ASTM Training Effort Benefits State Regulatory Programs
As any seasoned pilot will tell you, it is vital to plan your landing before you take off. Likewise, in 1993, an ASTM task group under what is now Subcommittee E50.04 on Corrective Action (part of Committee E50 on Environmental Assessment, Risk Management, and Corrective Action) put considerable effort into planning a nationwide comprehensive training program for a new risk and exposure assessment guide, even before the guide was approved as an ASTM standard. They knew the training would be crucial if the new guide was ever going to be successfully implemented by state environmental regulatory programs.
They planned it right. Both the new guide and the training course were launched in 1995 and the landing was successful. Through the ambitious ASTM training efforts, the new guide gained regulatory acceptance and widespread implementation. In 2005, the training effort and the guide remain active and relevant. They continue on course today with a solid record of success.
For 10 years now, ASTM E 1739, Guide for Risk-Based Corrective Action at Petroleum Release Sites, has provided the framework for many state environmental regulatory programs. More commonly known as RBCA (Rebecca), E 1739 put a new spin on environmental risk and exposure assessment at petroleum release sites. With 10 candles in the birthday cake, RBCA still remains state-of-the art. It is alive and well. Its ongoing success is evident by the number of states that have incorporated it into their corrective action programs. It is also evidenced by the continued demand for the award-winning ASTM RBCA training course, even as we head into the second decade of RBCA.
The RBCA Challenge
RBCA can be applied to any type of chemical release. However, E 1739 specifically focuses on petroleum. This is because, initially, the immense number of petroleum releases from leaking underground storage tanks was the impetus for a streamlined and consistent method of exposure and risk assessment. While the environmental damage caused by petroleum releases can be severe, they do not all pose the same risk. The challenge is to determine what poses a risk and what does not.
E 1739 has helped tackle this challenge by creating a streamlined process in which exposure and risk assessment practices are integrated with traditional components of the corrective action process. By definition, this process is RBCA. It helps to ensure that appropriate and cost-effective remedies are selected, and that limited resources are properly allocated when conducting corrective action at a release site. But the main goal is environmental protection.
Figure 1 shows the RBCA flowchart. This is the fundamental process on which E 1739 is based. From this flowchart it is evident that RBCA does more than just help determine appropriate environmental cleanup goals. Rather it incorporates risk into the entire corrective action process including the site characterization, initial response actions, site classification and even remedial action.
The RBCA process is also a framework on which an environmental regulatory program can be built. While E 1739 offers the framework, it is up to regulatory officials and other stakeholders to add the finishing components that will complete the RBCA program. With stakeholder involvement, regulatory officials can tailor the RBCA process to suit state-specific needs. This requires a clear understanding of the health, science and ecological issues that are essential components of a sound environmental regulatory program. To assist in the understanding of these issues, the guide contains a comprehensive appendix that covers petroleum chemistry, exposure assessment, and fate and transport modeling along with several complete examples on how to apply RBCA at a release site.
Officially completed in 1995, E 1739 provides the first step in meeting the challenge of a streamlined and consistent approach to risk and exposure assessment. However, to really get things off the ground, the task group had to launch an ambitious nationwide state training initiative that would complement the guide and seek both regulatory and stakeholder assistance in its implementation.
Focus on Training
From the onset, RBCA was developed with the idea of training and regulatory implementation in mind. The RBCA task group commenced the training initiative even before balloting was completed for the standard itself. To be successful, RBCA would have to be accepted by state environmental regulatory programs. The task group recognized that a sound training program was essential if states were to willingly and successfully implement RBCA. The completion of the training course development coincided with the completion of E 1739.
The resulting ASTM RBCA training course offered much more than just instruction on how to use the standard guide. It provided interactive instruction on the fundamentals of risk, toxicology, and fate and transport modeling using example problems. It also offered guidance on incorporating RBCA into state regulatory programs.
On March 1, 1995, the EPA issued a directive from the Office of Solid Waste and Emergency Response to the 10 EPA regional offices on the use of risk-based decision-making in underground storage tank corrective action programs. OSWER Directive 9610.17 encouraged the use of risk-based decision making. It also specifically referenced E 1739 as one possible starting point for the development of a process using the risk-based approach described in the directive. EPAs acceptance of E 1739 as a suitable tool for state programs triggered a nationwide interest in RBCA and spurred demand for the ASTM RBCA training course. Now was the time to deliver the goods.
The ABCs of RBCA Training
The objective of the ASTM RBCA training course is for the user to learn and understand the RBCA process along with the fundamental technical aspects of risk and exposure assessment. The planned outcome is the successful state implementation of RBCA programs.
The course is structured around three distinct training modules. Module 1 is an introduction to the concept of RBCA. It is designed to inform all levels of stakeholders on the fundamental logic and process of RBCA. It is a short introductory course that was created with the manager in mind; someone who should be knowledgeable of RBCA, but may not necessarily be involved in the day-to-day corrective action activities. It is also an ideal introduction to the concept of RBCA for those who follow up with the more thorough training in Module 2.
Module 2 consists of a comprehensive two-day workshop that provides detailed explanations of the key issues involved in risk assessment including toxicity assessment, exposure assessment, risk characterization, equilibrium partitioning, groundwater fate and transport, air fate and transport, and the RBCA framework. Module 2 is geared toward everyone who will be using the RBCA process, including state regulatory personnel, environmental consultants and site owners. It also provides sufficient information to help a state get started in establishing a RBCA program.
Module 3 consists of guidance on program implementation. Often, the Module 3 training would involve volunteers from industry and other state regulatory programs who would provide hands-on assistance in developing the states RBCA program.
Developing the course structure and content was only part of the task groups responsibilities. It was also necessary to hire and train qualified instructors. The first set of instructors would provide training exclusively to states. A nationwide search resulted in the selection of nine individuals with expertise in toxicology, risk assessment, fate and transport and, of course, the RBCA process. A second set of instructors were later selected to provide the training programs to the general users.
Partners in RBCA Implementation
A potential obstacle to achieving nationwide success with the RBCA training initiative was the cost. The task group recognized that states may not have the financial resources for the RBCA training program. It was also likely that states may be more inclined to participate in RBCA training if costs were minimal.
In response, a unique partnership was developed between ASTM, industry and the EPA. Formed in March of 1996, it was called Partners in RBCA Implementation, or PIRI. The purposes of PIRI were to make RBCA training available to all states at no cost and to assure that any interested state underground storage tank program would receive RBCA training and assistance in the design and implementation of a RBCA process.
Two distinct funds supported PIRI: a cooperative agreement and a private sector account. EPA established a cooperative agreement with ASTM to provide RBCA training to state and tribal underground storage tank programs. Industry created the private sector account to provide funds to ASTM. Overall, the EPA contributed $725,000 and industry contributed $1.7 million. These funds were used exclusively for state RBCA training and implementation.
An Award-Winning Training Course
With funding from PIRI, over 90 training courses were delivered to 47 states, as well as tribal lands and Puerto Rico. While this first training initiative was geared for state regulatory programs, the task group eventually designed a nearly identical training program for the private sector. Through ASTMs Technical and Professional Training program, RBCA workshops have been offered throughout the country. To date, RBCA training has been provided to over 1,500 individuals. The ASTM RBCA training course was the recipient of the 1997 Education Award of Excellence from the American Society of Association Executives. Even after 10 years, the course is still in demand.
In October of 2004, the ASTM RBCA training work group and active instructors met in Washington, D.C., to evaluate and refresh the training course. Today, new material has been added that addresses the risk and exposure assessment of methyl tertiary butyl ether, other oxygenates, and light non-aqueous phase liquid hydrocarbons. State regulatory information has also been updated, along with toxicity information from EPAs Integrated Risk Information System. The course remains relevant with the most current technical and regulatory information available.
Proven Benefits to States
RBCA has proved beneficial in that it provides consistency in the corrective action process while allowing state regulatory bodies the flexibility to establish their own policy decisions on specific issues. At least 44 states have environmental corrective action programs based entirely or partially on E 1739. The following are some current examples of RBCA implementation and ongoing training activity in four states.
Michigan: Still Training After All These Years Like many states, Michigan adopted RBCA for their underground storage tank program. On May 1, 1995, ASTM E 1739 was formally incorporated by reference into Part 213, Leaking Underground Storage Tanks, of Michigans Natural Resources and Environmental Protection Act of 1994, PA 451, as amended.
The Michigan Department of Environmental Quality requires that new applicants for certified underground storage tank professionals take RBCA training. The ASTM RBCA training course is currently the only one approved to meet this requirement. As with most states, the training was customized to meet some of the specific needs of the state of Michigan. For example, some new course material was added that addresses risk and exposure of the indoor air vapor pathway.
The RBCA training course is offered twice a year in Michigan. Chris Christensen, State of Michigan Department of Environmental Quality Remediation and Redevelopment Division, says that feedback from the certified underground storage tank professionals has been good. Christensen also believes that the RBCA standard and training have a very positive overall benefit to the state of Michigan. He reports, These ASTM International activities related to RBCA have benefited state government by permitting us to focus limited leaking underground storage site remediation funds on those sites that pose the biggest threat to our citizens. Finally, ASTM International has provided valuable training on the RBCA process to numerous Michigan Department of Environmental Quality employees at no charge to the state.
South Dakota: Early Start and Tailored Training As with the state of Michigan, South Dakota got an early start and adopted a RBCA program for cleanup of petroleum releases in 1995. The ASTM RBCA guide is specifically referenced in the statute. The state also benefited from the PIRI-sponsored training. After several years of experience with the RBCA program, the state requested a customized RBCA refresher course from ASTM for both state employees and private consultants. State personnel coordinated with ASTM and the designated trainer to modify the course to focus on areas where there was the greatest need for training. The resulting program was a two-day course where the first day focused on the classroom review of RBCA fundamentals such as risk, exposure, and fate and transport mechanisms. Day two consisted of hands-on problem solving, working with example cases and computer models to assess exposure and calculate cleanup goals.
Oregon: Merging with RBCA Oregon also first began implementing a risk-based cleanup program in 1995. Initially, the state created interim guidance that pointed to ASTM E 1739 as a method to comply with the risk-based cleanup requirements until the regulations could be revised. Michael Anderson, a hydrogeologist with the Oregon Department of Environmental Quality, says that eventually the state-specific requirements and the ASTM RBCA guide merged and a new detailed guidance was issued in 1999. Anderson suggests that the new guidance material is very similar to E 1739, but that additional exposure pathways, like the excavation worker scenario, were added. By adding this information, the Oregon Department of Environmental Quality was able to tailor RBCA to fit the states specific needs. The guidance manual was again updated in 2003 to include new toxicity data and to expand the application of risk-based decision-making to other release sites in addition to petroleum. The state originally received the ASTM PIRI- sponsored training. More recently, ASTM has been providing the training to environmental consultants and is coordinating with state officials to include a section on state-specific issues.
Arizona: How to Tier Two The state of Arizona first implemented a RBCA program in August 2002. The guidance referenced E 1739 and the states program is based on the general RBCA process. The program was tweaked to take into account current laws as well as political and social concerns specific to Arizona. ASTM is still actively providing training to Arizona consultants and contractors, and coordinates the training with state officials who address state-specific issues. Arizona is developing a new guidance on the use of the Tier Two models. The new guidance is appropriately entitled How to Tier Two. Jeanene Hanley, senior risk assessor for the Arizona Department of Environmental Quality, states that prior to the implementation of RBCA, very few consultants were conducting risk assessments at petroleum release sites. Now it is the standard procedure. She also reports that the state coordinates regularly with ASTMs Technical and Professional Training program to bring in the ASTM RBCA training course. This allows state officials to participate in the instruction by addressing Arizona-specific issues.
The RBCA Family
While E 1739 was the first RBCA, several sister standards have since been developed. E 2081, Guide for Risk-Based Corrective Action, is very similar to E 1739 but expands the same basic RBCA process to a broader range of chemicals than just petroleum. E 2205, Guide for Risk-Based Corrective Action for Protection of Ecological Resources, also known as Eco-RBCA, focuses on ecological receptors. Committee E50 on Environmental Assessment, Risk Management and Corrective Action has also produced two other RBCA-related standards: E 1943, Guide for Remediation of Ground Water by Natural Attenuation at Petroleum Release Sites, and E 2091, Guide for Use of Activity and Use Limitations, Including Institutional and Engineering Controls. All are consistent with E 1739.
Over the past 10 years RBCA has become a proven commodity. With financial support from EPA and industry, along with an ambitious ASTM training effort, RBCA has found its way into no less than 44 state regulatory programs. Protecting our environment is what it is all about. As it enters its second decade, RBCA will no doubt continue to promote environmental protection by providing an efficient and streamlined approach to risk and exposure assessment. //