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RECAP RECAP
Implementation Implementation Issues Issues
Transition to the 2003 RECAPTransition to the 2003 RECAP
The management of an AOC/AOI may The management of an AOC/AOI may continue under RECAP 2000 until the continue under RECAP 2000 until the current phase/task of the project has been current phase/task of the project has been completed and approved by the completed and approved by the Department. Further assessment of the Department. Further assessment of the AOC/AOI shall be under RECAP 2003 AOC/AOI shall be under RECAP 2003 unless otherwise approved by the unless otherwise approved by the Department.Department.
Transition to the 2003 RECAPTransition to the 2003 RECAP
Pick a version and stick with itPick a version and stick with it
RECAP 2003 is more flexible with more RECAP 2003 is more flexible with more toolstools
RECAP 2000 is an option if the RECAP 2000 is an option if the investigation was begun under RECAP investigation was begun under RECAP 20002000
TPH IssuesTPH Issues
TPH-GRO and DRO ranges redefinedTPH-GRO and DRO ranges redefined
Not necessary to re-analyze just to Not necessary to re-analyze just to account for account for
2003 TPH fractions!2003 TPH fractions!
Added TCEQ Methods 1005 and 1006Added TCEQ Methods 1005 and 1006
Omitted Washington method for TPH fractionsOmitted Washington method for TPH fractions
- SO, MO-1, MO-2- SO, MO-1, MO-2
- soil and groundwater- soil and groundwater
TPH IssuesTPH Issues
Use aliphatic and aromatic fractionations as Use aliphatic and aromatic fractionations as final remedial standards whenever possiblefinal remedial standards whenever possible
RECAP Appendix I applies to most RECAP Appendix I applies to most petroleum releases, not just UST sitespetroleum releases, not just UST sites
Enclosed space Enclosed space does notdoes not preclude the use of preclude the use of Appendix I.Appendix I.
TPH IssuesTPH Issues
Only TPH-G and/or equivalent fractions, Only TPH-G and/or equivalent fractions, not TPH-D or TPH-O, require sample not TPH-D or TPH-O, require sample collection using 5035collection using 5035
Only TPH-G and/or equivalent fractions not Only TPH-G and/or equivalent fractions not TPH-D or TPH-O require evaluation for TPH-D or TPH-O require evaluation for volatilization into an enclosed spacevolatilization into an enclosed space
TPH IssuesTPH IssuesSw and LSw and L
Sw and L are used in determination of DFSw and L are used in determination of DF Applies to vadose (unsaturated) zone only!Applies to vadose (unsaturated) zone only!
-not smear zone-not smear zone Identify borings with COC soil Identify borings with COC soil
concentration > SS above the zone of concentration > SS above the zone of groundwater fluctuation (not smear zone)groundwater fluctuation (not smear zone)
Typically 30’ X 30’ for Typically 30’ X 30’ for mostmost UST site AOIs UST site AOIs
Institutional ControlsInstitutional Controls
f the residual COC concentration in soil is > f the residual COC concentration in soil is > SoilSoil
nini, then a conveyance notification shall be , then a conveyance notification shall be
place on the property.place on the property.
f the residual COC concentration in a f the residual COC concentration in a groundwater 2 aquifer is > GWgroundwater 2 aquifer is > GW
22 (w/o DF2), then a (w/o DF2), then a
conveyance notice shall be place on the portion of conveyance notice shall be place on the portion of the plume within the property boundaries.the plume within the property boundaries.
*Does not apply to GW1 or GW3*Does not apply to GW1 or GW3
Identification of Landowners and Identification of Landowners and Easement/Right-of-Way HoldersEasement/Right-of-Way Holders
The Submitter shall identify the name and The Submitter shall identify the name and mailing address of all other landowners and mailing address of all other landowners and easement/right-of-way holders whose easement/right-of-way holders whose property is within an AOI.property is within an AOI.
Identification of Landowners and Identification of Landowners and Easement/Right-of-Way HoldersEasement/Right-of-Way Holders
Applicable property boundary standardsApplicable property boundary standards SoilniSoilni MCL or drinking water standard for GW1/2MCL or drinking water standard for GW1/2 Use of DF3 for GW3 aquifer Use of DF3 for GW3 aquifer does notdoes not
trigger notificationtrigger notification Enclosed space standards if applicableEnclosed space standards if applicable Likely offsite impact (common sense)Likely offsite impact (common sense)
Voluntary Remediation ProgramVoluntary Remediation Program(VRP)(VRP)
Only requires on-site delineation of nature Only requires on-site delineation of nature and extentand extent
Waiver of LiabilityWaiver of Liability
Possible pathway elimination based on Possible pathway elimination based on intended useintended use
Soil IntervalsSoil Intervals
Current/potential surface soil 0-15’ Current/potential surface soil 0-15’
SoilSoili/nii/ni, Soil, SoilGWGW , Soil , Soilsat sat and Soiland Soileses
Subsurface soil >15’ bgsSubsurface soil >15’ bgs
SoilSoilGWGW and Soil and Soilsatsat
Ambient and indoor air issuesAmbient 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 These result in Soiles/GWes errors in
Tables 2 and 3 of RECAPTables 2 and 3 of RECAP
These errors will be addressed through These errors will be addressed through rulemakingrulemaking
Soil GasSoil Gas
Soil gas as an alternative to Soiles/GWesSoil gas as an alternative to Soiles/GWes May be used in RECAP MO-2 or MO-3May be used in RECAP MO-2 or MO-3 Soil gas sampling protocol to be available Soil gas sampling protocol to be available
on RECAP website soonon RECAP website soon Compare Soil gas results times Alpha to CaCompare Soil gas results times Alpha to Ca
*Alpha = attenuation factor (0.01)*Alpha = attenuation factor (0.01)
BackgroundBackground
Number of samples - site-specific Number of samples - site-specific background background
A minimum dataset consisting of 4 discrete A minimum dataset consisting of 4 discrete samples from unimpacted area samples from unimpacted area
Arsenic background of 12 mg/kgArsenic background of 12 mg/kg
Compare Compare averageaverage of site samples to 12 of site samples to 12
Conceptual Site ModelConceptual Site Model Identification of exposure pathways is Identification of exposure pathways is
done a step before the estimation of done a step before the estimation of exposure concentrationsexposure concentrations
a pathway is complete if there exists a a pathway is complete if there exists a unique mechanism by which a unique mechanism by which a population may be exposed to the population may be exposed to the chemicals at or originating from the sitechemicals at or originating from the site
Self ImplementationSelf Implementation
Phase II site investigationsPhase II site investigations Small, quick or interim clean-upsSmall, quick or interim clean-ups Reporting requirements and Department Reporting requirements and Department
notification must be met.notification must be met.
Bad idea for larger or more detailed Bad idea for larger or more detailed sites/investigations – all work done at own sites/investigations – all work done at own riskrisk
Reminders/ Reminders/ Useful RECAP ToolsUseful RECAP Tools
ffococ
MO-2 and MO-3 onlyMO-2 and MO-3 only Changes (raises) Soili, Soilni, Soilgw, Soilsat Changes (raises) Soili, Soilni, Soilgw, Soilsat
and Soilesand Soiles Sample must be taken from un-impacted area Sample must be taken from un-impacted area
of siteof site Be sure to check sample location and lab Be sure to check sample location and lab
analysisanalysis ASTM 2974 Foc = % organic matter /174ASTM 2974 Foc = % organic matter /174
Foc – impact on benzene RSFoc – impact on benzene RS
foc 0.006 0.02
Soili 3.2 5.1Soilgw3 0.13 0.34Soilsat 900 2400Soilesi 0.1 0.28
SPLPSPLP
Alternative evaluation of soil to ground Alternative evaluation of soil to ground water pathwaywater pathway
Replaces and supercedes SoilgwReplaces and supercedes Soilgw May be used under any MO, including SOMay be used under any MO, including SO Sample must be taken from location with Sample must be taken from location with
highesthighest constituent concentration constituent concentration EPA Method 1312EPA Method 1312
SPLPSPLP
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 DF2GW2 – compare soil SPLP to GW2 X 20 X DF2 GW3 – compare soil SPLP to GW3 X 20 X DF3GW3 – compare soil SPLP to GW3 X 20 X DF3
AOIC must still meet lower of Soili and AOIC must still meet lower of Soili and SoilsatSoilsat
Addressing Exposure to Addressing Exposure to MultipleMultiple ConstituentsConstituents that that Elicit Elicit NoncarcinogenicNoncarcinogenic Effects on the Effects on the SameSame Target Target
Organ/SystemOrgan/System
Risk-basedRisk-based RS must be adjusted to account RS must be adjusted to account for potential additive effects for potential additive effects
» SoilSoilnini, Soil, Soilii, Soil, Soileses
» GWGW11, GW, GW22, GW, GWeses
Not applicable to SoilNot applicable to SoilGWGW, Soil, Soilsatsat, GW, GW33, , WaterWatersolsol, background levels, quantitation , background levels, quantitation limits, MCLs or ceiling valueslimits, MCLs or ceiling values
MO-1: Accounting for AdditivityMO-1: Accounting for AdditivityExampleExample
ChemicalChemical Target OrganTarget Organ RSRS Adjusted Adjusted RSRS
AA kidneykidney 24 824 8
BB kidney, liverkidney, liver 15 515 5
CC kidneykidney 60 2060 20
Divide the RS for A, B, and C by 3 (kidney)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 AdditivityMO-1: Accounting for AdditivityExampleExample
Chem. Target OrganChem. Target Organ RSRS Adjusted RS [COC] Adjusted RS [COC]
AA kidney kidney 24 824 8 18.0 18.0
BB kidney, liver kidney, liver 15 515 5 3.03.0
CC kidney kidney 60 2060 20 2.02.0
Divide the RS for A, B, and C by 3 (kidney)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 Hazard Index Approach to Adjustments for Additive EffectsAdjustments for Additive Effects
MO-2 and MO-3 onlyMO-2 and MO-3 only Just like MO-1 approach, applies only to Just like MO-1 approach, applies only to
direct human health-based standards, e.g. direct human health-based standards, e.g. Soili, Soilni, GW1, GW2 and Soiles. Soili, Soilni, GW1, GW2 and Soiles.
Do not blindly divide by the number of Do not blindly divide by the number of constituents!constituents!
Hazard Index ApproachHazard Index Approach
THITHIkidneykidney = EC = ECAA/RS/RSAA + EC + ECBB/RS/RSBB + EC + ECcc/RS/RScc
where:where:
EC = exposure concentrationEC = exposure concentration
RS = RECAP StandardRS = RECAP Standard
THITHIkidneykidney = 18/24 + 3/15 + 2/60 = 0.98 = 18/24 + 3/15 + 2/60 = 0.98
THI must be THI must be << 1.0 1.0
RECAPRECAP
QUESTIONS?QUESTIONS?