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ASTM E 2205 Document Information:
Title
Standard Guide for Risk-Based Corrective Action for Protection of Ecological Resources
ASTM International
Publication Date:
May 10, 2002
Scope:
This is a guide to risk-based corrective action for the protection of
ecological resources and
supplements the RBCA process (Guide E 2081). The primary objective of
the Eco-RBCA process is to
provide a flexible framework for a tiered approach to ERA and risk
management decision making at
chemical release sites. To this end, available guidance documents from
various federal and state
agencies were reviewed and their common attributes incorporated into
this guide, where possible.
The Eco-RBCA process complements existing technical and regulatory
ecological risk guidance (see
4.2). In particular, it is intended to be compatible with the USEPA
programmatic guidelines for ERA
(1), guidance for the Superfund program (2), and other USEPA (3) risk
assessment and
corrective-action programs. Eco-RBCA might also be used in conjunction
with corrective action
strategies that include human health issues (for example, Guide E
2081).
Chemical release sites vary greatly in terms of complexity, physical
and chemical characteristics,
and the risk that they might pose to ecological resources. The
Eco-RBCA process, as described in
Guide E 2081, recognizes this variability and incorporates a tiered
approach that integrates site
assessment, response actions, and remedial actions with ERA. The
process begins with relatively
simple analyses in Tier 1 and, if necessary, proceeds to more detailed
evaluations in Tier 2 or
Tier 3. The process of gathering and evaluating data is conducted in
such a manner that only those
data that are necessary for a given tier's decision making are
collected at each tier. Hence, this
can facilitate effective use of resources and reduce initial data
requirements.
Eco-RBCA is intended to provide a framework for sites not covered
under regulatory programs and for
sites under regulatory programs that lack specific guidance. Eco-RBCA
may also provide a useful
framework to help merge several possible approaches into a single
approach when multiple regulatory
programs apply. The user should be aware of the federal, state, and
local corrective action
programs and policies that are applicable for the site and, regardless
of the program, that agency
approvals might be required to implement the process for completing
ERAs.
Various TPDs will need to be made regarding the aspects of Eco-RBCA.
These TPDs may cover both the
philosophical and methodological aspects, from what values to protect
to exactly how the Eco-RBCA
process will be performed. TPDs may affect every stage of the process,
from the initial site
assessment to development and monitoring of the remedy. It is the
responsibility of the user to
identify the appropriate TPDs. Section 7, Appendix X2, and Guide E
2081 provide more detail
regarding TPDs in the Eco-RBCA process.
The general performance standard for this document requires that:
Applicable TPDs be identified, beginning at the initiation of the
Eco-RBCA process, and as
appropriate, at later stages;
Data used in the Eco-RBCA process be of sufficient quantity and
quality to answer the questions and
support the decisions made at the tier of investigation;
Site assessments be distinguished into tiers of appropriate levels of
evaluation;
Actions taken should integrate the Eco-RBCA process for the protection
of relevant ecological
receptors and habitats and RBCA for the protection of human health
(see Guide E 2081), as
appropriate;
Applicable federal, state, and local laws and regulations be followed;
and
Potential adverse effects on relevant ecological receptors and
habitats be considered when
selecting remedial action alternatives. The remedial action
alternatives should be consistent with
the TPDs and the RBCA process (see Guide E 2081).
Ecological resources are the focus of this guide; risks to human
health are addressed for petroleum
releases and chemical releases in other ASTM RBCA standards (Guides E
1739 and E 2081). There are
many features common to all three of the RBCA guides. These three
guides share the basic elements
of RBCA: (1) site assessment; (2) tiered evaluations of exposure,
effects, and risk; (3) risk-based
decision making; and (4) response, remedial action, and monitoring.
There are a number of
distinctions between human health and ecological risk assessments. For
example, while human health
risk assessments focus on individuals, evaluations of ecological risk
typically focus on
populations, communities, or ecosystems. Exceptions are species or
habitats designated for special
protection (for example, endangered species). Biological data to
support an ERA are more amenable
to direct field observation than are human exposure and
epidemiological data.
The Eco-RBCA process addresses current and potential future risks to
relevant ecological receptors
and habitats at chemical release sites. It is not intended to apply to
current permitted releases
and permit applications.
Eco-RBCA focuses on chemical stressors. However, the user may need to
consider biological or
physical stressors at the site or effects from chemical sources
unrelated to the site.
The process described in this guide integrates the principles of
current ERA practices with site
assessment activities and remedial-action selection to ensure that the
risk management decision
protects ecological resources. Fig. 1 illustrates the following
activities in Eco-RBCA and those
described in Section 7 (7.1-7.10):
Step 1 - Initial Site Assessment;
Step 2 - Decision Point;
Step 3 - Tier 1 Ecological Risk Assessment;
Step 4 - Tier 1 Decision Point;
Step 5 - Tier 2 Ecological Risk Assessment;
Step 6 - Tier 2 Decision Point;
Step 7 - Tier 3 Ecological Risk Assessment;
Step 8 - Tier 3 Decision Point;
Step 9 - Implementing the Remedial Action Program; and
Step 10 - Monitoring Programs (7.10).
The above steps can be applied in a flexible manner. It may not be
necessary to conduct a full tier
of evaluation if existing site information indicates that a subsequent
tier is more applicable to
address site-specific concerns. Where experience indicates that a more
sophisticated assessment is
warranted at a site, the user may elect to proceed conceptually
through any earlier tiers to
conduct a site-specific assessment typical of Tier 2 or Tier 3.
Additionally, the decision points
in Steps 4, 6, and 8 allow the user to exit the tiered evaluation
process and select the
appropriate remedial action once adequate information is available for
decision making.
This guide is organized as follows:
Section 2 lists referenced ASTM documents;
Section 3 defines terminology used in this guide;
Section 4 describes the significance and use of this guide;
Section 5 describes the tiered approach to the Eco-RBCA process;
Sections 6 and 7 presents Eco-RBCA procedures in a step-by-step
process; and
The reference section provides all documents cited in this guide.
This guide also includes the following appendices, which are provided
as supplemental information
and are not included as mandatory sections of this guide:
Appendix X1 presents information related to risk management issues;
Appendix X2 presents issues regarding TPDs;
Appendix X3 presents information on the activities occurring in each
tier of the Eco-RBCA process;
Appendix X4 describes screening criteria and how they can be applied
within the Eco-RBCA framework;
Appendix X5 presents the selection and use of relevant ecological
screening benchmarks;
Appendix X6 includes two examples of the application of the Eco-RBCA
framework; and
Appendix X7 presents information on uncertainty and its role in
Eco-RBCA.
Keywords:
- ecological risk assessment
- remedial action
- risk-based corrective action
- site assessment
- technical policy decisions
- tiered approach
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