Overview of the ASTM Risk-Based Corrective Action (RBCA) Program

John A. Connor, P.E. and Charles J. Neweli, Ph.D., P.E.,

Groundwater Services, Inc., Houston Texas

ABSTRACT

Over the past five years risk-based corrective action (RBCA) has become a
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more important approach for managing releases of chemicals to the

environment. One of the key forces behind this transformation has been
the efforts of American Society for Testing and Materials (ASTM)
committee members who have developed standardized frameworks for
implementing RBCA programs. Currently over 40 states are considering
adoption of RBCA procedures for management of corrective action at
USTs (Underground Storage Tanks) based on an XSTM (American Society
of Testing and Materials) standard issued in 1995. A new ASTM Standard,
Standard Provisional Guide to Risk-Based Corrective Action” (I’S 104-98)
was issued in 1998 and supercedes the older petroleum release standard.
The new standard is more generic, and addrtsses a wide variety of
chemical releases to the environment.

Overall, the new focus on risk-based approaches is a positive

development. A risk-based approach means environmental cleanups can
be conducted on a rationale manner based on tht! actual risk that the site
poses to society, and allows for a flexible approacl- to managing those risks.
Movement towards risk-based approaches does raise a concern that they
will impose greater complexity on site evaluation processes, with
significant variability among states. However, software tools can help to
make make it easier to implement RBCA approtiches at a wide variety of
sites.

ASTM RBCA STANDARDS

In December 1995, the American Society for Tebting and Materials (ASTM)
issued E-1739 “Standard Guide for Risk-Based C lrrective Action Applied at
Petroleum Release Sites”. Under RBCA, exi,+ting EPA risk assessment
practices are integrated with traditional site investigation and remedy
selection activities to identify cost-effective measures for protection of public
health and the environment at each site.

To provide for economical use at both small and large facilities, the RBCA
process has been designed to match the site 1valuation effort to the
relative risk or complexity of each site. For thi: purpose, a three-tiered

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 approach is employed for determination of risk-based cleanup goals,
involving increasingly sophisticated levels of data collection and analysis.
Under Tier 2, anticipated to be the key tier for most sites, Site-Specific
Target Levels (SSTLs) for soil and groundwater cleanup goals are
determined on the basis of site-specific information and/or points of
exposure. Simple analytical models are employed in conjunction with
additional site data to calculate Tier 2 SSTL values in a manner consistent
with EPA-recommended practices.
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In 1998, ASTM expanded the E-1739 RBCA standard to establish a

comprehensive process for management of both human health and
ecological risks associated with a wide variety of chemical releases to soil
or groundwater, not just petroleum releases This new standard,
“Standard Provisional Guide to Risk-Based Corrective Action” (PS 104-98),
while retaining the same tiered approach to risk-based soil and
groundwater cleanup goals, is more generic and supercedes the previous
standard.

OVERVIEW OF RBCA PROCESS

Both the E-1739 and the newer PS 104-98 ASTM RBCA standards represent a
streamlined approach for assessment and response to subsurface
contamination associated with hydrocarbon releases. These standards
integrate EPA risk assessment practices with traditional site investigation and
remedy selection activities in order to determine cost-effective measures for
protection of human health and environmental I-esources.

Under this integrated approach, petroleum release sites are characterized in

terms of sources, transport mechanisms, and receptors (see Figure 1).
Remedial measures are then applied as needed to prevent human or
environmental exposure to harmful levels of site constituents. Such risk-
based corrective action can be achieved by addressing any step in the exposure
process: i) removing or treating the source, ii) interrupting contaminant
transport mechanisms, or iii) controlling activities at the point of exposure.

Human or ecological
and affected media

Air, soil, groundwater, or

surface water migration
mechanisms

FIGURE 1. CONCEPTUAL EXPOSURE MODEL

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 RISK ASSESSMENT AND RESPONSE: BASIC STEPS

The risk-based site evaluation process can be distilled to four basis steps
shared by almost all risk-based regulatory programs:

Step 1. Site Assessment: Collect site information to characterize soil and

groundwater impacts and identify potential receptors. Key data needs
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include site soil and groundwater conditions, location of actual and

potential receptors, and concentrations of chemicals of concern in
various media (i.e., soil and groundwater).

Step 2. Exposure Assessment: Conduct exposure pathway screening

analysis to identify those exposure conditions which could apply to the
site (commonly based on the presence/absence of source media or
receptor and the presence/absence of chemicals above the threshold
screening level). For each applicable pathway, evaluate potential
exposure levels.

Step 3. Protective Standards: Compare potential exposure conditions to

protective criteria. Identify those affected media zones and chemicals
which pose a potentially harmful conditions (i.e., exceed the protective
criteria established for each area of concern). The calculations can either
be performed in a forward mode, where one compares the actual risk at
the site to protective criteria defined by regulatory agencies, or a
backward mode, where cleanup standards at the receptor are used to
generate cleanup standards at the source. Software is available to make
these calculations easier by combining fate and transport models,
standard risk assessment exposure factors, chemical/ toxicological
databases, and regulatory agency-mandated target risks in one integrated
package (Figure 2). These tools allow users to easily calculate the risks
associated with a particular site (the forward calculation) and calculate
cleanup standards for the source zone at a site that will be protective of
human health and the environment.

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Cleanup Level Calculation

Figure 2. Calculation Flowchart for Risk-Based Corrective Action (RBCA)

Software (from GSI RBCA Tool Kit)

Step 4. Response Action: Develop corrective action strategy to minimize risk

by preventing exposure to harmful levels of chemicals. Appropriate
measures may involve: i) removal/treatment of affected media, ii)
containment measures to prevent exposure to $oil or groundwater left in
place, and/or iii) instittltional controls, such as deed recordation, to limit
future uses of the property as needed to prevent unsafe exposure conditions
(e.g., limit use of a property to commercial/industrial uses with no
groundwater extraction). Each of these measures may successfully achieve
the risk protection criteria. Consequently, the choice among these options is
not a risk-based decision but a function of technical and economic
considerations as well as land use plans. The fmal response action should
serve the achieve the applicable protective standards while preserving the
active and productive use of the property.

The complete RBCA process is shown in the process flowchart shown on

Figure 3. As shown, based upon available site information, a site
classification step is completed to characterize the relative magnitude and
immediacy of site risks and prescribe immediate response actions (Step 2 on
Figure 3). After any acufe or near-term hazards have been properly addressed,
risk-based cleanup standards are developed to protect against potential
chronic health or environmental impacts associated with long-term exposure
to low levels of contaminants (Steps 3 - 7 on Figure 3). To achieve the final
risk management goals, the remedial action program may involve i) source
removal/treatment, ii) containment measures, iii) institutional controls, or
iv) some combination thereof. Feedback loops are included in the flowchart

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 to show how the RBCA process is intended to be an interative, flexible system
that accounts for new information from site characterication, remedial action,
and compliance monitoring.
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SiteCIasslficatlon a&l tnitial Response Action

- Classify site per specified scenarios and implement appropriate
lnltial response action. _ * Conduct partial source removal
or other action to reduce risk(s)
* Reclassify site as a propnate following lnltial and interim response and adjust site classification.
actions or additiona Pdata collection.

* Identify reasonable potential sources. transport pathways. ald

exposure pathways. I
- Select appropriate Tier 1 Fink-Based Screening Levels (RESLs) from
Tier 1 ‘Look-up Table’ or other relevant crrteria (taste. odor thresholds,
etc). Compare these values with site conditions.

r
I -.-.-... ----. ~--.--. .- .-- -.’ ~--.
I_ .“._. Tier 2 t+uation
..__
, Collect additional sate data as needed.
4
( - Conduct Tier 2 assessment per speafled procedures CampIre Tier 2
i Me-Speclfn Target Levels (SSTLs) wth site conditions

* Conduct Tier 3 assessment per specified procedures. Compctre Tier 3

Site-Spedfic Target Levels (SSTLs) with site condltlons

) j Step 8 L-

I
jc. .,I./ XI\.

l.l .- --...“-l.Remedial
_.._I AMion
..,... -I Program
..__
* Identify cost-elfective means of achiewng final correctwe acwn goals,
1. rncluding combinations of remedialion, natural attenuation. apd
Institutional conlrols. Implement Ihe preferred alternatIve.

Step 9 -3-

CompliananLMonitoring
Step 10 * Conduct monitoring program as needed to confirm that corrective ~-
action goals are satisfied.

FIGURE 3. ASTM RISK-BASED CORRECTIVE ACTION (RBCA) FLOWCHART

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 RBCA TOOL KIT FOR CHEMICAL RELEASES

The RBCA Tool Kit for Chemical Releases (Connor et al., 1998; www.gsi-
net.com), was developed expressly for use with the Tier 1 and Tier 2 site
evaluation procedures outlined in the new ASTM PS 104-98 RBCA Standard.
The RBCA Tool Kit combines fate-and-transport modeling, risk
characterization functions, and site-specific data supplied by the user (see
Connor et al., 1996 for parameter estimation guidelines) to compute the
following:
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0 Exposure Concentrations
0 Average Daily Intake
0 Baseline Risk Levels
0 Risk-Based Media Cleanup Le\ els
Key RBCA Tool Kit features are outlined below (from Connor et al, 1998).

Model Calculation Functions

The RBCA Tool Kit can calculate either baseline risk levels or cleanup
standards for each complete exposure pathway identified by the user using a
system of ten analytical models linked to internal libraries of standard
exposure factors and chemical/toxicological data for over 90 compounds. The
following calculation steps are performed by the system:
0 Exposure Concentrations: Based on representative concentrations of
constituents of concern (COCs) present in the affected source media,
maximum steady-state concentrations likely to occur at the point of
exposure (POE) are calculated using the steady-state analytical fate-and-
transport models identified in Appendix X3 of ASTM PS 104-98. To perform
these calculations, the system evaluates cross-media partitioning (e.g.,
volatilization from soil to air) and lateral transport from the source to the
POE (e.g., contaminant transport via air or groundwater flow). The source
media and optional exposure pathways included in the software are:
SQURCE~MEDIA : EXfC?OSURE~PATWBYS < ; ,I

Surface Soils 0 Inhalation of Vapor and Particulates

0 Dermal Contact with Soil
0 Ingestion of Soil ,tnd Dust
0 Leaching to Groundwater
Subsurface Soils 0 Inhalation of Vapor
0 Leaching to Groundwater
Groundwater 0 Ingestion of Potable Water
0 Inhalation of Val)or
0 Discharge to Surtace Water
- Ingestion/Derma I Contact via Swimming
- Ingestion via Fish Consumption
- Aquatic Life Protection

0 Average Daily Intake: Based upon the exposure factors selected by the user,
the average daily chemical intake for each receptor along each selected

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 pathway is calculated in accordance with EPA guidelines (see Connor et al.,
1998). These values are used in baseline risk calculations for each complete
pathway.
Baseline Risk Characterization: Human health risks associated with
exposure to COCs are calculated by the software on the basis of average
daily intake rates and the corresponding toxicological parameters for
carcinogenic and non-carcinogenic effects. For each complete pathway, the
system output provides both individual and additive constituent results
for carcinogens and non-carcinogens.
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Media Cleanup Values: The RBCA Tool Kit has the ability to i) compare
the site data to Tier 1 Risk-Based Screening Levels (RBSLs), computed
using the default parameter values as listed in ASTM PS 104-98, or ii)
calculate Tier 2 Site-Specific Target Levels (SSTLs) based on user-supplied
site information. For each source mediurn (i.e., affected soil and
groundwater), the software reports target concentrations for all complete
pathways and identifies the applicable (i.e., minimum) value for source
remediation.

Risk-Based Decision Support Features

The RBCA Tool Kit for Chemical Releases includes several features designed
to support key steps of the risk-based site evaluation process, including the
following:

Step-by-Step Evaluation Process: From the Main Screen of the graphical

user interface, the user is guided through ,111 the necessary steps for
completing the Tier 1 or Tier 2 evaluation process. On subsequent screens
the interface leads the user through exposure pathway identification,
model selection, site-specific parameter input, and output review. All
output screens may be printed in a report-quality format.
Analysis of Actual and Potential POEs: Multiple off-site exposure points
are allowed for the groundwater and outdoor air pathways. This enables
the user to evaluate risks at both actual (e.g. an actual nearby well) and
potential (e.g., a hypothetical well at the property boundary) POEs.
Whether site risks affect an actual or potential POE adds a qualitative
dimension to the risk calculations which mav be an important factor in
remedy selection at some sites.
Transient Groundwater Modeling Analyses An optional Transient
Domenico Worksheet is provided to allow the user to estimate the time
required for site constituents to impact off-site groundwater POEs.
Groundwater risk levels and cleanup standards calculated by the software
are based on steady-state concentrations. However, the time to reach
steady-state concentrations at off-site POEs may be very long for some
constituents. Thus, the time required to exceed a concentration limit at a
POE may be an important factor in remedy selection as near-term impacts

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 may require a significantly different responsrb than longer-term impacts
(e.g., an engineered response vs. natural attenuation).

SUMMARY

Risk-based management is becoming a more acceptable method under many

regulatory programs for responding to chemical releases to the environment.
Although on the surface these risk-based approaches appear to be highly
complex and difficult to perform, all of the various risk-based regulatory
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programs are based on relatively simple principles. Computer software

packages help making the calculation of risk and appropriate cleanup
standards easier and more straightforward. At sites where excess risk is
predicted to occur, risk-based management approaches allow more flexibility
in response actions by allowing containment and institutional controls in
addition to standard removal/treatment alternatives.

REFERENCES

American Society for Testing and Materials, 1995, “Standard Guide for Risk-Based Corrective
Action Applied at Petroleum Release Sites,” ASTM E-1739-95, Philadelphia, PA.
American Society for Testing and Materials, 1998, Stlzndarli Provisional Guide for Risk-Based
Corrective Action, ASTM I’S 104-98, Philadelphia, PA.
Connor, J.A., R.L. Bowers, J.P. Nevin, 1998, User’s Guide: RKA Tool Kit for Chemical Releases,
Groundwater Services, Inc., Houston, Texas. www-gsi-net.com
Connor, J.A., C.J. Newell, M.W. Malander, November 1996, Parameter Estimation Guidelines
for Risk-Based Corrective Action (RBCA) Modelin<?, Proceedings of NGWA Petroleum
Hydrocarbons Conference, Houston, Texas.
Novick, N. J., R. E. Payne, and J. G. Hill, November 1995, fl Tiered Approach to Demonstrate
Intrinsic Bioremediation of Petroleum Hydrocarbons in Groundwater, Proceedings of
NGWA/API Petroleum Hydrocarbons Conference, Houstl In, Texas.

BIOGRAPHICAL INFORMATION
Charles J. Newell, Ph.D., P.E. is a Vice President and Environmental Engineer with
Groundwater Services, Inc. in Houston, Texas. He holds a Ph.D. in Environmental Engineering
from Rice University, and also serves as an adjunct Professor of Environmental Engineering at
Rice. Dr. Newell serves as a certified trainer for the ASTM RBCA Training Initiative and is a
member of the ASTM Task Group for Groundwater Remediation by Natural Attenuation. (C.J.
Newell: Groundwater Services, Inc., 2211 Norfolk, Suite 10000, Houston, Texas 77098. Phone:
(713) 522-6300 Fax: (713) 522-8010 e-mail: cjnewell@gsi-nct.com)

John A. Connor, P.E., is President of Groundwater Services, Inc. He received an M.S. in Civil
Engineering from Stanford University and is a certified trainer for the ASTM Risk-Based
Corrective Action (RBCA) training initiative. (J.A. Connor: Groundwater Services, Inc., 2211
Norfolk, Suite 10000, Houston, Texas 77098. Phone: (71”) 522-6300 Fax: (713) 522-8010
e-mail: jaconnor@gsi-net.com)

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