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Transitioning to 2003 RECAP: Implementation and Key Issues in AOC/AOI Management

This document outlines the transition from the RECAP 2000 to RECAP 2003 protocols for the management of Areas of Concern (AOC) and Areas of Interest (AOI). Key changes include redefined Total Petroleum Hydrocarbon (TPH) ranges, new assessment methods, and guidelines for soil and groundwater evaluation. Importantly, it emphasizes the necessity of adhering to the new framework while permitting the continuation of ongoing projects under RECAP 2000 until completion. Additional insights on institutional controls and landowner identification requirements are also covered.

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Transitioning to 2003 RECAP: Implementation and Key Issues in AOC/AOI Management

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  1. RECAP  Implementation Issues 

  2. 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.

  3. 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

  4. 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

  5. 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.

  6. 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

  7. 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

  8. 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

  9. 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.

  10. 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)

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

  12. Soil Intervals • Current/potential surface soil 0-15’ • Soili/ni, SoilGW , Soilsat and Soiles • Subsurface soil >15’ bgs • SoilGW and Soilsat

  13. 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

  14. 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)

  15. 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

  16. 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

  17. 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

  18. Reminders/ Useful RECAP Tools

  19. 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

  20. Foc – impact on benzene RS

  21. 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

  22. 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

  23. 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

  24. 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)

  25. 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)

  26. 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!

  27. 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

  28. RECAP QUESTIONS?

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