RECAPRECAPFrom RECAP 2000From RECAP 2000

ToTo

RECAP 2003RECAP 2003

LDEQ’s RECAP LDEQ’s RECAP

RECAP revision scheduleRECAP revision schedule– FEIS Draft and Fiscal Office DraftFEIS Draft and Fiscal Office Draft 11/20/0211/20/02– NOI to State RegisterNOI to State Register 12/10/0212/10/02– NOI published in NOI published in Louisiana RegisterLouisiana Register

(comment period begins)(comment period begins) 12/20/0212/20/02– LDEQ Public Hearing DateLDEQ Public Hearing Date 01/24/0301/24/03– Comment period endsComment period ends 03/20/0303/20/03– Summary report to LOCSummary report to LOC 07/10/0307/10/03– Rule published in Rule published in Louisiana RegisterLouisiana Register 10/20/0310/20/03

and becomes finaland becomes final

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.

Current RegulationCurrent Regulation

LAC 33:I.1305 ApplicabilityLAC 33:I.1305 ApplicabilityA.A. This Chapter establishes…requirements to This Chapter establishes…requirements to

evaluate and/or remediate sites that have been evaluate and/or remediate sites that have been affected by constituents of concern…affected by constituents of concern…

B.B. This Chapter shall not apply…plans that were This Chapter shall not apply…plans that were approved by the department prior to December approved by the department prior to December 20, 1998, except when modification is deemed 20, 1998, except when modification is deemed by the department to be necessary to protect…by the department to be necessary to protect…

LAC 33:I.1305 ApplicabilityLAC 33:I.1305 Applicability

C.C. This Chapter shall not apply to:This Chapter shall not apply to:

1.1. current spills that:current spills that:

a.a. do not require notification under LAC do not require notification under LAC 33:I.Chapter 39;33:I.Chapter 39;

b.b. are remediated as soon as practicable, but are remediated as soon as practicable, but not more than 30 days, after learning of not more than 30 days, after learning of the discharge; andthe discharge; and

c.c. are remediated in a manner that will are remediated in a manner that will ensure protection of human health and the ensure protection of human health and the environment;environment;

LAC 33:I.1305LAC 33:I.1305

2.2. spills that create emergency conditions, as spills that create emergency conditions, as defined in LAC 33:I.3905, but do not defined in LAC 33:I.3905, but do not exceed a reportable quantity, provided exceed a reportable quantity, provided conditions specified in Subparagraphs conditions specified in Subparagraphs C.1.b-c of this Section are met;C.1.b-c of this Section are met;

3. spills solely to air; and3. spills solely to air; and

LAC 33:I.1305LAC 33:I.1305

4.4. current spills over the reportable quantity that current spills over the reportable quantity that require notification under LAC 33:I.Chapter 39, require notification under LAC 33:I.Chapter 39, that are remediated promptly in a manner that are remediated promptly in a manner protective of human health and the environment, protective of human health and the environment, provided that:provided that:

a.a. the spill is remediated as soon as practicable, but the spill is remediated as soon as practicable, but not more than 30 days, after learning of the not more than 30 days, after learning of the discharge;discharge;

b. notification is made in accordance with b. notification is made in accordance with LAC 33:I.Chapter 39; andLAC 33:I.Chapter 39; and

LAC 33:I.1305LAC 33:I.1305c.c. the written report required by LAC 33:I.Chapter 39, or a the written report required by LAC 33:I.Chapter 39, or a

subsequent follow-up report, documents that the material subsequent follow-up report, documents that the material has been removed to a level that will ensure protection of has been removed to a level that will ensure protection of human health and the environment. human health and the environment.

i.i. Such documentation may include confirmatory Such documentation may include confirmatory sampling, use of organic vapor monitoring devices or, sampling, use of organic vapor monitoring devices or, where appropriate (such as where the spill is of a dark where appropriate (such as where the spill is of a dark material and/or is very small), visual confirmation. material and/or is very small), visual confirmation.

ii.ii. Upon review of the reported cleanup Upon review of the reported cleanup documentation, the department may require documentation, the department may require a complete RECAP evaluation if the a complete RECAP evaluation if the department determines that the actions department determines that the actions taken do not adequately ensure protection of taken do not adequately ensure protection of human health and the environmenthuman health and the environment..

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.

Institutional ControlsInstitutional Controls

Clarification that if the residual COC Clarification that if the residual COC concentration in soil is > Soilconcentration in soil is > Soil

nini, then a conveyance , then a conveyance

notification shall be place on the property.notification shall be place on the property.

Clarification that if the residual COC Clarification that if the residual COC concentration in a groundwater 2 aquifer is > GWconcentration in a groundwater 2 aquifer is > GW

22

(w/o DF2), then a conveyance notice shall be (w/o DF2), then a conveyance notice shall be place on the portion of the plume within the place on the portion of the plume within the property boundaries.property boundaries.

Additional Guidance/Clarification Additional Guidance/Clarification

Use of monitored natural attenuationUse of monitored natural attenuation Use of dry vs. wet weightUse of dry vs. wet weight Identification of Identification of POC and the POE for POC and the POE for

GWGWeses and GW and GWairair..

Use of ARARs under RECAPUse of ARARs under RECAP

Additional Guidance/Clarification Additional Guidance/Clarification

Acute toxicity - soil/childAcute toxicity - soil/child

Minor changes to land use codesMinor changes to land use codes

Submitter may assume GW1 without TDS Submitter may assume GW1 without TDS

and yield dataand yield data

Data used under RECAP shall be obtained Data used under RECAP shall be obtained

from a laboratory accredited by the state from a laboratory accredited by the state

of Louisiana.of Louisiana.

Hierarchy of toxicity valuesHierarchy of toxicity values

1)1) EPA’s EPA’s Integrated Risk Information Integrated Risk Information SystemSystem ( (IRISIRIS) )

2)2) EPA’s National Center for Environmental EPA’s National Center for Environmental Assessment (NCEA) provisional values Assessment (NCEA) provisional values

3)3) EPA’s EPA’s Health Effects Assessment Health Effects Assessment Summary TablesSummary Tables (EPA) (EPA)

4)4) Values withdrawn from IRIS or HEASTValues withdrawn from IRIS or HEAST5)5) Other EPA or EPA-recommended source.Other EPA or EPA-recommended source.

Changes to the TablesChanges to the TablesRevised RS based on updated toxicity values Revised RS based on updated toxicity values

and default assumptions and default assumptions

Added SoilAdded Soileses to Table 2 to Table 2

Added GWAdded GWes es and Gwand Gwair air to Table 3to Table 3

Use of EPA recommended GW standard for Use of EPA recommended GW standard for MTBE – based on aesthetics MTBE – based on aesthetics

New constituents added to Tables: New constituents added to Tables: acenaphthylene, 2-methylnaphthalene and acenaphthylene, 2-methylnaphthalene and phenathrenephenathrene

Identification of the AOIIdentification of the AOI

Additional guidance/clarificationsAdditional guidance/clarifications

- Multiple releases- Multiple releases

- Id of multiple AOIs- Id of multiple AOIs

- Id of AOI based on land use- Id of AOI based on land use

- Id of AOI based on exposure - Id of AOI based on exposure pathwayspathways

- Only 1 or 2 locations > RSOnly 1 or 2 locations > RS

AOI Concentration (AOIC)AOI Concentration (AOIC)

Terminology new/use sameTerminology new/use same Additional guidance/clarificationsAdditional guidance/clarifications

- - Statistical considerations for 95%UCLStatistical considerations for 95%UCL

Small data setsSmall data sets

High variabilityHigh variability

Distribution of dataDistribution of data

- 95%UCL-AM vs Max Concentration- 95%UCL-AM vs Max Concentration

New Soil IntervalsNew Soil Intervals

Current/potential surface soil 0-15’ Current/potential surface soil 0-15’

SoilSoili/nii/ni, Soil, SoilGWGW and Soil and Soilsat sat

Subsurface soil >15’ bgsSubsurface soil >15’ bgs

SoilSoilGWGW and Soil and Soilsatsat

Identification and Application of Identification and Application of RECAP StandardsRECAP Standards

GWGWairair is required to be included in the is required to be included in the

identification of the limiting RSidentification of the limiting RS The GWThe GWeses pathway may now be addressed pathway may now be addressed

under MO-1 under MO-1 The SoilThe Soileses pathway may now be addressed pathway may now be addressed

under MO-1 under MO-1

Ambient and indoor air issuesAmbient and indoor air issues

Volatilization from soil and ground water > Volatilization from soil and ground water > 15’ bgs is an incomplete pathway (15’ bgs is an incomplete pathway (SoilSoileses

GWGWeses Gw Gwair air ))

LAC 33:III.5112 Ambient Air Standards LAC 33:III.5112 Ambient Air Standards (annual average) used for Cai(annual average) used for Cai

-eliminates inconsistency with air -eliminates inconsistency with air regulations regulations

BackgroundBackground

Number of SamplesNumber of Samples A minimum dataset consisting of 4 discrete A minimum dataset consisting of 4 discrete

samples from unimpacted area samples from unimpacted area

7 BKG = arithmetic mean7 BKG = arithmetic mean 8 BKG = arithmetic mean + 1 standard deviation8 BKG = arithmetic mean + 1 standard deviation

Arsenic background of 12 mg/kgArsenic background of 12 mg/kg

Appendix BAppendix B

         Clarification of air sampling guidelines.Clarification of air sampling guidelines.

      Added groundwater reporting submittal Added groundwater reporting submittal requirements.requirements.

Appendix CAppendix C

    Added a number of new submittal forms to Added a number of new submittal forms to promote consistency in RECAP submittals promote consistency in RECAP submittals received by the Department and thus assist received by the Department and thus assist the Department in the review of submittals.the Department in the review of submittals.

      Ecological checklist (RECAP Form 18): Ecological checklist (RECAP Form 18): The area of impacted soil that triggers a The area of impacted soil that triggers a screening level ecological risk assessment screening level ecological risk assessment has been increased from 1 acre to 5 acres.has been increased from 1 acre to 5 acres.

Appendix DAppendix D TPH-GRO and DRO ranges redefinedTPH-GRO and DRO ranges redefined

Added TCEQ Methods 1005 and 1006Added TCEQ Methods 1005 and 1006

Omitted Washington method for TPH fractionsOmitted Washington method for TPH fractions

Revised indicators for kerosene and jet fuel Revised indicators for kerosene and jet fuel

Added list of target organs for TPH releasesAdded list of target organs for TPH releases

Updated inputs for lead modelsUpdated inputs for lead models

Guidance on PCDD and PCDFGuidance on PCDD and PCDF

- SO, MO-1, MO-2- SO, MO-1, MO-2

- soil and groundwater- soil and groundwater

Appendix HAppendix H

New Appendix HNew Appendix H Appendix H + I + JAppendix H + I + J

Includes MO-3Includes MO-3

Guidance on id of application of RS in Guidance on id of application of RS in conjunction with monitoring data conjunction with monitoring data

(SPLP and indoor air)(SPLP and indoor air)

Appendix HAppendix H

New Appendix HNew Appendix H New Q/C values for VF (SSG 2001)New Q/C values for VF (SSG 2001)

Revised dermal exposure assumptionsRevised dermal exposure assumptions

- new ABS factors- new ABS factors

- revised SA, AF, IRDrevised SA, AF, IRDadjadj

- development of dermal tox valuesdevelopment of dermal tox values

use of online spreadsheets for 95%UCL-AM, SS, use of online spreadsheets for 95%UCL-AM, SS, and RSand RS

RECAPRECAP

Management Option 3Management Option 3 Omitted MO-3A Omitted MO-3A

Development of MO-3 RS onlyDevelopment of MO-3 RS only

Included in new Appendix HIncluded in new Appendix H

RECAPRECAP

Minor RevisionsMinor Revisions

Criteria for management under SO, MO-1, and Criteria for management under SO, MO-1, and

MO-2MO-2

Site Investigation RequirementsSite Investigation Requirements

Data Evaluation/UseabilityData Evaluation/Useability

Land UseLand Use

Bonus SlidesBonus Slides

RECAP ToolsRECAP Tools

OrOr

I’ve exceeded the MO-1 RECAP I’ve exceeded the MO-1 RECAP standards. Now what do I do?standards. Now what do I do?

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

TPH fractionationTPH fractionation

TPH mixtures (G,D&O) 8015BTPH mixtures (G,D&O) 8015B

aliphatic and aromatic fractionsaliphatic and aromatic fractions

RECAPRECAP

QUESTIONS?QUESTIONS?