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RECAP  Implementation Issues . Transition to the 2003 RECAP.

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Implementation Issues 

Transition to the 2003 recap
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.

Transition to the 2003 recap1
Transition to the 2003 RECAP

  • Pick a version and stick with it

  • RECAP 2003 is more flexible with more tools

  • RECAP 2000 is an option if the investigation was begun under RECAP 2000

Tph issues
TPH Issues

  • TPH-GRO and DRO ranges redefined

    Not necessary to re-analyze just to account for 2003 TPH fractions!

  • Added TCEQ Methods 1005 and 1006

  • Omitted Washington method for TPH fractions

    - SO, MO-1, MO-2

    - soil and groundwater

Tph issues1
TPH Issues

  • Use aliphatic and aromatic fractionations as final remedial standards whenever possible

  • RECAP Appendix I applies to most petroleum releases, not just UST sites

  • Enclosed space does not preclude the use of Appendix I.

Tph issues2
TPH Issues

  • Only TPH-G and/or equivalent fractions, not TPH-D or TPH-O, require sample collection using 5035

  • 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
TPH IssuesSw and L

  • Sw and L are used in determination of DF

  • 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)

  • Typically 30’ X 30’ for most UST site AOIs

Institutional controls
Institutional Controls

  • ·If the residual COC concentration in soil is > Soilni, then a conveyance notification shall be place on the property.

  • ·If the residual COC concentration in a groundwater 2 aquifer is > GW2 (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
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 holders1
Identification of Landowners and Easement/Right-of-Way Holders

  • Applicable property boundary standards

  • Soilni

  • MCL or drinking water standard for GW1/2

  • Use of DF3 for GW3 aquifer does not trigger notification

  • Enclosed space standards if applicable

  • Likely offsite impact (common sense)

Voluntary remediation program vrp
Voluntary Remediation Program Holders(VRP)

  • Only requires on-site delineation of nature and extent

  • Waiver of Liability

  • Possible pathway elimination based on intended use

Soil intervals
Soil Intervals Holders

  • Current/potential surface soil 0-15’

    • Soili/ni, SoilGW , Soilsat and Soiles

  • Subsurface soil >15’ bgs

    • SoilGW and Soilsat

  • Ambient and indoor air issues
    Ambient and indoor air issues Holders

    • Errors in RECAP Table H-5 (Cai)

    • These result in Soiles/GWes errors in Tables 2 and 3 of RECAP

    • These errors will be addressed through rulemaking

    Soil gas
    Soil Gas Holders

    • Soil gas as an alternative to Soiles/GWes

    • May be used in RECAP MO-2 or MO-3

    • Soil gas sampling protocol to be available on RECAP website soon

    • Compare Soil gas results times Alpha to Ca *Alpha = attenuation factor (0.01)

    Background Holders

    • Number of samples - site-specific background

      A minimum dataset consisting of 4 discrete samples from unimpacted area

    • Arsenic background of 12 mg/kg

      Compare average of site samples to 12

    Conceptual site model
    Conceptual Site Model Holders

    • 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

    Self implementation
    Self Implementation Holders

    • 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
    Reminders/ HoldersUseful RECAP Tools

    f Holdersoc

    • MO-2 and MO-3 only

    • Changes (raises) Soili, Soilni, Soilgw, Soilsat and Soiles

    • Sample must be taken from un-impacted area of site

    • Be sure to check sample location and lab analysis

    • ASTM 2974 Foc = % organic matter /174

    SPLP Holders

    • Alternative evaluation of soil to ground water pathway

    • Replaces and supercedes Soilgw

    • May be used under any MO, including SO

    • Sample must be taken from location with highest constituent concentration

    • EPA Method 1312

    SPLP Holders

    • GW1 – compare soil SPLP to GW1 X (20)

    • GW2 – compare soil SPLP to GW2 X 20 X DF2

    • GW3 – compare soil SPLP to GW3 X 20 X DF3

    • AOIC must still meet lower of Soili and Soilsat

    Addressing Exposure to HoldersMultipleConstituents that Elicit Noncarcinogenic Effects on the Same Target Organ/System

    • Risk-based RS must be adjusted to account for potential additive effects

      • Soilni, Soili, Soiles

      • GW1, GW2, GWes

    • Not applicable to SoilGW, Soilsat, GW3, Watersol, background levels, quantitation limits, MCLs or ceiling values

    Mo 1 accounting for additivity example
    MO-1: Accounting for Additivity HoldersExample

    Chemical Target Organ RS Adjusted RS

    A kidney 24 8

    B kidney, liver 15 5

    C kidney 60 20

    • Divide the RS for A, B, and C by 3 (kidney)

      (Same as calculating a RS using a THQ of 0.33)

    Mo 1 accounting for additivity example1
    MO-1: Accounting for Additivity HoldersExample

    Chem. Target Organ RS Adjusted RS [COC]

    A kidney 24 8 18.0

    B kidney, liver 15 5 3.0

    C kidney 60 20 2.0

    • Divide the RS for A, B, and C by 3 (kidney)

      (Same as calculating a RS using a THQ of 0.33)

    Hazard index approach to adjustments for additive effects
    Hazard Index Approach to Adjustments for Additive Effects Holders

    • MO-2 and MO-3 only

    • Just like MO-1 approach, applies only to direct human health-based standards, e.g. Soili, Soilni, GW1, GW2 and Soiles.

    • Do not blindly divide by the number of constituents!

    Hazard index approach
    Hazard Index Approach Holders

    THIkidney = ECA/RSA + ECB/RSB + ECc/RSc


    EC = exposure concentration

    RS = RECAP Standard

    THIkidney = 18/24 + 3/15 + 2/60 = 0.98

    • THI must be < 1.0

    RECAP Holders