The Texas Risk Reduction Program Rule

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The Texas Risk Reduction Program Rule

• Presentation to
• Texas Aggregates and Concrete Association
• Paul S. Lewis, P.G.
• Technical Support Section
• Remediation Division
• Texas Commission on Environmental Quality

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(No Transcript)
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TRRP from Space

• TRRP Overview
• TRRP Process
• Applicability
• Spill Response vs. TRRP

What Youll See from Orbit
TRRP Texas Risk Reduction Program
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Evolution of Risk-based Cleanup Rules
TRRP
Ch. Chapter in Title 30 Texas Administrative
Code
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TRRP Objectives

• Update risk assessment methods
• Combine elements of previous rules
• Standard process for all remediation programs
• Expedite cleanup process
• Protective of human health and environment
• Preserve productive use of land

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TRRPese

• The Language of Response Actions
• Person whoever is TRRPing
• COC chemical of concern
• Affected Property media w/ COCs greater than
  residential assessment levels
• PCL Protective Concentration Level
• POE Point of Exposure
• Response Action actions to comply with TRRP

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What is a PCL?

• Protective Concentration Level
• Amount of Chemical of Concern (COC) that can
  remain in media (soil, groundwater, etc) for a
  given pathway
• Protective of Human Health exposure pathways
• Water ingestion, air inhalation, dermal contact,
  etc.
• Protective of Ecological Receptors
• Considers Fate and Transport of the COC
• Calculate at Tier 1, 2 or 3 with increasing site
  specificity
• Tier 1 PCLs available on lookup tables

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Tiered PCL Development
ERA Ecological Risk Assessment
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Remedy Standards

• Remedy Standard - a demonstration that an
  affected property is protective of human health
  and the environment.
• Remedy Standard A - Pollution Cleanup
• Remove/Decontaminate
• Remedy Standard B - Exposure Prevention
• Remove/Decontaminate/Control

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TRRP Process Applicability
Establish Applicability

• Determine the applicability of TRRP or other
  requirements to the release.

Affected Property Assessment
Remedy Standard Selection
Tiered PCL Evaluation
Response Action
Post-Response Action Care
No Further Action
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TRRP Applicability
Does TRRP Apply to Me?
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Other Rules

• TRRP Interacts with theses Chapters 312, 327,
  330 thru 336
• Exceptions and Overlaps
• More stringent or additional requirements
• Examples Permits Federal requirements
• Petroleum Storage Tank program
• Existing releases stay under Ch. 334 rules
• New releases reported ? 9/1/03 use TRRP rule

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Report the Release

• Follow Reporting Requirements of
• Permit or Order
• Applicable Program statutes or rules
• TRRP does not compel initial reporting of
  releases
• Notify actions under TRRP with
• Self Implementation Notice (SIN), or
• Response Action Plan (RAP)

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TRRP and Spill Rules30 TAC Chapter 327

• Possible Scenarios
• Report Spill per Chapter 327 rules
• Use Chapter 327 or go to TRRP
• Elect to switch to TRRP at any time
• Must switch to TRRP after maximum 180 days
• Use TRRP report forms if switched
• Affected Property Assessment Report,
• Response Action Completion Report, etc.

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TRRP Process Assessment
Establish Applicability

• Collect Data to Calculate PCLs and to Determine
  the Response Action
• Chemicals of Concern (COCs) and Affected Media
• Land Use Groundwater Classification
• Exposure Pathways Receptors
• Map Affected Property using Assessment Level
  contours

Affected Property Assessment
Remedy Standard Selection
Tiered PCL Evaluation
Response Action
Post-Response Action Care
No Further Action
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Exposure Pathways
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TRRP Process Remedy and PCLs
Establish Applicability
Affected Property Assessment
Remedy Standard Selection
Tiered PCL Evaluation
Response Action
Post-Response Action Care
No Further Action
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TRRP Process Remedy and PCLs
Establish Applicability

• Develop Critical PCL lowest of all applicable
  PCLs, any tier
• Map PCL Exceedence (PCLE) Zone Volume of
  environmental media exceeding Critical PCL
• PCLE Zone becomes Focus of Remedy Standard

Affected Property Assessment
Remedy Standard Selection
Tiered PCL Evaluation
Response Action
Post-Response Action Care
No Further Action
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TRRP Process Response Action
Establish Applicability

• Carry out Response Actions to achieve either
  Remedy Standard A or Remedy Standard B at the
  PCLE Zone, consistent with project objectives.

Affected Property Assessment
Remedy Standard Selection
Tiered PCL Evaluation
Response Action
Post-Response Action Care
No Further Action
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Remedy Standard APollution Cleanup

• Clean up PCLE Zone to Critical PCL set at Tier 1,
  2 or 3 using removal or decontamination methods
• Institutional Control only for Com/Ind land use

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Remedy Standard BExposure Prevention

• Control / clean up PCLE Zone
• Institutional Controls
• Post Response Action Care
• Financial assurance for physical controls

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Response Actions and Deliverables

• Conduct response action in reasonable time
• File Reports and Notices
• Affected Property Assessment Report
• Self Implementation Notice - Std A only
• Response Action Plan -Std B (opt Std A)
• Response Action Effectiveness Report every 3
  years until done
• Notify 10 days prior to confirmation sampling

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TRRP Process Goals Reached!
Establish Applicability

• Demonstrate attainment of Remedy Standard by
• Submit Response Action Completion Report (RACR)
  w/in 90 days of attainment
• TCEQ approves RACR
• Submit proof of filing Institutional Control
  (options) w/in 90 days
• TCEQ issues Conditional or Final No Further
  Action (NFA) letter
• Post Response Action Care Reports if needed (Std
  B only)

Affected Property Assessment
Remedy Standard Selection
Tiered PCL Evaluation
Response Action
Post-Response Action Care
No Further Action
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