Establishing Surface Water Cleanup Levels Under WAC 173340730

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Establishing Surface Water Cleanup Levels Under
WAC 173-340-730

• Pete Kmet, P.E.
• Department of Ecology
• Toxics Cleanup Program
• [phone] pkme461_at_ecy.wa.gov

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Establishing Surface Water Cleanup Levels under
WAC 173-340-730

• Key Differences
• Federal National Toxics Rule Criteria added as
  ARAR
• Added WET test as presumptive method for
  demonstrating a cleanup level is protective of
  aquatic life

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Establishing Surface Water Cleanup Levels under
WAC 173-340-730

• Key Differences (cont.)
• Added description of how to determine TPH surface
  water cleanup level.
• Presumption added that Method A groundwater TPH
  cleanup level is protective for human health
• Added limit that cleanup level cannot result in
  NAPL forming in or on surface water

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Establishing Surface Water Cleanup Levels under
WAC 173-340-730

• Cleanup Standard Concentration
• Point of Compliance
• ARARs
• Must use reasonable maximum exposure
• (defined by surface water classification)

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Establishing Surface Water Cleanup Levels under
WAC 173-340-730
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Establishing Method A Surface Water Cleanup
Levels under WAC 173-340-730(2)
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Establishing Method A Surface Water Cleanup
Levels under WAC 173-340-730(2)
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Establishing Method A Surface Water Cleanup
Levels under WAC 173-340-730(2)
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Establishing Method B Surface Water Cleanup
Levels under WAC 173-340-730(3)
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Establishing Method B Surface Water Cleanup
Levels under WAC 173-340-730(3)
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Establishing Method B Surface Water Cleanup
Levels under WAC 173-340-730(3)
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Establishing Method B Surface Water Cleanup
Levels under WAC 173-340-730(3)
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Establishing Method C Surface Water Cleanup
Levels under WAC 173-340-730(4)

• Method C can be used where
• All practicable methods of treatment have been
  used institutional controls established and one
  of the following conditions exist
• Method A or B below technically possible
  concentration
• Method A or B below area background
• Method A or B poses greater overall threat

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Establishing Method C Surface Water Cleanup
Levels under WAC 173-340-730(4)

• Essentially the same as Method B except for
• Somewhat less stringent assumptions are used in
  the calculation of a cleanup level
• The allowable cancer risk is higher
• (1 X 10-5)

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Establishing Surface Water Cleanup Levels for
TPH Mixtures under WAC 173-340-730

• Must evaluate noncarcinogenic effects of TPH
  Mixture as a whole
• Must evaluate ARARs, noncarcinogenic and
  carcinogenic effects for individual TPH
  components
• Need either measured or predicted surface water
  composition including TPH fractions and
  components
• Must evaluate environmental effects

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Establishing Surface Water Cleanup Levels under
WAC 173-340-730

• Point of Compliance
• Standard Point of Compliance is throughout the
  site (most sites)
• Conditional point of compliance may be used for
  point source discharges
• (e.g. treatment plant discharges)

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Establishing Surface Water Cleanup Levels under
WAC 173-340-730

• Compliance Monitoring
• Surface water testing
• Testing of fish, shellfish or other aquatic
  organisms and sediments
• Evaluate compliance using procedures in water
  quality law or using statistical methods approved
  by Ecology

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Establishing Surface Water Cleanup Standards
under WAC 173-340-730

• Summary
• Highlighted key differences
• Establishing cleanup levels under Method A
• Establishing cleanup levels under Methods B and
  C.
• Special considerations for TPH mixtures
• Point of Compliance options
• Compliance monitoring requirements