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RECAP  Implementation Issues . Transition to the 2003 RECAP.

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Presentation Transcript
slide1
RECAP 

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(VRP)
  • Only requires on-site delineation of nature and extent
  • Waiver of Liability
  • Possible pathway elimination based on intended use
soil intervals
Soil Intervals
  • 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
  • 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
  • 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
Background
  • 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
  • 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
  • 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
slide19
foc
  • 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
slide21
SPLP
  • 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
slide22
SPLP
  • 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
slide23
Addressing Exposure to MultipleConstituents 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 AdditivityExample

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 AdditivityExample

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
  • 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

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

where:

EC = exposure concentration

RS = RECAP Standard

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

  • THI must be < 1.0
recap
RECAP

QUESTIONS?

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