Risk-Based Corrective Action Applied at Petroleum Release Sites
Risk-Based Corrective Action Applied at Petroleum Release Sites
1.1 This is a guide to risk-based corrective action (RBCA), cern at the site with Tier 1 Risk Based Screening Levels
which is a consistent decision-making process for the assess- (RBSLs) given in a look-up table;
ment and response to a petroleum release, based on the 1.2.5 Deciding whether further tier evaluation is warranted,
protection of human health and the environment. Sites with if implementation of interim remedial action is warranted or if
petroleum release vary greatly in terms of complexity, physical RBSLs may be applied as remediation target levels;
and chemical characteristics, and in the risk that they may pose 1.2.6 Collection of additional site-specific information as
to human health and the environment. The RBCA process necessary, if further tier evaluation is warranted;
recognizes this diversity, and uses a tiered approach where 1.2.7 Development of site-specific target levels (SSTLs) and
corrective action activities are tailored to site-specific condi- point(s) of compliance (Tier 2 evaluation);
tions and risks. While the RBCA process is not limited to a 1.2.8 Comparison of the concentrations of chemical(s) of
particular class of compounds, this guide emphasizes the concern at the site with the Tier 2 evaluation SSTL at the
application of RBCA to petroleum product releases through the determined point(s) of compliance or source area(s);
use of the examples. Ecological risk assessment, as discussed 1.2.9 Deciding whether further tier evaluation is warranted,
in this guide, is a qualitative evaluation of the actual or if implementation of interim remedial action is warranted, or if
potential impacts to environmental (nonhuman) receptors. Tier 2 SSTLs may be applied as remediation target levels;
There may be circumstances under which a more detailed 1.2.10 Collection of additional site-specific information as
ecological risk assessment is necessary (see Ref (1).2 necessary, if further tier evaluation is warranted;
1.2 The decision process described in this guide integrates 1.2.11 Development of SSTL and point(s) of compliance
risk and exposure assessment practices, as suggested by the (Tier 3 evaluation);
United States Environmental Protection Agency (USEPA), 1.2.12 Comparison of the concentrations of chemical(s) of
with site assessment activities and remedial measure selection concern at the site at the determined point(s) of compliance or
to ensure that the chosen action is protective of human health source area(s) with the Tier 3 evaluation SSTL; and
and the environment. The following general sequence of events 1.2.13 Development of a remedial action plan to achieve the
is prescribed in RBCA, once the process is triggered by the SSTL, as applicable.
suspicion or confirmation of petroleum release: 1.3 The guide is organized as follows:
1.2.1 Performance of a site assessment; 1.3.1 Section 2 lists referenced documents,
1.2.2 Classification of the site by the urgency of initial 1.3.2 Section 3 defines terminology used in this guide,
response; 1.3.3 Section 4 describes the significance and use of this
1.2.3 Implementation of an initial response action appropri- guide,
ate for the selected site classification; 1.3.4 Section 5 is a summary of the tiered approach,
1.3.5 Section 6 presents the RBCA procedures in a step-by-
step process,
1
This guide is under the jurisdiction of ASTM Committee E50 on Environmental 1.3.6 Appendix X1 details physical/chemical and toxico-
Assessment and is the direct responsibility of Subcommittee E50.04 on Performance logical characteristics of petroleum products,
Standards Related to Environmental Regulatory Programs. 1.3.7 Appendix X2 discusses the derivation of a Tier 1
Current edition approved Sept. 10, 1995. Published November 1995. Originally
published as ES 38 – 94. Last previous edition ES 38 – 94.
RBSL Look-Up Table and provides an example,
2
The boldface numbers in parentheses refer to the list of references at the end of 1.3.8 Appendix X3 describes the uses of predictive model-
this guide. ing relative to the RBCA process,
Copyright © ASTM International, 100 Barr Harbor Drive, PO Box C700, West Conshohocken, PA 19428-2959, United States.
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of a site to determine potential exposure pathways and recep- carbons or the location of highest soil and ground water
tors based on known or readily available information. concentrations of the chemical(s) of concern.
3.1.26 reasonable maximum exposure (RME)—the highest 3.1.41 target levels—numeric values or other performance
exposure that is reasonably expected to occur at a site. RMEs criteria that are protective of human health, safety, and the
are estimated for individual pathways or a combination of environment.
exposure pathways. 3.1.42 Tier 1 evaluation—a risk-based analysis to develop
3.1.27 reasonable potential exposure scenario— a situation non-site-specific values for direct and indirect exposure path-
with a credible chance of occurence where a receptor may ways utilizing conservative exposure factors and fate and
become directly or indirectly exposed to the chemical(s) of transport for potential pathways and various property use
concern without considering extreme or essentially impossible categories (for example, residential, commercial, and industrial
circumstances. uses). Values established under Tier 1 will apply to all sites that
3.1.28 reasonably anticipated future use—future use of a fall into a particular category.
site or facility that can be predicted with a high degree of 3.1.43 Tier 2 evaluation—a risk-based analysis applying the
certainty given current use, local government planning, and direct exposure values established under a Tier 1 evaluation at
zoning. the point(s) of exposure developed for a specific site and
3.1.29 receptors—persons, structures, utilities, surface wa- development of values for potential indirect exposure pathways
ters, and water supply wells that are or may be adversely at the point(s) of exposure based on site-specific conditions.
affected by a release. 3.1.44 Tier 3 evaluation—a risk-based analysis to develop
3.1.30 reference dose—a preferred toxicity value for evalu- values for potential direct and indirect exposure pathways at
ating potential noncarcinogenic effects in humans resulting the point(s) of exposure based on site-specific conditions.
from exposure to a chemical(s) of concern. 3.1.45 user—an individual or group involved in the RBCA
3.1.31 remediation/remedial action—activities conducted to process including owners, operators, regulators, underground
protect human health, safety, and the environment. These storage tank (UST) fund managers, attorneys, consultants,
activities include evaluating risk, making no-further-action legislators, and so forth.
determinations, monitoring institutional controls, engineering
controls, and designing and operating cleanup equipment. 4. Significance and Use
3.1.32 risk assessment—an analysis of the potential for 4.1 The allocation of limited resources (for example, time,
adverse health effects caused by a chemical(s) of concern from money, regulatory oversight, qualified professionals) to any
a site to determine the need for remedial action or the one petroleum release site necessarily influences corrective
development of target levels where remedial action is required. action decisions at other sites. This has spurred the search for
3.1.33 risk reduction—the lowering or elimination of the innovative approaches to corrective action decision making,
level of risk posed to human health or the environment through which still ensures that human health and the environment are
interim remedial action, remedial action, or institutional or protected.
engineering controls. 4.2 The RBCA process presented in this guide is a consis-
3.1.34 risk-based screening level/screening levels tent, streamlined decision process for selecting corrective
(RBSLs)—risk-based site-specific corrective action target lev- actions at petroleum release sites. Advantages of the RBCA
els for chemical(s) of concern developed under the Tier 1 approach are as follows:
evaluation. 4.2.1 Decisions are based on reducing the risk of adverse
3.1.35 site—the area(s) defined by the extent of migration human or environmental impacts,
of the chemical(s) of concern. 4.2.2 Site assessment activities are focussed on collecting
3.1.36 site assessment—an evaluation of subsurface geol- only that information that is necessary to making risk-based
ogy, hydrology, and surface characteristics to determine if a corrective action decisions,
release has occurred, the levels of the chemical(s) of concern, 4.2.3 Limited resources are focussed on those sites that pose
and the extent of the migration of the chemical(s) of concern. the greatest risk to human health and the environment at any
The site assessment collects data on ground water quality and time,
potential receptors and generates information to support reme- 4.2.4 The remedial action achieves an acceptable degree of
dial action decisions. exposure and risk reduction,
completed within 30-day time periods that do not reflect the implemented simultaneously with the RBCA process. Sites
actual urgency of and risks posed by the site, should be reclassified as actions are taken to resolve concerns
4.5.4 Use of the RBCA process only when active remedia- or as better information becomes available.
tion is not technically feasible, rather than a process that is 5.5 Tier 1 Evaluation—A look-up table containing screen-
applicable during all phases of corrective action, ing level concentrations is used to determine whether site
4.5.5 Requiring the user to achieve technology-based reme- conditions satisfy the criteria for a quick regulatory closure or
dial limits (for example, asymptotic levels) prior to requesting
warrant a more site-specific evaluation. Ground water, soil, and
the approval for the RBSL or SSTL,
vapor concentrations may be presented in this table for a range
4.5.6 The use of predictive modelling that is not supported
of site descriptions and types of petroleum products ((for
by available data or knowledge of site conditions,
example, gasoline, crude oil, and so forth). The look-up table
4.5.7 Dictating that corrective action goals can only be
of RBSL is developed in Tier 1 or, if a look-up table has been
achieved through source removal and treatment actions,
previously developed and determined to be applicable to the
thereby restricting the use of exposure reduction options, such
as engineering and institutional controls, site by the user, then the existing RBSLs are used in the Tier 1
4.5.8 The use of unjustified or inappropriate exposure fac- process. Tier 1 RBSLs are typically derived for standard
tors, exposure scenarios using current RME and toxicological pa-
4.5.9 The use of unjustified or inappropriate toxicity param- rameters as recommended by the USEPA. These values may
eters, change as new methodologies and parameters are developed.
4.5.10 Neglecting aesthetic and other criteria when deter- Tier 1 RBSLs may be presented as a range of values,
mining RBSLs or SSTLs, corresponding to a range of risks or property uses.
4.5.11 Not considering the effects of additivity when screen- 5.6 Tier 2 Evaluation—Tier 2 provides the user with an
ing multiple chemicals, option to determine SSTLs and point(s) of compliance. It is
4.5.12 Not evaluating options for engineering or institu- important to note that both Tier 1 RBSL and Tier 2 SSTLs are
tional controls, exposure point(s), compliance point(s), and based on achieving similar levels of protection of human health
carcinogenic risk levels before submitting remedial action and the environment (for example, 10−4 to 10−6 risk levels).
plans, However, in Tier 2 the non-site-specific assumptions and
4.5.13 Not maintaining engineering or institutional controls, point(s) of exposure used in Tier 1 are replaced with site-
and specific data and information. Additional site-assessment data
4.5.14 Requiring continuing monitoring or remedial action may be needed. For example, the Tier 2 SSTL can be derived
at sites that have achieved the RBSL or SSTL. from the same equations used to calculate the Tier 1 RBSL,
except that site-specific parameters are used in the calculations.
5. Tiered Approach to Risk-Based Corrective Action The additional site-specific data may support alternate fate and
(RBCA) at Petroleum Release Sites transport analysis. At other sites, the Tier 2 analysis may
5.1 RBCA is the integration of site assessment, remedial involve applying Tier 1 RBSLs at more probable point(s) of
action selection, and monitoring with USEPA-recommended exposure. Tier 2 SSTLs are consistent with USEPA-
risk and exposure assessment practices. This creates a process recommended practices.
• Explosive levels, or concentrations of vapors that could cause acute • Evacuate occupants and begin abatement measures such as
health effects, are present in a residence or other building. subsurface ventilation or building pressurization.
• Explosive levels of vapors are present in subsurface utility system(s), but • Evacuate immediate vicinity and begin abatement measures such as
no building or residences are impacted. ventilation.
• Free-product is present in significant quantities at ground surface, on • Prevent further free-product migration by appropriate containment
surface water bodies, in utilities other than water supply lines, or in measures, institute free-product recovery, and restrict area access.
surface water runoff.
• An active public water supply well, public water supply line, or public • Notify user(s), provide alternate water supply, hydraulically control
surface water intake is impacted or immediately threatened. contaminated water, and treat water at point-of-use.
• Ambient vapor/particulate concentrations exceed concentrations of • Install vapor barrier (capping, foams, and so forth), remove source,
concern from an acute exposure or safety viewpoint. or restrict access to affected area.
• A sensitive habitat or sensitive resources (sport fish, economically • Minimize extent of impact by containment measures and implement
important species, threatened and endangered species, and so forth) are habitat management to minimize exposure.
impacted and affected.
2. Short-term (0 to 2 years) threat to human health, safety, Notify appropriate authorities, property owners, and potentially affected parties,
or sensitive environmental receptors and only evaluate the need to
• There is potential for explosive levels, or concentrations of vapors that • Assess the potential for vapor migration (through monitoring/
could cause acute effects, to accumulate in a residence or other building. modeling) and remove source (if necessary), or install vapor
migration barrier.
• Shallow contaminated surface soils are open to public access, and • Remove soils, cover soils, or restrict access.
dwellings, parks, playgrounds, day-care centers, schools, or similar use
facilities are within 500 ft (152 m) of those soils.
• A non-potable water supply well is impacted or immediately threatened. • Notify owner/user and evaluate the need to install point-of-use water
treatment, hydraulic control, or alternate water supply.
• Ground water is impacted, and a public or domestic water supply well • Institute monitoring and then evaluate if natural attenuation is
producing from the impacted aquifer is located within two-years projected sufficient, or if hydraulic control is required.
ground water travel distance down gradient
of the known extent of chemical(s) concern.
• Ground water is impacted, and a public or domestic water supply well • Monitor ground water well quality and evaluate if control is
producing from a different interval is located within the known extent of necessary to prevent vertical migration to the supply well.
chemicals of concern.
• Impacted surface water, storm water, or ground water discharges within • Institute containment measures, restrict access to areas near
500 ft (152 m) of a sensitive habitat or surface water body used for human discharge, and evaluate the magnitude and impact of the discharge.
drinking water or contact recreation.
3. Long-term (>2 years) threat to human health, safety, or sensitive Notify appropriate authorities, property owners, and potentially affected parties,
environmental receptors and only evaluate the need to
• Subsurface soils (>3 ft (0.9 m) BGS) are significantly impacted, and the • Monitor ground water and determine the potential for future migration
depth between impacted soils and the first potable aquifer is less than 50 of the chemical(s) concerns to the aquifer.
ft (15 m).
• Ground water is impacted, and potable water supply wells producing from • Monitor the dissolved plume and evaluate the potential for natural
the impacted interval are located >2 years ground water travel time from attenuation and the need for hydraulic control.
the dissolved plume.
• Ground water is impacted, and non-potable water supply wells producing • Identify water usage of well, assess the effect of potential impact,
from the impacted interval are located >2 years ground water travel time monitor the dissolved plume, and evaluate whether natural
from the dissolved plume. attenuation or hydraulic control are appropriate control measures.
• Ground water is impacted, and non-potable water supply wells that do not • Monitor the dissolved plume, determine the potential for vertical
produce from the impacted interval are located within the known extent of migration, notify the user, and determine if any impact is likely.
chemical(s) of concern.
• Impacted surface water, storm water, or ground water discharges within • Investigate current impact on sensitive habitat or surface water body,
1500 ft (457 m) of a sensitive habitat or surface water body used for restrict access to area of discharge (if necessary), and evaluate the
human drinking water or contact recreation. need for containment/control measures.
• Shallow contaminated surface soils are open to public access, and • Restrict access to impact soils.
dwellings, parks, playgrounds, day-care centers, schools, or similar use
facilities are more than 500 ft (152 m) of those soils.
4. No demonstrable long-term threat to human health or safety Notify appropriate authorities, property owners, and potentially affected parties,
or sensitive environmental receptors and only evaluate the need to
Priority 4 scenarios encompass all other conditions not described in Priorities 1, 2,
and 3 and that are consistent with the priority description given above. Some
examples are as follows:
• Non-potable aquifer with no existing local use impacted. • Monitor ground water and evaluate effect of natural attenuation on
dissolved plume migration.
• Impacted soils located more than 3 ft (0.9 m) BGS and greater than 50 ft • Monitor ground water and evaluate effect of natural attenuation on
(15 m) above nearest aquifer. leachate migration.
• Ground water is impacted, and non-potable wells are located down • Monitor ground water and evaluate effect of natural attenuation on
gradient outside the known extent of the chemical(s) of concern, and they dissolved plume migration.
produce from a nonimpacted zone.
A
Johnson, P. C., DeVaull, G. E., Ettinger, R. A., MacDonald, R. L. M., Stanley, C. C., Westby, T. S., and Conner, J., “Risk-Based Corrective Action: Tier 1 Guidance
Manual,” Shell Oil Co., July 1993.
B
Note that these are potential initial response actions that may not be appropriate for all sites. The user is encouraged to select options that best address the short-term
health and safety concerns of the site, while the RBCA process progresses.
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sources, transport mechanisms, and pathways leading to the panied by the issuing of a no-further-action letter by the
chemical(s) of concern above the RBSL. Adjust the mix of oversight regulatory agency.
remedial action measures until no potential receptors have 6.8 Tier 2—Tier 2 provides the user with an option to
concentrations of chemical(s) of concerns above the RBSL determine the site-specific point(s) of compliance and corre-
with the remedial action measures in place. Show the most sponding SSTL for the chemical(s) of concern applicable at the
likely Tier 1 remedial action measure(s) selected for this site by point(s) of compliance and source area(s). Additional site
marking the appropriate valve symbols on the flowchart and assessment data may be required; however, the incremental
recording a remedial action measure on the right-hand-side of effort is typically minimal relative to Tier 1. If the user
this figure. completes a Tier 1 evaluation, in most cases, only a limited
6.7 Evaluation of Tier Results—At the conclusion of each number of pathways, exposure scenarios, and chemical(s) of
tier evaluation, the user compares the target levels (RBSLs or concern are considered in the Tier 2 evaluation since many are
SSTLs) to the concentrations of the chemical(s) of concern at eliminated from consideration during the Tier 1 evaluation.
the point(s) of compliance. 6.8.1 In Tier 2, the user:
6.7.1 If the concentrations of the chemical(s) of concern 6.8.1.1 Identifies the indirect exposure scenarios to be
exceed the target levels at the point(s) of compliance, then addressed and the appropriate site-specific point(s) of compli-
either remedial action, interim remedial action, or further tier ance. A combination of assessment data and predictive mod-
evaluation should be conducted. eling results are used to determine the SSTL at the source
6.7.1.1 Remedial Action— A remedial action program is area(s) or the point(s) of compliance, or both; or
designed and implemented. This program may include some 6.8.1.2 Applies Tier 1 RBSL Look-Up Table values for the
combination of source removal, treatment, and containment direct exposure scenarios at reasonable point(s) of exposure (as
technologies, as well as engineering and institutional controls. opposed to the source area(s) as is done in Tier 1). The SSTLs
Examples of these include the following: soil venting, biovent- for source area(s) and point(s) of compliance can be deter-
ing, air sparging, pump and treat, and natural attenuation/ mined based on the demonstrated and predicted attenuation
passive remediation. When concentrations of chemical(s) of (reduction in concentration with distance) of compounds that
concern no longer exceed the target levels at the point of migrate away from the source area(s).
compliance, then the user may elect to move to 6.7.3. 6.8.1.3 An example of a Tier 2 application is illustrated in
6.7.1.2 Interim Remedial Action—If achieving the desired Appendix X5.
risk reduction is impracticable due to technology or resource 6.8.2 Tier 2 of the RBCA process involves the development
limitations, an interim remedial action, such as removal or of SSTL based on the measured and predicted attenuation of
treatment of “hot spots,” may be conducted to address the most the chemical(s) of concern away from the source area(s) using
significant concerns, change the site classification, and facili- relatively simplistic mathematical models. The SSTLs for the
tate reassessment of the tier evaluation. source area(s) are generally not equal to the SSTL for the
6.7.1.3 Further Tier Evaluation—If further tier evaluation is point(s) of compliance. The predictive equations are character-
warranted, additional site assessment information may be ized by the following:
collected to develop SSTLs under a Tier 2 or Tier 3 evaluation. 6.8.2.1 The models are relatively simplistic and are often
Further tier evaluation is warranted when: algebraic or semianalytical expressions;
((1) The basis for the RBSL values (for example, geology, 6.8.2.2 Model input is limited to practicably attainable
exposure parameters, point(s) of exposure, and so forth) are not site-specific data or easily estimated quantities (for example,
representative of the site-specific conditions; or total porosity, soil bulk density); and
((2) The SSTL developed under further tier evaluation will 6.8.2.3 The models are based on descriptions of relevant
be significantly different from the Tier 1 RBSL or will physical/chemical phenomena. Most mechanisms that are ne-
significantly modify the remedial action activities; or glected result in predicted concentrations that are greater than
((3) Cost of remedial action to RBSLs will likely be greater those likely to occur (for example, assuming constant concen-
than further tier evaluation and subsequent remedial action. trations in source area(s)). Appendix X3 discusses the use of
evaluate the tier results in accordance with 6.7 except that a tier 6.12 Monitoring and Site Maintenance—In many cases,
upgrade (6.7.5) is not available. monitoring is necessary to demonstrate the effectiveness of
6.10 Implementing the Selected Remedial Action implemented remedial action measures or to confirm that
Program—When it is judged by the user that no further current conditions persist or improve with time. Upon comple-
assessment is necessary, or practicable, a remedial alternatives tion of this monitoring effort (if required), no further action is
evaluation should be conducted to confirm the most cost- required. In addition, some measures (for example, physical
effective option for achieving the final remedial action target barriers such as capping, hydraulic control, and so forth)
levels (RBSLs or SSTLs, as appropriate). Detailed design require maintenance to ensure integrity and continued perfor-
specifications may then be developed for installation and mance.
operation of the selected measure. The remedial action must 6.13 No Further Action and Remedial Action Closure—
continue until such time as monitoring indicates that concen- When RBCA RBSLs or SSTLs have been demonstrated to be
trations of the chemical(s) of concern are not above the RBSL achieved at the point(s) of compliance or source area(s), or
or SSTL, as appropriate, at the points of compliance or source both, as appropriate, and monitoring and site maintenance are
area(s), or both. no longer required to ensure that conditions persist, then no
6.11 RBCA Report— After completion of the RBCA activi- further action is necessary, except to ensure that institutional
ties, a RBCA report should be prepared and submitted to the controls (if any) remain in place.
(Nonmandatory Information)
X1.1. The height of, and area under, each peak are measures of the use of leaded gasolines. Leaded gasolines were phased out
how much of that component is present in the mixture. As of most markets by 1989.
would be expected by their higher volatilities, the lighter X1.2.4.5 In order to reduce atmospheric emissions of lead,
hydrocarbons (up to about C7) evaporate first and are greatly lead “scavengers” were sometimes added to leaded gasolines.
reduced in the weathered gasoline. The gas chromatogram of a Ethylene dibromide (EDB) and ethylene dichloride (EDC)
fuel oil is also shown for comparison. were commonly used for this purpose.
X1.2.4.2 The aromatic hydrocarbons in gasoline are prima- X1.2.5 Kerosene and Jet Fuel—The hydrocarbons in kero-
rily benzene (C6H6), toluene (C7H8), ethylbenzene (C8H10), sene commonly fall into the C11 to C13 range, and distill at
and xylenes (C8H 10); these are collectively referred to as approximately 150 to 250°C. Special wide-cut (that is, having
“BTEX.” Some heavier aromatics are present also, including broader boiling range) kerosenes and low-flash kerosenes are
low amounts of polyaromatic hydrocarbons (PAHs). Aromatics also marketed. Both aliphatic and aromatic hydrocarbons are
typically comprise about 10 to 40 % of gasoline. present, including more multi-ring compounds and kerosene.
X1.2.4.3 Oxygenated compounds (“oxygenates”) such as X1.2.5.1 Commercial jet fuels JP-8 and Jet A have similar
alcohols (for example, methanol or ethanol) and ethers (for compositions to kerosene. Jet fuels JP-4 and JP-5 are wider
example, methyl tertiarybutyl ether—MTBE) are sometimes cuts used by the military. They contain lighter distillates and
added to gasoline as octane boosters and to reduce carbon have some characteristics of both gasoline and kerosene.
monoxide exhaust emissions. Methyl tertiarbutyl ether has X1.2.5.2 Aromatic hydrocarbons comprise about 10 to
been a common additive only since about 1980. 20 % of kerosene and jet fuels.
X1.2.4.4 Leaded gasoline, which was more common in the X1.2.6 Diesel Fuel and Light Fuel Oils—Light fuel oils
past, contained lead compounds added as octane boosters. include No. 1 and No. 2 fuel oils, and boil in the range from
Tetraethyl lead (TEL) is one lead compound that was com- 160 to 400°C. Hydrocarbons in light fuel oils and diesel fuel
monly used as a gasoline additive. Other similar compounds typically fall in the C10 to C20 range. Because of their higher
were also used. Sometimes mixtures of several such com- molecular weights, constituents in these products are less
pounds were added. Because of concerns over atmospheric volatile, less water soluble, and less mobile than gasoline- or
emissions of lead from vehicle exhaust, the EPA has reduced kerosene-range hydrocarbons.
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See Ref (8).
I
See Ref (9).
J
Estimation Equation (from (10)):
(1) log Koc = −0.55 log S + 3.64, where S = water solubility (mg/L)
(2) log Koc = 0.544 log P + 1.377
K
Listed in the January 1991 Drinking Water Priority List and may be subject to future regulation (56 FR 1470, 01/14/91).
L
USEPA. May 1993. Office of Drinking Water. 15 µg/L is an action level; standard for tap water.
M
Proposed standard.
N
See Ref (11).
O
See Ref (6). Health-based criteria for carcinogenic polycyclic aromatic compounds (PAHs) with the exception of dibenzo(a,h)anthracene are set at one tenth of the
level of benzo(a)pyrene due to their recognized lesser potency.
X1.4.2 Table X1.3 identifies chemicals of concern most fuel, as well as their toxicity, water solubility, subsurface
often considered when assessing impacts of petroleum prod- mobility, aesthetic characteristics, and the availability of suf-
ucts, based on knowledge of their concentration in the specific ficient information to conduct risk assessments. The chemicals
of concern are identified by an “X” in the appropriate column.
TABLE X1.3 Commonly Selected Chemicals of Concern for
Petroleum Products X1.5 Toxicity of Petroleum Hydrocarbons:
Unleaded Leaded Kerosene/
Diesel/ Heavy X1.5.1 The following discussion gives a brief overview of
Light Fuel
Gasoline Gasoline Jet Fuels
Fuel Oils Oils
origin of the toxicity parameters (reference doses (RfDs)), and
slope factors (SFs), a justification for common choices of
Benzene X X X ... ...
Toluene X X X ... ... chemicals of concern and then, in X1.6, a brief summary of the
Ethylbenzene X X X ... ... toxicological, physical, and chemical parameters associated
Xylene X X X ... ... with these chemicals of concern.
MTBE, TBA, when when ... ... ...
MEK, MIBK, suspectedA suspectedA X1.5.2 How Toxicity Is Assessed: Individual Chemicals
methanol, ethanol Versus Mixtures—The toxicity of an individual chemical is
Lead, EDC, EDB ... X ... ... ...
PNAsB ... ... X X X
typically established based on dose-response studies that esti-
A
mate the relationship between different dose levels and the
For example, when these compounds may have been present in the spilled
gasoline. These additives are not present in all gasolines. magnitude of their adverse effects (that is, toxicity). The
B
A list of selected PNAs for consideration is presented in Table X1.2. dose-response data is used to identify a “safe dose” or a toxic
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TPH are often used in site assessments. These methods usually effects include those given for acute and chronic studies.
determine the total amount of hydrocarbons present as a single X1.5.6.4 Ideally, safe or acceptable doses are calculated
number, and give no information on the types of hydrocarbon from chronic studies, although, due to the frequent paucity of
present. Such TPH methods may be useful for risk assessments chronic data, subchronic studies are used.
where the whole product toxicity approach is appropriate. X1.5.6.5 For noncarcinogens, safe doses are based on no
However in general, TPH should not be used for “individual observed adverse effect levels (NOAELs) or lowest observed
constituent” risk assessments because the general measure of adverse effect levels (LOAELs) from the studies.
TPH provides insuffıcient information about the amounts of X1.5.6.6 Acceptable doses for carcinogens are determined
individual compounds present. from mathematical models used to generate dose-response
curves in the low-dose region from experimentally determined
X1.5.5 Toxicity Assessment Process—Dose-response data
dose-response curves in the high-dose region.
are used to identify a “safe dose” or toxic level for a particular
X1.5.7 Data from the preceding studies are used to generate
observed adverse effect. Observed adverse effects can include reference doses (RfDs), reference concentrations (RfCs), and
whole body effects (for example, weight loss, neurological slope factors (SFs) and are also used in generating drinking
observations), effects on specific body organs, including the water maximum concentration levels (MCLs) and goals
central nervous system, teratogenic effects (defined by the (MCLGs), health advisories (HAs), and water quality criteria.
ability to produce birth defects), mutagenic effects (defined by These terms are defined in Table X1.5 and further discussed in
the ability to alter the genes of a cell), and carcinogenic effects X3.8.
(defined by the ability to produce malignant tumors in living X1.5.8 Selection of Chemicals of Concern—The impact on
tissues). Because of the great concern over risk agents which human health and the environment in cases of gasoline and
may produce incremental carcinogenic effects, the USEPA has middle distillate contamination of soils and ground water can
developed weight-of-evidence criteria for determining whether be assessed based on potential receptor (that is, aquatic
a risk agent should be considered carcinogenic (see Table organisms, human) exposure to three groups of materials: light
X1.4). aromatic hydrocarbons, PAHs, and in older spills, lead. Al-
X1.5.6 Most estimates of a “safe dose” or toxic level are though not one of the primary contaminants previously de-
based on animal studies. In rare instances, human epidemio- scribed, EDB and EDC were used as lead scavengers in some
logical information is available on a chemical. Toxicity studies leaded gasolines and may be considered chemicals of concern,
can generally be broken into three categories based on the when present.
X1.5.9 The light aromatics, benzene, toluene, xylenes, and in gasolines, are of concern because of their high toxicity
ethylbenzene have relatively high water solubility and sorb (potential carcinogens) and their high mobility in the environ-
poorly to soils. Thus, they have high mobility in the environ- ment.
ment, moving readily through the subsurface. When released X1.5.12 In summary, benzene and benzo(a)pyrene (and in
into surface bodies of water, these materials exhibit moderate some cases EDB and EDC) are chemicals of concern because
to high acute toxicity to aquatic organisms. Although environ- of their carcinogenicity. Other PAHs may also be grouped with
mental media are rarely contaminated to the extent that acute B(a)P because of uncertainties in their carcinogenicity and
human toxicity is an issue, benzene is listed by the USEPA as because they may accumulate (bioconcentrate) in living tissue.
a Group A Carcinogen (known human carcinogen) and, thus, X1.5.13 Toxicity and Physical/Chemical Properties for
exposure to even trace levels of this material is considered Chemicals of Concern—A summary of health effects and
significant. physical/chemical properties for a number of chemicals of
concern is provided in Table X1.2. This table provides toxico-
X1.5.10 Polycyclic aromatics can be broken into two cat-
logical data from a variety of sources, regardless of data
egories: naphthalenes and methylnaphthalenes (diaromatics) quality. A refined discussion for selected chemicals of concern
have moderate water solubility and soil sorption potential and, is given as follows. The reader is cautioned that this informa-
thus, their movement through the subsurface tends to be less tion is only current as of the dates quoted, and the sources
than monoaromatics, but substantial movement can still occur. quoted may have been updated, or more recent information
When released into surface bodies of water, these materials may be available in the peer-reviewed literature.
have moderate to high toxicity to aquatic organisms. The PAHs X1.5.13.1 The RfD or SF values are generally obtained
with three or more condensed rings have very low solubility from a standard set of reference tables (for example, Integrated
(typically less than 1 mg/L) and sorb strongly to soils. Thus, Risk Information System, IRIS (2), or the Health Effects
their movement in the subsurface is minimal. Several members Assessment Summary Tables, HEAST (3)). Except as noted,
in the group of three to six-ring PAHs are known or suspected the toxicity evaluations that follow were taken from IRIS (2)
carcinogens and, thus, exposure to low concentrations in because these are EPA-sanctioned evaluations. The informa-
drinking water or through the consumption of contaminated tion in IRIS (2), however, has typically only been peer-
soil by children is significant. In addition, materials containing reviewed within the EPA and may not always have support
four to six-ring PAHs are poorly biodegradable and, coupled from the external scientific community. The information in
with the potential to bioaccumulate in tissues of aquatic IRIS may also be subject to error (as exampled by recent
organisms, these materials have the potential to bioconcentrate revisions in the slope factor for B(a)P and RfC for MTBE).
(be found at levels in living tissue far higher than present in the X1.5.13.2 HEAST (3) is a larger database than IRIS (2) and
general surroundings) in the environment. is often used as a source of health effects information. Whereas
X1.5.11 Although almost totally eliminated from use in the information in IRIS (2) has been subject to data quality
gasolines in the United States, lead is found associated with review, however, the information in the HEAST (3) tables has
older spills. Lead was typically added to gasoline either as not. The user is expected to consult the original assessment
tetraethyl or tetramethyl lead and may still be found in its documents to appreciate the strengths and limitations of the
original form in areas containing free product. Typically data in HEAST (3). Thus, care should be exercised in using the
outside the free product zones, these materials have decom- values in HEAST (3).
posed into inorganic forms of lead. Lead is a neurotoxin and X1.5.13.3 References for the physical/chemical properties
lead in the blood of children has been associated with reduced are provided in Table X1.2. All Henry’s law constants quoted
in text are from Ref (11) except MTBE which is from
intellectual development. The ingestion by children of lead-
estimation: H = (Vp)(MW)/760(S), where MW is the molecular
contaminated soils is an exposure route of great concern, as is
weight, V p = 414 mmHg at 100°F, and S = 48 000 mg/L.
the consumption of lead-contaminated drinking water. Ethyl-
ene dibromide and ethylene dichloride, used as lead scavengers X1.6 Profiles of Select Compounds:
--```,`,,,`,`,`,``,,,,,```````-`-`,,`,,`,`,,`---
moderate low Kow value (3.15) and is biodegradable. There- carcinogenic to experimental animals. On the other hand,
fore, it is not expected to bioaccumulate. In laboratory tests, benz[a]-anthracene, benzo[a]pyrene, dibenz[a,h]anthracene,
when a free gasoline phase was in equilibrium with water, and 7,12-dimethylbenz[a]-anthracene have been shown to be
typical combined ethylbenzene and xylenes concentrations in carcinogenic in laboratory animals. B(a)P and pyrene are
water ranged from 1.08 3 104 to 2.39 3 10 4µg/L. discussed in X1.6.7 and X1.6.8 as representatives of carcino-
X1.6.5 Naphthalenes: genic and noncarcinogenic effects of this class.
X1.6.5.1 Toxicity Summary—In general, poisoning may oc- X1.6.7 Benzo(a)pyrene (BaP):
cur by ingestion of large doses, inhalation, or skin adsorption
of naphthalene. It can cause nausea, headache, diaphoresis, X1.6.7.1 Toxicity Summary—Based on animal data, B(a)P
hematuria, fever, anemia, liver damage, vomiting, convulsions, has been classified as a probable human carcinogen (B2
and coma. Methylnaphthalenes are presumably less acutely carcinogen) by the USEPA. A range of oral slope factors from
−1
toxic than naphthalene. Skin irritation and skin photosensitiza- 4.5 to 11.7 (mg/kg/day)
−1
with a geometric mean of 7.3
tion are the only effects reported in man. Inhalation of the (mg/kg/day) has been derived for B(a)P based on the
vapor may cause headache, confusion, nausea, and sometimes observance of tumors of the forestomach and squamous cell
vomiting. The environmental concerns with naphthalenes are carcinomas in mice. The data was considered less than optimal
primarily attributed to effects on aquatic organisms. As a but acceptable (note that the carcinogenicity assessment for
consequence, the EPA has not set any human health criteria for B(a)P may change in the near future pending the outcome of an
these materials (that is, there is no RfD or RfC, no drinking on-going EPA review). The EPA has proposed a drinking water
water MCL or MCLG or ambient water quality criteria). A risk MCL at 0.2 µg/L (based on the analytical detection limits). The
assessment to define a RfD for these materials is presently MCLG for B(a)P is set at zero. In situations in which both
under review by the EPA. Drinking water health advisories aquatic life and water are consumed from a particular body of
range from 20 µg/L (lifetime, adult) to 500 µg/L (one-day water, a recommended
−3
EPA water quality criterion is set at
advisory for a child).6 2.8 3 10 µg/L. When only aquatic organisms are consumed,
the criterion is 3.11 3 10−2µg/L.
X1.6.5.2 Physical/Chemical Parameter Summary:
Naphthalene—Naphthalene has a relatively high Henry’s law X1.6.7.2 Physical/Chemical Parameter Summary—When
constant (1.15 3 10−3 m3-atm/mol) and, thus, has the capacity released to water, PAHs are not subject to rapid volatilization
to volatilize rapidly under common above-ground environmen- (Henry’s law constants are on the order of 1.0 3 10 −4
tal conditions. It has a moderate water solubility (3.10 3 10 m3-atm/mol or less) under common environmental conditions.
4µg/L) and log Koc (3.11) and has the potential to leach to They have low aqueous solubility values and tend to sorb to
ground water. A moderate log Kow value of 3.01 has been soils and sediments and remain fixed in the environment. Three
reported, but because naphthalene is very biodegradable, it is ring members of this group such as anthracene and phenan-
unlikely to bioconcentrate to a significant degree. threne have water solubilities on the order of 1000 µg/L. The
water solubilities decrease substantially for larger molecules in
the group, for example, benzo[a]pyrene has a water solubility
of 1.2 µg/L. The log Koc values for PAHs are on the order of 4.3
6
Office of Water, USEPA, Washington, DC. and greater, which suggests that PAHs will be expected to
--```,`,,,`,`,`,``,,,,,```````-`-`,,`,,`,`,,`---
1 3 10−6 remained unregulated. (18). The State of Maine Department of Human Services
X1.7.4.2 For small populations, regulatory action never (DHS) uses a lifetime risk of one in one hundred thousand as
resulted for individual risks below 1 3 10−4. a reference for non-threshold (carcinogenic) effects in its risk
X1.7.4.3 For potential effects resulting from exposures to management decisions regarding exposures to environmental
the entire United States population, a risk level below 1 3 10 contaminants (19). Similarly, a lifetime incremental cancer risk
−6 never triggered action; above 3 3 10
−4
always triggered of one in one hundred thousand is used by the Commonwealth
action. of Massachusetts as a cancer risk limit for exposures to
X1.7.5 Rodricks, et al (15) also evaluated regulatory deci- substances in more than one medium at hazardous waste
sions and reached similar conclusions. In decisions relating to disposal sites (20). This risk limit represents the total cancer
promulgation of National Emission Standards for Hazardous risk at the site associated with exposure to multiple chemicals
Air Pollutants (NESHAPS), the USEPA has found the maxi- in all contaminated media. The State of California has also
mum individual risks and total population risks from a number established a level of risk of one in one hundred thousand for
of radionuclide and benzene sources too low to be judged use in determining levels of chemicals and exposures that pose
significant. Maximum individual risks were in the range from no significant risks of cancer under the Safe Drinking Water
3.6 3 10−5 to 1.0 3 10 −3. In view of the risks deemed and Toxic Enforcement Act of 1986 (Proposition 65) (21).
insignificant
−5
by USEPA, Rodricks, et al (15) noted that Workplace air standards developed by the Occupational Safety
1 3 10 (1 in 100 000) appears to be in the range of what and Health Administration (OSHA) typically reflect theoretical
USEPA might consider an insignificant average lifetime risk, at risks of one in one thousand (1 3 10 −3) or greater (15).
least where aggregate population risk is no greater than a X1.7.10 Ultimately, the selection of an acceptable and de
fraction of a cancer yearly. minimis risk level is a policy decision in which both costs and
X1.7.6 Recently, final revisions to the National Contingency benefits of anticipated courses of action should be thoroughly
Plan (16) have set the acceptable risk range between 10−4 and evaluated. However, actuarial data and risk estimates of
10−6 at hazardous waste sites regulated under CERCLA. In the common human activities, regulatory precedents, and the
recently promulgated Hazardous Waste Management System relationship between the magnitude and variance of back-
Toxicity Characteristics Revisions (17) , the USEPA has stated ground and incremental risk estimates all provide compelling
that: support for the adoption of the de minimis risk level of
“For drinking water contaminants, EPA sets a reference risk range for carcino- 1 3 10−5 for regulatory purposes.
gens at 10−6 excess individual cancer risk from lifetime exposure. Most regula-
tory actions in a variety of EPA programs have generally targeted this range X1.7.11 In summary, U.S. Federal and state regulatory
using conservative models which are not likely to underestimate the risk.” agencies have adopted a one-in-one-million cancer risk as
being of negligible concern in situations where large popula-
X1.7.7 Interestingly, the USEPA has selected and promul- tions (for example, 200 million people) are involuntarily
gated a single risk level of 1 in 100 000 (1 3 10 −5) in the exposed to suspect carcinogens (for example, food additives).
Hazardous Waste Management System Toxicity Characteristics When smaller populations are exposed (for example, in occu-
Revisions (17). In their justification, the USEPA cited the pational settings), theoretical cancer risks of up to 10−4 (1 in
following rationale: 10 000) have been considered acceptable.
TABLE X2.1 Example Tier 1 Risk-Based Screening Level (RBSL) Look-up TableA
NOTE 1—This table is presented here only as an example set of Tier 1 RBSLs. It is not a list of proposed standards. The user should review all
assumptions prior to using any values. Appendix X2 describes the basis of these values.
--```,`,,,`,`,`,``,,,,,```````-`-`,,`,,`,`,,`---
--```,`,,,`,`,`,``,,,,,```````-`-`,,`,,`,`,,`---
cancer risk = 1E-04 1.72E + 00 RES
ingestion target
chronic HQ = 1 5.75E + 02 1.29E + 02 RES 2.29E + 01
level, mg/kg
commercial/ cancer risk = 1E-06 5.78E-02 1.85E + 00
industrial
cancer risk = 1E-04 5.78E + 00 RES
chronic HQ = 1 1.61E + 03 3.61E + 02 RES 6.42E + 01
Ground Water
Ground water residential cancer risk = 1E-06 1.10E + 01 >SE
volatilization cancer risk = 1E-04 1.10E + 03 >S
to outdoor chronic HQ = 1 >S >S >S >S
air, mg/L commercial/ cancer risk = 1E-06 1.84E + 01 >S
industrial cancer risk = 1E-04 >S >S
chronic HQ = 1 >S >S >S >S
Ground water MCLs 5.00E-03 7.00E-01 1.00E + 00 1.00E + 01 N/A 2.00E-04
ingestion, residential cancer risk = 1E-06 2.94E-03 1.17E-05
mg/L cancer risk = 1E-04 2.94E-01 1.17E-03
chronic HQ = 1 3.65E + 00 7.30E + 00 7.30E + 01 1.46E-01
commercial/ cancer risk = 1E-06 9.87E-03 3.92E-05
industrial cancer risk = 1E-04 9.87E-01 >S
chronic HQ = 1 1.02E + 01 2.04E + 01 >S 4.09E-01
Ground residential cancer risk = 1E-06 2.38E-02 >S
water—vapor cancer risk = 1E-04 2.38E + 00 >S
intrusion from chronic HQ = 1 7.75E + 01 3.28E + 01 >S 4.74E + 00
ground water commercial/ cancer risk = 1E-06 7.39E-02 >S
to buildings, industrial cancer risk = 1E-04 7.39E + 00 >S
mg/L chronic HQ = 1 >S 8.50E + 01 >S 1.23E + 01
A
As benzene soluble coal tar pitch volatiles.
B
See Ref (22).
C
See Refs (23-25).
D
RES—Selected risk level is not exceeded for pure compound present at any concentration.
E
>S—Selected risk level is not exceeded for all possible dissolved levels (5< pure component solubility).
X2.1.4.1 In the case of compounds that have been classified hazard quotient 5 average intake @mg/kg2day#/
as carcinogens, the RBSLs are based on the general equation: reference dose @mg/kg2day# (X2.2)
risk 5 average lifetime intake@mg/kg2day# where the intake depends on exposure parameters (ingestion
3 potency factor@mg/kg2day#21 (X2.1) rate, exposure duration, and so forth), the source concentration,
and transport rates between the source and receptor. The
where the intake depends on exposure parameters (ingestion reference dose is selected after reviewing a number of sources,
rate, exposure duration, and so forth), the source concentration, including the USEPA Integrated Risk Information System
and transport rates between the source and receptor. The (IRIS) (2) database, USEPA Health Effects Assessment Sum-
potency factor is selected after reviewing a number of sources, mary Tables (HEAST) (3), and peer-reviewed sources. The
including the USEPA Integrated Risk Information System RBSL values appearing in Table X2.1 correspond to hazard
(IRIS) (2) database, USEPA Health Effects Assessment Sum- quotients of unity resulting from the specified exposure. Note
mary Tables (HEAST) (3), and peer-reviewed sources. The that this hazard quotient value does not reflect the probability
RBSL values appearing in Table X2.1 correspond to probabili- for the specified exposure scenario to occur. Therefore, the
ties of adverse health effects (“risks”) in the range from 10 −6 actual potential impact to a population for these RBSLs is
to 10−4 resulting from the specified exposure. Note that this lower than a hazard quotient of unity.
risk value does not reflect the probability for the specified X2.1.5 Tables X2.2-X2.7 summarize the equations and
exposure scenario to occur. Therefore, the actual potential risk parameters used to prepare the example look-up Table X2.1.
to a population for these RBSLs is lower than the 10−6 to 10−4 The basis for each of these equations is discussed in X2.2-
range. X2.10.
X2.1.4.2 In the case of compounds that have not been
classified as carcinogens, the RBSLs are based on the general X2.2 Air—Inhalation of Vapors (Outdoors/Indoors) —In
equation: this case chemical intake results from the inhalation of vapors.
--```,`,,,`,`,`,``,,,,,```````-`-`,,`,,`,`,,`---
It is assumed that vapor concentrations remain constant over case chemical intake results from ingestion of ground water. It
the duration of exposure, and all inhaled chemicals are ab- is assumed that the dissolved hydrocarbon concentrations
sorbed. Equations appearing in Tables X2.2 and X2.3 for remain constant over the duration of exposure. Equations
estimating RBSLs for vapor concentrations in the breathing appearing in Tables X2.2 and X2.3 for estimating RBSLs for
zone follow guidance given in Ref (26). Should the calculated drinking water concentrations follow guidance given in Ref
RBSL exceed the saturated vapor concentration for any indi- (26) for ingestion of chemicals in drinking water. Should the
vidual component, “>Pvap” is entered in the table to indicate calculated RBSL exceed the pure component solubility for any
that the selected risk level or hazard quotient cannot be reached individual component, “>S” is entered in the table to indicate
or exceeded for that compound and the specified exposure that the selected risk level or hazard quotient cannot be reached
scenario.
X2.3 Ground Water—Ingestion of Ground Water— In this
or exceeded for that compound and the specified exposure If the selected target vapor concentration is some value other
scenario (unless free-phase product is mixed with the ingested than the RBSL for inhalation (that is, odor threshold or
water). ecological criterion), this value can be substituted for the
RBSLair parameter appearing in the equations given in Tables
X2.4 Ground Water—Inhalation of Outdoor Vapors:
X2.2 and X2.3.
X2.4.1 In this case chemical intake is a result of inhalation X2.4.2 A conceptual model for the transport of chemicals
of outdoor vapors which originate from dissolved hydrocar-
from ground water to ambient air is depicted in Fig. X2.1. For
bons in ground water located some distance below ground
simplicity, the relationship between outdoor air and dissolved
surface. Here the goal is to determine the dissolved hydrocar-
ground water concentrations is represented in Tables X2.2 and
bon RBSL that corresponds to the target RBSL for outdoor
vapors in the breathing zone, as given in Tables X2.2 and X2.3.
--```,`,,,`,`,`,``,,,,,```````-`-`,,`,,`,`,,`---
X2.3 by the “volatilization factor,” VFwamb [(mg/m3-air)/(mg/ X2.5.2 A conceptual model for the transport of chemicals
L-H 2O)], defined in Table X2.5. It is based on the following from ground water to indoor air is depicted in Fig. X2.2. For
assumptions: simplicity, the relationship between enclosed-space air and
X2.4.2.1 A constant dissolved chemical concentration in dissolved ground water concentrations is represented in Tables
ground water, X2.2 and X2.3 by the “volatilization factor” VFwesp [(mg/m3-
X2.4.2.2 Linear equilibrium partitioning between dissolved air)/(mg/L-H2O)] defined in Table X2.5. It is based on the
chemicals in ground water and chemical vapors at the ground following assumptions:
water table, X2.5.2.1 A constant dissolved chemical concentration in
X2.4.2.3 Steady-state vapor- and liquid-phase diffusion ground water,
through the capillary fringe and vadose zones to ground X2.5.2.2 Equilibrium partitioning between dissolved chemi-
surface, cals in ground water and chemical vapors at the ground water
X2.4.2.4 No loss of chemical as it diffuses towards ground table,
surface (that is, no biodegradation), and X2.5.2.3 Steady-state vapor- and liquid-phase diffusion
X2.4.2.5 Steady well-mixed atmospheric dispersion of the through the capillary fringe, vadose zone, and foundation
emanating vapors within the breathing zone as modeled by a cracks,
“box model” for air dispersion. X2.5.2.4 No loss of chemical as it diffuses towards ground
X2.4.3 Should the calculated RBSL w exceed the pure surface (that is, no biodegradation), and
component solubility for any individual component, “>S” is X2.5.2.5 Steady, well-mixed atmospheric dispersion of the
entered in the table to indicate that the selected risk level or emanating vapors within the enclosed space, where the con-
hazard quotient cannot be reached or exceeded for that vective transport into the building through foundation cracks or
compound and the specified exposure scenario. openings is negligible in comparison with diffusive transport.
X2.5.3 Should the calculated RBSL w exceed the pure
X2.5 Ground Water—Inhalation of Enclosed-Space (In- component solubility for any individual component, “>S” is
door) Vapors: entered in the table to indicate that the selected risk level or
X2.5.1 In this case chemical intake results from the inhala- hazard quotient cannot be reached or exceeded for that
tion of vapors in enclosed spaces. The chemical vapors compound and the specified exposure scenario.
originate from dissolved hydrocarbons in ground water located
some distance below ground surface. Here the goal is to X2.6 Surficial Soils—Ingestion, Dermal Contact, and Va-
determine the dissolved hydrocarbon RBSL that corresponds to por and Particulate Inhalation:
the target RBSL for vapors in the breathing zone, as given in X2.6.1 In this case it is assumed that chemical intake results
Tables X2.2 and X2.3. If the selected target vapor concentra- from a combination of intake routes, including: ingestion,
tion is some value other than the RBSL for inhalation (that is, dermal absorption, and inhalation of both particulates and
odor threshold or ecological criterion), this value can be vapors emanating from surficial soil.
substituted for the RBSLair parameter appearing in the equa- X2.6.2 Equations used to estimate intake resulting from
tions given in Tables X2.2 and X2.3. ingestion follow guidance given in Ref (26) for ingestion of
--```,`,,,`,`,`,``,,,,,```````-`-`,,`,,`,`,,`---
chemicals in soil. For this route, it has been assumed that been assumed that surficial soil chemical concentrations and
surficial soil chemical concentrations and intake rates remain absorption rates remain constant over the exposure duration.
constant over the exposure duration. X2.6.4 Equations used to estimate intake resulting from the
X2.6.3 Equations used to estimate intake resulting from inhalation of particulates follow guidance given in Ref (26) for
dermal absorption follow guidance given in Ref (26) for inhalation of airborne chemicals. For this route, it has been
dermal contact with chemicals in soil. For this route, it has assumed that surficial soil chemical concentrations, intake
TABLE X2.7 Chemical-Specific Properties Used in the Derivation Example Tier 1 RBSLs
Chemical CAS Number Mw, g/mol H, L-H2O/L-air D air, cm2/s D w, cm2/s log(Koc), L/kg log(Kow), L/kg
Benzene 71-43-2 78A 0.22A 0.093A 1.1 3 10−5A 1.58A 2.13A
Toluene 108-88-3 92A 0.26A 0.085A 9.4 3 10−6B 2.13A 2.65A
Ethyl benzene 100-41-4 106A 0.32A 0.076A 8.5 3 10−6B 3.11A 3.13A
Mixed xylenes 1330-20-7 106A 0.29A 0.072B 8.5 3 10−6B 2.38A 3.26A
Naphthalene 91-20-3 128A 0.049A 0.072B 9.4 3 10−6A 3.11A 3.28A
Benzo(a)pyrene 50-32-8 252C 5.8 3 10−8D 0.050B 5.8 3 10−6B 5.59E 5.98D
Chemical CAS Number SFo, kg-day/mg SFi, kg-day/mg RfDo, mg/kg-day RfDi, mg/kg-day
Benzene 71-43-2 0.029F 0.029F ... ..
Toluene 108-88-3 ... ... 0.2F 0.11F
Ethyl benzene 100-41-4 ... ... 0.1F 0.29F
Mixed xylenes 1330-20-7 ... ... 2.0F 2.0F
Naphthalene 91-20-3 ... ... 0.004G 0.004G
Benzo(a)pyrene 50-32-8 7.3F 6.1F ... ...
A
See Ref (34).
B
Diffusion coefficient calculated using the method of Fuller, Schettler, and Giddings, from Ref (11).
C
See Ref (7).
D
See Ref (35).
E
Calculated from Kow/Koc correlation: log( Koc) = 0.937 log(K ow) − 0.006, from Ref (11).
F
See Ref (2).
G
See Ref (3).
rates, and atmospheric particulate concentrations remain con- For simplicity, the relationship between outdoor air and surfi-
stant over the exposure duration. cial soil concentrations is represented in Tables X2.2 and X2.3
X2.6.5 Equations used to estimate intake resulting from the by the “volatilization factor” VFss [(mg/m3-air)/(mg/kg-soil)]
inhalation of airborne chemicals resulting from the volatiliza- defined in Table X2.5. It is based on the following assump-
tion of chemicals from surficial soils follow guidance given in tions:
Ref (26) for inhalation of airborne chemicals. X2.6.6.1 Uniformly distributed chemical throughout the
X2.6.6 A conceptual model for the volatilization of chemi- depth 0—d (cm) below ground surface,
cals from surficial soils to outdoor air is depicted in Fig. X2.3.
--```,`,,,`,`,`,``,,,,,```````-`-`,,`,,`,`,,`---
--```,`,,,`,`,`,``,,,,,```````-`-`,,`,,`,`,,`---
--```,`,,,`,`,`,``,,,,,```````-`-`,,`,,`,`,,`---
--```,`,,,`,`,`,``,,,,,```````-`-`,,`,,`,`,,`---
--```,`,,,`,`,`,``,,,,,```````-`-`,,`,,`,`,,`---
--```,`,,,`,`,`,``,,,,,```````-`-`,,`,,`,`,,`---
specific phenomena (for example, ground water transport) and vary in complexity, depending on assumptions made during model development. In RBCA, simplistic
screening-level migration models are utilized in Tiers 1 and 2, while more complex models are utilized in Tier 3.
X3.7.2 References to many simplistic models suitable for X3.7.4.2 Total soil porosity (for a typical soil: ' 0.38
screening-level evaluations for a number of pathways relevant cm3/cm3),
to hydrocarbon contaminant releases are listed in Table X3.1. X3.7.4.3 Soil moisture content can be conservatively esti-
Most of the screening-level migration models have a simple mated in many cases. It is approximately equal to the total soil
mathematical form and are based on multiple limiting assump- porosity beneath the water table, and typically >0.05 cm -
3
tions rather than on actual phenomena. For example, a simple H2O/cm 3-soil in the vadose zone; this can be a critical input
model is the use of estimated ground water flow velocity to parameter in the case of diffusion models and may require
assess the travel time between the leading edge of a dissolved site-specific determination unless conservative values are used,
hydrocarbon plume and a ground water well. The travel time is
approximated by the following: X3.7.4.4 Fraction organic matter in soil particles
( = 0.00d − 0.01: sandy soil is often conservatively assumed);
@distance to well ~ft!/flow velocity ~ft/years!# 5 travel time ~years!
this can also be a critical parameter requiring site-specific
(X3.1)
determination unless conservative values are used),
X3.7.2.1 In the case of a relatively light compound such as X3.7.4.5 Hydraulic conductivity (generally site-specific de-
benzene dissolved in ground water, the flow velocity may best termination required),
be equated with the ground water flow velocity. Heavier
compounds such as naphthalene may be retarded so that a flow X3.7.4.6 Ground water gradient and flow direction (requires
velocity lower than the ground water velocity may be used. If site-specific determination), and
miscible liquids are present on the ground water surface, such X3.7.4.7 First-order decay-rate (generally requires site-
as gasoline, the liquid flow velocity may actually exceed the specific calibration as models are very sensitive to this param-
ground water velocity. eter); see Tables X3.2 and X3.3 and Ref (41) for a summary of
X3.7.3 The use of more complex models is not precluded in measured values currently available from the literature. The
the RBCA process; however, given limited data and assump- data in Table X3.3 include retardation and dispersion as well as
tions that must be made, many complex numerical models natural biodegradation in attenuation rates measured. However,
reduce to the analytical expressions given in Table X3.1. sensitivity studies indicate that natural biodegradation is the
X3.7.4 Migration Model Data Requirements—Predictive dominant factor. The sensitivity studies use Ref (42). Accord-
migration models require input of site-specific characteristics. ing to these sensitivity studies, an order of magnitude increase
Those most commonly required for various simplistic models in natural biodegradation rate is 3.5 times as effective as an
include the following: order of magnitude increase in retardation and 12 times as
X3.7.4.1 Soil bulk density (for a typical soil: ' 1.7 g/cm3), effective as an order of magnitude increase in dispersion in
E
Howard, et al Literature 0.0009 [730] 0.025 [28] 0.003 [228] 0.0019 [365] ... 0.0019 [365] to 0.0027 [258] 0.0007 [1058]
to 0.069 [10] to 0.099 [7] to 0.116 [6] to 0.0495 [14] 0.0866 [8] to 0.0061 [114]
A
See Ref (36).
B
See Ref (37).
C
See Ref (38).
D
See Ref (39).
E
See Ref (40).
TABLE X3.3 Results of Exponential Regression for X3.7.7 Generally, site-specific physical and chemical prop-
Concentration Versus TimeA erties for the most sensitive parameters are required for
k, % per migration models to obtain accurate results. However, instead
Site Compound
day
of site-specific data, conservative values selected from the
Campbell, CA benzene 1.20
ethylbenzene 0.67
literature may be used with appropriate caution.
xylene 1.12 X3.7.8 Migration Modeling Procedure
benzene 0.42
Palo Alto, CA benzene 0.30 The procedure for applying a migration model includes the
Virginia Beach, VA PCE 0.46 following steps: definition of study objectives, development of
TCE 0.30
Montrose County, CO benzene 0.42
a conceptual model, selection of a computer code or algorithm,
Provo, UT benzene 0.23 construction of the model, calibration of the model and
San Jose, CA benzene 0.16 performance of sensitivity analysis, making predictive simula-
benzene 0.10
Chemical facility toluene 0.39 tions, documentation of the modeling process, and performing
PCE 0.34 a postaudit. These steps are generally followed in order;
TCE 0.26 however, there is substantial overlap between steps, and
A
Source: Ref (41). previous steps are often revisited as new concepts are explored
or as new data are obtained. The iterative modeling approach
attenuating concentration over distance. Therefore, approxi- may also require the reconceptualization of the problem. The
mately 80 % of the attenuation shown in the Ref (41) data can basic modeling steps are discussed as follows.
be attributed to natural biodegradation. X3.7.8.1 Modeling Objectives—Modeling objectives must
X3.7.4.8 A similar analysis of the sensitivity of attenuation first be identified (that is, the questions to be answered by the
parameters for the vapor transport pathway also indicates that model). The objectives aid in determining the level of detail
natural biodegradation is the predominant attenuation mecha- and accuracy required in the model simulation. Complete and
nism (43). Soil geology is not considered an attenuation detailed objectives would ideally be specified prior to any
mechanism directly, but is a stronger determinant of how far modeling activities. Objectives may include interpreting site
contamination travels than even natural biodegradation. Gaso- characterization and monitoring data, predicting future migra-
line contamination does not travel very far in clay (less than 30 tion, determining corrective action requirements, or predicting
ft (9 m)) according to the vapor transport model (43). the effect of proposed corrective action measures.
X3.7.5 Depending on the models selected, other informa-
tion may be required, such as meteorological information X3.7.8.2 Conceptual Model—A conceptual model of a sub-
(wind speed, precipitation, temperature), soil particle size surface contaminant release, such as a hydrocarbon release
distributions, and nearby building characteristics. from an underground tank, is an interpretation or working
X3.7.6 In most cases, measurements of the attenuation description of the characteristics and dynamics of the physical
(decrease in concentrations) of compounds with distance away system. The purpose of the conceptual model is to consolidate
from the contaminant source area will be required to calibrate site and regional data into a set of assumptions and concepts
and verify the predictive capabilities of the selected models. that can be evaluated quantitatively. Development of the
The amount of data required varies depending on the follow- conceptual model requires the collection and analysis of
ing: physical data pertinent to the system under investigation.
X3.7.6.1 The model code used, (1) The conceptual model identifies and describes important
X3.7.6.2 The model’s sensitivity to changes in input param- aspects of the physical system, including the following: geo-
eters, and logic and hydrologic framework; media type (for example,
X3.7.6.3 The contribution of the pathway of concern to the fractured or porous); physical and chemical processes; and
total incremental exposure and risk. hydraulic, climatic, and vapor properties. The conceptual
intensive and may require much more data and information to calibration with respect to that parameter. If a small change in
be collected. the input parameter or boundary condition causes a significant
(3) Other factors may also be considered in the decision- change in the output, the model is sensitive to that parameter or
making process, such as the model analyst’s experience and boundary condition.
those described as follows for model construction process;
(2) Whether a given change in the model calibration is
factors such as dimensionality will determine the capabilities
considered significant or insignificant is a matter of judgment.
of the computer code required for the model.
However, changes in the model’s conclusions are usually able
X3.7.8.4 Model Construction—Model construction is the
to be characterized objectively. For example, if a model is used
process of transforming the conceptual model into a math-
to determine whether a contaminant is captured by a potable
ematical form. The model typically consists of two parts, the
supply well, then the computed concentration is either detect-
data set and the computer code. The model construction
able or not at the location. If, for some value of the input that
process includes building the data set used by the computer
is being varied, the model’s conclusions are changed but the
code. Fundamental components of a migration model are
change in model calibration is insignificant, then the model
dimensionality, discretization, boundary and initial conditions,
results may be invalid because, over the range of that param-
contaminant, and media properties.
eter in which the model can be considered calibrated, the
X3.7.8.5 Model Calibration—Calibration of a model is the
conclusions of the model change. More information regarding
process of adjusting input for which data are not available
conducting a sensitivity analysis for a ground water flow model
within reasonable ranges to obtain a match between observed
application is presented in Guide D 5611.
and simulated values. The range over which model parameters
and boundary conditions may be varied is determined by data X3.7.8.7 Model Predictions—Once these steps have been
presented in the conceptual model. In the case where param- conducted, the model is used to satisfy the modeling objec-
eters are well characterized by field measurements, the range tives. Predictive simulations should be documented with ap-
over which that parameter is varied in the model should be propriate illustrations, as necessary, in the model report.
consistent with the range observed in the field. The degree of
fit between model simulations and field measurements can be X3.8 Procedures for Risk, Exposure, and Dose-Response
quantified using statistical techniques. Assessment Models:
(1) In practice, model calibration is frequently accomplished X3.8.1 “Exposure models” are used to estimate the chemi-
through trial-and-error adjustment of the model’s input data to cal uptake, or dose, while “risk assessment models” are used to
match field observations. The calibration process continues relate human health or ecological impacts to the uptake of a
until the degree of correspondence between the simulation and chemical. Risk and exposure assessment models are often
the physical system is consistent with the objectives of the combined to calculate a target exposure point concentration of
project. a compound in air, water, or soil.
X4.1 Introduction: a statutory mandate (see Appendix X4.2) requiring the use of
X4.1.1 The purpose of this appendix is to provide a review deed restrictions (see Appendix X4.3) as a way of enforcing
of generally used institutional controls. For purposes of this use restrictions (see Appendix X4.4) and posting signage (a
appendix, “institutional controls” are those controls that can be type of access control, see X4.5). Thus, the institutional
used by responsible parties and regulatory agencies in remedial controls listed as follows are often used as overlapping
programs where, as a part of the program, certain concentra- strategies, and this blurs the distinctions between them.
tions of the chemical(s) of concern will remain on site in soil
or ground water, or both. Referenced in this appendix are X4.2 Statutory Mandates—Some states’ emergency re-
examples of programs from California, Connecticut, Illinois, sponse programs mandate post-remediation institutional con-
Indiana, Iowa, Massachusetts, Michigan, Missouri, and New trols and impose civil penalties for noncompliance. The
Jersey. In addition, federal programs, such as Superfund schemes vary from state to state, but all impose obligations on
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settlements and RCRA closure plans have used the following landowners to use one or more institutional controls listed in
techniques described for some years as a mechanism to ensure this appendix.
that exposure to remaining concentrations of chemical(s) of
concern is reduced to the degree necessary. X4.3 Deed Restrictions:
X4.1.2 The types of institutional controls discussed in this X4.3.1 Deed restrictions place limits and conditions on the
appendix are as follows: use and conveyance of land. They serve two purposes: ( 1)
X4.1.2.1 Deed restrictions, or restrictive covenants, informing prospective owners and tenants of the environmental
X4.1.2.2 Use restrictions (including well restriction areas), status of the property and (2) ensuring long-term compliance
X4.1.2.3 Access controls, with the institutional controls that are necessary to maintain the
X4.1.2.4 Notice, including record notice, actual notice, and integrity of the remedial action over time. Restraining the way
notice to government authorities, someone can use their land runs counter to the basic assump-
X4.1.2.5 Registry act requirements, tions of real estate law, so certain legal rules must be satisfied
X4.1.2.6 Transfer act requirements, and in order to make a deed restriction binding and enforceable.
X4.1.2.7 Contractual obligations. X4.3.2 There are four requirements for a promise in a deed
X4.1.3 Institutional controls for environmental remedial restriction (also called a “restrictive covenant”) to be held
programs vary in both form and content. Agencies and land- against current and subsequent landowners: (1) a writing, (2 )
owners can invoke various authorities and enforcement mecha- intention by both original parties that particular restrictions be
nisms, both public and private, to implement any one or a placed on the land in perpetuity, (3 ) “privity of estate,” and (4)
combination of the controls. For example, a state could adopt that the restrictions “touch and concern the land.”
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X4.6 Notice—Regulations of this type generally provide registry may obtain the withdrawal of the proposed registration
notice of specific location of chemical(s) of concern on the site, by entering into a consent agreement with the state. Such a
and disclose any restrictions on access, use, and development consent agreement establishes a timetable and responsibility
of part or all of the contaminated site to preserve the integrity for remedial action.
of the remedial action.
X4.7.5 When a site appears on the state registry, the owner
X4.6.1 Record Notice: must comply with regulatory requirements in regard to use and
X4.6.1.1 Some states require that sites having releases of transfer of the site. The use of a site listed on the registry may
hazardous waste file a notice on the land records providing to not be changed without permission of the state agency. In
any subsequent purchaser of the property information regard- negotiations for a conveyance of a registered site, the owner
ing the past or current activities on the site. may be obligated to disclose the registration early in the
X4.6.1.2 The record notice requirement may be broad; the process, and permission of the state agency may be required to
program may require any property subject to a response action convey a registered property. Under other schemes, permission
to obtain a professional opinion and then prepare and record a to convey is not required, but the seller must notify the state
Grant of Environmental Restriction that is supported by that agency of the transaction.
opinion. X4.7.6 Finally, registry acts require that the listing of a
X4.6.1.3 The record notice requirement can be ancillary to property on a hazardous materials site registry be recorded in
a transfer act (see Appendix X4.8), in which case recording of the records of the appropriate locality so that the registration
an environmental statement is only required in conjunction will appear in the chain of title.
with a land transaction.
X4.6.2 Actual Notice: X4.8 Transfer Act Requirements:
X4.6.2.1 States may require direct notice of environmental
information to other parties to a land transaction. These laws X4.8.1 Some states have transfer act programs that require
protect potential buyers and tenants, and they also help ensure full evaluation of all environmental issues before or after the
that use restrictions and other institutional controls are perpetu- transfer occurs. It may be that within such program, institu-
ated. tional controls can be established by way of consent order,
X4.6.2.2 Actual notice of an environmental defect or failure administrative order, or some other technique that establishes
to provide notice may give a party the right to cancel the implementation and continued responsibility for institutional
transaction and result in civil penalties. For example, landlords controls.
and sellers who do not give notice as required by the state may X4.8.2 A typical transfer act imposes obligations and con-
be liable for actual damages plus fines. Nonresidential tenants fers rights on parties to a land transaction arising out of the
who fail to notify landowners of suspected or actual hazardous environmental status of the property to be conveyed. Transfer
substance releases can have their leases canceled and are acts impose information obligations on the seller or lessor of a
subject to fines. property (see Appendix X4.6.3). That party must disclose
X4.6.3 Notice to Government Authorities—Parties to a land general information about strict liability for cleanup costs as
transaction may also be required to file the environmental well as property-specific information, such as presence of
statement with various environmental authorities. Notice to the hazardous substances, permitting requirements and status,
government may be required before the transaction takes place. releases, and enforcement actions and variances.
X4.8.3 Compliance with transfer act obligations in the
X4.7 Registry Act Requirements: manner prescribed is crucial for ensuring a successful convey-
X4.7.1 Some states have registry act programs that provide ance. Sometimes the transfer act operates to render a transac-
for the maintenance of a registry of hazardous waste disposal tion voidable before the transfer occurs. Failure to give notice
sites and the restriction of the use and transfer of listed sites. in the required form and within the time period required or the
X4.7.2 A typical registry act provides that the state environ- revelation of an environmental violation or unremediated
mental agency establish and maintain a registry of all real condition will relieve the transferee and the lender of any
property which has been used for hazardous substance disposal obligation to close the transaction, even if a contract has
either illegally or before regulation of hazardous waste disposal already been executed. Moreover, violation of the transfer act
began in that state. can be the basis for a lawsuit to recover consequential
X4.7.3 The state agency is responsible for investigating damages.
potential sites for inclusion on the registry. The registry
includes the location of the site and a listing of the hazardous X4.9 Contractual Obligations:
X5.1 Introduction—The following examples illustrate the X5.2.2 Site Assessment— The responsible party completes
use of RBCA at petroleum release sites. The examples are an initial site assessment focussed on potential source areas
hypothetical and have been simplified in order to illustrate that (for example, tanks, lines, dispensers) and receptors. Based on
RBCA leads to reasonable and protective decisions; neverthe- historical knowledge that gasoline and diesel have been dis-
less, they do reflect conditions commonly encountered in pensed at this facility, chemical analyses of soil and ground
practice. water are limited to benzene, toluene, ethylbenzene, xylenes,
and naphthalene. Site assessment results are summarized as
X5.2 Example 1—Corrective Action Based on Tier 1 follows:
Risk-Based Screening Levels: X5.2.2.1 Field screening instruments and laboratory analy-
X5.2.1 Scenario—A release from the underground storage ses indicate that the extent of petroleum-impacted soils is
tank (UST), piping, and dispenser system at a service station is confined to the vicinity of the fill ports for the tanks. A tank and
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discovered during a real estate divestment assessment. It is line test reveals no leaks; therefore, evidence suggests that soils
known that there are petroleum-impacted surficial soils in the are impacted due to spills and overfills associated with filling
area of the tank fill ports; however, the extent to which the soils the storage tank,
are impacted is unknown. In the past, both gasoline and diesel X5.2.2.2 The current tanks and piping were installed five
have been sold at the facility. The new owner plans to continue years ago,
operating the service station facility. X5.2.2.3 The concrete driveway is highly fractured,
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the corrective action plan. ground water flow velocities are at most tens of feet per year,
X5.3.2.8 Ground water yield from this aquifer is estimated
X5.3 Example 2—RBCA Based on Tier 2 Evaluation: to be in excess of 5 gal/min (18.9 L/min), and total dissolved
X5.3.1 Scenario—During the installation of new double- solids levels are less than 700 mg/L. Based on this information,
contained product transfer lines, petroleum-impacted soils are this aquifer is considered to be a potential drinking water
discovered in the vicinity of a gasoline dispenser at a service supply,
station located close to downtown Metropolis. In the past, both X5.3.2.9 A shallow soil gas survey indicates that no detect-
gasoline and diesel have been sold at this facility, which has able levels of hydrocarbon vapors are found in the utility
been operating as a service station for more than twenty years. easement running along the southern border of the property, or
X5.3.2 Site Assessment— The owner completes an initial in soils surrounding the service station kiosk,
site assessment focussed on potential source areas (for ex- X5.3.2.10 Impacted soils extend down to the first encoun-
ample, tanks, lines, dispensers) and receptors. Based on his- tered ground water. Maximum concentrations detected in soil
torical knowledge that gasoline and diesel have been dispensed and ground water are as follows:
at this facility, chemical analyses of soil and ground water are
Compound Soil, mg/kg Ground water, mg/L
limited to benzene, toluene, ethylbenzene, xylenes, and naph- Benzene 20 2
thalene. Results of the site investigation are as follows: Ethylbenzene 4 0.5
X5.3.2.1 The extent of petroleum-impacted soils is confined Toluene 120 5
Xylenes 100 5.0
to the vicinity of the tanks and dispensers. A recent tank and Napthalene 2 0.05
line test revealed no leaks; therefore, evidence suggests that the
releases occurred sometime in the past, X5.3.2.11 A receptor survey indicates that no domestic
X5.3.2.2 The current tanks, lines, and dispensers were water wells are located within one-half mile of the site;
installed three years ago, however, there is an older residential neighborhood located
X5.3.2.3 The asphalt driveway is competent and not 1200 ft (365.7 m) hydraulically down gradient of the site. Land
cracked, use in the immediate vicinity is light commercial (for example,
X5.3.2.4 Another service station is located hydraulically strip malls). The site is bordered by two streets and a strip mall
down gradient, diagonally across the intersection, parking lot.
X5.3.2.5 The site is underlain by silty sands with a few thin X5.3.3 Site Classification and Initial Response Action—
discontinuous clay layers, Based on classification scenarios given in Table 1, this site is
X5.3.2.6 Ground water, which is first encountered at 32 ft classified as a Class 3 site because conditions are such that, at
(9.7 m) below ground surface, is impacted, with highest worst, it is a long-term threat to human health and environ-
dissolved concentrations observed beneath the suspected mental resources (see Table X5.2). The appropriate initial
source areas. Dissolved concentrations decrease in all direc- response is to evaluate the need for a ground water monitoring
tions away from the source areas, and ground water samples program. The owner proposes that the ground water monitor-
taken hydraulically down gradient from a well located in the ing well located hydraulically down gradient in the street
center divider of the street (about 100 ft (30.4 m) from the divider be used as a sentinel well, and be sampled yearly. The
source area) do not contain any detectable levels of dissolved regulatory agency concurs, provided that the well be sampled
hydrocarbons, every six months.
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X5.4.4 Development of Tier 1 Look-Up Table of Risk-Based be conducted to ensure that building vapors are not the result
Screening Level (RBSL) Selection—Assumptions used to de- of other sources. After some period of operation, when
rive example Tier 1 RBSL Look-Up Table X2.1 in Appendix hydrocarbon removal rates decline, a soil and ground water
X2 are reviewed and presumed valid for this site. Target soil assessment plan will be instituted to collect data to support a
and ground water concentrations are determined based on the Tier 2 evaluation.
vapor intrusion scenario. After considering health-based,
OSHA PEL, national ambient background, and aesthetic vapor X5.5 Example 4—RBCA Based on Use of a Tier 2 Table
concentrations, target soil levels are based on achieving a 10 −4 Evaluation—In circumstances where site-specific data are
chronic inhalation risk for benzene, and hazard quotients of similar among several sites, a table of Tier 2 SSTL values can
unity for all other compounds. The agency agrees to base be created. The following example uses such a table.
compliance on the volatile monoaromatic compounds in gaso-
line (benzene, toluene, xylenes, and ethylbenzene), but re- X5.5.1 Scenario—Petroleum-impacted ground water is dis-
serves the right to alter the target levels if aesthetic effects covered in monitoring wells at a former service station. The
persist in the building basement at the negotiated levels. underground tanks and piping were removed, and the site is ow
X5.4.5 Exposure Pathway Evaluation—Given that: (1) occupied by an auto repair shop.
there is a very low potential for ground water usage, (2) a 20- X5.5.2 Site Assessment— The responsible party completes
ft (6.1-m) thick aquitard separates the upper perched water an initial site assessment to determine the extent of
from any potential drinking water supplies, and (3) the close hydrocarbon-impacted soil and ground water. Because gasoline
proximity of the apartment building, the owner proposes was the only fuel dispensed at the site, the assessment focussed
focusing on the vapor intrusion—residential inhalation sce- on benzene, toluene, ethylene benzene, and xylenes (BTEX) as
nario (see Fig. X5.3). The agency concurs, but in order to the chemicals of concern. Site assessment results are summa-
eliminate potential ground water users as receptors of concern, rized as follows:
requests that a down-gradient piezometer be installed in the X5.5.2.1 The area of hydrocarbon-impacted soil is approxi-
lower aquifer. The owner concurs. mately 18 000 ft2 (1672 m2) and the depth of soil impaction is
X5.4.6 Comparison of Site Conditions With Tier 1 RBSLs— less than 5 ft (1.5 m); The plume is off site,
While a complete initial site investigation has yet to be X5.5.2.2 The site is covered by asphalt or concrete,
conducted, all parties agree that currently the RBSLs are likely
X5.5.2.3 The site is underlain by clay,
to be exceeded.
X5.4.7 Evaluation of Tier 1 Results—The owner decides to X5.5.2.4 Hydrocarbon-impacted perched ground water is
implement an interim corrective action plan based on Tier 1 encountered at 1 to 3 ft (0.3 to 0.9 m) below grade. This water
RBSLs, but reserves the right to propose a Tier 2 evaluation in is non-potable. The first potable aquifer is located over 100 ft
the future. (30 m) below grade and is not impacted. There is no free
X5.4.8 Tier 1 Remedial Action Evaluation—The owner product,
proposes expanding the vapor extraction system to remediate X5.5.2.5 Maximum detected concentrations are as follows:
source area soils. In addition he proposes continuing to operate Compound Soil, Ground water,
the free-product recovery/hydraulic control system until prod- mg/kg mg/L
Benzene 39 1.8
uct recovery ceases. Monitoring of the piezometer placed in the Toluene 15 4.0
lower aquifer will continue, as well as periodic monitoring of Ethylbenzene 12 0.5
the apartment building basement. Additional assessments will Xylenes 140 9.0
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of concern are presented as functions of both the distance from X5.5.8.3 Assumptions used to derive the example Tier 2
the source to the receptor and the soil type. SSTL table are reviewed and presumed valid for this site. Due
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