ASTM E2205/E2205M-02(2009)e1

NOTICE: This standard has either been superseded and replaced by a new version or withdrawn.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: E2205/E2205M − 02(Reapproved 2009)
Standard Guide for
Risk-Based Corrective Action for Protection of Ecological
Resources
ThisstandardisissuedunderthefixeddesignationE2205/E2205M;thenumberimmediatelyfollowingthedesignationindicatestheyear
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.
ε NOTE—The designation and the units of measurement were editorially revised in March 2009.
INTRODUCTION
This guide for risk-based corrective action for the protection of ecological resources (Eco-RBCA)
provides a flexible framework for a tiered approach to ecological risk assessment (ERA) and risk
management decision-making at chemical release sites. The framework of the Eco-RBCA guide
parallels the framework in Guide E2081 with respect to the tiered approach for data gathering,
evaluationanddecision-making,andshould,whenpossible,beconductedconcurrentwiththebroader
RBCAprocess activities. The Eco-RBCAguide directs the user to Guide E2081 for development and
implementation of a corrective action program. This guide supplements Guide E2081 and was
developed after careful consideration of the peer-reviewed published literature and existing federal,
regional, and state ecological risk–assessment guidance. The user of this guide, as defined in 3.1.45,
needs to be familiar with Guide E2081 and the overall RBCA process. The RBCA process provides
a flexible, technically defensible framework for corrective action that has applicability to a wide range
of sites and chemicals of concern.
ASTM guides are not federal or state regulations; rather, they are consensus standards that can be
followed voluntarily. It is not within the scope of this standard to provide the details of specific
regulatory requirements. Collectively, the Eco-RBCA and RBCA guides provide an integrated
framework to corrective action. Eco-RBCA is intended to complement rather than replace the
decision-making structures of regulatory programs. In addition, Eco-RBCA is intended to provide a
framework for sites not covered under regulatory programs, for sites under regulatory programs that
lackguidance,orforsitesunderprogramswithguidancethatlackdetail.Eco-RBCAmayalsoprovide
a useful framework to help merge an approach when multiple regulatory programs apply. Even when
a site is not currently governed by a regulatory program, consultation with the appropriate regulatory
agency(ies) will ensure regulatory compliance and provide technical guidance.
TheEco-RBCAprocessisintendedtoaccommodateadiversityofsitesandconditionsbyproviding
a framework that can address site-specific needs. The appendixes provide useful technical details and
case study examples, although the application of this guide does not require their use. Eco-RBCA is
a process for evaluating ecological risk and decision making. To facilitate the implementation of
Eco-RBCA, the framework is organized into ten steps and three risk assessment tiers that begin with
relatively simple analyses and progress to more complex assessments as site conditions warrant (see
Fig. 1).Although organized into steps and tiers, the user should recognize that Eco-RBCAprogresses
conceptually in a linear manner, but may not be implemented in a linear manner.The objective should
be to conduct the evaluation in the manner that most appropriately meets the needs and goals of the
assessment. Each tier includes five types of activities that increase in complexity and level of effort
as the evaluation progresses through the RBCAprocess.These activities are (1) planning and scoping,
(2) data and information acquisition, (3) analysis and evaluation, (4) decision making, and (5)
remedial actions. The details of the activities and how they are implemented can vary, depending on
the nature and complexity of the site and the tier level. Early in the Eco-RBCAprocess, assumptions
are biased toward being overly protective (that is, “conservative”) because of uncertainties inherent in
non–site-specificdata.Typically,asthesiteprogressesthroughthetieredevaluation,moresite-specific
information is collected and uncertainty decreases; therefore, less-conservative assumptions can be
used in the evaluation.As understanding of site conditions improves, confidence often increases. The
Copyright © ASTM International, 100 Barr Harbor Drive, PO Box C700, West Conshohocken, PA 19428-2959. United States
´1
E2205/E2205M − 02 (2009)
progression of the evaluation through the tiered process is accompanied by an increasing degree of
formalization that could include the documentation of a screening-level assessment or the use of
formal ecological risk assessment (ERA) methods. As additional site-specific information is
developed,theuncertaintyassociatedwithsiteconditionsisreduced.Commensuratewiththisreduced
uncertainty, the user can employ more site-specific and less conservative estimates and assumptions
of exposure and effects. The manner in which uncertainty, conservatism, data quality, and other
technical aspects are addressed is by technical policy decisions.
Technical policy decisions (TPDs) are an important part of the Eco-RBCAprocess, and while it is
not within the scope of this standard to identify the TPDs appropriate for a specific site, Appendix X2
and Guide E2081 provide additional insight into their identification, understanding, and development.
Technical policy decisions generally fall into three categories: (1) those that are identified as existing
priortotheEco-RBCAassessmentandwillnotchange(thatis,prescribedandwithoutflexibilitysuch
as regulations or policy), (2) those that are identified as existing prior to the Eco-RBCA assessment
but may change or be modified based on site-specific information (for example, sampling protocols,
selection of models or other tools, or corrective-action goals), and (3) those that are developed
specifically for the Eco-RBCA assessment (for example, development of a site-specific model).
Technical policy decisions are typically identified, negotiated (if appropriate), and documented in the
initial site assessment (see 7.1). It is the responsibility of the user of the Eco-RBCAguide to identify
andconsidertheTPDsandappropriatestakeholdersforasite.TheseTPDsmayneedtobereevaluated
each time the Eco-RBCA evaluation proceeds through an iteration or progresses to a new tier. Both
the RBCA and Eco-RBCA processes encourage user-led initiatives and appropriate stakeholder
involvement in identifying TPDs and developing the Eco-RBCAprogram. Laws and regulations may
require coordination with federal, state, and natural resource trustees.
This guide serves to complement existing guidance for hazardous-waste sites and facilities and to
provideguidanceforsitesnotunderregulatoryprograms.Thisguidedoesnotsubstituteforapplicable
federal, regional, state, local, or other regulatory requirements.This guide is not a regulation itself and
may not apply to a particular situation, based on the circumstances.
This guide is not intended to replace professional judgment or to recommend a specific course of
action.Allaspectsofthisguidemightnotbeapplicableinallcircumstances.Thisguideisnotintended
to represent or replace the standard of care by which the adequacy of a given professional service is
judged,norshouldthisdocumentbeappliedwithoutconsiderationofaproject’smanyuniqueaspects.
The word “Standard” in the title of this document means only that the document has been approved
through the ASTM consensus process.
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 Feb. 1, 2009. Published March 2009. Originally approved in 2002. Last previous edition approved in 2002 as E2205 – 02. DOI:
10.1520/E2205_E2205M-02R09E01.
´1
E2205/E2205M − 02 (2009)
FIG. 1 Eco-RBCA Process Flowchart—Adapted from the RBCA Flowchart (Guide E2081)
´1
E2205/E2205M − 02 (2009)
FIG. 2 Tier 1 Evaluation Flowchart
´1
E2205/E2205M − 02 (2009)
FIG. 3 Tier 2 Evaluation Flowchart
´1
E2205/E2205M − 02 (2009)
FIG. 4 Tier 3 Evaluation Flowchart
´1
E2205/E2205M − 02 (2009)
1. Scope 1.5.2 Data used in the Eco-RBCA process be of sufficient
quantity and quality to answer the questions and support the
1.1 This is a guide to risk-based corrective action for the
decisions made at the tier of investigation;
protection of ecological resources and supplements the RBCA
1.5.3 Site assessments be distinguished into tiers of appro-
process (Guide E2081). The primary objective of the Eco-
priate levels of evaluation;
RBCA process is to provide a flexible framework for a tiered
1.5.4 Actions taken should integrate the Eco-RBCAprocess
approach to ERA and risk management decision making at
for the protection of relevant ecological receptors and habitats
chemical release sites. To this end, available guidance docu-
and RBCA for the protection of human health (see Guide
ments from various federal and state agencies were reviewed
E2081), as appropriate;
and their common attributes incorporated into this guide,
1.5.5 Applicable federal, state, and local laws and regula-
where possible. The Eco-RBCAprocess complements existing
tions be followed; and
technical and regulatory ecological risk guidance (see 4.2). In
1.5.6 Potential adverse effects on relevant ecological recep-
particular, it is intended to be compatible with the USEPA
programmatic guidelines for ERA (1) , guidance for the tors and habitats be considered when selecting remedial action
alternatives. The remedial action alternatives should be con-
Superfund program (2), and other USEPA (3) risk assessment
andcorrective-actionprograms.Eco-RBCAmightalsobeused sistent with the TPDs and the RBCA process (see Guide
in conjunction with corrective action strategies that include E2081).
human health issues (for example, Guide E2081).
1.6 Ecological resources are the focus of this guide; risks to
1.2 Chemical release sites vary greatly in terms of
human health are addressed for petroleum releases and chemi-
complexity, physical and chemical characteristics, and the risk cal releases in other ASTM RBCA standards (Guides E1739
that they might pose to ecological resources. The Eco-RBCA
and E2081). There are many features common to all three of
process, as described in Guide E2081, recognizes this variabil- the RBCAguides. These three guides share the basic elements
ity and incorporates a tiered approach that integrates site
of RBCA: (1) site assessment; (2) tiered evaluations of
assessment, response actions, and remedial actions with ERA. exposure, effects, and risk; (3) risk-based decision making; and
The process begins with relatively simple analyses in Tier 1
(4) response, remedial action, and monitoring. There are a
and, if necessary, proceeds to more detailed evaluations inTier number of distinctions between human health and ecological
2 or Tier 3. The process of gathering and evaluating data is
riskassessments.Forexample,whilehumanhealthriskassess-
conducted in such a manner that only those data that are ments focus on individuals, evaluations of ecological risk
necessary for a given tier’s decision making are collected at
typically focus on populations, communities, or ecosystems.
each tier. Hence, this can facilitate effective use of resources Exceptions are species or habitats designated for special
and reduce initial data requirements.
protection (for example, endangered species). Biological data
to support an ERA are more amenable to direct field observa-
1.3 Eco-RBCAis intended to provide a framework for sites
tion than are human exposure and epidemiological data.
not covered under regulatory programs and for sites under
regulatory programs that lack specific guidance. Eco-RBCA
1.7 The Eco-RBCA process addresses current and potential
may also provide a useful framework to help merge several
future risks to relevant ecological receptors and habitats at
possible approaches into a single approach when multiple
chemical release sites. It is not intended to apply to current
regulatory programs apply. The user should be aware of the
permitted releases and permit applications.
federal, state,andlocalcorrectiveactionprogramsand policies
1.8 Eco-RBCAfocuses on chemical stressors. However, the
that are applicable for the site and, regardless of the program,
usermayneedtoconsiderbiologicalorphysicalstressorsatthe
that agency approvals might be required to implement the
site or effects from chemical sources unrelated to the site.
process for completing ERAs.
1.9 The process described in this guide integrates the
1.4 Various TPDs will need to be made regarding the
principles of current ERA practices with site assessment
aspects of Eco-RBCA. These TPDs may cover both the
activities and remedial-action selection to ensure that the risk
philosophical and methodological aspects, from what values to
management decision protects ecological resources. Fig. 1
protect to exactly how the Eco-RBCA process will be per-
illustrates the following activities in Eco-RBCA and those
formed. TPDs may affect every stage of the process, from the
described in Section 7 (7.1-7.10):
initial site assessment to development and monitoring of the
1.9.1 Step 1—Initial Site Assessment;
remedy. It is the responsibility of the user to identify the
1.9.2 Step 2—Decision Point;
appropriate TPDs. Section 7, Appendix X2, and Guide E2081
1.9.3 Step 3—Tier 1 Ecological Risk Assessment;
provide more detail regardingTPDs in the Eco-RBCAprocess.
1.9.4 Step 4—Tier 1 Decision Point;
1.5 The general performance standard for this document
1.9.5 Step 5—Tier 2 Ecological Risk Assessment;
requires that:
1.9.6 Step 6—Tier 2 Decision Point;
1.5.1 Applicable TPDs be identified, beginning at the ini-
1.9.7 Step 7—Tier 3 Ecological Risk Assessment;
tiation of the Eco-RBCA process, and as appropriate, at later
stages; 1.9.8 Step 8—Tier 3 Decision Point;
1.9.9 Step 9—Implementing the Remedial Action Program;
2 and
The boldface numbers in parentheses refer to the list of references at the end of
this standard. 1.9.10 Step 10—Monitoring Programs (7.10).
´1
E2205/E2205M − 02 (2009)
1.9.11 The above steps can be applied in a flexible manner. 3. Terminology
It may not be necessary to conduct a full tier
...