RECAP Implementation Issues Implementation Issues

Transition to the 2003 RECAP The management of an AOC/AOI may continue under RECAP 2000 until the current phase/task of the project has been completed and approved by the Department. Further assessment of the AOC/AOI shall be under RECAP 2003 unless otherwise approved by the Department. The management of an AOC/AOI may continue under RECAP 2000 until the current phase/task of the project has been completed and approved by the Department. Further assessment of the AOC/AOI shall be under RECAP 2003 unless otherwise approved by the Department.

Transition to the 2003 RECAP Pick a version and stick with it Pick a version and stick with it RECAP 2003 is more flexible with more tools RECAP 2003 is more flexible with more tools RECAP 2000 is an option if the investigation was begun under RECAP 2000 RECAP 2000 is an option if the investigation was begun under RECAP 2000

TPH Issues TPH-GRO and DRO ranges redefined TPH-GRO and DRO ranges redefined Not necessary to re-analyze just to account for 2003 TPH fractions! Added TCEQ Methods 1005 and 1006 Added TCEQ Methods 1005 and 1006 Omitted Washington method for TPH fractions Omitted Washington method for TPH fractions - SO, MO-1, MO-2 - soil and groundwater

TPH Issues Use aliphatic and aromatic fractionations as final remedial standards whenever possible Use aliphatic and aromatic fractionations as final remedial standards whenever possible RECAP Appendix I applies to most petroleum releases, not just UST sites RECAP Appendix I applies to most petroleum releases, not just UST sites Enclosed space does not preclude the use of Appendix I. Enclosed space does not preclude the use of Appendix I.

TPH Issues n Only TPH-G and/or equivalent fractions, not TPH-D or TPH-O, require sample collection using 5035 n Only TPH-G and/or equivalent fractions not TPH-D or TPH-O require evaluation for volatilization into an enclosed space

TPH Issues Sw and L Sw and L are used in determination of DF Sw and L are used in determination of DF Applies to vadose (unsaturated) zone only! Applies to vadose (unsaturated) zone only! -not smear zone Identify borings with COC soil concentration > SS above the zone of groundwater fluctuation (not smear zone) Identify borings with COC soil concentration > SS above the zone of groundwater fluctuation (not smear zone) Typically 30’ X 30’ for most UST site AOIs Typically 30’ X 30’ for most UST site AOIs

Institutional Controls n  f the residual COC concentration in soil is > Soil ni, then a conveyance notification shall be place on the property. n  f the residual COC concentration in a groundwater 2 aquifer is > GW 2 (w/o DF2), then a conveyance notice shall be place on the portion of the plume within the property boundaries. *Does not apply to GW1 or GW3

Identification of Landowners and Easement/Right-of-Way Holders The Submitter shall identify the name and mailing address of all other landowners and easement/right-of-way holders whose property is within an AOI.

Identification of Landowners and Easement/Right-of-Way Holders n Applicable property boundary standards Soilni Soilni MCL or drinking water standard for GW1/2 MCL or drinking water standard for GW1/2 Use of DF3 for GW3 aquifer does not trigger notification Use of DF3 for GW3 aquifer does not trigger notification Enclosed space standards if applicable Enclosed space standards if applicable Likely offsite impact (common sense) Likely offsite impact (common sense)

Voluntary Remediation Program (VRP) n Only requires on-site delineation of nature and extent n Waiver of Liability n Possible pathway elimination based on intended use

Soil Intervals  Current/potential surface soil 0-15’ Soil i/ni, Soil GW, Soil sat and Soil es Soil i/ni, Soil GW, Soil sat and Soil es  Subsurface soil >15’ bgs Soil GW and Soil sat Soil GW and Soil sat

Ambient and indoor air issues Errors in RECAP Table H-5 (Cai) Errors in RECAP Table H-5 (Cai) These result in Soiles/GWes errors in Tables 2 and 3 of RECAP These result in Soiles/GWes errors in Tables 2 and 3 of RECAP These errors will be addressed through rulemaking These errors will be addressed through rulemaking

Soil Gas n Soil gas as an alternative to Soiles/GWes n May be used in RECAP MO-2 or MO-3 n Soil gas sampling protocol to be available on RECAP website soon n Compare Soil gas results times Alpha to Ca *Alpha = attenuation factor (0.01)

Background Background  Number of samples - site-specific background A minimum dataset consisting of 4 discrete samples from unimpacted area n Arsenic background of 12 mg/kg Compare average of site samples to 12

Conceptual Site Model n Identification of exposure pathways is done a step before the estimation of exposure concentrations a pathway is complete if there exists a unique mechanism by which a population may be exposed to the chemicals at or originating from the site a pathway is complete if there exists a unique mechanism by which a population may be exposed to the chemicals at or originating from the site

Self Implementation  Phase II site investigations  Small, quick or interim clean-ups  Reporting requirements and Department notification must be met.  Bad idea for larger or more detailed sites/investigations – all work done at own risk

Reminders/ Useful RECAP Tools

f oc MO-2 and MO-3 only MO-2 and MO-3 only Changes (raises) Soili, Soilni, Soilgw, Soilsat and Soiles Changes (raises) Soili, Soilni, Soilgw, Soilsat and Soiles Sample must be taken from un-impacted area of site Sample must be taken from un-impacted area of site Be sure to check sample location and lab analysis Be sure to check sample location and lab analysis ASTM 2974 Foc = % organic matter /174 ASTM 2974 Foc = % organic matter /174

Foc – impact on benzene RS

SPLP n Alternative evaluation of soil to ground water pathway Replaces and supercedes Soilgw Replaces and supercedes Soilgw May be used under any MO, including SO May be used under any MO, including SO Sample must be taken from location with highest constituent concentration Sample must be taken from location with highest constituent concentration EPA Method 1312 EPA Method 1312

SPLP GW1 – compare soil SPLP to GW1 X (20) GW1 – compare soil SPLP to GW1 X (20) GW2 – compare soil SPLP to GW2 X 20 X DF2 GW2 – compare soil SPLP to GW2 X 20 X DF2 GW3 – compare soil SPLP to GW3 X 20 X DF3 GW3 – compare soil SPLP to GW3 X 20 X DF3 AOIC must still meet lower of Soili and Soilsat AOIC must still meet lower of Soili and Soilsat

Addressing Exposure to Multiple Constituents that Elicit Noncarcinogenic Effects on the Same Target Organ/System n Risk-based RS must be adjusted to account for potential additive effects »Soil ni, Soil i, Soil es »GW 1, GW 2, GW es n Not applicable to Soil GW, Soil sat, GW 3, Water sol, background levels, quantitation limits, MCLs or ceiling values

MO-1: Accounting for Additivity Example ChemicalTarget OrganRSAdjusted RS Akidney24 8 Bkidney, liver15 5 Ckidney60 20 è Divide the RS for A, B, and C by 3 (kidney) (Same as calculating a RS using a THQ of 0.33) (Same as calculating a RS using a THQ of 0.33)

MO-1: Accounting for Additivity Example Chem. Target OrganRSAdjusted RS [COC] A kidney B kidney, liver C kidney è Divide the RS for A, B, and C by 3 (kidney) (Same as calculating a RS using a THQ of 0.33) (Same as calculating a RS using a THQ of 0.33)

Hazard Index Approach to Adjustments for Additive Effects n MO-2 and MO-3 only n Just like MO-1 approach, applies only to direct human health-based standards, e.g. Soili, Soilni, GW1, GW2 and Soiles. n Do not blindly divide by the number of constituents!

Hazard Index Approach THI kidney = EC A /RS A + EC B /RS B + EC c /RS c where: EC = exposure concentration RS = RECAP Standard THI kidney = 18/24 + 3/15 + 2/60 = 0.98 P THI must be < 1.0

RECAP QUESTIONS? QUESTIONS?