ASTM D5745-23

Standard Guide for Developing and Implementing Interim and Early Actions for Waste Contamination Site Remediation

SIGNIFICANCE AND USE
5.1 This guide is intended to provide a systematic approach for the application and execution of early actions for purposes of remediating both hazardous and non-hazardous contamination. Iterative development of a CSM is fundamental to the use of this guide.  
5.2 Anticipated users of this guide are owners or operators at sites of environmental contamination; technical professionals involved in the field of environmental site characterization and remediation; environmental regulators, property owners, employees, and residents adjacent to sites of environmental contamination; and lenders, sureties, and persons of general interest within an affected community.  
5.3 This guide is not intended to replace legal requirements for remediating sites of environmental contamination. This guide should be used to supplement existing regulatory guidance and to focus remedial efforts toward final remedy solutions.
Note 2: The quality of the result produced by this standard is dependent on the competence of the personnel performing it, and the suitability of the equipment and facilities used. Agencies that meet the criteria of Practice D3740 are generally considered capable of competent and objective testing/sampling/inspection/etc. Users of this standard are cautioned that compliance with Practice D3740 does not in itself assure reliable results. Reliable results depend on many factors; Practice D3740 provides a means of evaluating some of those factors.
SCOPE
1.1 The purpose of this guide is to assist practitioners in the development, selection, design, and implementation of interim, 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 underground storage tank (UST) programs are equally applicable) in addition to the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA)/National Oil and Hazardous Substances Pollution Contigency Plan (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 operations, it does not address the applicability of regulatory limitations and local requirements.  
1.4 This guide offers an organized collection of information or a series of options and does not recommend a specific course of action. This document cannot replace education or experience and should be used in conjunction with professional judgment. Not all aspects of this guide may be applicable in all circumstances. This ASTM standard is not intended to represent or replace the standard of care by which the adequacy of a given professional service must be judged, nor should this document be applied without consideration of a project’s many unique aspects. The word “Standard” in the title of this document means only that the document has been approved through the ASTM consensus process.  
1.5 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, health, and environmental practices and determine the applicability of regulatory limitations prior to use.  
1.6 This international standard was developed in accordance with internationally recognized principles on standardization established in the Decision on Principles for the Development...

General Information

• Status: Published
• Publication Date: 30-Jun-2023
• ICS: 13.100 - Occupational safety. Industrial hygiene
• Technical Committee: D18 - Soil and Rock
• Drafting Committee: D18.21 - Groundwater and Vadose Zone Investigations

Relations

• Refers: ASTM D3740-23 - Standard Practice for Minimum Requirements for Agencies Engaged in Testing and/or Inspection of Soil and Rock as Used in Engineering Design and Construction
• Effective Date: 01-Nov-2023
• Refers: ASTM D3740-19 - Standard Practice for Minimum Requirements for Agencies Engaged in Testing and/or Inspection of Soil and Rock as Used in Engineering Design and Construction
• Effective Date: 01-Oct-2019
• Refers: ASTM D6235-18 - Standard Practice for Expedited Site Characterization of Vadose Zone and Groundwater Contamination at Hazardous Waste Contaminated Sites
• Effective Date: 15-Dec-2018
• Refers: ASTM E1739-95(2015) - Standard Guide for Risk-Based Corrective Action Applied at Petroleum Release Sites (Withdrawn 2024)
• Effective Date: 01-Apr-2015
• Refers: ASTM D653-14 - Standard Terminology Relating to Soil, Rock, and Contained Fluids
• Effective Date: 01-Aug-2014
• Refers: ASTM D3740-12a - Standard Practice for Minimum Requirements for Agencies Engaged in Testing and/or Inspection of Soil and Rock as Used in Engineering Design and Construction
• Effective Date: 01-May-2012
• Refers: ASTM D3740-12 - Standard Practice for Minimum Requirements for Agencies Engaged in Testing and/or Inspection of Soil and Rock as Used in Engineering Design and Construction
• Effective Date: 01-Mar-2012
• Refers: ASTM D653-11 - Standard Terminology Relating to Soil, Rock, and Contained Fluids
• Effective Date: 01-Sep-2011
• Refers: ASTM D3740-11 - Standard Practice for Minimum Requirements for Agencies Engaged in Testing and/or Inspection of Soil and Rock as Used in Engineering Design and Construction
• Effective Date: 01-Sep-2011
• Refers: ASTM E1739-95(2010)e1 - Standard Guide for Risk-Based Corrective Action Applied at Petroleum Release Sites
• Effective Date: 01-Sep-2010
• Refers: ASTM E2081-00(2010)e1 - Standard Guide for Risk-Based Corrective Action
• Effective Date: 01-Sep-2010
• Refers: ASTM D6235-04(2010) - Standard Practice for Expedited Site Characterization of Vadose Zone and Groundwater Contamination at Hazardous Waste Contaminated Sites
• Effective Date: 01-May-2010
• Refers: ASTM D3740-10 - Standard Practice for Minimum Requirements for Agencies Engaged in Testing and/or Inspection of Soil and Rock as Used in Engineering Design and Construction
• Effective Date: 01-Mar-2010
• Refers: ASTM D653-09 - Standard Terminology Relating to Soil, Rock, and Contained Fluids
• Effective Date: 01-Jan-2009
• Refers: ASTM D653-08a - Standard Terminology Relating to Soil, Rock, and Contained Fluids
• Effective Date: 01-Dec-2008

Overview

ASTM D5745-23: Standard Guide for Developing and Implementing Interim and Early Actions for Waste Contamination Site Remediation provides a comprehensive framework for the development, selection, design, and implementation of interim and early actions for remediating hazardous and non-hazardous contamination at environmental sites. This ASTM guide is designed for use by site owners or operators, environmental professionals, regulators, and other stakeholders involved in environmental site remediation and risk management. The standard aims to support prompt risk reduction while maintaining alignment with regulatory requirements and ultimate remedial goals.

Key Topics

• Iterative Conceptual Site Model (CSM) Development
  • Central to the guide is the formulation and refinement of a Conceptual Site Model, which organizes information about site conditions, contamination sources, migration pathways, and exposed receptors.
• Systematic Early Action Planning
  • Outlines steps such as risk estimation, identification of exposure pathways, formulating early actions, obtaining legal authority, and executing and monitoring remediation actions.
• Types of Early Actions
  • Source control (e.g., containment, removal of contaminated material)
  • Pathway control (e.g., barriers, runoff diversion)
  • Receptor protection (e.g., alternate water supplies, site access restrictions)
• Documentation and Verification
  • Emphasizes the necessity of thorough documentation, public participation, and ongoing evaluation to ensure early action benefits are realized and supportive of final remedy selection.

Applications

Implementing ASTM D5745-23 delivers practical value in several contexts within site remediation and environmental risk management:

• Hazardous and Non-Hazardous Sites: Applies to all forms of waste contamination sites addressed by regulations such as CERCLA, SARA, RCRA, and HSWA.
• Regulatory Compliance Support: Complements existing federal and state regulatory processes, including state Underground Storage Tank programs and the National Oil and Hazardous Substances Pollution Contingency Plan (NCP).
• Site Risk Reduction: Enables rapid intervention to minimize risks to human health and the environment, often resulting in cost savings and reduced timeframes for site closure.
• Stakeholder Engagement: Encourages early involvement of regulators, community members, lending institutions, and property owners to ensure broad support for remedial decisions and activities.
• Comprehensive Remedial Strategy: Integrates early and interim actions into the overall site remediation process, streamlining the pathway to effective and sustainable long-term site management.

Related Standards

Several standards and guidance documents are referenced in ASTM D5745-23, reinforcing its alignment with widely accepted site characterization and remediation practices:

• ASTM D653: Terminology Relating to Soil, Rock, and Contained Fluids
• ASTM D3740: Minimum Requirements for Agencies Engaged in Testing and/or Inspection of Soil and Rock
• ASTM D6235: Practice for Expedited Site Characterization of Vadose Zone and Groundwater Contamination
• ASTM E1689: Guide for Developing Conceptual Site Models for Contaminated Sites
• ASTM E1739 & E2081: Guides for Risk-Based Corrective Action at Petroleum Release Sites and General Applications
• ASTM E2616: Guide for Remedy Selection Integrating Risk-Based and Non-Risk Considerations

Key regulatory documents from the US EPA and other authorities are also referenced for additional guidance on remedial investigations, data quality, and corrective action plans.

---

Keywords: site remediation, early action, interim remedial measures, environmental risk management, hazardous waste, nonhazardous waste, site characterization, conceptual site model, regulatory compliance, ASTM D5745

Standards Content (Sample)

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: D5745 − 23
Standard Guide for
Developing and Implementing Interim and Early Actions for
Waste Contamination Site Remediation
This standard is issued under the fixed designation D5745; 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 (´) indicates an editorial change since the last revision or reapproval.
1. Scope* 1.5 This standard does not purport to address all of the
safety concerns, if any, associated with its use. It is the
1.1 The purpose of this guide is to assist practitioners in the
responsibility of the user of this standard to establish appro-
development, selection, design, and implementation of interim,
priate safety, health, and environmental practices and deter-
short-term, or early action remedies undertaken at sites of
mine the applicability of regulatory limitations prior to use.
waste contamination for the purpose of managing, controlling,
1.6 This international standard was developed in accor-
or reducing risk posed by environmental site contamination.
dance with internationally recognized principles on standard-
Early action remedies and strategies are applicable to the
ization established in the Decision on Principles for the
management of other regulatory processes (for example, state
Development of International Standards, Guides and Recom-
underground storage tank (UST) programs are equally appli-
mendations issued by the World Trade Organization Technical
cable) in addition to the Comprehensive Environmental
Barriers to Trade (TBT) Committee.
Response, Compensation and Liability Act (CERCLA)/
National Oil and Hazardous Substances Pollution Contigency
2. Referenced Documents
Plan (NCP) process. This guide identifies and describes a
2.1 ASTM Standards:
standard process, technical requirements, information needs,
D653 Terminology Relating to Soil, Rock, and Contained
benefits, and strategy for early actions.
Fluids
1.2 This guide is applicable to both nonhazardous and
D3740 Practice for Minimum Requirements for Agencies
hazardous sites of contamination as defined by CERCLA as
Engaged in Testing and/or Inspection of Soil and Rock as
amended by the Superfund Amendments and Reauthorization
Used in Engineering Design and Construction
Act of 1986 (SARA) and the Resource Conservation and
D6235 Practice for Expedited Site Characterization of Va-
Recovery Act (RCRA) as amended by the Hazardous and Solid
dose Zone and Groundwater Contamination at Hazardous
Waste Amendments (HSWA) of 1986.
Waste Contaminated Sites
1.3 To the extent that this guide may be used for hazardous
E1689 Guide for Developing Conceptual Site Models for
materials operations, it does not address the applicability of
Contaminated Sites
regulatory limitations and local requirements.
E1739 Guide for Risk-Based Corrective Action Applied at
Petroleum Release Sites
1.4 This guide offers an organized collection of information
E2081 Guide for Risk-Based Corrective Action
or a series of options and does not recommend a specific
E2616 Guide for Remedy Selection Integrating Risk-Based
course of action. This document cannot replace education or
Corrective Action and Non-Risk Considerations
experience and should be used in conjunction with professional
judgment. Not all aspects of this guide may be applicable in all
2.2 USEPA DocumentsAvailable from United States Envi-
circumstances. This ASTM standard is not intended to repre-
ronmental Protection Agency (EPA), William Jefferson Clinton
sent or replace the standard of care by which the adequacy of
Bldg., 1200 Pennsylvania Ave., NW, Washington, DC 20460,
a given professional service must be judged, nor should this
http://www.epa.gov.
document be applied without consideration of a project’s many
Guidance for Performing Preliminary Assessments under
unique aspects. The word “Standard” in the title of this
CERCLA, September 1991, EPA/9345.0-01A
document means only that the document has been approved
Guidance for Performing Site Inspections under CERCLA,
through the ASTM consensus process.
September 1992, EPA/9345.1-05
This guide is under the jurisdiction of ASTM Committee D18 on Soil and Rock
and is the direct responsibility of Subcommittee D18.21 on Groundwater and For referenced ASTM standards, visit the ASTM website, www.astm.org, or
Vadose Zone Investigations. contact ASTM Customer Service at [e-mail]. For Annual Book of ASTM
Current edition approved July 1, 2023. Published July 2023. Originally approved Standards volume information, refer to the standard’s Document Summary page on
in 1995. Last previous approved in 2015 as D5745 – 15. DOI: 10.1520/D5745-23. the ASTM website.
*A Summary of Changes section appears at the end of this standard
Copyright © ASTM International, 100 Barr Harbor Drive, PO Box C700, West Conshohocken, PA 19428-2959. United States
D5745 − 23
Data Quality Objectives for Remedial Response Activities: 3.2.12 size characterization, n—the process by which infor-
Development Process, EPA/540/G-87/003 mation relating to the nature, extent, potential migration
RCRA Corrective Action Interim Measures Guidance, In- pathways, and receptors of environmental contaminants is
terim Final, June 1988, EPA/9902.4 gathered, interpreted, and documented.
RCRA Corrective Action Plan (Final), May 1994, EPA/
3.2.12.1 Discussion—Site characterization efforts to provide
9902.3-2A
a basis for the following: (1) the development of a conceptual
site model (CSM), (2) the selection and design of a site
3. Terminology
remediation plan, or (3) the measuring point against which the
effectiveness of a remedy can be evaluated, or some combina-
3.1 Definitions—For definitions of common technical terms
tion thereof (see Practice D6235).
in this standard, refer to Terminology D653.
3.2.13 site remediation, n—those actions taken in the event
3.2 Definitions of Terms Specific to This Standard:
of a release or threatened release of a hazardous substance into
3.2.1 applicable or relevant and appropriate requirements
the environment, to prevent or minimize the impact of the
(ARAR)—those requirements, cleanup standards, standards of
release, or to mitigate a substantial hazard to present or future
control, and other substantive environmental protection
environmental conditions.
requirements, criteria, or limitations promulgated under federal
3.2.13.1 Discussion—This early action may or may not lead
or state law that show either a direct correspondence or address
to ultimate restoration of the site.
problems or situations sufficiently similar at a site to show that
they are well suited for application. 3.2.14 source, n—the location at which contamination has
entered the natural environment.
3.2.2 conceptual site model (CSM), n—a written or pictorial
representation of the physical system and the iterative charac-
4. Summary of Guide
terization of the physical and chemical processes and condi-
tions that affect the transport of contaminants from sources
4.1 The basic activities associated with implementing an
through environmental media to receptors or potential recep-
interim or early action are as follows: (1) construction of a
tors (see Guide E1689).
CSM and estimation of risk(s); (2) identification of exposure
control pathways amenable to engineered control; (3) devel-
3.2.3 contaminant, n—any substance potentially hazardous
opment of partial solutions, estimation of engineered risk, and
to human health or the environment present in the environmen-
identification and negotiation of required action levels; (4)
tal media of concern, and for which there exist regulatory
selection of the desired solution(s); (5) attainment of legal
limits.
authority for implementation of the planned solution(s); (6)
3.2.4 early action, n—a remedial plan initiated in advance
design and execution of the selected solution(s); and (7)
of a complete or final characterization of a contaminated site.
post-implementation monitoring of the conceptual site model.
3.2.5 final remedy, n—complete site restoration.
4.2 Five common objectives for an early action are to
3.2.6 interim action, n—a remedial action that implements a
achieve the following: (1) minimize the human or environmen-
partial solution prior to the selection of a final remedy.
tal risk exposure, or both; (2) minimize the time required to
3.2.7 migration, n—the movement of contaminant(s) away
implement a final remedy; (3) protect resources (for example,
from a source through permeable subsurface media (such as the
financial, mineral, and ecological); (4) minimize the complex-
movement of a groundwater plume of contamination) or the
ity of a final remedy; or (5) provide a solution-oriented project
movement of contaminant(s) by a combination of surficial and
focus, or combination thereof.
subsurface processes.
4.3 There are three basic types of interim or early action
3.2.8 potential migration pathway, n—the route that may be
remedies: (1) source control remedies, (2) pathway control
taken by contaminants in the environment as they move or are
remedies, and (3) receptor control remedies. Early actions are
transported from the source(s), usually in a downgradient
commonly categorized as source or receptor control since
direction.
pathway controls usually require a sophisticated understanding
3.2.9 receptor, n—humans or other species potentially at of the conceptual site model dynamics.
risk from exposure to contaminant(s) at the point(s) of expo-
NOTE 1—Some examples of interim and early action remedies include:
sure.
fences; site access controls; warning signs; physical security; covers;
barriers; underground barrier walls; drainage controls; runoff diversion
3.2.10 release, n—any spilling, leaking, pumping, emitting,
barriers; berms; dikes; impoundment areas; capping; neutralizing chemi-
emptying, discharging, injecting, escaping, leaching, dumping,
cals; removal of debris; removal of drums, tanks, containers; removal of
and disposing into the environment (including the abandon-
soil or solid materials; removal of liquids; in-situ treatments; bioremedia-
ment or discarding of barrels, containers, and other closed
tion; alternate water treatment process; provision of alternate potable
receptacles) of any hazardous substance. water sources or supplies; and provision of alternate habitat.
3.2.11 removal, n—immediate, short-term measures in- 4.4 The development of a final remedy is often an iterative
tended to protect people from immediate threats posed by
process that evolves frequently with the compilation of new
contaminants. data in the CSM. Prompt development and implementation of
3.2.11.1 Discussion—Examples are handling, transport, and early actions increases attainment of a project’s remediation
off-site disposal of sources or potential sources. objectives.
D5745 − 23
4.5 Early actions or interim remedial measures are effective contamination; and lenders, sureties, and persons of general
risk management tools when designed and executed properly. interest within an affected community.
Some common benefits derived from early actions include: (1)
5.3 This guide is not intended to replace legal requirements
human, ecological, and financial resources are protected; (2)
for remediating sites of environmental contamination. This
the time required to remediate an unacceptable environmental
guide should be used to supplement existing regulatory guid-
condition is minimized or reduced; (3) decreased geometric
ance and to focus remedial efforts toward final remedy solu-
magnitude or scale of an unacceptable environmental condi-
tions.
tion; (4) minimized complexity and scope of a final remedial
NOTE 2—The quality of the result produced by this standard is
solution; and (5) environmental projects become “solution”
dependent on the competence of the personnel performing it, and the
suitability of the equipment and facilities used. Agencies that meet the
oriented.
criteria of Practice D3740 are generally considered capable of competent
4.6 A successful strategy for the application of early actions
and objective testing/sampling/inspection/etc. Users of this standard are
has been developed. The strategy consists of phases or steps
cautioned that compliance with Practice D3740 does not in itself assure
reliable results. Reliable results depend on many factors; Practice D3740
that include:
provides a means of evaluating some of those factors.
4.6.1 Development of a potential proactive early action
remedies list.
6. Procedure
4.6.2 Identification of early action candidate sites.
4.6.3 Selection of site-specific and easily definable CSM
6.1 Assembling Required Information—Assemble all avail-
component(s).
able information, including the following: historical records,
4.6.3.1 Establishment and prioritization of early action ob-
interviews, previous studies, environmental analytical data,
jectives for each CSM component.
permits, regulatory guidance and requirements, maps, geologic
4.6.3.2 Identification of early action alternatives to address-
cross sections, engineering infrastructure as-built plans, and
ing each objective, anticipated or expected results and their
drawings (see Practice D6235). At least one site visit by
impact on final regulations and remedy.
technical personnel tasked with the responsibility of designing
4.6.3.3 Selection of regulatory and public comment, as
and implementing an early action is required prior to the
appropriate.
development of a remedial plan.
4.6.4 Establishment of funding for early actions.
NOTE 3—For sites subject to USEPA CERCLA additional guidance is
4.6.5 Prioritization of early action solutions consistent with
available by reviewing “Guidance for Performing Preliminary Assess-
the objectives, public response, expected results, and funding
ments under CERCLA” and “Guidance for Performing Site Inspections
availability. under CERCLA.”
4.6.6 Selection and integration of early action solutions.
6.2 Development of the Conceptual Site Model—An initial
4.6.6.1 Determination of appropriate criteria for manage-
concept of the site(s) CSM should be developed using all
ment of early action progress and results.
assembled information (see Guide E1689). The quality and
4.6.6.2 Establishment of documentation and record proce-
accuracy of all information should be assessed both quantita-
dures for early action and effective final remedy implementa-
tively and qualitatively, and the use of the information should
tion.
be focused on the following:
4.6.6.3 Analysis of the validation approach prior to the
6.2.1 Identification of Contaminants—Identify the environ-
implementation of early action.
mental contaminants for all pathways of a CSM. Particular
4.6.7 Preparation and finalization of the early action reme-
emphasis should be placed on identifying the contaminants for
dial plan.
any suspected exposure pathways of concern.
4.6.8 Implementation and documentation of early action
6.2.2 Characterization of Background Conditions—The
activities.
natural and secondary (modified) background concentration of
4.6.8.1 Frequent and periodic validation of early action
contaminants in all CSM pathways must be characterized or
results in comparison to the early action plan and the final
estimated in order to design a useful early action. This
remedial action frequently and periodically.
information is necessary in order to develop appropriate action
4.6.8.2 Frequent and periodic review of early action activi-
levels, identify possible synergism, estimate environmental
ties.
risk, and identify and design remedial solutions.
6.2.3 Contaminant Source Characterization—An under-
5. Significance and Use
standing of contaminant source characteristics is essential in
5.1 This guide is intended to provide a systematic approach
developing a successful early action remedy. At a minimum,
for the application and execution of early actions for purposes
the following source characteristics should be measured or
of remediating both hazardous and non-hazardous contamina-
estimated for a site:
tion. Iterative development of a CSM is fundamental to the use
6.2.3.1 Source location, boundaries, volume, and mass;
of this guide.
6.2.3.2 Hazardous constituents and their concentration at a
source;
5.2 Anticipated users of this guide are owners or operators
6.2.3.3 Time, duration, rate of contaminant release (both
at sites of environmental contamination; technical profession-
als involved in the field of environmental site characterization volume and mass) from a source; and
and remediation; environmental regulators, property owners, 6.2.3.4 Suspected areas (three dimensional) of contaminant
employees, and residents adjacent to sites of environmental migration within a pathway from a point or source release.
D5745 − 23
6.2.4 Potential Migration Pathway Characterization— 6.3.3.1 Each site of environmental contamination has a
Potential migration pathways through the soil, surface water, CSM component appropriate to manage for the control of
air, and ground water must be identified and characterized human or ecological risk. Example of these components
primarily for each source of contamination at a site. The include: (1) surface water diversion and runoff control from a
minimum information or characte
...

This document is not an ASTM standard and is intended only to provide the user of an ASTM standard an indication of what changes have been made to the previous version. Because
it may not be technically possible to adequately depict all changes accurately, ASTM recommends that users consult prior editions as appropriate. In all cases only the current version
of the standard as published by ASTM is to be considered the official document.
Designation: D5745 − 15 D5745 − 23
Standard Guide for
Developing and Implementing Short-Term Measures or
Interim and Early Actions for Waste Contamination Site
Remediation
This standard is issued under the fixed designation D5745; 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 (´) indicates an editorial change since the last revision or reapproval.
1. Scope Scope*
1.1 The purpose of this guide is to assist practitioners in the development, selection, design, and implementation of partial,interim,
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 underground storage tank (UST) programs are equally applicable) in addition
to the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA)/NCP (CERCLA)/National Oil and
Hazardous Substances Pollution Contigency Plan (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 operations, it does not address the applicability of regulatory
limitations and local requirements.
1.4 This guide offers an organized collection of information or a series of options and does not recommend a specific course of
action. This document cannot replace education or experience and should be used in conjunction with professional judgment. Not
all aspects of this guide may be applicable in all circumstances. This ASTM standard is not intended to represent or replace the
standard of care by which the adequacy of a given professional service must be judged, nor should this document be applied
without consideration of a project’s many unique aspects. The word “Standard” in the title of this document means only that the
document has been approved through the ASTM consensus process.
1.5 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 healthsafety, health, and environmental practices and determine
the applicability of regulatory limitations prior to use.
1.6 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.
This guide is under the jurisdiction of ASTM Committee D18 on Soil and Rock and is the direct responsibility of Subcommittee D18.21 on Groundwater and Vadose
Zone Investigations.
Current edition approved Sept. 1, 2015July 1, 2023. Published September 2015July 2023. Originally approved in 1995. Last previous approved in 20092015 as
D5745 – 09.D5745 – 15. DOI: 10.1520/D5745-15.10.1520/D5745-23.
*A Summary of Changes section appears at the end of this standard
Copyright © ASTM International, 100 Barr Harbor Drive, PO Box C700, West Conshohocken, PA 19428-2959. United States
D5745 − 23
2. Referenced Documents
2.1 ASTM Standards:
D653 Terminology Relating to Soil, Rock, and Contained Fluids
E1528D3740 Practice for Limited Environmental Due Diligence: Transaction Screen ProcessMinimum Requirements for
Agencies Engaged in Testing and/or Inspection of Soil and Rock as Used in Engineering Design and Construction
D6235 Practice for Expedited Site Characterization of Vadose Zone and Groundwater Contamination at Hazardous Waste
Contaminated Sites
E1689 Guide for Developing Conceptual Site Models for Contaminated Sites
E1739 Guide for Risk-Based Corrective Action Applied at Petroleum Release Sites
E2081 Guide for Risk-Based Corrective Action
E2616 Guide for Remedy Selection Integrating Risk-Based Corrective Action and Non-Risk Considerations
2.2 Code of Federal Regulations:
Corrective Action or Solid Waste Management Units at Hazardous Waste Management Facilities, Proposed Rule, 27 July 1990,
40 CFR Parts 264, 265, 270, and 271 (55 FR 30797)
Corrective Action Management Units and Temporary Units; Corrective Action Provisions; Final Rule, 16 February 1993, 58 FR
National Oil and Hazardous Substances Pollution Contingency Plan, Final Rule, 8 March 1990, 40 CFR Part 300
2.2 EPA DocumentsUSEPA DocumentsAvailable from United States Environmental Protection Agency (EPA), William Jefferson
Clinton Bldg., 1200 Pennsylvania Ave., NW, Washington, DC 20460, http://www.epa.gov.
CERCLA, Compliance with Other Laws Manual, Part I (Interim Final), August 1988, EPA/9234.1-01
CERCLA, Compliance with Other Laws Manual, Part II: Clean Air Act and Other Environmental Statutes and State
Requirements, August 1989, EPA/9234.1-02
Guidance for Performing Preliminary Assessments under CERCLA, September 1991, EPA/9345.0-01A
Guidance for Performing Site Inspections under CERCLA, September 1992, EPA/9345.1-05
Data Quality Objectives for Remedial Response Activities: Development Process, EPA/540/G-87/003
Guidance for Conducting Remedial Investigations and Feasibility Studies (RI/FS) under CERCLA, October 1988, EPA/
9355.3-01
RCRA Corrective Action Interim Measures Guidance, Interim Final, June 1988, EPA/9902.4
RCRA Corrective Action Plan (Final), May 1994, EPA/9902.3-2A
3. Terminology
3.1 Definitions—For definitions of common technical terms in this standard, refer to Terminology D653.
3.2 Definitions:Definitions of Terms Specific to This Standard:
3.2.1 applicable or relevant and appropriate requirements (ARAR)—those requirements, cleanup standards, standards of control,
and other substantive environmental protection requirements, criteria, or limitations promulgated under federal or state law that
show either a direct correspondence or address problems or situations sufficiently similar at a site to show that they are well suited
for application.
3.2.2 conceptual site model, model (CSM), n—a mental or physicalwritten or pictorial representation of the physical system and
the iterative characterization of the physical and chemical processes and conditions that affect the transport of contaminants from
sources through environmental media to receptors or potential receptors.receptors (see Guide E1689).
3.2.3 contaminant, n—any substance potentially hazardous to human health or the environment and present in the environment
above background concentration.environmental media of concern, and for which there exist regulatory limits.
3.2.4 early action, n—anya remedial plan initiated in advance of a complete or final characterization of a contaminated site.
3.2.5 final remedy, n—complete site restoration.
3.2.6 interim remedial measure, action, n—a remedial action that implements a partial solution prior to the selection of a final
complete remedy. Interim remedial measures may be early actions.remedy.
For referenced ASTM standards, visit the ASTM website, www.astm.org, or contact ASTM Customer Service at [e-mail]. For Annual Book of ASTM Standards
volume information, refer to the standard’s Document Summary page on the ASTM website.
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3.2.7 migration, n—the movement of contaminant(s) away from a source through permeable subsurface media (such as the
movement of a groundwater plume of contamination) or the movement of contaminant(s) by a combination of surficial and
subsurface processes.
3.1.8 partial remedy, n—an interim or incomplete solution intended to be consistent with the expected permanent remedy for
treatment, control, elimination, or management of risk associated with the release of a contaminant to the environment.
3.2.8 potential migration pathway, n—the route that may be taken by contaminants in the environment as they move or are
transported from the source(s), usually in a downgradient direction.
3.1.10 preliminary assessment (PA), n—a review of existing information and an off-site reconnaissance, if appropriate, to
determine whether a release may require additional investigation or action. A preliminary assessment may include an on-site
reconnaissance, if appropriate. See ASTM Guidance for Transaction Screen Questionnaire (Practice E1528).
3.2.9 receptor, n—humans or other species potentially at risk from exposure to contaminant(s) at the point(s) of exposure.
3.2.10 release, n—any spilling, leaking, pumping, emitting, emptying, discharging, injecting, escaping, leaching, dumping, and
disposing into the environment (including the abandonment or discarding of barrels, containers, and other closed receptacles) of
any hazardous chemical, extremely hazardous substance, or CERCLA hazardous substance.
3.2.11 short-term measure, removal, n—an early action designed to have an authorized duration of less than one year for the
effective control or management of a contaminant released to the environment.immediate, short-term measures intended to protect
people from immediate threats posed by contaminants.
3.2.11.1 Discussion—
Examples are handling, transport, and off-site disposal of sources or potential sources.
3.2.12 size characterization, n—the process by which information relating to the nature, extent, potential migration pathways, and
receptors of environmental contaminants is gathered, interpreted, and documented. Site characterization efforts to provide a basis
for the following: (1) the development of a conceptual site model (CSM), (2) the selection and design of a site remediation plan,
or (3) the measuring point against which the effectiveness of a remedy can be evaluated, or some combination thereof.
3.2.12.1 Discussion—
Site characterization efforts to provide a basis for the following: (1) the development of a conceptual site model (CSM), (2) the
selection and design of a site remediation plan, or (3) the measuring point against which the effectiveness of a remedy can be
evaluated, or some combination thereof (see Practice D6235).
3.1.15 site inspection (SI), n—an on-site investigation to determine whether a release or potential release exists and the nature of
the associated threats. The purpose is to augment the data collected in the preliminary assessment and to generate, if necessary,
sampling and other field data to determine whether further action or investigation is appropriate.
3.2.13 site remediation, n—those actions taken in the event of a release or threatened release of a hazardous substance in to into
the environment, to prevent or minimize the impact of the release, or to mitigate a substantial hazard to present or future
environmental conditions. This early action may or may not lead to ultimate restoration of the site.
3.2.13.1 Discussion—
This early action may or may not lead to ultimate restoration of the site.
3.2.14 source, n—the location at which contamination has entered the natural environment.
3.2 Definitions of Terms Specific to This Standard:
3.2.1 removal, n—immediate, short-term responses intended to protect people from immediate threats posed by hazardous waste
sites. Examples are handling, transport, and off-site disposal of sources or potential sources.
3.2.2 significantly above background, adj—the mean concentration of a site contaminant can be shown (by statistical analysis of
other methods) to be enough greater than nearby background samples from the same pathway to be considered significant by the
user.
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4. Summary of Guide
4.1 The basic activities associated with implementing an interim or early action are as follows: (1) construction of a CSM and
estimation of risk(s); (2) identification of exposure control pathways amenable to engineered control; (3) development of interim
or partial solutions, estimation of engineered risk, and identification and negotiation of required action levels; (4) selection of the
desired solution(s); (5) attainment of legal authority for implementation of the planned solution(s); (6) design and execution of the
selected solution(s); and (7) post-implementation monitoring of the conceptual site model.
4.2 Five common objectives for an early action are to achieve the following: (1) minimize the human or environmental risk
exposure, or both; (2) minimize the time required to implement a final remedy; (3) protect resources (for example, financial,
mineral, and ecological); (4) minimize the complexity of a final remedy; or (5) provide a solution-oriented project focus, or
combination thereof.
4.3 There are three basic types of partial, short-term interim or early action remedies: (1) source control remedies, (2) pathway
control remedies, and (3) receptor control remedies. Early actions are commonly categorized as source or receptor control since
pathway controls usually require a sophisticated understanding of the conceptual site model dynamics.
NOTE 1—Some examples of interim and early action remedies include: fences; site access controls; warning signs; physical security; covers; barriers;
underground barrier walls; drainage controls; runoff diversion barriers; berms; dikes; impoundment areas; capping; neutralizing chemicals; removal of
debris; removal of drums, tanks, containers; removal of soil or solid materials; removal of liquids; in-situ treatments; bioremediation; alternate water
treatment process; provision of alternate potable water sources or supplies; and provision of alternate habitat.
4.4 The development of a final remedy is often an iterative process that evolves frequently with the compilation of new data in
the CSM. Prompt development and implementation of early actions increases attainment of a project’s remediation objectives.
4.5 Early actions, short-term remedies, actions or interim remedial measures are effective risk management tools when designed
and executed properly. Some common benefits derived from early actions include: (1) human, ecological, and financial resources
are protected; (2) the time required to remediate an unacceptable environmental condition is minimized or reduced; (3) decreased
geometric magnitude or scale of an unacceptable environmental condition; (4) minimized complexity and scope of a final remedial
solution; and (5) environmental projects become “solution” oriented.
4.6 A successful strategy for the application of early actions has been developed. The strategy consists of phases or steps that
include:
4.6.1 Development of a potential proactive early action remedies list.
4.6.2 Identification of early action candidate sites.
4.6.3 Selection of site-specific and easily definable CSM component(s).
4.6.3.1 Establishment and prioritization of early action objectives for each CSM component.
4.6.3.2 Identification of early action alternatives to addressing each objective, anticipated or expected results and their impact on
final regulations and remedy.
4.6.3.3 Selection of regulatory and public comment, as appropriate.
4.6.4 Establishment of funding for early actions.
4.6.5 Prioritization of early action solutions consistent with the objectives, public response, expected results, and funding
availability.
4.6.6 Selection and integration of early action solutions.
4.6.6.1 Determination of appropriate criteria for management of early action progress and results.
4.6.6.2 Establishment of documentation and record procedures for early action and effective final remedy implementation.
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4.6.6.3 Analysis of the validation approach prior to the implementation of early action.
4.6.7 Preparation and finalization of the early action remedial plan.
4.6.8 Implementation and documentation of early action activities.
4.6.8.1 Frequent and periodic validation of early action results in comparison to the early action plan and the final remedial action
frequently and periodically.
4.6.8.2 Frequent and periodic review of early action activities.
5. Significance and Use
5.1 This guide is intended to provide a systematic approach for the application and execution of early actions for purposes of
remediating both hazardous and non-hazardous contamination. Iterative development of a CSM is fundamental to the use of this
guide.
5.2 Anticipated users of this guide are owners or operators at sites of environmental contamination; technical professionals
involved in the field of environmental site characterization and remediation; environmental regulators, property owners,
employees, and residents adjacent to sites of environmental contamination; and lenders, sureties, and persons of general interest
within an affected community.
5.3 This guide is not intended to replace legal requirements for remediating sites of environmental contamination. This guide
should be used to supplement existing regulatory guidance and to focus remedial efforts toward final remedy solutions.
NOTE 2—The quality of the result produced by this standard is dependent on the competence of the personnel performing it, and the suitability of the
equipment and facilities used. Agencies that meet the criteria of Practice D3740 are generally considered capable of competent and objective
testing/sampling/inspection/etc. Users of this standard are cautioned that compliance with Practice D3740 does not in itself assure reliable results. Reliable
results depend on many factors; Practice D3740 provides a means of evaluating some of those factors.
6. Procedure
6.1 Assembling Required Information—Assemble all available information, including the following: historical records, interviews,
previous studies, environmental analytical data, permits, regulatory guidance and requirements, maps, geologic cross sections,
engineering infrastructure as-built plans, and drawings. drawings (see Practice D6235). At least one site visit by technical personnel
tasked with the responsibility of designing and implementing an early action is required prior to the development of a remedial
plan.
NOTE 3—For sites subject to USEPA CERCLA additional guidance is available by reviewing “Guidance for Performing Preliminary Assessments under
CERCLA” and “Guidance for Performing Site Inspections under CERCLA.”
6.2 Development of the Conceptual Site Model—An initial concept of the site(s) conceptual site model CSM should be developed
using all assembled information. information (see Guide E1689). The quality and accuracy of all information should be assessed
both quantitatively and qualitatively, and the use of the information should be focused on the following:
6.2.1 Identification of Contaminants—Identify the environmental contaminants for all pathways of a conceptual site model. CSM.
Particular emphasis should be placed on identifying the contaminants for any suspected exposure pathways of concern.
6.2.2 Characterization of Background Conditions—The natural and secondary (modified) background concentration of contami-
nants in all conceptual site model CSM pathways must be characterized or estimated in order to design a useful early action. This
information is necessary in order to develop appropriate action levels, identify possible synergism, estimate environmental risk,
and ide
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