Standard Guide for Risk-Based Corrective Action

SIGNIFICANCE AND USE
4.1 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.  
4.2 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.  
4.3 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.  
4.4 In order to properly apply the RBCA process, the user should AVOID the following:  
4.4.1 Prescribing Tier 1 RBSL or RESC as remedial action standards for all sites rather than screening levels,  
4.4.2 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,  
4.4.3 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,  
4.4.4 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,  
4.4.5 Conducting active remedial action to achieve only technology-based remedial limits (for example, asymptotic levels) prior to determining applicable corrective action goals,  
4.4.6 Using predictive modeling that is not supported by available data or knowledge of site conditions,  
4.4.7 Limiting remedial action options to a single class of remedial actions for all sites (for example Guide E1943),  
4.4.8 Using unjustified or inappropriate exposure factors,  
4.4.9 Using unjustifie...
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 proce...

General Information

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Publication Date
31-Mar-2022
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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: E2081 − 22
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 (´) 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 activities to site-specific conditions and risks. The evaluations
and methods used in the RBCA process begin with simple
1.1 This is a guide for conducting risk-based corrective
analyses in Tier 1 and move to more complex evaluations in
action (RBCA) at chemical release sites based on protecting
either Tier 2 or Tier 3, as applicable. The process of gathering
human health and the environment. The RBCAis a consistent
and evaluating data is conducted in a scaled fashion.
decision-making process for the assessment and response to
Consequently, only the data that are necessary for a particular
chemical releases. Chemical release sites vary greatly in terms
tier’s decision-making are collected at that tier.
ofcomplexity,physicalandchemicalcharacteristics,andinthe
risk that they may pose to human health and the environment.
1.2 This guide describes an approach for risk-based correc-
The RBCA process recognizes this diversity by using a tiered tive action. It is intended to help direct and streamline the
approach that integrates site assessment and response actions
corrective action process and to complement but not to
withhumanhealthandecologicalriskassessmenttodetermine supersede federal, state and local regulations. It can be em-
the need for remedial action and to tailor corrective action
ployed at sites where corrective action is being conducted
includingsiteswheretheremaynotbearegulatoryframework
for corrective action, or where the user wishes to conduct
1
correctiveactionsuchassitesinvoluntarycleanupprogramsor
ThisguideisunderthejurisdictionofASTMCommitteeE50onEnvironmental
Assessment, Risk Management and CorrectiveAction and is the direct responsibil-
underBrownfieldsinitiatives.Inaddition,itcanalsobeusedas
ity of Subcommittee E50.04 on Corrective Action.
a unifying framework when several different agency programs
Current edition approved April 1, 2022. Published May 2022. Originally
affect the site. Furthermore, the user should be aware of the
approvedin1998.Lastpreviouseditionapprovedin2015asE2081-00(2015).DOI:
10.1520/E2081-22. federal, state and local corrective action
...

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: E2081 − 00 (Reapproved 2015) E2081 − 22
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. A number in parentheses indicates the year of last reapproval. A
superscript epsilon (´) 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
corrective action that is applicable to a wide range of sites and chemical(s) of concern. The framework
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 Further Action.” The successful implementation of the RBCA framework
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 RBCA process, 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
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. The RBCA process encourages user-led initiatives and stakeholder involvement in both the
development of the technical policy decisions and the RBCA program. It recognizes the diversity of
sites and provides appendixes for possible applications and examples. The appendixes are provided for
additional information and are not mandatory sections of this standard guide. ASTM standards are not
federal or state regulations; they are consensus standards that can voluntarily be followed.
1. 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
1
This guide is under the jurisdiction of ASTM Committee E50 on Environmental Assessment, Risk Management and Corrective Action and is the direct responsibility
of Subcommittee E50.04 on Corrective Action.
Current edition approved April 1, 2015April 1, 2022. Published May 2015May 2022. Originally approved in 1998. Last previous edition approved in 20102015 as
ε1
E2081-00 (2010)(2015). . DOI: 10.1520/E2081-00R5.10.1520/E2081-22.
Copyright © ASTM International, 100 Barr Harbor Drive, PO Box C700, West Conshohocken, PA 19428-2959. United States
1

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E2081 − 22
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 feder
...

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