by available data or knowledge of site conditions,
Limiting remedial action options to a single class of remedial actions for all sites,
Using unjustified or inappropriate exposure factors,
Using unjustified or inappropriate toxicity parameters,
Failing to consider cumulative risks and additive effects when eva...
SCOPE
1.1 This is a guide for conducting risk-based corrective action (RBCA) at chemical release sites based on protecting human health and the environment. The RBCA is a consistent decision-making process for the assessment and response to chemical releases. Chemical release sites 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 by using a tiered approach that integrates site assessment and response actions with human health and ecological risk assessment to determine the need for remedial action and to tailor corrective action activities to site-specific conditions and risks. The evaluations and methods used in the RBCA process begin with simple analyses in Tier 1 and move to more complex evaluations in either Tier 2 or Tier 3, as applicable. The process of gathering and evaluating data is conducted in a scaled fashion. Consequently, only the data that are necessary for a particular tier's decision-making are collected at that tier.
1.2 This guide describes an approach for risk-based corrective action. It is intended to help direct and streamline the corrective action process and to complement but not to supersede federal, state and local regulations. It can be employed at sites where corrective action is being conducted including sites where there may not be a regulatory framework for corrective action, or where the user wishes to conduct corrective action such as sites in voluntary cleanup programs or under Brownfields initiatives. In addition, it can also be used as a unifying framework when several different agency programs affect the site. Furthermore, the user should be aware of the federal, state and local corrective action programs that are applicable for the site and, regardless of the program, federal, state and local agency approvals may be required to implement the proces...

General Information

• Status: Historical
• Publication Date: 31-Aug-2010
• ICS: 71.020 - Production in the chemical industry
• Technical Committee: E50 - Environmental Assessment, Risk Management and Corrective Action
• Drafting Committee: E50.04 - Corrective Action

Relations

• Replaces: ASTM E2081-00(2004)e1 - Standard Guide for Risk-Based Corrective Action
• Effective Date: 01-Sep-2010
• Referred By: ASTM E2876-13(2020) - Standard Guide for Integrating Sustainable Objectives into Cleanup
• Effective Date: 01-Sep-2010
• Referred By: ASTM D5745-23 - Standard Guide for Developing and Implementing Interim and Early Actions for Waste Contamination Site Remediation
• Effective Date: 01-Sep-2010
• Referred By: ASTM E3155-19 - Standard Guide for Assessing Mammal Health at Chemically Contaminated Terrestrial Sites Using Rodent Sperm Analysis
• Effective Date: 01-Sep-2010
• Referred By: ASTM E2681-21 - Standard Guide for Environmental Management of Underground Storage Tank Systems Storing Regulated Substances
• Effective Date: 01-Sep-2010
• Referred By: ASTM E3300-21 - Standard Guide for NAPL Mobility and Migration in Sediment— Evaluating Ebullition and Associated NAPL/Contaminant Transport
• Effective Date: 01-Sep-2010
• Referred By: ASTM E2531-06(2020) - Standard Guide for Development of Conceptual Site Models and Remediation Strategies for Light Nonaqueous-Phase Liquids Released to the Subsurface
• Effective Date: 01-Sep-2010
• Referred By: ASTM E2205/E2205M-22 - Standard Guide for Risk-Based Corrective Action for Protection of Ecological Resources
• Effective Date: 01-Sep-2010
• Referred By: ASTM E3240-20 - Standard Guide for Risk-Based Corrective Action for Contaminated Sediment Sites
• Effective Date: 01-Sep-2010
• Referred By: ASTM E2790-20 - Standard Guide for Identifying and Complying With Continuing Obligations
• Effective Date: 01-Sep-2010
• Referred By: ASTM E3248-20 - Standard Guide for NAPL Mobility and Migration in Sediment – Conceptual Models for Emplacement and Advection
• Effective Date: 01-Sep-2010
• Referred By: ASTM E2137-22 - Standard Guide for Estimating Monetary Costs and Liabilities for Environmental Matters
• Effective Date: 01-Sep-2010
• Referred By: ASTM E2616-09(2020) - Standard Guide for Remedy Selection Integrating Risk-Based Corrective Action and Non-Risk Considerations
• Effective Date: 01-Sep-2010
• Referred By: ASTM E2435-05(2020) - Standard Guide for Application of Engineering Controls to Facilitate Use or Redevelopment of Chemical-Affected Properties
• Effective Date: 01-Sep-2010
• Referred By: ASTM E3358-23a - Standard Guide for Per- and Polyfluoroalkyl Substances Site Screening and Initial Characterization
• Effective Date: 01-Sep-2010

Standards Content (Sample)

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: E2081 − 00(Reapproved 2010)
Standard Guide for
Risk-Based Corrective Action
This standard is issued under the fixed designation E2081; 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.
ε NOTE—Units information was editorially revised in November 2010.
INTRODUCTION
This guide provides guidance for the development of a Risk-Based Corrective Action (RBCA)
program that integrates the sciences of ecological and human health risk-based decision making into
the corrective action process. The RBCA provides a flexible, technically defensible framework for
correctiveactionthatisapplicabletoawiderangeofsitesandchemical(s)ofconcern.Theframework
incorporates a tiered analytical approach, applying increasingly complex levels of data collection and
analysis as the user proceeds through the process. It provides a starting point for the integration of
multiple regulatory programs into a site-wide corrective action activity and a technically defensible
process for achieving “No FurtherAction.” The successful implementation of the RBCAframework
is dependent on an understanding by the user of the technical policy decisions that are critical to the
risk management process and the identification and determination of these technical policy decisions
prior to beginning the process (see 3.2.60). There are numerous technical policy decisions that must
be made to implement the RBCAprocess, for example, defining data quality objectives, determining
target risk levels and addressing resource protection. It is not the intent of this guide to define
appropriate technical policy decisions. The RBCA process is not intended to replace existing
regulatory programs, but rather to complement these programs. Regardless of whether a corrective
actionisspecificallygovernedbyaregulatoryprogram,theusershouldconsulttheregulatoryagency
requirements to identify the appropriate technical policy decisions prior to implementing the RBCA
process. The RBCA process encourages user-led initiatives and stakeholder involvement in both the
development of the technical policy decisions and the RBCAprogram. It recognizes the diversity of
sitesandprovidesappendixesforpossibleapplicationsandexamples.Theappendixesareprovidedfor
additionalinformationandarenotmandatorysectionsofthisstandardguide.ASTMstandardsarenot
federal or state regulations; they are consensus standards that can voluntarily be followed.
1. Scope the need for remedial action and to tailor corrective action
activities to site-specific conditions and risks. The evaluations
1.1 This is a guide for conducting risk-based corrective
and methods used in the RBCA process begin with simple
action (RBCA) at chemical release sites based on protecting
analyses in Tier 1 and move to more complex evaluations in
human health and the environment. The RBCAis a consistent
either Tier 2 or Tier 3, as applicable. The process of gathering
decision-making process for the assessment and response to
and evaluating data is conducted in a scaled fashion.
chemical releases. Chemical release sites vary greatly in terms
Consequently, only the data that are necessary for a particular
ofcomplexity,physicalandchemicalcharacteristics,andinthe
tier’s decision-making are collected at that tier.
risk that they may pose to human health and the environment.
The RBCA process recognizes this diversity by using a tiered
1.2 This guide describes an approach for risk-based correc-
approach that integrates site assessment and response actions
tive action. It is intended to help direct and streamline the
withhumanhealthandecologicalriskassessmenttodetermine
corrective action process and to complement but not to
supersede federal, state and local regulations. It can be em-
1 ployed at sites where corrective action is being conducted
ThisguideisunderthejurisdictionofASTMCommitteeE50onEnvironmental
Assessment, Risk Management and CorrectiveAction and is the direct responsibil-
includingsiteswheretheremaynotbearegulatoryframework
ity of Subcommittee E50.04 on Corrective Action.
for corrective action, or where the user wishes to conduct
Current edition approved Sept. 1, 2010. Published November 2010. Originally
ε1 correctiveactionsuchassitesinvoluntarycleanupprogramsor
approved in 1998. Last previous edition approved in 2004 as E2081-00 (2004) .
DOI: 10.1520/E2081-00R10E01. underBrownfieldsinitiatives.Inaddition,itcanalsobeusedas
Copyright © ASTM International, 100 Barr Harbor Drive, PO Box C700, West Conshohocken, PA 19428-2959. United States
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E2081 − 00 (2010)
a unifying framework when several different agency programs activities and remedial action selection to ensure that the
affect the site. Furthermore, the user should be aware of the chosen actions are protective of human health and the envi-
federal, state and local corrective action programs that are ronment. The following general sequence of events is pre-
applicable for the site and, regardless of the program, federal, scribed in RBCA:
stateandlocalagencyapprovalsmayberequiredtoimplement
1.8.1 Performaninitialsiteassessmentanddevelopthefirst
the processes outlined in this guide. Finally, regardless of iteration of the site conceptual model. If the information is
whether a corrective action is specifically governed by a
sufficient to demonstrate that there are no complete or poten-
regulatory program, the user should consult the regulatory tially complete exposure pathways, then no further action is
agency requirements to identify the appropriate technical
warranted,
policy decisions prior to implementing the RBCA process.
1.8.2 Evaluate the site (see definition of site 3.2.50) for
response actions (multiple sites at a single facility may require
1.3 Therearenumeroustechnicalpolicydecisionsthatmust
different response actions and times),
be made to implement the RBCA process, for example,
1.8.3 Implement a response action that is appropriate for
defining data quality objectives, determining target risk levels,
conditions found at the site during the site response action
specifying the appropriate statistics and sample sizes for
evaluation,
calculating exposure concentrations, selection of exposure
1.8.4 Define data requirements, develop data quality
assumptions, determining when and how to account for cumu-
objectives, and perform a site assessment for the Tier 1
lative risks and additive effects among chemical(s) of concern
evaluation if the site conceptual model indicates that the tiered
and addressing resource protection. It is not the intent of this
evaluation is appropriate,
guidetodefineappropriatetechnicalpolicydecisions.Theuser
1.8.5 Conductanexposurepathwayanalysistodetermineif
must identify the appropriate technical policy decisions.
relevant ecological receptors and habitats are present and if
1.4 The general performance standard for this guide re-
complete and potentially complete exposure pathways are
quires that:
present. If no relevant ecological receptors or habitats or
1.4.1 Technical policy decisions be identified before begin-
complete and potentially complete exposure pathways exist,
ning the process,
then no further action for relevant ecological receptors and
1.4.2 Data and information collected during the RBCA
habitats is warranted,
process, including historical data as well as new data collected
1.8.6 For potential human exposure pathways, identify the
during the site assessment, will be relevant to and of sufficient
applicable Risk Based Screening Levels (RBSL) and for
quantity and quality to answer the questions posed by and the
potentialecologicalexposurepathways,identifytheapplicable
decisions to be made in the RBCA process,
Relevant Ecological Screening Criteria (RESC). In addition,
1.4.3 Actions taken during the risk-based decision process
identify any Other Relevant Measurable Criteria (ORMC), as
will be protective of human health and the environment,
applicable. Collectively these are the Tier 1 corrective action
1.4.4 Applicable federal, state and local regulations will be
goals for the site;
followed (for example, waste management requirements,
1.8.7 ComparesiteconditionstotheTier1correctiveaction
ground water designations, worker protection) and,
goals determined to be applicable to the site;
1.4.5 Remedial actions implemented will not result in
1.8.8 If site conditions meet the corrective action goals for
higher risk levels than existed before taking actions.
chemical(s) of concern then, no further action is warranted,
1.5 ASTM standards are not federal or state regulations,
1.8.9 If site conditions do not meet corrective action goals
they are consensus standards that can voluntarily be followed.
for chemical(s) of concern then, one or more of the following
1.6 The RBCAprocess is not limited to a particular class of
actions is appropriate:
compounds.ThisguideisintendedtobeacompaniontoGuide
1.8.9.1 Further tier evaluation;
E1739, and does not supersede that document for petroleum
1.8.9.2 Implement interim remedial action;
releases. If a release site contains a mixture of releases of
1.8.9.3 Design and implement remedial action to achieve
petroleum and other chemicals, this guide should be followed.
the corrective action goals.
1.7 The United States Environmental Protection Agency
1.8.10 Define Tier 2 data requirements, data quality
(USEPA) has developed guidance for human health risk
objectives, collect additional site-specific information and
evaluation(seeAppendixX8forotherresources).Manyofthe
update the site conceptual model, as necessary, if further tier
components of this guidance have been integrated into the
evaluation is warranted,
RBCA framework. The science of ecological evaluation and
1.8.11 Develop point(s) of demonstration andTier 2 correc-
theprocessbywhichthescienceisapplied,however,arenotas
tive action goals based on Site-Specific Target Levels (SSTL),
welldefinedandagreeduponashumanhealthriskassessment.
Site-Specific Ecological Criteria (SSEC) or ORMC, where
Therefore, the information provided in this guide for each tier
appropriate, for complete and potentially complete exposure
evaluation for relevant ecological receptors and habitats is
pathways, including exposure pathways for which no RBSL,
general. The user is referred to Appendix X5, which provides
RESC or ORMC, as applicable, were determined;
additional information regarding the development of a RBCA
1.8.12 Compare site conditions to the Tier 2 corrective
framework for protection of ecological resources.
action goals determined to be applicable to the site;
1.8 The decision process described in this guide integrates 1.8.13 If site conditions meet corrective action goals for
exposure and risk assessment practices with site assessment chemical(s) of concern, then no further action is warranted,
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E2081 − 00 (2010)
1.8.14 If site conditions do not meet corrective action goals 2. Referenced Documents
for chemical(s) of concern then, one or more of the following 2
2.1 ASTM Standards:
actions is appropriate:
D5447GuideforApplicationofaGroundwaterFlowModel
1.8.14.1 Further tier evaluation;
to a Site-Specific Problem
D5490Guide for Comparing Groundwater Flow Model
1.8.14.2 Implement interim remedial action;
Simulations to Site-Specific Information
1.8.14.3 Design and implement remedial action to achieve
D5610GuideforDefiningInitialConditionsinGroundwater
the corrective action goals.
Flow Modeling
1.8.15 Define Tier 3 data requirements, data quality objec-
D5611Guide for Conducting a Sensitivity Analysis for a
tivesandcollectadditionalsite-specificinformationandupdate
Groundwater Flow Model Application
the site conceptual model, as necessary, if further tier evalua-
D5612Guide for Quality Planning and Field Implementa-
tion is warranted,
tion of a Water Quality Measurement Program
1.8.16 Developpoint(s)ofdemonstrationandTier3correc-
D5718Guide for Documenting a Groundwater Flow Model
tive action goals based on SSTL, SSEC, or ORMC, where
Application
appropriate;
D5880Guide for Subsurface Flow and Transport Modeling
1.8.17 Compare site conditions to the Tier 3 corrective
D6235Practice for Expedited Site Characterization of Va-
action goals,
dose Zone and Groundwater Contamination at Hazardous
1.8.18 If site conditions meet corrective action goals for Waste Contaminated Sites
chemical(s) of concern, then no further action is warranted, E978Practice for Evaluating Mathematical Models for the
Environmental Fate of Chemicals (Withdrawn 2002)
1.8.19 If site conditions do not meet corrective action goals
E1527PracticeforEnvironmentalSiteAssessments:PhaseI
forchemical(s)ofconcern,thenoneofthefollowingactionsis
Environmental Site Assessment Process
appropriate:
E1599Guide for Corrective Action for Petroleum Releases
1.8.19.1 Implement interim remedial action to facilitate
(Withdrawn 2002)
reassessment of the tier evaluation;
E1689Guide for Developing Conceptual Site Models for
1.8.19.2 Design and implement remedial action to achieve
Contaminated Sites
the corrective action goals.
E1739Guide for Risk-Based Corrective Action Applied at
1.8.20 Develop and implement a monitoring plan based on
Petroleum Release Sites
thecorrectiveactiongoalstovalidatetheassumptionsusedfor
E1903Practice for Environmental Site Assessments: Phase
the tier evaluation and to demonstrate effectiveness of the
II Environmental Site Assessment Process
remedial action, as applicable.
E1912Guide forAccelerated Site Characterization for Con-
firmed or Suspected Petroleum Releases
1.9 For chemical release sites currently in corrective action,
E1943Guide for Remediation of Ground Water by Natural
the user should review information and data available for the
Attenuation at Petroleum Release Sites
site and determine the most appropriate entry point into the
RBCA framework consistent with the general performance
3. Terminology
standards and sequence of events outlined in this guide.
3.1 The reader should review the definitions presented here
1.10 This Guide is Organized as Follows—Section 2 lists
prior to reviewing the guide, as many of the terms included in
referenced documents, Section 3 defines terminology used in
this guide may have different meanings than the specific
this guide, Section 4 describes the significance and use of this
regulatory definitions within existing federal, state or local
guide, Section 5 is a summary of the tiered approach, and
programs.Thefollowingtermsarebeingdefinedtoreflecttheir
Section 6 presents the RBCA procedures in a step-by-step
specificuseinthisguide.Theusershouldnotassumethatthese
proce
...