RECAP

1
RECAP

• From RECAP 2000
• To
• RECAP 2003

2
LDEQs RECAP

• RECAP revision schedule
• FEIS Draft and Fiscal Office Draft 11/20/02
• NOI to State Register 12/10/02
• NOI published in Louisiana Register
• (comment period begins) 12/20/02
• LDEQ Public Hearing Date 01/24/03
• Comment period ends 03/20/03
• Summary report to LOC 07/10/03
• Rule published in Louisiana Register 10/20/03
• and becomes final

3
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.

4
Current Regulation

• LAC 33I.1305 Applicability
• This Chapter establishesrequirements to evaluate
  and/or remediate sites that have been affected by
  constituents of concern
• This Chapter shall not applyplans that were
  approved by the department prior to December 20,
  1998, except when modification is deemed by the
  department to be necessary to protect

5
LAC 33I.1305 Applicability

• C. This Chapter shall not apply to
• 1. current spills that
• a. do not require notification under LAC
  33I.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

6
LAC 33I.1305

• spills that create emergency conditions, as
  defined in LAC 33I.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

7
LAC 33I.1305

• 4. current spills over the reportable quantity
  that require notification under LAC 33I.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
  33I.Chapter 39 and

8
LAC 33I.1305

• the written report required by LAC 33I.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.

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
Institutional Controls

• Clarification that if the residual COC
  concentration in soil is gt Soilni, then a
  conveyance notification shall be place on the
  property.
• Clarification that if the residual COC
  concentration in a groundwater 2 aquifer is gt GW2
  (w/o DF2), then a conveyance notice shall be
  place on the portion of the plume within the
  property boundaries.

11
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

12
Additional Guidance/Clarification

• Acute toxicity - soil/child
• Minor changes to land use codes
• Submitter may assume GW1 without TDS and yield
  data
• Data used under RECAP shall be obtained from a
  laboratory accredited by the state of Louisiana.

13
Hierarchy of toxicity values

• EPAs Integrated Risk Information System (IRIS)
• EPAs National Center for Environmental
  Assessment (NCEA) provisional values
• EPAs Health Effects Assessment Summary Tables
  (EPA)
• Values withdrawn from IRIS or HEAST
• Other EPA or EPA-recommended source.

14
Changes to the Tables

• Revised RS based on updated toxicity values and
  default assumptions
• Added Soiles to Table 2
• Added GWes and Gwair to Table 3
• Use of EPA recommended GW standard for MTBE
  based on aesthetics
• New constituents added to Tables acenaphthylene,
  2-methylnaphthalene and phenathrene

15
Identification of the AOI

• 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 gt RS

16
AOI Concentration (AOIC)

• Terminology new/use same
• Additional guidance/clarifications
• - Statistical considerations for 95UCL
• Small data sets
• High variability
• Distribution of data
• - 95UCL-AM vs Max Concentration

17
New Soil Intervals

• Current/potential surface soil 0-15
• Soili/ni, SoilGW and Soilsat
• Subsurface soil gt15 bgs
• SoilGW and Soilsat

18
Identification and Application of RECAP Standards

• GWair is required to be included in the
  identification of the limiting RS
• The GWes pathway may now be addressed under MO-1
• The Soiles pathway may now be addressed under
  MO-1

19
Ambient and indoor air issues

• Volatilization from soil and ground water gt 15
  bgs is an incomplete pathway (Soiles GWes Gwair )
• LAC 33III.5112 Ambient Air Standards (annual
  average) used for Cai
• -eliminates inconsistency with air
  regulations

20
Background

• Number of Samples
• A minimum dataset consisting of 4 discrete
  samples from unimpacted area
• ? 7 BKG arithmetic mean
• ? 8 BKG arithmetic mean 1 standard deviation
• Arsenic background of 12 mg/kg

21
Appendix B

•  
•    Clarification of air sampling guidelines.
•    Added groundwater reporting submittal
  requirements.

22
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.
•    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.

23
Appendix D

• TPH-GRO and DRO ranges redefined
• Added TCEQ Methods 1005 and 1006
• Omitted Washington method for TPH fractions
• Revised indicators for kerosene and jet fuel
• Added list of target organs for TPH releases
• Updated inputs for lead models
• Guidance on PCDD and PCDF
• - SO, MO-1, MO-2
• - soil and groundwater

24
Appendix H

• New Appendix H
• Appendix H I J
• Includes MO-3
• Guidance on id of application of RS in
  conjunction with monitoring data (SPLP and
  indoor air)

25
Appendix H

• New Appendix H
• New Q/C values for VF (SSG 2001)
• Revised dermal exposure assumptions
• - new ABS factors
• revised SA, AF, IRDadj
• development of dermal tox values
• use of online spreadsheets for 95UCL-AM, SS, and
  RS

26
RECAP

• Management Option 3
• Omitted MO-3A
• Development of MO-3 RS only
• Included in new Appendix H

27
RECAP

• Minor Revisions
• Criteria for management under SO, MO-1, and MO-2
• Site Investigation Requirements
• Data Evaluation/Useability
• Land Use

28
Bonus Slides
29
RECAP Tools

• OrIve exceeded the MO-1 RECAP
  standards. Now what do I do?

30
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

31
Foc impact on benzene RS
32
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

33
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

34
Addressing Exposure to Multiple Constituents 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

35
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)

36
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)

37
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!

38
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 lt 1.0

39
TPH fractionation

• TPH mixtures (G,DO) 8015B
• aliphatic and aromatic fractions

40
RECAP

• QUESTIONS?