Standard Guide for Risk-Based Corrective Action

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 processes outlined in this guide. Finally, regardless of whether a corrective action is specifically governed by a regulatory program, the user should consult the regulatory agency requirements to identify the appropriate technical policy decisions prior to implementing the RBCA process.
1.3 There are numerous technical policy decisions that must be made to implement the RBCA process, for example, defining data quality objectives, determining target risk levels, specifying the appropriate statistics and sample sizes for calculating exposure concentrations, selection of exposure assumptions, determining when and how to account for cumulative risks and additive effects among chemical(s) of concern and addressing resource protection. It is not the intent of this guide to define appropriate technical policy decisions. The user must identify the appropriate technical policy decisions.
1.4 The general performance standard for this guide requires that:
1.4.1 Technical policy decisions be identified before beginning the process,
1.4.2 Data and information collected during the RBCA process, including historical data as well as new data collected during the site assessment, will be relevant to and of sufficient quantity and quality to answer the questions posed by and the decisions to be made in the RBCA process,
1.4.3 Actions taken during the risk-based decision process will be protective of human health and the environment,
1.4.4 Applicable federal, state and local regulations will be followed (for example, waste management requirements, ground water designations, worker protection) and,
1.4.5 Remedial actions implemented will not result in higher risk levels than existed before taking actions.
1.5 ASTM standards are not federal or state regulations, they are consensus standards that can voluntarily be followed.
1.6 The RBCA process is not limited to a particular class of compounds. This guide is intended to be a companion to Guide E1739, and does not supersede that document for petroleum releases. I...

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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
Designation: E 2081 – 00
Standard Guide for
1
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 (e) indicates an editorial change since the last revision or reapproval.
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 and methods used in the RBCA process begin with simple
analyses in Tier 1 and move to more complex evaluations in
1.1 This is a guide for conducting risk-based corrective
either Tier 2 or Tier 3, as applicable. The process of gathering
action (RBCA) at chemical release sites based on protecting
and evaluating data is conducted in a scaled fashion. Conse-
human health and the environment. The RBCAis a consistent
quently, only the data that are necessary for a particular tier’s
decision-making process for the assessment and response to
decision-making are collected at that tier.
chemical releases. Chemical release sites vary greatly in terms
1.2 This guide describes an approach for risk-based correc-
ofcomplexity,physicalandchemicalcharacteristics,andinthe
tive action. It is intended to help direct and streamline the
risk that they may pose to human health and the environment.
corrective action process and to complement but not to
The RBCA process recognizes this diversity by using a tiered
supersede federal, state and local regulations. It can be em-
approach that integrates site assessment and response actions
ployed at sites where corrective action is being conducted
withhumanhealthandecologicalriskassessmenttodetermine
includingsiteswheretheremaynotbearegulatoryframework
the need for remedial action and to tailor corrective action
for corrective action, or where the user wishes to conduct
activities to site-specific conditions and risks. The evaluations
correctiveactionsuchassitesinvoluntarycleanupprogramsor
underBrownfieldsinitiatives.Inaddition,itcanalsobeusedas
a unifying framework when several different agency programs
1
ThisguideisunderthejurisdictionofASTMCommitteeE50onEnvironmental
affect the site. Furthermore, the user should be aware of the
AssessmentandisthedirectresponsibilityofSubcommitteeE50.04onPerformance
federal, state and local corrective action programs that are
Standards Related to Environmental Regulatory Programs.
applicable for the site and, regardless of the program, federal,
Current edition approvedApril 10, 2000. Published November 2000. Originally
published as PS 104–98. stateandlocalagencyapprovalsmayberequiredtoimplement
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