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?