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decisions need to be risk-based, and made on a site-by-site basis, with all exposure pathways <br /> and chemicals of concern evaluated and monitored. Passive bioremediation is just one of <br /> many available remedial options that may be appropriate at a LUST site. <br /> Passive. bioremediation is an alternative for containment, remediation and reduction of the <br /> mass and concentration of petroleum hydrocarbons in the environment at petroleum relem <br /> sites to protect human health and environmental resources. Bioremediation depends upon <br /> natural processes such as biodegradation, dispersion, dilution, and adsorption to degrzde and <br /> dissipate petroleum constituents in soil and ground water to achieve remedial goals. <br /> Passive. bioremediation should NOT be interpreted to mean 'doing nothing'. Passive <br /> bioremediation requires site characterization As=ment-oLpoten�sks ua of <br /> effectiveness, and documentation of remedial progress (monitoring) similar to other <br /> remedial action tecIEo_gYes. t ou die no cearly however, that natural attenuation is <br /> an active er mR do hcn oice; that is, it is chosen at a site that IS NOT deemed to be low <br /> enou h nsk to,simplyclose, but requires some action to protect human health and the <br /> envirortment. As such monitoring should be performed to ensure that what is expected <br /> actually is occurring at the site. <br /> EPA supports the appropriate application of passive bioremediation for cleanup of LUST sites <br /> and is t:urrently working with ASTM to develop a national standard for remediation by <br /> natural attenuation (passive bioremediation) at LUST sites. <br /> Recommendation 2: Immediately modify the ASTM Risk-Based Corrective Action <br /> (RBCA) framework based on California's historical LUST essa data <br /> Over the past two years, EPA has worked in conjunction with ASTM to develop a standard <br /> using risk-based corrective action (R.BCA) techniques at petroleum-release sites (ASTM E- <br /> 1739). EPA issued an Office of Solid Waste and Emergency Response (OSWER) Directive <br /> supporting the use of risk-based approaches which protect human health and the environment, <br /> while allowing for consideration of site-specific circumstances. Many states have already <br /> implemented risk-based corrective action programs for management of petroleum releases. <br /> There is much in this report that can assist California in designing a risk-based corrective <br /> action process for LUSTs. EPA has encouraged California to incorporate risk-based decision <br /> making in its state-wide cleanup policy to ensure that the over 28,000 confirmed releases are <br /> addressed in a timely and cost-effective manner concentrating on the highest risk sites. <br /> Recommendation 3: Apply a modified ASTM RBCA Framework as soon as possible to <br /> LUST cases where fuel hydrocarbons (petroleum) have affected soil <br /> but do not threaten groundwater <br /> 4 <br />