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RECAP From RECAP 2000 To RECAP 2003
LDEQ’s RECAP n RECAP revision schedule – FEIS Draft and Fiscal Office Draft – NOI to State Register – NOI published in Louisiana Register (comment period begins) – LDEQ Public Hearing Date – Comment period ends – Summary report to LOC – Rule published in Louisiana Register and becomes final 11/20/02 12/10/02 12/20/02 01/24/03 03/20/03 07/10/03 10/20/03
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.
Current Regulation LAC 33: I. 1305 Applicability A. This Chapter establishes…requirements to evaluate and/or remediate sites that have been affected by constituents of concern… B. This Chapter shall not apply…plans that were approved by the department prior to December 20, 1998, except when modification is deemed by the department to be necessary to protect…
LAC 33: I. 1305 Applicability C. This Chapter shall not apply to: 1. current spills that: a. do not require notification under LAC 33: I. Chapter 39; b. are remediated as soon as practicable, but not more than 30 days, after learning of the discharge; and c. are remediated in a manner that will ensure protection of human health and the environment;
LAC 33: I. 1305 2. spills that create emergency conditions, as defined in LAC 33: I. 3905, but do not exceed a reportable quantity, provided conditions specified in Subparagraphs C. 1. b-c of this Section are met; 3. spills solely to air; and
LAC 33: I. 1305 4. current spills over the reportable quantity that require notification under LAC 33: I. Chapter 39, that are remediated promptly in a manner protective of human health and the environment, provided that: a. the spill is remediated as soon as practicable, but not more than 30 days, after learning of the discharge; b. notification is made in accordance with LAC 33: I. Chapter 39; and
LAC 33: I. 1305 c. i. the written report required by LAC 33: I. Chapter 39, or a subsequent follow-up report, documents that the material has been removed to a level that will ensure protection of human health and the environment. Such documentation may include confirmatory sampling, use of organic vapor monitoring devices or, where appropriate (such as where the spill is of a dark material and/or is very small), visual confirmation. ii. Upon review of the reported cleanup documentation, the department may require a complete RECAP evaluation if the department determines that the actions taken do not adequately ensure protection of human health and the environment.
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.
Institutional Controls n ·Clarification that if the residual COC concentration in soil is > Soilni, then a conveyance notification shall be place on the property. n ·Clarification that if the residual COC concentration in a groundwater 2 aquifer is > GW 2 (w/o DF 2), then a conveyance notice shall be place on the portion of the plume within the property boundaries.
Additional Guidance/Clarification § Use of monitored natural attenuation § Use of dry vs. wet weight § Identification of POC and the POE for GWes and GWair. § Use of ARARs under RECAP
Additional Guidance/Clarification u Acute toxicity - soil/child u Minor changes to land use codes u Submitter may assume GW 1 without TDS and yield data u Data used under RECAP shall be obtained from a laboratory accredited by the state of Louisiana.
Hierarchy of toxicity values 1) 2) 3) 4) 5) EPA’s Integrated Risk Information System (IRIS) EPA’s National Center for Environmental Assessment (NCEA) provisional values EPA’s Health Effects Assessment Summary Tables (EPA) Values withdrawn from IRIS or HEAST Other EPA or EPA-recommended source.
Changes to the Tables 1. Revised RS based on updated toxicity values and default assumptions 2. Added Soiles to Table 2 3. Added GWes and Gwair to Table 3 4. Use of EPA recommended GW standard for MTBE – based on aesthetics 5. New constituents added to Tables: acenaphthylene, 2 -methylnaphthalene and phenathrene
Identification of the AOI u Additional guidance/clarifications - Multiple releases - Id of multiple AOIs - Id of AOI based on land use - Id of AOI based on exposure pathways - Only 1 or 2 locations > RS
AOI Concentration (AOIC) Terminology new/use same è Additional guidance/clarifications - Statistical considerations for 95%UCL Small data sets High variability Distribution of data - 95%UCL-AM vs Max Concentration
New Soil Intervals § Current/potential surface soil 0 -15’ üSoili/ni, Soil. GW and Soilsat § Subsurface soil >15’ bgs ü Soil. GW and Soilsat
Identification and Application of RECAP Standards GWair is required to be included in the identification of the limiting RS n The GWes pathway may now be addressed under MO-1 n The Soiles pathway may now be addressed under MO-1 n
Ambient and indoor air issues § Volatilization from soil and ground water > 15’ bgs is an incomplete pathway (Soiles GWes Gwair ) § LAC 33: III. 5112 Ambient Air Standards (annual average) used for Cai -eliminates inconsistency with air regulations
Background Number of Samples n A minimum dataset consisting of 4 discrete samples from unimpacted area n 7 BKG = arithmetic mean 8 BKG = arithmetic mean + 1 standard deviation n Arsenic background of 12 mg/kg n
Appendix B n · Clarification of air sampling guidelines. n · Added groundwater reporting submittal requirements.
Appendix C · Added a number of new submittal forms to promote consistency in RECAP submittals received by the Department and thus assist the Department in the review of submittals. n · Ecological checklist (RECAP Form 18): The area of impacted soil that triggers a screening level ecological risk assessment has been increased from 1 acre to 5 acres.
Appendix D ü TPH-GRO and DRO ranges redefined ü Added TCEQ Methods 1005 and 1006 ü Omitted Washington method for TPH fractions ü Revised indicators for kerosene and jet fuel ü Added list of target organs for TPH releases ü Updated inputs for lead models ü Guidance on PCDD and PCDF
Appendix H u New Appendix H è Appendix H + I + J è Includes MO-3 èGuidance on id of application of RS in conjunction with monitoring data (SPLP and indoor air)
Appendix H u New Appendix H è New Q/C values for VF (SSG 2001) è Revised dermal exposure assumptions - new ABS factors - revised SA, AF, IRDadj - development of dermal tox values èuse of online spreadsheets for 95%UCL-AM, SS, and RS
RECAP u Management Option 3 è Omitted MO-3 A è Development of MO-3 RS only è Included in new Appendix H
RECAP u Minor Revisions § Criteria for management under SO, MO-1, and MO-2 § Site Investigation Requirements § Data Evaluation/Useability § Land Use
RECAP Tools Or I’ve exceeded the MO-1 RECAP standards. Now what do I do?
foc ü MO-2 and MO-3 only ü Changes (raises) Soili, Soilni, Soilgw, Soilsat and Soiles ü Sample must be taken from un-impacted area of site ü Be sure to check sample location and lab analysis ü ASTM 2974 Foc = % organic matter /174
Foc – impact on benzene RS
SPLP n Alternative evaluation of soil to ground water pathway ü Replaces and supercedes Soilgw ü May be used under any MO, including SO ü Sample must be taken from location with highest constituent concentration ü EPA Method 1312
SPLP ü ü ü GW 1 – compare soil SPLP to GW 1 X (20) GW 2 – compare soil SPLP to GW 2 X 20 X DF 2 GW 3 – compare soil SPLP to GW 3 X 20 X DF 3 ü AOIC must still meet lower of Soili and Soilsat
Addressing Exposure to Multiple Constituents that Elicit Noncarcinogenic Effects on the Same Target Organ/System n Risk-based RS must be adjusted to account for potential additive effects » Soilni, Soiles » GW 1, GW 2, GWes n Not applicable to Soil. GW, Soilsat, GW 3, Watersol, background levels, quantitation limits, MCLs or ceiling values
MO-1: Accounting for Additivity Example Chemical A B C Target Organ kidney, liver kidney RS 24 15 60 Adjusted RS 8 5 20 è 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 Example Chem. A B C Target Organ kidney, liver kidney RS 24 15 60 Adjusted RS 8 5 20 [COC] 18. 0 3. 0 2. 0 è 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 MO-2 and MO-3 only n Just like MO-1 approach, applies only to direct human health-based standards, e. g. Soili, Soilni, GW 1, GW 2 and Soiles. n Do not blindly divide by the number of constituents! n
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 P THI must be < 1. 0
TPH fractionation n TPH mixtures (G, D&O) 8015 B n aliphatic and aromatic fractions