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Risk-Based Corrective Action Applied at Petroleum Release Sites

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Risk-Based Corrective Action Applied at Petroleum Release Sites

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© © All Rights Reserved
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Designation: E 1739 – 95 (Reapproved 2002)

Standard Guide for


Risk-Based Corrective Action Applied at Petroleum Release
Sites1
This standard is issued under the fixed designation E 1739; the number immediately following the designation indicates the year of
original adoption or, in the case of revision, the year of last revision. A number in parentheses indicates the year of last reapproval. A
superscript epsilon (e) indicates an editorial change since the last revision or reapproval.

1. Scope 1.2.4 Comparison of concentrations of chemical(s) of con-


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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,

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E 1739 – 95 (2002)
1.3.9 Appendix X4 discusses considerations for institutional 3.1.9 exposure assessment—the determination or estimation
controls, and (qualitative or quantitative) of the magnitude, frequency, du-
1.3.10 Appendix X5 provides examples of RBCA applica- ration, and route of exposure.
tions. 3.1.10 exposure pathway—the course a chemical(s) of con-
1.4 This guide describes an approach for RBCA. It is cern takes from the source area(s) to an exposed organism. An
intended to compliment but not supersede federal, state, and exposure pathway describes a unique mechanism by which an
local regulations. Federal, state, or local agency approval may individual or population is exposed to a chemical(s) of concern
be required to implement the processes outlined in this guide. originating from a site. Each exposure pathway includes a
1.5 The values stated in either inch-pound or SI units are to source or release from a source, a point of exposure, and an
be regarded as the standard. The values given in parentheses exposure route. If the exposure point differs from the source, a
are for information only. transport/exposure medium (for example, air) or media also is
1.6 This standard does not purport to address all of the included.
safety concerns, if any, associated with its use. It is the 3.1.11 exposure route—the manner in which a chemical(s)
responsibility of the user of this standard to establish appro- of concern comes in contact with an organism (for example,
priate safety and health practices and determine the applica- ingestion, inhalation, and dermal contact).
bility of regulatory limitations prior to use. 3.1.12 facility—the property containing the source of the
2. Referenced Documents chemical(s) of concern where a release has occurred.
3.1.13 hazard index—the sum of two or more hazard
2.1 ASTM Standards:
quotients for multiple chemical(s) of concern or multiple
E 1599 Guide for Corrective Action for Petroleum Re-
exposure pathways, or both.
leases3
2.2 NFPA Standard: 3.1.14 hazard quotients—the ratio of the level of exposure
NFPA 329 Handling Underground Releases of Flammable of a chemical(s) of concern over a specified time period to a
and Combustible Liquids4 reference dose for that chemical(s) of concern derived for a
similar exposure period.
3. Terminology 3.1.15 incremental carcinogenic risk levels—the potential
3.1 Definitions of Terms Specific to This Standard: for incremental carcinogenic human health effects due to
3.1.1 active remediation—actions taken to reduce the con- exposure to the chemical(s) of concern.
centrations of chemical(s) of concern. Active remediation 3.1.16 indirect exposure pathways—an exposure pathway
could be implemented when the no-further-action and passive with at least one intermediate release to any media between the
remediation courses of action are not appropriate. source and the point(s) of exposure (for example, chemicals of
3.1.2 attenuation—the reduction in concentrations of concern from soil through ground water to the point(s) of
chemical(s) of concern in the environment with distance and exposure).
time due to processes such as diffusion, dispersion, absorption, 3.1.17 institutional controls—the restriction on use or ac-
chemical degradation, biodegradation, and so forth. cess (for example, fences, deed restrictions, restrictive zoning)
3.1.3 chemical(s) of concern—specific constituents that are to a site or facility to eliminate or minimize potential exposure
identified for evaluation in the risk assessment process. to a chemical(s) of concern.
3.1.4 corrective action—the sequence of actions that in- 3.1.18 interim remedial action—the course of action to
clude site assessment, interim remedial action, remedial action, mitigate fire and safety hazards and to prevent further migra-
operation and maintenance of equipment, monitoring of tion of hydrocarbons in their vapor, dissolved, or liquid phase.
progress, and termination of the remedial action. 3.1.19 maximum contaminant level (MCL)—a standard for
3.1.5 direct exposure pathways—an exposure pathway drinking water established by USEPA under the Safe Drinking
where the point of exposure is at the source, without a release Water Act, which is the maximum permissible level of chemi-
to any other medium. cal(s) of concern in water that is delivered to any user of a
3.1.6 ecological assessment—a qualitative appraisal of the public water supply.
actual or potential effects of chemical(s) of concern on plants 3.1.20 Monte Carlo simulation—a procedure to estimate the
and animals other than people and domestic species. value and uncertainty of the result of a calculation when the
3.1.7 engineering controls—modifications to a site or facil- result depends on a number of factors, each of which is also
ity (for example, slurry walls, capping, and point of use water uncertain.
treatment) to reduce or eliminate the potential for exposure to
3.1.21 natural biodegradation—the reduction in concentra-
a chemical(s) of concern.
tion of chemical(s) of concern through naturally occurring
3.1.8 exposure—contact of an organism with chemical(s) of
microbial activity.
concern at the exchange boundaries (for example, skin, lungs,
and liver) and available for absorption. 3.1.22 petroleum—including crude oil or any fraction
thereof that is liquid at standard conditions of temperature and
pressure (60°F and 14.7 lb/in.2 absolute; (15.5°C and 10 335.6
3
Annual Book of ASTM Standards, Vol 11.04.
kg/m2)). The term includes petroleum-based substances com-
4
Available from National Fire Protection Association, 1 Batterymarch Park, P.O. prised of a complex blend of hydrocarbons derived from crude
Box 9101, Quincy, MA 02269. oil through processes of separation, conversion, upgrading, and
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E 1739 – 95 (2002)
finishing, such as motor fuels, jet oils, lubricants, petroleum 3.1.37 site classification—a qualitative evaluation of a site
solvents, and used oils. based on known or readily available information to identify the
3.1.23 point(s) of compliance—a location(s) selected be- need for interim remedial actions and further information
tween the source area(s) and the potential point(s) of exposure gathering. Site classification is intended to specifically priori-
where concentrations of chemical(s) of concern must be at or tize sites.
below the determined target levels in media (for example, 3.1.38 site-specific target level (SSTL)—risk-based remedial
ground water, soil, or air). action target level for chemical(s) of concern developed for a
3.1.24 point(s) of exposure—the point(s) at which an indi- particular site under the Tier 2 and Tier 3 evaluations.
vidual or population may come in contact with a chemical(s) of 3.1.39 site-specific—activities, information, and data
concern originating from a site. unique to a particular site.
3.1.25 qualitative risk analysis—a nonnumeric evaluation 3.1.40 source area(s)—either the location of liquid hydro-

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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,

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E 1739 – 95 (2002)
4.2.5 Compliance can be evaluated relative to site-specific by which corrective action decisions are made in a consistent
standards applied at site-specific point(s) of compliance, manner that is protective of human health and the environment.
4.2.6 Higher quality, and in some cases faster, cleanups than 5.2 The RBCA process is implemented in a tiered approach,
are currently realized, and involving increasingly sophisticated levels of data collection
4.2.7 A documentation and demonstration that the remedial and analysis. The assumptions of earlier tiers are replaced with
action is protective of human health, safety, and the environ- site-specific data and information. Upon evaluation of each
ment. tier, the user reviews the results and recommendations and
4.3 Risk assessment is a developing science. The scientific decides whether more site-specific analysis is warranted.
approach used to develop the RBSL and SSTL may vary by
state and user due to regulatory requirements and the use of 5.3 Site Assessment— The user is required to identify the
alternative scientifically based methods. sources of the chemical(s) of concern, obvious environmental
4.4 Activities described in this guide should be conducted impacts (if any), any potentially impacted humans and envi-
by a person familiar with current risk and exposure assessment ronmental receptors (for example, workers, residents, water
methodologies. bodies, and so forth), and potentially significant transport
4.5 In order to properly apply the RBCA process, the user pathways (for example, ground water flow, utilities, atmo-
should avoid the following: spheric dispersion, and so forth). The site assessment will also
4.5.1 Use of Tier 1 RBSLs as mandated remediation stan- include information collected from historical records and a
dards rather than screening levels, visual inspection of the site.
4.5.2 Restriction of the RBCA process to Tier 1 evaluation 5.4 Site Classification—Sites are classified by the urgency
only and not allowing Tier 2 or Tier 3 analyses, of need for initial response action, based on information
4.5.3 Placing arbitrary time constraints on the corrective collected during the site assessment. Associated with site
action process; for example, requiring that Tiers 1, 2, and 3 be classifications are initial response actions that are to be
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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.

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E 1739 – 95 (2002)
5.7 Tier 3 Evaluation—Tier 3 provides the user with an 6.2.1.9 A qualitative evaluation of impacts to environmental
option to determine SSTLs for both direct and indirect path- receptors.
ways using site-specific parameters and point(s) of exposure 6.2.2 In addition to the information gathered in 6.2.1, the
and compliance when it is judged that Tier 2 SSTLs should not site assessment information for Tier 2 evaluation may include
be used as target levels. Tier 3, in general, can be a substantial the following:
incremental effort relative to Tiers 1 and 2, as the evaluation is 6.2.2.1 Determination of site-specific hydrogeologic and
much more complex and may include additional site assess- geologic characteristics (for example, depth to ground water,
ment, probabilistic evaluations, and sophisticated chemical aquifer thickness, flow direction, gradient, description of con-
fate/transport models. fining units, and ground water quality);
5.8 Remedial Action— If the concentrations of chemical(s)
6.2.2.2 Determination of extent of chemical(s) of concern
of concern at a site are above the RBSL or SSTL at the point(s)
relative to the RBSL or SSTL, as appropriate;
of compliance or source area, or both, and the user determines
that the RBSL or SSTL should be used as remedial action 6.2.2.3 Determination of changes in concentrations of
target levels, the user develops a remedial action plan in order chemical(s) of concern over time (for example, stable, increas-
to reduce the potential for adverse impacts. The user may use ing, and decreasing); and
remediation processes to reduce concentrations of the chemi- 6.2.2.4 Determination of concentrations of chemical(s) of
cal(s) of concern to levels below or equal to the target levels or concern measured at point(s) of exposure (for example, dis-
to achieve exposure reduction (or elimination) through institu- solved concentrations in nearby drinking water wells or vapor
tional controls discussed in Appendix X4, or through the use of concentrations in nearby conduits or sewers).
engineering controls, such as capping and hydraulic control. 6.2.3 In addition to the information gathered in 6.2.1 and
6.2.2, the site assessment information for Tier 3 evaluation
6. Risk-Based Corrective Action (RBCA) Procedures includes additional information that is required for site-specific
6.1 The sequence of principal tasks and decisions associated modeling efforts.
with the RBCA process are outlined on the flowchart shown in 6.3 Site Classification and Initial Response Action—As the
Fig. 1. Each of these actions and decisions is discussed as user gathers data, site conditions should be evaluated and an
follows. initial response action should be implemented, consistent with
6.2 Site Assessment— Gather the information necessary for site conditions. This process is repeated when new data
site classification, initial response action, comparison to the indicate a significant change in site conditions. Site urgency
RBSL, and determining the SSTL. Site assessment may be classifications are presented in Table 1, along with example
conducted in accordance with Guide E 1599. Each successive classification scenarios and potential initial responses. Note
tier will require additional site-specific data and information that the initial response actions given in Table 1 may not be
that must be collected as the RBCA process proceeds. The user applicable for all sites. The user should select an option that
may generate site-specific data and information or estimate best addresses the short-term health and safety concerns of the
reasonable values for key physical characteristics using soil site while implementing the RBCA process.
survey data and other readily available information. The site 6.3.1 The classification and initial response action scheme
characterization data should be summarized in a clear and given in Table 1 is an example. It is based on the current and
concise format. projected degree of hazard to human health and the environ-
6.2.1 The site assessment information for Tier 1 evaluation ment. This is a feature of the process that can be customized by
may include the following: the user. “Classification 1” sites are associated with immediate
6.2.1.1 A review of historical records of site activities and threats to human health and the environment; “Classification 2”
past releases; sites are associated with short-term (0 to 2-year) threats to
6.2.1.2 Identification of chemical(s) of concern; human health, safety, and the environment; “Classification 3”
6.2.1.3 Location of major sources of the chemical(s) of sites are associated with long-term (greater than 2-year) threats
concern; to human health, safety, and the environment; “Classification
6.2.1.4 Location of maximum concentrations of chemical(s) 4” sites are associated with no reasonable potential threat to
of concern in soil and ground water; human health or to the environment.
6.2.1.5 Location of humans and the environmental receptors 6.3.2 Associated with each classification scenario in Table 1
that could be impacted (point(s) of exposure); is an initial response action; the initial response actions are
6.2.1.6 Identification of potential significant transport and implemented in order to eliminate any potential immediate
exposure pathways (ground water transport, vapor migration impacts to human health and the environment as well as to
through soils and utilities, and so forth); minimize the potential for future impacts that may occur as the
6.2.1.7 Determination of current or potential future use of user proceeds with the RBCA process. Note that initial
the site and surrounding land, ground water, surface water, and response actions do not always require active remediation; in
sensitive habitats; many cases the initial response action is to monitor or further
6.2.1.8 Determination of regional hydrogeologic and geo- assess site conditions to ensure that risks posed by the site do
logic characteristics (for example, depth to ground water, not increase above acceptable levels over time. The initial
aquifer thickness, flow direction, gradient, description of con- response actions given in Table 1 are examples, and the user is
fining units, and ground water quality); and free to implement other alternatives.
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FIG. 1 Risk-Based Corrective Action Process Flowchart

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E 1739 – 95 (2002)
TABLE 1 Example Site Classification and Initial Response ActionsA
Criteria and Prescribed Scenarios Example Initial Response ActionsB
1. Immediate threat to human health, safety, or sensitive Notify appropriate authorities, property owners, and potentially affected parties,
environmental receptors and only evaluate the need to
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• 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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6.3.3 The need to reclassify the site should be evaluated the transport and fate model parameters, or the choice of the
when additional site information is collected that indicates a models themselves. Again, the reader should note that the
significant change in site conditions or when implementation of example is presented here only as an abbreviated example of a
an interim response action causes a significant change in site Tier 1 RBSL Look-Up Table for typical compounds of concern
conditions. associated with petroleum products.
6.4 Development of a Tier 1 Look-Up Table of RBSL—If a 6.4.3 Use of Total Petroleum Hydrocarbon Measurements—
look-up table is not available, the user is responsible for Various chemical analysis methods commonly referred to as
developing the look-up table. If a look-up table is available, the total petroleum hydrocarbons (TPHs) are often used in site
user is responsible for determining that the RBSLs in the assessments. These methods usually determine the total
look-up table are based on currently acceptable methodologies amount of hydrocarbons present as a single number and give
and parameters. The look-up table is a tabulation for potential no information on the types of hydrocarbon present. The TPHs
exposure pathways, media (for example, soil, water, and air), a should not be used for risk assessment because the general
range of incremental carcinogenic risk levels (10E-4 to 10E-6 measure of TPH provides insufficient information about the
are often evaluated as discussed in Appendix X1 paragraph amounts of individual chemical(s) of concern present.
X1.7, Discussion of Acceptable Risk) and hazard quotients 6.5 Comparison of Site Conditions with Tier 1 Risk-Based
equal to unity, and potential exposure scenarios (for example, Screening Levels (RBSL)—In Tier 1, the point(s) of exposure
residential, commercial, industrial, and agricultural) for each and point(s) of compliance are assumed to be located within
chemical(s) of concern. close proximity to the source area(s) or the area where the
6.4.1 The RBSLs are determined using typical, non- highest concentrations of the chemical(s) of concern have been
sitespecific values for exposure parameters and physical pa- identified. Concentrations of the chemical(s) of concern mea-
rameters for media. The RBSLs are calculated according to sured at the source area(s) identified at the site should be
methodology suggested by the USEPA. For each exposure compared to the look-up table RBSL. If there is sufficient site
scenario, the RBSLs are based on current USEPA RME assessment data, the user may opt to compare RBSLs with
parameters and current toxicological information given in Refs statistical limits (for example, upper confidence levels) rather
(2, 3) or peer-reviewed source(s). Consequently, the RBSL than maximum values detected. Background concentrations
look-up table is updated when new methodologies and param- should be considered when comparing the RBSLs, to the site
eters are developed. For indirect pathways, fate and transport concentrations as the RBSLs may sometimes be less than
models can be used to predict RBSLs at a source area that background concentrations. Note that additivity of risks is not
corresponds to exposure point concentrations. An example of explicitly considered in the Tier 1 evaluation, as it is expected
the development of a Tier 1 Look-Up Table and RBSL is given that the RBSLs are typically for a limited number of chemi-
in Appendix X2. Fig. 2 and Appendix X2 are presented solely cal(s) of concern considered at most sites. Additivity may be
for the purpose of providing an example development of the addressed in Tier 2 and Tier 3 analyses. To accomplish the Tier
1 comparison:
RBSL, and the values should not be viewed as proposed RBSLs.
6.5.1 Select the potential exposure scenario(s) (if any) for
6.4.2 Appendix X2 is an example of an abbreviated Tier 1
the site. Exposure scenarios are determined based on the site
RBSL Look-Up Table for compounds of concern associated
assessment information described in 6.2;
with petroleum releases. The exposure scenarios selected in the
6.5.2 Based on the impacted media identified, determine the
example case are for residential and industrial/commercial
primary sources, secondary sources, transport mechanisms,
scenarios characterized by USEPA RME parameters for adult
and exposure pathways;
males. The assumptions and methodology used in deriving the
example are discussed in Appendix X2. Note that not all 6.5.3 Select the receptors (if any) based on current and
possible exposure pathways are considered in the derivation of anticipated future use. Consider land use restrictions and
the example. The user should always review the assumptions surrounding land use when making this selection.
and methodology used to derive values in a look-up table to 6.5.4 Identify the exposure scenarios where the measured
make sure that they are consistent with reasonable exposure concentrations of the chemical(s) of concern are above the
scenarios for the site being considered as well as currently RBSL.
accepted methodologies. The value of creating a look-up table 6.6 Exposure Evaluation Flowchart—During a Tier 1
is that users do not have to repeat the exposure calculations for evaluation, the risk evaluation flowchart presented in Fig. 2
each site encountered. The look-up table is only altered when may be used as a tool to guide the user in selecting appropriate
RME parameters, toxicological information, or recommended exposure scenarios based on site assessment information. This
methodologies are updated. Some states have compiled such worksheet may also be used in the evaluation of remedial
tables for direct exposure pathways that, for the most part, action alternatives. To complete this flowchart:
contain identical values (as they are based on the same 6.6.1 Characterize site sources and exposure pathways,
assumptions). Values for the cross-media pathways (for ex- using the data summarized from Tier 1 to customize the risk
ample, volatilization and leaching), when available, often differ evaluation flowchart for the site by checking the small check-
because these involve coupling exposure calculations with box for every relevant source, transport mechanism, and
predictive equations for the fate and transport of chemicals in exposure pathway.
the environment. As yet, there is little agreement in the 6.6.2 Identify receptors, and compare site conditions with
technical community concerning non-site-specific values for Tier 1 levels: For each exposure pathway selected, check the

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FIG. 2 Exposure Scenario Evaluation Flowchart

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receptor characterization (residential, commercial, and so 6.7.2 If the concentrations of chemicals of concern at the
forth) where the concentrations of the chemical(s) of concern point of compliance are less than the target levels, but the user
are above the RBSL. Consider land use restrictions and is not confident that data supports the conclusion that concen-
surrounding land use when making this selection. Do not check trations will not exceed target levels in the future, then the user
any boxes if there are no receptors present, or likely to be institutes a monitoring plan to collect data sufficient to confi-
present, or if institutional controls prevent exposure from dently conclude that concentrations will not exceed target
occurring and are likely to stay in place. levels in the future. When this data is collected, the user moves
6.6.3 Identify potential remedial action measures. Select to 6.7.3.
remedial action options to reduce or eliminate exposure to the 6.7.3 If the concentrations of chemicals of concern at the
chemical(s) of concern. point of compliance are less than target levels, and the user is
6.6.4 The exposure evaluation flowchart (Fig. 2) can be confident that data supports the conclusion that concentrations
used to graphically portray the effect of the Tier 1 remedial will not exceed target levels in the future, then no additional
action. Select the Tier 1 remedial action measure or measures corrective action activities are necessary, and the user has
(shown as valve symbols) that will break the lines linking completed the RBCA process. In practice, this is often accom-
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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

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E 1739 – 95 (2002)
predictive models and presents models that might be consid- regulatory agency. The RBCA report should, at a minimum,
ered for Tier 2 evaluation. include the following:
6.8.3 Tier 2 Evaluation—Identify the exposure scenarios 6.11.1 An executive summary;
where the measured concentrations of the chemical(s) of 6.11.2 A site description;
concern are above the SSTL at the point(s) of compliance, and 6.11.3 A summary of the site ownership and use;
evaluate the tier results in accordance with 6.7. 6.11.4 A summary of past releases or potential source areas;
6.9 Tier 3—In a Tier 3 evaluation, SSTLs for the source 6.11.5 A summary of the current and completed site activi-
area(s) and the point(s) of compliance are developed on the ties;
basis of more sophisticated statistical and contaminant fate and 6.11.6 A description of regional hydrogeologic conditions;
transport analyses, using site-specific input parameters for both 6.11.7 A description of site-specific hydrogeologic condi-
direct and indirect exposure scenarios. Source area(s) and the tions;
point(s) of compliance SSTLs are developed to correspond to 6.11.8 A summary of beneficial use;
concentrations of chemical(s) of concern at the point(s) of 6.11.9 A summary and discussion of the risk assessment
exposure that are protective of human health and the environ- (hazard identification, dose response assessment, exposure
ment. Tier 3 evaluations commonly involve collection of assessment, and risk characterization), including the methods
significant additional site information and completion of more and assumptions used to calculate the RBSL or SSTL, or both;
extensive modeling efforts than is required for either a Tier 1 or 6.11.10 A summary of the tier evaluation;
Tier 2 evaluation.
6.11.11 A summary of the analytical data and the appropri-
6.9.1 Examples of Tier 3 analyses include the following:
ate RBSL or SSTL used;
6.9.1.1 The use of numerical ground water modeling codes
6.11.12 A summary of the ecological assessment;
that predict time-dependent dissolved contaminant transport
under conditions of spatially varying permeability fields to 6.11.13 A site map of the location;
predict exposure point(s) of concentrations; 6.11.14 An extended site map to include local land use and
6.9.1.2 The use of site-specific data, mathematical models, ground water supply wells;
and Monte Carlo analyses to predict a statistical distribution of 6.11.15 Site plan view showing location of structures,
exposures and risks for a given site; and aboveground storage tanks, underground storage tanks, buried
6.9.1.3 The gathering of sufficient data to refine site-specific utilities and conduits, suspected/confirmed sources, and so
parameter estimates (for example, biodegradation rates) and forth;
improve model accuracy in order to minimize future monitor- 6.11.16 Site photos, if available;
ing requirements. 6.11.17 A ground water elevation map;
6.9.2 Tier 3 Evaluation—Identify the exposure scenarios 6.11.18 Geologic cross section(s); and
where the measured concentrations of the chemical(s) of 6.11.19 Dissolved plume map(s) of the chemical(s) of
concern are above the SSTL at the point(s) of compliance, and concern.
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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.

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APPENDIXES

(Nonmandatory Information)

X1. PETROLEUM PRODUCTS CHARACTERISTICS: COMPOSITION, PHYSICAL AND CHEMICAL


PROPERTIES, AND TOXICOLOGICAL ASSESSMENT SUMMARY

X1.1 Introduction: Hydrocarbons make up the vast majority of the composition of


X1.1.1 Petroleum products originating from crude oil are petroleum products. The non-hydrocarbon compounds in pe-
complex mixtures of hundreds to thousands of chemicals; troleum products are mostly hydrocarbon-like compounds
however, practical limitations allow us to focus only on a containing minor amounts of oxygen, sulfur, or nitrogen. Most
limited subset of key components when assessing the impact of of the trace levels of metals found in crude oil are removed by
petroleum fuel releases to the environment. Thus, it is impor- refining processes for the lighter petroleum products.
tant to have a basic understanding of petroleum properties, X1.2.3 Descriptions and Physical Properties of Petroleum
compositions, and the physical, chemical, and toxicological Products—In order to simplify the description of various
properties of some compounds most often identified as the key petroleum products, boiling point ranges and carbon number
chemicals or chemicals of concern. (number of carbon atoms per molecule) ranges are commonly
X1.1.2 This appendix provides a basic introduction to the used to describe and compare the compositions of various
physical, chemical, and toxicological characteristics of petro- petroleum products. Table X1.1 summarizes these characteris-
leum products (gasoline, diesel fuel, jet fuel, and so forth)5 and tics for a range of petroleum products. Moving down the list
other products focussed primarily towards that information from gasoline, increases in carbon number range and boiling
which is most relevant to assessing potential impacts due to range and decreases in volatility (denoted by increasing flash
releases of these products into the subsurface. Much of the point) indicate the transition to “heavier products.” Additional
information presented is summarized from the references listed descriptions of each of these petroleum products are provided
at the end of this guide. For specific topics, the reader is as follows.
referred to the following sections of this appendix: X1.2.4 Gasoline—Gasoline is composed of hydrocarbons
X1.1.2.1 Composition of Petroleum Fuels—See X1.2. and “additives” that are blended with the fuel to improve fuel
X1.1.2.2 Physical, Chemical, and Toxicological Properties performance and engine longevity. The hydrocarbons fall
of Petroleum Fuels—See X1.3. primarily in the C4 to C12 range. The lightest of these are
X1.1.2.3 Chemical of Concern—See X1.4. highly volatile and rapidly evaporate from spilled gasoline.
X1.1.2.4 Toxicity of Petroleum Hydrocarbons—See X1.5. The C4 and C5 aliphatic hydrocarbons rapidly evaporate from
X1.1.2.5 Profiles of Select Compounds—See X1.6. spilled gasoline (hours to months, depending primarily on the
temperature and degree of contact with air). Substantial por-
X1.2 Composition of Petroleum Products: tions of the C6 and heavier hydrocarbons also evaporate, but at
X1.2.1 Most petroleum products are derived from crude oil lower rates than for the lighter hydrocarbons.
by distillation, which is a process that separates compounds by X1.2.4.1 Fig. X1.1 shows gas chromatograms of a fresh
volatility. Crude oils are variable mixtures of thousands of gasoline and the same gasoline after simulated weathering; air
chemical compounds, primarily hydrocarbons; consequently, was bubbled through the gasoline until 60 % of its initial
the petroleum products themselves are also variable mixtures volume was evaporated. In gas chromatography, the mixture is
of large numbers of components. The biggest variations in separated into its components, with each peak representing
composition are from one type of product to another (for different compounds. Higher molecular weight components
example, gasoline to motor oil); however, there are even appear further to the right along the x-axis. For reference,
significant variations within different samples of the same positions of the n-aliphatic hydrocarbons are indicated in Fig.
product type. For example, samples of gasoline taken from the
same fuel dispenser on different days, or samples taken from
TABLE X1.1 Generalized Chemical and Physical Characterization
different service stations, will have different compositions. of Petroleum Products
These variations are the natural result of differing crude oil Predominant
sources, refining processes and conditions, and kinds and Boiling Range, Flash Point,A
Carbon No.
°C °C
amount of additives used. Range
X1.2.2 Components of Petroleum Products—The compo- Gasoline C4 to C12 25 to 215 −40
nents of petroleum products can be generally classified as Kerosene and Jet C11 to C13 150 to 250 <21,B 21 to 55,C
Fuels >55D
either hydrocarbons (organic compounds composed of hydro- Diesel Fuel and Light C10 to C20 160 to 400 >35
gen and carbon only) or as non-hydrocarbons (compounds Fuel Oils
containing other elements, such as oxygen, sulfur, or nitrogen). Heavy Fuel Oils C19 to C25 315 to 540 >50
Motor Oils and Other C20 to C45 425 to 540 >175
Lubricating Oils
A
Typical values.
5
“Alternative products,” or those products not based on petroleum hydrocarbons B
Jet-B, AVTAG and JP-4.
(or containing them in small amounts), such as methanol or M85, are beyond the C
Kerosene, Jet A, Jet A-1, JP-8 and AVTUR.
D
scope of the discussion in this appendix. AVCAT and JP-5.
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FIG. X1.1 Gas Chromatograms of Some Petroleum Fuels

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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X1.2.6.1 About 25 to 35 % of No. 2 fuel oil is composed of X1.3.1.3 Greater density,
aromatic hydrocarbons, primarily alkylated benzenes and X1.3.1.4 Lower water solubility, and
naphthalenes. The BTEX concentrations are generally low. X1.3.1.5 Stronger adhesion to soils and less mobility in the
X1.2.6.2 No. 1 fuel oil is typically a straight run distillate. subsurface.
X1.2.6.3 No. 2 fuel oil can be either a straight run distillate, X1.3.2 Table X1.2 lists physical, chemical, and toxicologi-
or else is produced by catalytic cracking (a process in which cal properties for a number of hydrocarbons found in petro-
larger molecules are broken down into smaller ones). Straight leum products. In general:
run distillate No. 2 is commonly used for home heating fuel, X1.3.2.1 Aliphatic petroleum hydrocarbons with more than
while the cracked product is often used for industrial furnaces ten carbon atoms are expected to be immobile in the subsur-
and boilers. Both No. 1 and No. 2 fuel oils are sometimes used face, except when dissolved in nonaqueous phase liquids
as blending components for jet fuel or diesel fuel formulations. (NAPLs), due to their low water solubilities, low vapor
X1.2.7 Heavy Fuel Oils— The heavy fuel oils include Nos. pressures, and strong tendency to adsorb to soil surfaces.
4, 5, and 6 fuel oils. They are sometimes referred to as “gas X1.3.2.2 Aromatic hydrocarbons are more water soluble
oils” or “residual fuel oils.” These are composed of hydrocar- and mobile in water than aliphatic hydrocarbons of similar
bons ranging from about C19 to C25 and have a boiling range molecular weight.
from about 315 to 540°C. They are dark in color and X1.3.2.3 Oxygenates generally have much greater water
considerably more viscous than water. They typically contain solubilities than hydrocarbons of similar molecular weight, and
15 to 40 % aromatic hydrocarbons, dominated by alkylated hence are likely to be the most mobile of petroleum fuel
phenanthrenes and naphthalenes. Polar compounds containing constituents in leachate and ground water. The light alcohols,
nitrogen, sulfur, or oxygen may comprise 15 to 30 % of the oil. including methanol and ethanol, are completely miscible with
X1.2.7.1 No. 6 fuel oil, also called “Bunker Fuel” or water in all proportions.
“Bunker C,” is a gummy black product used in heavy industrial X1.3.3 Properties of Mixtures—It is important to note that
applications where high temperatures are available to fluidize the partitioning behavior of individual compounds is affected
the oil. Its density is greater than that of water. by the presence of other hydrocarbons in the subsurface. The
X1.2.7.2 Nos. 4 and 5 fuel oils are commonly produced by maximum dissolved and vapor concentrations achieved in the
blending No. 6 fuel oil with lighter distillates. subsurface are always less than that of any pure compound,
X1.2.8 Motor Oils and Other Lubricating Oils— when it is present as one of many constituents of a petroleum
Lubricating oils and motor oils are predominately comprised of fuel. For example, dissolved benzene concentrations in ground
compounds in the C20 to C45 range and boil at approximately water contacting gasoline-impacted soils rarely exceed 1 to
425 to 540°C. They are enriched in the most complex molecu- 3 % of the ;1800-mg/L pure component solubility of benzene.
lar fractions found in crude oil, such as cycloparaffins and
X1.3.4 Trends in Toxicological Properties of
PNAs having up to three rings or more. Aromatics may make
Hydrocarbons—A more detailed discussion of toxicological
up to 10 to 30 % of the oil. Molecules containing nitrogen,
assessment is given in X1.5 (see also Appendix X3), followed
sulfur, or oxygen are also common. In addition, used automa-
by profiles for select chemicals found in petroleum products
tive crankcase oils become enriched with PNAs and certain
given in X1.6. Of the large number of compounds present in
metals.
petroleum products, aromatic hydrocarbons (BTEX, PAHs, and
X1.2.8.1 These oils are relatively viscous and insoluble in
so forth) are the constituents that human and aquatic organisms
ground water and relatively immobile in the subsurface.
tend to be most sensitive to (relative to producing adverse
X1.2.8.2 Waste oil compositions are even more difficult to
health impacts).
predict. Depending on how they are managed, waste oils may
contain some portion of the lighter products in addition to
X1.4 Chemicals of Concern for Risk Assessments:
heavy oils. Used crankcase oil may contain wear metals from
engines. Degreasing solvents (gasoline, naphtha, or light chlo- X1.4.1 It is not practicable to evaluate every compound
rinated solvents, or a combination thereof) may be present in present in a petroleum product to assess the human health or
some wastes. environmental risk from a spill of that product. For this reason,
risk management decisions are generally based on assessing
X1.3 Physical, Chemical, and Toxicological Characteris- the potential impacts from a select group of “indicator”
tics of Petroleum Products: compounds. It is inherently assumed in this approach that a
X1.3.1 Trends in Physical/Chemical Properties of significant fraction of the total potential impact from all
Hydrocarbons—In order to better understand the subsurface chemicals is due to the chemicals of concern. The selection of
behavior of hydrocarbons it is helpful to be able to recognize chemicals of concern is based on the consideration of exposure
trends in important physical properties with increasing number routes, concentrations, mobilities, toxicological properties, and
of carbon atoms. These trends are most closely followed by aesthetic characteristics (taste, odor, and so forth). Historically,
compounds with similar molecular structures, such as the the relatively low toxicities and dissolved-phase mobilities of
straight-chained, single-bonded aliphatic hydrocarbons. In aliphatic hydrocarbons have made these chemicals of concern
general, as the carbon number (or molecule size) increases, the of less concern relative to aromatic hydrocarbons. When
following trends are observed: additives are present in significant quantities, consideration
X1.3.1.1 Higher boiling points (and melting points), should also be given to including these as chemicals of
X1.3.1.2 Lower vapor pressure (volatility), concern.
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TABLE X1.2 Chemical and Toxicological Properties of Selected Hydrocarbons
Octanol/Water Organic Carbon
Weight of
Oral RfD, Inhalation RfC, Oral Slope Factor,A Drinking Water MCL,A Solubility,B Partition Adsorption
Compounds Evidence
mg/kg-day mg/m3 mg/kg-day−1 mg/L mg/L Coefficient,B Coefficient,B
ClassA
log Kow log Koc
C C,D
Benzene A 0.029D 0.005 1750 2.13 1.58
Toluene D 0.2A 0.4A ... 1 535 2.65 2.13
Ethylbenzene D 0.1A 1A ... 0.7 152 3.13 1.98
Xylenes D 2A 0.3C,E ... 10.0 198 3.26 2.38
C
n-Hexane 0.06E, 0.6F 0.2F ... ... 13G ... ...
C
MTBE ... 3A ... ... 48 000H 1.06–1.30I 1.08J
MEK D 0.6A 1A ... K
268 000 0.26 0.65
MIBK ... 0.05E, 0.5F 0.08C,E, 0.8F ... ... ... ... ...
Methanol ... 0.5A C
... ... ... ... ...
Ethanol ... ... ... ... ... 1 000 000 −0.032 0.34
TBA ... ... ... ... ... ... ... ...
Lead B2 ... ... ... 0.015L ... ... ...
EDC B2 ... ... 0.091 0.006 8 520 1.48 1.15
C
EDB B2 ... 85 0.00006 4 300 1.76 1.64
PNAs:
Pyrene D 0.03A ... ... ... 0.132 4.88 4.58
Benzo(a)pyrene B2 ... ... 7.3 0.0002M 0.00120 5.98 5.59
Anthracene D 0.3A ... ... ... 0.0450 4.45 4.15
Phenanthrene D ... ... ... ... 1.00 4.46 4.15
Naphthalene DC 0.004E, 0.04F ... ... ... 31.0G 3.28G 3.11N
Chrysene B2 ... ... 1.15O 0.0002 0.00180 5.61 5.30
Benzo(k)fluoranthene B2 ... ... ... 0.0002M 0.430 6.06 5.74
Fluorene D 0.04A ... ... ... 1.69 4.20 3.86
Fluoranthene D 0.04A ... ... ... 0.206 4.90 4.58
Benzo(g,h,i)perylene D ... ... ... ... 0.000700 6.51 6.20
Benzo(b)fluoranthene B2 ... ... ... 0.0002M 0.0140 6.06 5.74
Benz(a)anthracene B2 ... ... ... 0.0002M 0.00670 5.60 6.14
A
See Ref (2).
B
See Ref (4).
C
The data is pending in the EPA-IRIS database.
D
The inhalation unit risk for benzene is 8.3 3 10 −3(mg/m3)−1. The drinking water unit is 8.3 3 10−4(mg/L).
E
Chronic effect. See Ref (5).
F
Subchronic effect. See Ref (5).
G
See Ref (7).
H

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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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E 1739 – 95 (2002)
level for a particular adverse effect. For a complex mixture of TABLE X1.4 Weight of Evidence Criteria for Carcinogens
chemicals, the same approach can be used. For example, to Category Criterion
evaluate the toxicity of gasoline, a “pure” reference gasoline A Human carcinogen, with sufficient evidence from epidemiological
would be evaluated instead of the individual chemical. This studies
B1 Probable human carcinogen, with limited evidence from epide-
“whole-product” approach to toxicity assessment is strictly miological studies
applicable only to mixtures identical to the evaluated mixture; B2 Probable human carcinogen, with sufficient evidence from animal
studies and inadequate evidence or no data from epidemiological
gasolines with compositions different from the reference gaso- studies
line might have toxicities similar to the reference, but some C Possible human carcinogen, with limited evidence from animal
differences would be expected. In addition, as the composition studies in the absence of human data
D Not classifiable as to human carcinogenicity, owing to inadequate
of gasoline released to the environment changes through human and animal evidence
natural processes (volatilization, leaching, biodegradation), the E Evidence of noncarcinogenicity for humans, with no evidence of
toxicity of the remaining portion may change also. carcinogenicity in at least two adequate animal tests in different
species, or in both adequate animal and epidemiological studies
X1.5.3 An alternative to the “whole-product” approach for
assessing the toxicity of mixtures is the “individual-
constituent” approach. In this approach, the toxicity of each number of exposures to the risk agent and the length of time the
individual constituent (or a selected subset of the few most study group was exposed to the risk agent. These studies can be
toxic constituents, so-called chemicals of concern) is sepa- described as follows:
rately assessed and the toxicity of the mixture is assumed to be X1.5.6.1 Acute Studies— Acute studies typically use one
the sum of the individual toxicities using a hazard index dose or multiple doses over a short time frame (24 h).
approach. This approach is often used by the USEPA; however, Symptoms are usually observed within a short time frame and
it is inappropriate to sum hazard indices unless the toxicologi- can vary from weight loss to death.
cal endpoints and mechanisms of action are the same for the X1.5.6.2 Chronic Studies— Chronic studies use multiple
individual compounds. In addition, the compounds to be exposures over an extended period of time, or a significant
assessed must be carefully selected based on their concentra- fraction of the animal’s (typically two years) or the individual’s
tions in the mixture, their toxicities, how well their toxicities lifetime. The chronic effects of major concern are carcinogenic,
are known, and how mobile they are in the subsurface. Lack of mutagenic, and teratogenic effects. Other chronic health effects
sufficient toxicological information is often an impediment to such as liver and kidney damage are also important.
this procedure. X1.5.6.3 Subchronic Studies—Subchronic studies use mul-
X1.5.4 Use of TPH Measurements in Risk Assessments— tiple or continuous exposures over an extended period (three
Various chemical analysis methods commonly referred to as months is the usual time frame in animal studies). Observed

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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.

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TABLE X1.5 Definitions of Important Toxicological Characteristics
Reference Dose—A reference dose is an estimate (with an uncertainty typically spanning an order of magnitude) of a daily exposure (mg/kg/day) to the general
human population (including sensitive subgroups) that is likely to be without an appreciable risk of deleterious effects during a lifetime of exposure.
Reference Concentration—A reference concentration is an estimate (with an uncertainty spanning perhaps an order of magnitude) of a continuous exposure to the
human population (including sensitive subgroups) that is likely to be without appreciable deleterious effects during a lifetime.
Slope Factor—The slope of the dose-response curve in the low-dose region. When low-dose linearity cannot be assumed, the slope factor is the slope of the straight
line from zero dose to the dose at 1 % excess risk. An upper bound on this slope is usually used instead of the slope itself. The units of the slope factor are usually
expressed as (mg/kg/day).−1
Drinking Water MCLs and MCLGs—Maximum contaminant levels (MCLs) are drinking water standards established by the EPA that are protective of human health.
However, these standards take into account the technological capability of attaining these standards. The EPA has, therefore, also established MCL goals (MCLGs)
which are based only on the protection of human health. The MCL standards are often used as clean-up criteria.
Drinking Water Health Advisories—The Office of Drinking Water provides health advisories (HAs) as technical guidance for the protection of human health. They are
not enforceable federal standards. The HA’s are the concentration of a substance in drinking water estimated to have negligible deleterious effects in humans, when
ingested for specified time periods.
Water Quality Criteria—These criteria are not rules and they do not have regulatory impact. Rather, these criteria present scientific data and guidance of the
environmental effects of pollutants which can be useful to derive regulatory requirements based on considerations of water quality impacts.

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:
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X1.6.1 Benzene: An uncertainty factor of 300 and a modifying factor of 1 were
X1.6.1.1 Toxicity Summary—Based on human epidemio- used to convert the lowest observed adverse effect level
logical studies, benzene has been found to be a human (LOAEL) to the RfC. The overall confidence in the RfC was
carcinogen (classified as a Group A carcinogen, known human established as medium because of the use of a LOAEL and
carcinogen by the USEPA). An oral slope factor of because of the paucity of exposure information.
2.9 3 10−2(mg/kg/day)−1 has been derived for benzene based X1.6.2.4 Physical/Chemical Parameter Summary—Toluene
on the observance of leukemia from occupational exposure by is expected to volatilize rapidly, under common above-ground
inhalation. The USEPA has set a drinking water maximum environmental conditions, due to its relatively high Henry’s
contaminant level (MCL) at 5 µg/L. The maximum contami- law constant (6.6 3 10−3 m3-atm/mol). It will be mobile in
nant level goal (MCLG) for benzene is set at zero. soils based on an aqueous solubility of 5.35 3 10 5µg/L and
X1.6.1.2 Although the EPA does not usually set long-term relatively poor sorption to soils (estimated log Koc = 2.48) and,
drinking water advisories for carcinogenic materials (no expo- hence, has a potential to leach into ground water. Toluene has
sure to carcinogens is considered acceptable), a ten-day drink- a relatively low log Kow(2.73) and is biodegradable. Bioaccu-
ing water health advisory for a child has been set at 0.235 mg/L mulation of toluene is, therefore, expected to be negligible. In
based on hematological impairment in animals. The EPA is in laboratory tests, when a free gasoline phase was in equilibrium
the process of evaluating noncancer effects and an oral RfD for with water, typical toluene concentrations in water ranged from
benzene is pending. 3.48 3 104 to 8.30 3 104µg/L.
X1.6.1.3 In situations in which both aquatic life and water X1.6.3 Xylenes:
are consumed from a particular body of water, a recommended X1.6.3.1 Toxicity Summary—Using data from animal stud-
EPA water quality criterion is set at 0.66 µg/L. When only ies, the USEPA has set an oral RfD for xylenes at 2.0
aquatic organisms are consumed, the criterion is 40 µg/L. mg/kg/day. In converting a NOAEL from the animal study, in
These criteria were established at the one-in-one-million risk which the critical effects observed were hyperactivity, de-
level (that is, the criteria represent a one-in-one-million esti- creased body weight, and increased mortality (among male
mated incremental increase in cancer risk over a lifetime). rats), an uncertainty factor of 100 and a modifying factor of 1
X1.6.1.4 Physical/Chemical Parameter Summary— were used. The EPA has assigned an overall medium level of
Benzene is subject to rapid volatilization (Henry’s law con- confidence in the RfD because, although the principal study
stant = 5.5 3 10−3 m3-atm/mol) under common above-ground was well designed and performed, supporting chemistry was
environmental conditions. Benzene will be mobile in soils due not performed. A medium level of confidence was also as-
to its high water solubility (2.75 3 10 6µg/L) and relatively low signed to the database. Based on the RfD and assuming 20 %
sorption to soil particles (log Koc = 1.92) and, thus, has the exposure from drinking water, the EPA has set both drinking
potential to leach into ground water. Benzene has a relatively water MCL and MCLG of 10 mg/L. Drinking water health
low log Kowvalue (2.12) and is biodegradable. Therefore, it is advisories of 10 mg/L (lifetime, adult) and 40 mg/L (one-day,
not expected to bioaccumulate. In laboratory tests, when a free ten-day, and long-term child) are quoted by the EPA’s Office of
gasoline phase was in equilibrium with water, typical benzene Drinking Water. No USEPA ambient water criteria are avail-
concentrations in water ranged from 2.42 3 104 to 1.11 3 10 able for xylenes at this time. Evaluation of an inhalation RfC is
5µg/L. pending.
X1.6.2 Toluene: X1.6.3.2 Physical/Chemical Parameter Summary—
X1.6.2.1 Toxicity Summary—Using data from animal stud- Xylenes are expected to rapidly volatilize under common
ies, the USEPA has set an oral RfD for toluene at 0.2 above-ground environmental conditions based on their Henry’s
mg/kg/day. In converting a NOAEL from an animal study, in law constants (for o-xylene, H = 5.1 3 10 −3 m3-atm/mol).
which the critical effect observed was changes in liver and Xylenes have a moderate water solubility (1.46 to
kidney weights, an uncertainty factor of 1000 and a modifying 1.98 3 105µg/L) (pure compound) as well as moderate capaci-
factor of 1 were used. The EPA has assigned an overall medium ties to sorb to soils (estimated log Koc 2.38 to 2.79) and,
level of confidence in the RfD because, although the principal therefore, they will be mobile in soils and may leach into
study was well performed, the length of the study corresponded ground water. Xylenes are biodegradable, and with log Kow
to only subchronic rather than a chronic evaluation, and values in the range from 2.8 to 3.3, they are not expected to
reproductive aspects were lacking. Based on the RfD and bioaccumulate.
assuming 20 % exposure from drinking water, the EPA has set X1.6.4 Ethylbenzene:
both drinking water MCL and MCLG of 1000 µg/L. Drinking X1.6.4.1 Toxicity Summary—Using data from animal stud-
water health advisories range from 1 mg/L (lifetime equivalent ies, the USEPA has set an oral RfD for ethylbenzene at 0.1
to the RfD) to 20 mg/L (one-day advisory for a child). mg/kg/day. In converting a NOAEL from the animal study, in
X1.6.2.2 In situations in which both aquatic life and water which the critical effects observed were liver and kidney
are consumed from a particular body of water, the recom- toxicity, an uncertainty factor of 1000 and a modifying factor
mended water quality criterion is set at 1.43 3 104µg/L. When of 1 were used. The EPA has assigned an overall low level of
only aquatic5
organisms are consumed, the criterion is confidence in the RfD because the study was poorly designed
4.24 3 10 µg/L. and confidence in the supporting database is also low. Based on
X1.6.2.3 An inhalation RfC of 0.4 mg/m3 was derived based the RfD and assuming 20 % exposure from drinking water, the
on neurological effects observed in a small worker population. EPA has set both drinking water MCL and MCLG of 700 µg/L.

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Drinking water health advisories range from 700 µg/L (lifetime X1.6.5.3 Methylnaphthalenes—Henry’s law constants
equivalent to the RfD) to 32 mg/L (one-day advisory for a (2.60 3 10−4 m3-atm/mol and 5.18 3 10−4 m3-atm/mol for 1-
child). In situations in which both aquatic life and water are and 2-methylnaphthalene, respectively) suggest that these ma-
consumed from a particular body of water, a recommended terials have the potential to volatilize under common above-
ambient water criterion is set at 1400 µg/L. When only aquatic ground environmental conditions. 1-Methylnaphthalene exhib-
organisms are consumed, the criterion is 3280 µg/L. An its a water solubility similar to naphthalene (2.60 3 104µg/L to
inhalation RfC of 1 mg/m3 was derived based on developmen- 2.8 3 104µg/L). However, solubility decreases with increasing
tal toxicity effects observed in rats and rabbits. An uncertainty alkylation (dimethylnaphthalenes: 2.0 3 10 3µg/L to
factor of 300 and a modifying factor of 1 were used to convert 1.1 3 104µg/L, 1,4,5-trimethylnaphthalene: 2.0 3 103µg/L).
the NOAEL to the RfC. Both the study design and database These materials are, therefore, expected to be slightly mobile to
were rated low and, thus, the overall confidence in the RfC was relatively immobile in soil (for example, log Kocis in the range
established as low. from 2.86 to 3.93 for 1- and 2-methylnaphthalenes). In aquatic
X1.6.4.2 Physical/Chemical Parameter Summary— systems, methylnaphthalenes may partition from the water
Ethylbenzene has a relatively high Henry’s law constant column to organic matter contained in sediments and sus-
(8.7 3 10−3 m3-atm/mol) and, therefore, can rapidly volatilize pended solids. Methylnaphthalenes have high log K owvalues
under common above-ground environmental conditions. Based (greater than 3.5) and have the potential to bioaccumulate.
on its moderate water solubility (1.52 3 10 5µg/L) and mod- They do, however, exhibit a moderate degree of biodegrada-
erate capacity to sorb to soils (estimated log Koc = 3.04), it will tion, which typically decreases with increased alkylation.
have moderate mobility in soil and may leach into ground X1.6.6 Three to Six-Ringed PAHs—The most significant
water. In laboratory tests, when a free gasoline phase was in health effect for this class of compounds is their carcinogenic-
equilibrium with water, typical combined ethylbenzene and ity, which is structure-dependent. Anthracene and phenan-
xylenes concentrations in water ranged from 1.08 3 10 4 to threne have not been shown to cause cancer in laboratory
2.39 3 104µg/L, due to partitioning effects. Ethylbenzene has a animals. The available data does not prove pyrene to be
--```,`,,,`,`,`,``,,,,,```````-`-`,,`,,`,`,,`---

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

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adsorb very strongly to soil. The PAHs with more than three some of the effects may occur at such low concentrations as to
rings generally have high log Kow values (6.06 for benzo[a]py- suggest no threshold. The EPA has also determined that lead is
rene), have poor biodegradability characteristics and may a probable human carcinogen (classified as B2). The agency
bioaccumulate. has chosen not to set a numeric slope factor at this time,
X1.6.8 Pyrene: however, because it is believed that standard procedures for
X1.6.8.1 Toxicity Summary—Using data from animal stud- doing so may not be appropriate for lead. At present, the EPA
ies, the USEPA has set an oral RfD for pyrene at 3 3 10−2 has set an MCLG of zero but has set no drinking water (MCL)
mg/kg/day. In converting a NOAEL from the animal study, in or health advisories because of the observance of low-level
which the critical effects observed were kidney toxicity, an effects, the overall Agency goal of reducing total lead exposure
uncertainty factor of 3000 and a modifying factor of 1 were and because of its classification as a B2 carcinogen. An action
used. The EPA has assigned an overall low level of confidence of level of 15 µg/L has been set for water distribution systems
in the RfD because although the study was well-designed, (standard at the tap). The recommended EPA water quality
confidence in the supporting database is low. No drinking criterion for consumption of both aquatic life and water is set
water MCLs or health advisories have been set. In situations in at 50 µg/L.
which both aquatic life and water are consumed from a X1.6.10.2 Physical/Chemical Parameter Summary—
particular body of water, a recommended EPA water quality Organic lead additive compounds are volatile (estimated Hen-
criterion is set at 2.8 3 10 −3µg/L. When only aquatic organ- ry’s law constant for tetraethyl lead = 7.98 3 10 −2 m3-atm/
isms are consumed, the criterion is 3.11 3 10−2µg/L. mol) and may also sorb to particulate matter in the air.
X1.6.8.2 Physical/Chemical Parameter Summary—Refer to Tetraethyl lead has an aqueous solubility of 800 µg/L and an
X1.6.7.2 for BaP. Also see Table X1.2. estimated log Koc of 3.69 and, therefore, should not be very
X1.6.9 MTBE: mobile in the soil. It decomposes to inorganic lead in dilute
X1.6.9.1 Toxicity Summary—Using data from animal stud- aqueous solutions and in contact with other environmental
ies, the USEPA has set an inhalation RfC for MTBE at 3 media. In free product (gasoline) plumes, however, it may
mg/m3. In converting a NOAEL from the animal study, in remain unchanged. Inorganic lead compounds tightly bind to
which the critical effects observed included increased liver and most soils with minimal leaching under natural conditions.
kidney weight and increased severity of spontaneous renal Aqueous solubility varies depending on the species involved.
lesions (females), increased prostration (females) and swollen The soil’s capacity to sorb lead is correlated with soil pH,
pericolar tissue, an uncertainty factor of 100 and a modifying cation exchange capacity, and organic matter. Lead does not
factor of 1 were used. The EPA has assigned an overall medium appear to bioconcentrate significantly in fish but does in some
level of confidence in the RfC because although the study was shellfish, such as mussels. Lead is not biodegradable.
well-designed, some information on the chemistry was lacking.
The confidence in the supporting database is medium to high. X1.7 Discussion of Acceptable Risk (12)—Beginning in the
No drinking water MCLs or ambient water quality criteria have late 1970s and early 1980s, regulatory agencies in the United
been set. However, a risk assessment, which may define a RfD States and abroad frequently adopted a cancer risk criteria of
for this material, is presently under review by EPA. Drinking one-in-one-million as a negligible (that is, of no concern) risk
water health advisories range from 40µ g/L (lifetime, adult) to when fairly large populations might be exposed to a suspect
3000 µg/L (one-day advisory for a child).6 carcinogen. Unfortunately, theoretical increased cancer risks of
X1.6.9.2 Physical/Chemical Parameter Summary—The one-in-one-million are often incorrectly portrayed as serious
Henry’s law constant for MTBE is estimated to be approxi- public health risks. As recently discussed by Dr. Frank Young
mately 1.0 3 10−3 m3-atm/mol. It is, therefore, expected to (13), the current commissioner of the Food and Drug Admin-
have the potential to rapidly volatilize under common above- istration (FDA), this was not the intent of such estimates:
ground environmental conditions. It is very water soluble X1.7.1 In applying the de minimis concept and in setting
(water solubility is 4.8 3 107µg/L), and with a relatively low other safety standards, the FDA has been guided by the figure
capacity to sorb to soils (estimated log Koc = 1.08), MTBE will of “one-in-one-million.” Other Federal agencies have also used
migrate at the same velocity as the water in which it is a one-in-one-million increased risk over a lifetime as a
dissolved in the subsurface. The log Kow value has been reasonable criterion for separating high-risk problems warrant-
estimated to be between 1.06 and 1.30, indicating MTBE’s low ing agency attention from negligible risk problems that do not.
bioaccumulative potential. It is expected to have a low poten- X1.7.2 The risk level of one-in-one-million is often misun-
tial to biodegrade, but no definitive studies are available. derstood by the public and the media. It is not an actual risk,
X1.6.10 Lead: that is, we do not expect one out of every million people to get
X1.6.10.1 Toxicity Summary—(The following discussion is cancer if they drink decaffeinated coffee. Rather, it is a
for inorganic lead—not the organic forms of lead (tetraethyl- mathematical risk based on scientific assumptions used in risk
lead, tetramethyllead) that were present in petroleum prod- assessment. The FDA uses a conservative estimate to ensure
ucts.) A significant amount of toxicological information is that the risk is not understated. We interpret animal test results
available on the health effects of lead. Lead produces neuro- conservatively, and we are extremely careful when we extrapo-
toxic and behavioral effects particularly in children. However, late risks to humans. When the FDA uses the risk level of
the EPA believes that it is inappropriate to set an RfD for lead one-in-one-million, it is confident that the risk to humans is
and its inorganic compounds because the agency believes that virtually nonexistent.
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X1.7.3 In short, a “one-in-one-million” cancer risk estimate, The chosen risk level of 10−5 is at the midpoint of the reference risk range for
which is often tacitly assumed by some policy-makers to carcinogens (10−4 to 10−6) generally used to evaluate CERCLA actions. Fur-
thermore, by setting the risk level at 10−5 for TC carcinogens, EPA believes that
represent a trigger level for regulatory action, actually repre- this is the highest risk level that is likely to be experienced, and most if not all
sents a level of risk that is so small as to be of negligible risks will be below this level due to the generally conservative nature of the ex-
concern. posure scenario and the underlying health criteria. For these reasons, the
Agency regards a 10−5 risk level for Group A, B, and C carcinogens as ad-
X1.7.4 Another misperception within the risk assessment equate to delineate, under the Toxicity Characteristics, wastes that clearly pose
arena is that all occupational and environmental regulations a hazard when mismanaged.”
have as their goal a theoretical maximum cancer risk of 1 in X1.7.8 When considering these limits it is interesting to
1 000 000. Travis, et al (14) recently conducted a retrospective note that many common human activities entail annual risks
examination of the level of risk that triggered regulatory action greatly in excess of one-in-one-million. These have been
in 132 decisions. Three variables were considered: (1) indi- discussed by Grover Wrenn, former director of Federal Com-
vidual risk (an upper-bound estimate of the probability at the pliance and State Programs at OSHA, as follows:
highest exposure), (2) population risk (an upper-limit estimate X1.7.9 State regulatory agencies have not uniformly
of the number of additional incidences of cancer in the exposed adopted a one-in-one-million (1 3 10−6) risk criterion in mak-
population), and ( 3) population size. The findings of Travis, et ing environmental and occupational decisions. The states of
al (14) can be summarized as follows: Virginia, Maryland, Minnesota, Ohio, and Wisconsin have
X1.7.4.1 Every chemical with an individual lifetime risk employed or proposed to use the one-in-onehundred-thousand
above 4 3 10−3 received regulation. Those with values below (1 3 10−5) level of risk in their risk management decisions

--```,`,,,`,`,`,``,,,,,```````-`-`,,`,,`,`,,`---
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.

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X2. DEVELOPMENT OF RISK-BASED SCREENING LEVELS (RBSLs) APPEARING IN SAMPLE LOOK-UP

X2.1 Introduction: X2.1.2.4 Inhalation of indoor vapors originating from dis-


X2.1.1 This appendix contains the equations and parameters solved hydrocarbons in ground water,
used to construct the example “Look-Up” (Table X2.1). This X2.1.2.5 Ingestion of surficial soil, inhalation of outdoor
table was prepared solely for the purpose of presenting an vapors and particulates emanating from surficial soils, and
example Tier 1 matrix of RBSLs, and these values should not dermal absorption resulting from surficial soil contact with
be viewed, or misused, as proposed remediation “standards.” skin,
The reader should note that not all possible pathways have X2.1.2.6 Inhalation of outdoor vapors originating from
been considered and a number of assumptions concerning hydrocarbons in subsurface soils,
exposure scenarios and parameter values have been made.
These should be reviewed for appropriateness before using the X2.1.2.7 Inhalation of indoor vapors originating from sub-
listed RBSLs as Tier 1 screening values. surface hydrocarbons, and
X2.1.2 The approaches used to calculate RBSLs appearing X2.1.2.8 Ingestion of ground water impacted by leaching of
in Table X2.1 are briefly discussed as follows for exposure to dissolved hydrocarbons from subsurface soils.
vapors, ground water, surficial soils, and subsurface soils by X2.1.3 For the pathways considered, approaches used in
means of the following pathways: this appendix are consistent with guidelines contained in Ref
X2.1.2.1 Inhalation of vapors, (26).
X2.1.2.2 Ingestion of ground water, X2.1.4 The development presented as follows focuses only
X2.1.2.3 Inhalation of outdoor vapors originating from
on human-health RBSLs for chronic (long-term) exposures.
dissolved hydrocarbons in ground water,

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.

Exposure Receptor Xylenes Benzo


Target Level Benzene Ethylbenzene Toluene Napthalenes
Pathway Scenario (Mixed) (a)pyrene
Air
Indoor air residential cancer risk = 1E-06 3.92E-01 1.86E-03
screening cancer risk = 1E-04 3.92E + 01 1.86E-01
levels for chronic HQ = 1 1.39E + 03 5.56E + 02 9.73E + 03 1.95E + 01
inhalation commercial/ cancer risk = 1E-06 4.93E-01 2.35E-03
exposure, industrial cancer risk = 1E-04 4.93E + 01 2.35E-01
3
µ/ m chronic HQ = 1 1.46E + 03 5.84E + 02 1.02E + 04 2.04E + 01
Outdoor residential cancer risk = 1E-06 2.94E-01 1.40E-03
air cancer risk = 1E-04 2.94E + 01 1.40E-01
screening chronic HQ = 1 1.04E + 03 4.17E + 02 7.30E + 03 1.46E + 01
levels for
commercial/ cancer risk = 1E-06 4.93E-01 2.35E-03
inhalation
industrial cancer risk = 1E-04 4.93E + 01 2.35E-01
exposure,
µg/m3 chronic HQ = 1 1.46E + 03 5.84E + 02 1.02E + 04 2.04E + 01
OSHA TWA PEL,µ g/m3 3.20E + 03 4.35E + 05 7.53E + 05 4.35E + 06 5.00E + 04 2.00E + 02A
Mean odor detection threshold,µ g/m3B 1.95E + 05 6.00E + 03 8.70E + 04 2.00E + 02
National indoor background concentration range,µ g/m3C 3.25E + 00 to 2.20E + 00 to 9.60E-01 to 4.85E + 00 to
2.15E + 01 9.70E + 00 2.91E + 01 4.76E + 01
Soil
Soil residential cancer risk = 1E-06 2.72E-01 RESD
volatilization cancer risk = 1E-04 2.73E + 01 RES
to outdoor air, chronic HQ = 1 RES RES RES RES
mg/kg commercial cancer risk = 1E-06 4.57E-01 RES
industrial cancer risk = 1E-04 4.57E + 01 RES
chronic HQ = 1 RES RES RES RES
Soil-vapor
intrusion from residential cancer risk = 1E-06 5.37E-03 RES
soil to buildings, cancer risk = 1E-04 5.37E-01 RES
mg/kg chronic HQ = 1 4.27E + 02 2.06E + 01 RES 4.07E + 01
commercial/ cancer risk = 1E-06 1.69E-02 RES
industrial cancer risk = 1E-04 1.69E + 00 RES
chronic HQ = 1 1.10E + 03 5.45E + 01 RES 1.07E + 02

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TABLE X2.1 Continued


Exposure Receptor Xylenes Benzo
Target Level Benzene Ethylbenzene Toluene Napthalenes
Pathway Scenario (Mixed) (a)pyrene
Surficial soil residential cancer risk = 1E-06 5.82E + 00 1.30E-01
(0 to 3 ft) cancer risk = 1E-04 5.82E + 02 1.30E + 01
(0 to 0.9 m) chronic HQ = 1 7.83E + 03 1.33E + 04 1.45E + 06 9.77E + 02
ingestion/
commercial/ cancer risk = 1E-06 1.00E + 01 3.04E-01
dermal/
industrial cancer risk = 1E-04 1.00E + 03 3.04E + 01
inhalation,
mg/kg chronic HQ = 1 1.15E + 04 1.87E + 04 2.08E + 05 1.50E + 03
Soil-leachate MCLs 2.93E-02 1.10E + 02 1.77E + 01 3.05E + 02 N/A 9.42E + 00
to protect
residential cancer risk = 1E-06 1.72E-02 5.50E-01
ground water

--```,`,,,`,`,`,``,,,,,```````-`-`,,`,,`,`,,`---
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.

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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

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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.

--```,`,,,`,`,`,``,,,,,```````-`-`,,`,,`,`,,`---

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TABLE X2.4 Exposure Parameters Appearing in Tables X2.2 and X2.3
Parameters Definitions, Units Residential Commercial/Industrial
ATc averaging time for carcinogens, years 70 years 70 yearsA
ATn averaging time for noncarcinogens, years 30 years 25 yearsA
BW adult body weight, kg 70 kg 70 kgA
ED exposure duration, years 30 years 25 yearsA
EF exposure frequency, days/years 350 days/year 250 days/yearA
IRsoil soil ingestion rate, mg/day 100 mg/day 50 mg/dayA
--```,`,,,`,`,`,``,,,,,```````-`-`,,`,,`,`,,`---

IRair-indoor daily indoor inhalation rate, m3/day 15 m3/day 20 m3/dayA


IRair-outdoor daily outdoor inhalation rate, m3/day 20 m3/day 20 m3/dayA
IRw daily water ingestion rate, L/day 2 L/day 1 L/dayA
LFsw leaching factor, (mg/L-H2O)/(mg/kg-soil)—see Table X2.5 chemical-specific chemical-specific
M soil to skin adherence factor, mg/cm2 0.5 0.5B
RAFd dermal relative absorption factor, volatiles/PAHs 0.5/0.05 0.5/0.05B
RAFo oral relative absorption factor 1.0 1.0
RBSLi risk-based screening level for media i, mg/kg-soil, mg/L-H2O, orµ g/m3-air chemical-, media-, and exposure route- chemical-, media-, and exposure
specific route-specific
RfDi inhalation chronic reference dose, mg/kg-day chemical-specific chemical-specific
RfDo oral chronic reference dose, mg/kg-day chemical-specific chemical-specific
SA skin surface area, cm2/day 3160 3160A
SFi inhalation cancer slope factor, (mg/kg-day)−1 chemical-specific chemical-specific
SFo oral cancer slope factor, (mg/kg-day)−1 chemical-specific chemical-specific
THQ target hazard quotient for individual constituents, unitless 1.0 1.0
TR target excess individual lifetime cancer risk, unitless for example, 10−6 or 10−4 for example, 10−6 or 10−4
VFi volatilization factor, (mg/m3-air)/(mg/kg-soil) or (mg/m3-air)/(mg/L-H2O)—see chemical- and media-specific chemical- and media-specific
Table X2.5
A
See Ref (27).
B
See Ref (28).

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

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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

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TABLE X2.6 Soil, Building, Surface, and Subsurface Parameters Used in Generating Example Tier 1 RBSLs

NOTE 1—See X2.10 for justification of parameter selection.


Parameters Definitions, Units Residential Commercial/Industrial
d lower depth of surficial soil zone, cm 100 cm 100 cm
D air diffusion coefficient in air, cm2/s chemical-specific chemical-specific
D wat diffusion coefficient in water, cm2/s chemical-specific chemical-specific
ER enclosed-space air exchange rate, 1/sec 0.00014 s−1 0.00023 s−1
foc fraction of organic carbon in soil, g-C/g-soil 0.01 0.01
H henry’s law constant, (cm3-H2O)/(cm3-air) chemical-specific chemical-specific
hcap thickness of capillary fringe, cm 5 cm 5 cm
hv thickness of vadose zone, cm 295 cm 295 cm
I infiltration rate of water through soil, cm/years 30 cm/year 30 cm/year
koc carbon-water sorption coefficient, cm3-H2O/g-C chemical-specific chemical-specific
ks soil-water sorption coefficient, cm3-H2O/g-soil foc 3 koc foc 3 koc
LB enclosed-space volume/infiltration area ratio, cm 200 cm 300 cm
Lcrack enclosed-space foundation or wall thickness, cm 15 cm 15 cm
LGW depth to ground water = hcap + hv, cm 300 cm 300 cm
LS depth to subsurface soil sources, cm 100 cm 100 cm
Pe particulate emission rate, g/cm2-s 6.9 3 10−14 6.9 3 10−14
S pure component solubility in water, mg/L-H2O chemical-specific chemical-specific
Uair wind speed above ground surface in ambient mixing zone, cm/s 225 cm/s 225 cm/s
Ugw ground water Darcy velocity, cm/year 2500 cm/year 2500 cm/year
W width of source area parallel to wind, or ground water flow direction, cm 1500 cm 1500 cm
dair ambient air mixing zone height, cm 200 cm 200 cm
dgw ground water mixing zone thickness, cm 200 cm 200 cm
h areal fraction of cracks in foundations/walls, cm2-cracks/cm2-total area 0.01 cm2-cracks/cm2-total area 0.01 cm2-cracks/cm2-total area
uacap volumetric air content in capillary fringe soils, cm3-air/cm3-soil 0.038 cm3-air/cm3-soil 0.038 cm3-air/cm3-soil
uacrack volumetric air content in foundation/wall cracks, cm3-air/cm3 total volume 0.26 cm3-air/cm3 total volume 0.26 cm3-air/cm3 total volume
uas volumetric air content in vadose zone soils, cm3-air/cm3-soil 0.26 cm3-air/cm3-soil 0.26 cm3-air/cm3-soil
uT total soil porosity, cm3/cm3-soil 0.38 cm3/cm3-soil 0.38 cm3/cm3-soil
uwcap volumetric water content in capillary fringe soils, cm3-H2O/cm3-soil 0.342 cm3-H2O/cm3-soil 0.342 cm3-H2O/cm3-soil
uwcrack volumetric water content in foundation/wall cracks, cm3-H2O/cm3 total volume 0.12 cm3-H2O/cm3 total volume 0.12 cm3-H2O/cm3 total volume
uws volumetric water content in vadose zone soils, cm3-H2O/cm3-soil 0.12 cm3-H2O/cm3-soil 0.12 cm3-H2O/cm3-soil
rs soil bulk density, g-soil/cm3-soil 1.7 g/cm3 1.7 g/cm3
t averaging time for vapor flux, s 9.46 3 108 s 7.88 3 108 s

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.

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X2.6.6.5 Steady well-mixed atmospheric dispersion of the
emanating vapors within the breathing zone as modeled by a
“box model” for air dispersion.
X2.6.7 In the event that the time-averaged flux exceeds that
which would occur if all chemical initially present in the
surficial soil zone volatilized during the exposure period, then
the volatilization factor is determined from a mass balance
assuming that all chemical initially present in the surficial soil
zone volatilizes during the exposure period.
X2.7 Subsurface Soils—Inhalation of Outdoor Vapors:
X2.7.1 In this case chemical intake is a result of inhalation
of outdoor vapors which originate from hydrocarbons con-
tained in subsurface soils located some distance below ground
surface. Here the goal is to determine the RBSL for subsurface
soils that corresponds to the target RBSL for outdoor vapors in
FIG. X2.1 Volatilization from Ground Water to Ambient Air the breathing zone, as given in Table X2.1. If the selected target
vapor concentration is some value other than the RBSL for
inhalation (that is, odor threshold or ecological criterion), this
value can be substituted for the RBSLair parameter appearing in
the equations given in Tables X2.2 and X2.3.
X2.7.2 A conceptual model for the transport of chemicals
from subsurface soils to ambient air is depicted in Fig. X2.4.
For simplicity, the relationship between outdoor air and soil
concentrations is represented in Tables X2.2 and X2.3 by the
“volatilization factor,” VFsamb [(mg/m3-air)/(mg/kg-soil)], de-
fined in Table X2.5. It is based on the following assumptions:
X2.7.2.1 A constant chemical concentration in subsurface
soils,
X2.7.2.2 Linear equilibrium partitioning within the soil
matrix between sorbed, dissolved, and vapor phases, where the
partitioning is a function of constant chemical- and soil-
specific parameters,
X2.7.2.3 Steady-state vapor- and liquid-phase diffusion
through the vadose zone to ground surface,
X2.7.2.4 No loss of chemical as it diffuses towards ground
surface (that is, no biodegradation), and
FIG. X2.2 Volatilization from Ground Water to Enclosed-Space Air
X2.7.2.5 Steady well-mixed atmospheric dispersion of the
emanating vapors within the breathing zone as modeled by a
“box model” for air dispersion.
--```,`,,,`,`,`,``,,,,,```````-`-`,,`,,`,`,,`---

X2.7.3 Should the calculated RBSLs exceed the value for


which the equilibrated vapor and dissolved pore-water phases

FIG. X2.3 Volatilization from Surficial Soils

X2.6.6.2 Linear equilibrium partitioning within the soil


matrix between sorbed, dissolved, and vapor phases, where the
partitioning is a function of constant chemical- and soil-
specific parameters,
X2.6.6.3 Diffusion through the vadose zone,
X2.6.6.4 No loss of chemical as it diffuses towards ground
surface (that is, no biodegradation), and FIG. X2.4 Volatilization from Subsurface Soils to Ambient Air

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become saturated, Cs sat [mg/kg-soil] (see Table X2.5 for calculation of this value), “RES” is entered in the table to
calculation of this value), “RES” is entered in the table to indicate that the selected risk level or hazard quotient cannot be
indicate that the selected risk level or hazard quotient cannot be reached or exceeded for that compound and the specified
reached or exceeded for that compound and the specified exposure scenario (even if free-phase product or precipitate is
exposure scenario (even if free-phase product or precipitate is present in the soil).
present in the soil).
X2.9 Subsurface Soils—Leaching to Ground Water:
X2.8 Subsurface Soils—Inhalation of Enclosed-Space (In-
X2.9.1 In this case chemical intake is a result of chemicals
door) Vapors:
leaching from subsurface soils, followed by inhalation of
X2.8.1 In this case chemical intake is a result of inhalation enclosed-space vapors, inhalation of outdoor vapors, or inges-
of enclosed-space vapors which originate from hydrocarbons tion of ground water as discussed in X2.1-X2.3. Here the goal
contained in subsurface soils located some distance below is to determine the RBSL for subsurface soils that corresponds
ground surface. Here the goal is to determine the RBSL for to the target RBSLs for the inhalation or ingestion routes. If the
subsurface soils that corresponds to the target RBSL for indoor selected target ground water concentration is some value other
vapors, as given in Tables X2.2 and X2.3. If the selected target than an RBSL for ground water (that is, odor threshold or
vapor concentration is some value other than the RBSL for ecological criterion), this value can be substituted for the
inhalation (that is, odor threshold or ecological criterion), this RBSLw parameter appearing in the equations given in Tables
value can be substituted for the RBSLair parameter appearing X2.2 and X2.3.
in the equations given in Tables X2.2 and X2.3. X2.9.2 A conceptual model for the leaching of chemicals
X2.8.2 A conceptual model for the transport of chemicals from subsurface soils to ground water is depicted in Fig. X2.6.
from subsurface soils to enclosed spaces is depicted in Fig. For simplicity, the relationship between ground water and soil
X2.5. For simplicity, the relationship between indoor air and concentrations is represented in Tables X2.2 and X2.3 by the
soil concentrations is represented in Tables X2.2 and X2.3 by “leaching factor,” LFsw [(mg/L-H2O)/ (mg/kg-soil)], defined in
the “volatilization factor,” VFsesp [(mg/m3-air)/(kg-soil)], de- Table X2.5. It is based on the following assumptions:
fined in Table X2.5. It is based on the following assumptions: X2.9.2.1 A constant chemical concentration in subsurface
X2.8.2.1 A constant chemical concentration in subsurface soils,
soils, X2.9.2.2 Linear equilibrium partitioning within the soil
X2.8.2.2 Linear equilibrium partitioning within the soil matrix between sorbed, dissolved, and vapor phases, where the
matrix between sorbed, dissolved, and vapor phases, where the partitioning is a function of constant chemical- and soil-
partitioning is a function of constant chemical- and soil- specific parameters,
specific parameters, X2.9.2.3 Steady-state leaching from the vadose zone to
X2.8.2.3 Steady-state vapor- and liquid-phase diffusion ground water resulting from the constant leaching rate I [cm/s],
through the vadose zone and foundation cracks, X2.9.2.4 No loss of chemical as it leaches towards ground
X2.8.2.4 No loss of chemical as it diffuses towards ground water (that is, no biodegradation), and
surface (that is, no biodegradation), and X2.9.2.5 Steady well-mixed dispersion of the leachate
X2.8.2.5 Well-mixed atmospheric dispersion of the emanat- within a ground water “mixing zone.”
ing vapors within the enclosed space. X2.9.3 Should the calculated RBSLs exceed the value Cs sat,
X2.8.3 Should the calculated RBSLs exceed the value Cssat
--```,`,,,`,`,`,``,,,,,```````-`-`,,`,,`,`,,`---

for which the equilibrated vapor and dissolved pore-water


[mg/kg-soil] for which the equilibrated vapor and dissolved phases become saturated (see Table X2.5 for calculation of this
pore-water phases become saturated (see Table X2.5 for value), “RES” is entered in the table to indicate that the
selected risk level or hazard quotient cannot be reached or

FIG. X2.5 Volatilization from Subsurface Soils to Enclosed-Space


Air FIG. X2.6 Leaching from Subsurface Soils to Ground Water

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exceeded for that compound and the specified exposure sce- for adult males given in Ref (27). The soil-to-skin adherence
nario (even if free-phase product or precipitate is present in the factor, M [mg/cm2], and dermal relative absorption factor, RAF
soil). d[mg-absorbed/mg-applied], are based on guidance issued by
X2.9.4 In some regulatory programs, “dilution attenuation Ref (28).
factors” (DAFs) are currently being proposed based on fate and X2.10.3 Soil properties are based on typical values for
transport modeling results. A DAF is typically defined as the sandy soils and are consistent with values given in Ref (30).
ratio of a target ground water concentration divided by the
X2.10.4 Physical dimensions are consistent with the scale
source leachate concentration, and is inherently very similar to
of typical underground fuel tank releases.
the leachate factor, LFsw, discussed here. The difference
between these two terms is that LFsw represents the ratio of the X2.10.5 Particulate emission rates were estimated by the
target ground water concentration divided by the source area approach presented by Cowherd, et al (32). It was assumed that
soil concentration. Should a regulatory program already have a the mode of the surficial soil size distribution was 2 mm, the
technically defensible DAF value, it can be equated to a erosion potential was unlimited, there was no vegetative cover,
leachate factor by the following expression: and the mean average annual wind speed was 4 m/s.
DAF 3 rs X2.10.6 The chemical-specific parameters used are defined
LFsw 5 3 100 (X2.3) in Table X2.7.
@uws 1 ksrs 1 Hu as#
where the parameters are defined in Table X2.6. X2.10.7 In this development, surficial soils are defined as
those soils present within 1 m of ground surface. Subsurface
X2.10 Parameter Values: soil RBSLs are based on assumed source depths of 1 m.
X2.10.1 Table X2.4 lists exposure parameters used to cal- Ground water is assumed to be located 3 m below ground
culate the RBSLs appearing in sample Look-Up Table X2.1. surface.
All values given are based on adult exposures only. With the X2.10.8 Once again, the reader is reminded that the param-
exception of the dermal exposure parameters (SA, M, and eter (and corresponding RBSL) values are presented here as
RAFd), the values given are reasonable maximum exposure examples only, and are not intended to be used as standards. At
(RME) values presented in Ref (27) and are regarded as upper best, the parameters presented are reasonable values based on
bound estimates for each individual exposure parameter. current information and professional judgment. The reader
X2.10.2 The skin surface area, SA = 3160 cm2/day, is based should review and verify all assumptions prior to using any of
on the average surface area of the head, hands, and forearms the example RBSLs as screening level values.

X3. USE OF PREDICTIVE MODELING IN THE RISK-BASED CORRECTIVE ACTION PROCESS

X3.1 Scope: D 653 Terminology Relating to Soil, Rock, and Contained


X3.1.1 Predictive modeling is a valuable tool that can Fluids7
provide information to the risk management process. In a D 5447 Guide for Application of a Ground-Water Flow
RBCA, modeling is used to predict the location and concen- Model to a Site-Specific Problem8
tration contaminants and to interpret, or extrapolate, site D 5490 Guide for Comparing Ground-Water Flow Model
characterization data, historical monitoring data, and toxico- Simulations to Site-Specific Information8
logical information. In addition, predictive modeling may be E 943 Terminology Relating to Biological Effects and Envi-
used in evaluation of remedial alternatives and in evaluating ronmental Fate9
compliance targets in monitoring plans. This appendix dis- E 978 Practice for Evaluating Environmental Fate Models of
cusses the following: Chemicals9
X3.1.1.1 Significance and use of predictive modeling in the D 5609 Guide for Defining Boundary Conditions in Ground-
RBCA process; Water Flow Modeling8
D 5610 Guide for Defining Initial Conditions in Ground-
X3.1.1.2 Interpretation of predictive modeling results;
Water Flow Modeling8
X3.1.1.3 Procedures for predictive migration models; and D 5611 Guide for Conducting a Sensitivity Analysis for a
X3.1.1.4 Procedures for exposure, risk, and dose-response Ground-Water Flow Model Application8
assessment.
X3.1.2 This appendix is not intended to be all inclusive. X3.3 Terminology:
Each predictive model is unique and may require additional X3.3.1 Definitions— For definitions of terms used in this
procedures in its development and application. All such addi- appendix, see Terminologies D 653 and E 943.
tional analyses should be documented in the RBCA process.
7
X3.2 Referenced Documents: Annual Book of ASTM Standards, Vol 04.08.
8
Annual Book of ASTM Standards, Vol 04.09.
X3.2.1 ASTM Standards: 9
Annual Book of ASTM Standards, Vol 11.04.

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X3.3.2 Descriptions of Terms Specific to This Appendix: X3.3.2.13 sensitivity (model application)—the degree to
X3.3.2.1 analytical model—a model that uses mathematical which the model result is affected by changes in a selected
solutions to governing equations that are continuous in space model input representing fluid and media properties and
and time and applicable to the flow and transport process. boundary conditions.
X3.3.2.14 simulation— in migration modeling, one com-
X3.3.2.2 application verification—using the set of param-
plete execution of a fluid flow modeling computer program,
eter values and boundary conditions from a calibrated model to
including input and output.
approximate acceptably a second set of field data measured
DISCUSSION—for the purposes of this appendix, a simu-
under similar conditions. lation refers to an individual modeling run. However, simula-
DISCUSSION—Application verification is to be distin- tion is sometimes also used broadly to refer to the process of
guished from code verification, which refers to software modeling in general.
testing, comparison with analytical solutions, and comparison
with other similar codes to demonstrate that the code represents X3.4 Significance and Use:
its mathematical foundation. X3.4.1 Predictive modeling is significant in many phases of
X3.3.2.3 boundary condition—a mathematical expression RBCA, including the following:
of a state of the physical system that constrains the equations X3.4.1.1 Determining the potential urgency of response
of the mathematical model. based on estimated migration and attenuation rates of com-
X3.3.2.4 calibration (model application)—the process of pounds of concern,
refining the model representation of the fluid and media X3.4.1.2 Determining the extent of corrective action based
properties and boundary conditions to achieve a desired degree on estimated migration and attenuation rates of compounds of
of correspondence between the model simulation and observa- concern,
tions of the real system. X3.4.1.3 Establishing relationships between administered
X3.3.2.5 code validation— the process of determining how doses and adverse impacts to humans and sensitive environ-
mental receptors, and
well a modeling code’s theoretical foundation and computer
X3.4.1.4 Determining RBSLs concentrations at points of
implementation describe actual system behavior in terms of the
exposure.
“degree of correlation” between calculated and independently
X3.4.2 Examples of predictive modeling uses in the RBCA
observed cause-and-effect responses of the prototype fluid flow
process include the following:
system (for example, research site or laboratory experiment)
X3.4.2.1 The prediction of contaminant concentration dis-
for which the code has been developed.
tributions for future times based on historical trend data, as in
X3.3.2.6 code verification—the procedure aimed at estab- the case of ground water transport modeling,
lishing the completeness, consistency, correctness, and accu- X3.4.2.2 The recommendation of sampling locations and
racy of modeling software with respect to its design criteria by sampling frequency based on current interpretation and future
evaluating the functionality and operational characteristics of expectations of contaminant distributions, as in the design of
the code and testing embedded algorithms and data transfers ground water monitoring networks,
through execution of problems for which independent bench- X3.4.2.3 The design of corrective action measures, as in the
marks are available. case of hydraulic control systems, and
X3.3.2.7 computer code (computer program)—the assem- X3.4.2.4 The calculation of site-specific exposure point
bly of numerical techniques, bookkeeping, and control lan- concentrations based on assumed exposure scenarios, as in the
guage that represents the model from acceptance of input data case of direct exposure to surficial soils.
and instructions to delivery of output. X3.4.3 Predictive modeling is not used in the RBCA pro-
X3.3.2.8 conceptual model—an interpretation or working cess as a substitute for validation of site-specific data.
description of the characteristics and dynamics of the physical
system. X3.5 Interpretation of Predictive Modeling Results:
X3.3.2.9 ground water flow model—application of a math- X3.5.1 Predictive models are mathematical approximations
ematical model to represent a site-specific ground water flow of real processes, such as the movement of chemicals in the
system. subsurface, the ingestion of chemicals contained in drinking
water, and adverse impacts to human health and environmental
X3.3.2.10 mathematical model—mathematical equations
resources resulting from significant exposures. One key step
expressing the physical system and including simplifying
towards evaluating model results is to assess the accuracy and
assumptions. The representation of a physical system by
uncertainty, and to verify the model used.
mathematical expressions from which the behavior of the
X3.5.2 The accuracy of modeling-based predictions is
system can be deduced with known accuracy.
evaluated using a post audit and is dependent upon a number of
X3.3.2.11 migration model— application of a mathematical factors, including the following:
model to represent a site-specific fluid flow system. X3.5.2.1 The approximations used when describing the real
X3.3.2.12 model—an assembly of concepts in the form of system by mathematical expressions,
mathematical equations that portray understanding of a natural X3.5.2.2 The model setup, that is, the input parameters (for
phenomenon. example, boundary conditions) used to generate the results, and
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X3.5.2.3 The mathematical methods used to solve the gov- more reasonable case scenario. This level requires more
erning equations (for example, user selection of numerical specific information about the site and may involve the use of
solution methods, expansion approximations, numerical pa- either simple or moderately complex mathematical models. It
rameters, and so forth). may involve the use of most likely exposure scenario (that is,
X3.5.3 Predictive modeling results are always subject to USEPA MLE values). This information is used to set conser-
some degree of uncertainty. It is important to quantify this vative corrective action objectives that are still regarded as
uncertainty to properly interpret the results. Many times this is overly protective. At some sites a comprehensive assessment is
done with a sensitivity analysis in which the user identifies required (Tier 3) where SSTLs are determined using a site-
those parameters that most significantly influence the results. If specific transport and exposure model and, in some cases,
most of all of the parameters do not produce “sensitivity,” then parameter distributions. Tier 3 provides the most realistic
the model may need to be reevaluated because it is possible evaluation of potential exposure and risk.
that the key parameters are missing from the model. X3.6 Types of Predictive Migration and Risk Assessment
X3.5.4 A postaudit may be performed to determine the Models:
accuracy of the predictions. While model calibration and X3.6.1 Predictive models typically used in the RBCA pro-
verification demonstrate that the model accurately simulates cess can be grouped into two broad categories:
past behavior of the system, the postaudit tests whether the X3.6.1.1 Migration models, and
model can predict future system behavior. Postaudits are X3.6.1.2 Exposure, risk, and dose-response assessment
normally performed several years after the initial assessment models.
and corrective action. X3.6.2 The determination of Tier 1 RBSLs or Tiers 2 and 3
X3.5.5 In the RBCA process, “conservative” is an important SSTLs generally involves the use of combinations of both
criterion of predictive modeling. In the initial evaluation, Tier types of models. A more detailed description of each type of
1, the most conservative approach, is used, which provides a model is given in X3.7 and X3.8.
worst case scenario for potential exposure and risk. Models
that, because of their simplicity, neglect factors that yield X3.7 Procedures for Predictive Migration Models:
conservative results are used. Input may include conservative X3.7.1 Migration (fate and transport) models predict the
values such as the USEPA RME values. When a more rigorous movement of a petroleum release through soil, ground water,
approach is warranted, such as in Tier 2 of the RBCA process, or air, or combination thereof, over time. Most models focus on
conservative values are often used, but in conjunction with a

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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

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TABLE X3.2 Reported Degradation Rates for Petroleum Hydrocarbons
Chemical Decay Rates (day−1, [half-life days])
Source
Reference Ethyl- Benzo
of Data Benzene Toluene Xylenes O-Xylene MTBE Naphthalene
Benzene (a)Pyrene
Barker, et alA Borden Aquifer, 0.007 [99] 0.011 [63] ... ... 0.014 [50] ... ... ...
Canada
B
Kemblowski Eastern Florida Aquifer 0.0085 [82] ... ... ... ... ... ... ...
Chiang, et alC Northern Michigan 0.095 [7] ... ... ... ... ... ... ...
Aquifer
Wilson, et alD Traverse City, MI 0.007 to 0.024 0.067 [10] ... 0.004 to 0.014 ... ... ... ...
Aquifer [99] to [29] [173] to [50]
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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

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model is described in more detail for ground water flow (2) Calibration of a model is evaluated through analysis of
systems in Guide D 5447. residuals. A residual is the difference between the observed and
(2) Provide an analysis of data deficiencies and potential simulated variable. Statistical tests and illustrations showing
sources of error with the conceptual model. The conceptual the distribution of residuals are described for ground water
model usually contains areas of uncertainty due to the lack of flow models in Guide D 5490.
field data. Identify these areas and their significance to the (3) Calibration of a model to a single set of field measure-
conceptual model evaluated with respect to project objectives. ments does not guarantee a unique solution. To minimize the
X3.7.8.3 Computer Code Selection—Computer code selec- likelihood of nonuniqueness, the model should be tested to a
tion is the process of choosing the appropriate software different set of boundary conditions or stresses. This process is
algorithm, or other analysis technique, capable of simulating referred to as application verification. If there is poor corre-
the characteristics of the physical system, as identified in the spondence to a second set of field data, then additional
conceptual model. The types of codes generally used in the calibration or data collection are required. Successful verifica-
RBCA process are analytical and numerical models. The tion of an application results in a higher degree of confidence
selected code should be appropriate to fit the available data and in model predictions. A calibrated but unverified model may
meet the modeling objectives. The computer code must also be still be used to perform predictive simulations when coupled
tested for the intended use and be well documented. with a sensitivity analysis.
(1) Analytical models are generally based on assumptions of X3.7.8.6 Sensitivity Analysis—Sensitivity analysis is a
uniform properties and regular geometries. Advantages include quantitative method of determining the effect of parameter
quick setup and execution. Disadvantages include, in many variation on model results. Two purposes of a sensitivity
cases, that analytical models are so simplistic that important analysis are (1) to quantify the uncertainty in the calibrated
aspects of a given system are neglected. model caused by uncertainty in the estimates of parameters,
(2) Numerical models allow for more complex heteroge- stresses, and boundary conditions, and (2) to identify the model
neous systems with distributed properties and irregular geom- inputs that have the most influence on model calibration and
etries. Advantages include the flexibility to simulate more predictions.
complex physical systems and natural parameter variability. (1) Sensitivity of a model parameter is often expressed as the
Disadvantages include that the approach is often very time- relative rate of change of a selected model calculation during
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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.

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X3.8.1.1 In the case of compounds that have been classified but has been adopted by the USEPA. For genotoxic and
as carcinogens, exposure and risk assessment models are carcinogenic agents, extrapolations from high experimental
generally linked by the expression: doses to low doses of environmental significance require the
risk 5 average lifetime intake@mg/kg2day# use of mathematical models to general low dose-response
3 slope factor@mg/kg2day# 21 (X3.2) curves. It should be noted that although the EPA uses the linear
multi-state model to describe incremental carcinogenic effect,
where the intake depends on exposure parameters (ingestion there is no general agreement in the scientific community that
rate, exposure duration, and so forth) and the concentration at this is the appropriate model to use.
point-of-exposure. The slope factor (sometimes called the
X3.8.5 The critical factor determined from the dose-
“potency factor”) is itself based on a model and set of
response curve is the slope factor (SF), which is the slope of
underlying assumptions, which are discussed as follows.
the dose-response curve in the low-dose region. The units of
X3.8.1.2 In the case of compounds that have not been
the slope factor are expressed as (mg/kg-day) −1 and relate a
classified as carcinogens, exposure and risk assessment models
given environmental intake to the risk of additional incidence
are generally :
of cancer above background.
average intake @mg/kg2day# X3.8.6 The RfD or SF values are generally obtained from a
hazard quotient 5 reference dose @mg/kg2day# (X3.3)
standard set of reference tables (for example, Ref (2) or Ref
where the intake depends on exposure parameters (ingestion (3)). It is important to note that the information in IRIS has
rate, exposure duration, and so forth) and the concentration at typically only been peer-reviewed within the EPA and may not
point-of-exposure. The reference dose is itself based on a always have support from the external scientific community.
model and set of underlying assumptions, which are discussed Whereas the information in IRIS has been subject to agency-
as follows. wide data quality review, the information in the HEAST tables
X3.8.2 Toxicity Assessment: Dose-Response Models— has not. The user is expected to consult the original assessment
Toxicity assessments use dose-estimates of a “safe dose” or documents to appreciate the strengths and limitations of the
toxic level based on animal studies. In some instances, human data in HEAST. Thus, care should be exercised in using the
epidemiological information is available on a chemical. Toxi- values in HEAST. Some state and local agencies have toxicity
cologists generally make two assumptions about the effects of factors they have derived themselves or preferences for factors
risk agents at the low concentrations typical of environmental to use if neither IRIS nor HEAST lists a value. Values for a
exposures: range of hydrocarbons typically of interest are presented in
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X3.8.2.1 Thresholds exist for most biological effects; in Table X3.1.


other words, for noncarcinogenic, nongenetic toxic effects, X3.8.7 It is important to note that in extrapolating the
there are doses below which no adverse effects are observed in information obtained in animal studies to humans, a number of
a population of exposed individuals, and conservative assumptions are made.
X3.8.2.2 No thresholds exist for genetic damage or incre- X3.8.7.1 For noncarcinogens, an arbitrary system of default
mental carcinogenic effects. Any level of exposure to the safety and uncertainty factors, as discussed (in multiples of
genotoxic or carcinogenic risk agent corresponds to some ten), is used to convert observations, in animals to estimates in
non-zero increase in the likelihood of inducing genotoxic or humans.
incremental carcinogenic effects. X3.8.7.2 For carcinogens, some of the most important
X3.8.3 The first assumption is widely accepted in the assumptions include: (1) the results of the most sensitive
scientific community and is supported by empirical evidence. animal study are used to extrapolate to humans, (2) in general,
The threshold value for a chemical is often called the NOAEL. chemicals with any incremental carcinogenic activity in ani-
Scientists usually estimate NOAELs from animal studies. An mals are assumed to be potential human carcinogens, and (3)
important value that typically results from a NOAEL or no threshold exists for carcinogens.
LOAEL value is the RfD. A reference dose is an estimate (with
X3.8.8 The uncertainty in the RfD and SF values are often
an uncertainty typically spanning an order of magnitude) of a
neglected in deference to single point values which are then
daily exposure (mg/kg/day) to the general human population
typically summarized in databases such as IRIS and HEAST
(including sensitive subgroups) that is likely to be without an
and assumptions described are risk management policy deci-
appreciable risk of deleterious effects during a lifetime of
sions made by the USEPA. These assumptions are not explic-
exposure. The RfD value is derived from the NOAEL or
itly defined and further obscure the conservatism in the safe
LOAEL by application of uncertainty factors (UF) that reflect
dose estimate. Thus, care must be exercised in interpreting
various types of data used to estimate RfDs and an additional
results which have as a basis these conservative toxicity
modifying factor (MF), which is based on a professional
evaluations.
judgment of the quality of the entire database of the chemical.
The oral RfD, for example, is calculated from the following X3.8.9 Exposure Assessment Modeling—The goal of expo-
equation: sure assessment modeling is to estimate the chemical uptake
that occurs when a receptor is exposed to compounds present
NOAEL in their environment. In principal, the process for developing
RfD 5 (X3.4)
~UF 3 MF! and using migration models presented in X3.7 is directly
X3.8.4 The second assumption regarding no threshold ef- applicable to exposure assessment modeling. In this case the
fects for genotoxic or carcinogenic agents is more controversial user:

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X3.8.9.1 Develops a conceptual model by identifying sig- be carefully reviewed. While point values are often selected for
nificant exposure pathways and receptors, simplicity, statistical distributions for many of the exposure
X3.8.9.2 Selects a model to describe the contact rate and parameters are readily available for Tier 3 analyses.
subsequent uptake of the chemical(s), X3.8.13 It is common for USEPA RME values to be used in
X3.8.9.3 Performs a sensitivity analysis to identify critical exposure assessment calculation, as is done for the example
parameters, Tier 1 Look-Up Table discussed in Appendix X2. The RME
X3.8.9.4 Selects appropriate exposure parameters (breath- value is generally defined as a statistical upper limit of
ing rates, and so forth), available data (generally 85 to 90 % of all values are less than
X3.8.9.5 Generates estimates of exposure and uptake, and the RME value). Therefore, by consistently selecting and
X3.8.9.6 Assesses the uncertainty in the estimates. multiplying conservative RME values the user models a
X3.8.10 There are differences between the process outlined scenario that is very improbable and always more conservative
in X3.7 and that which can be practically applied to exposure than the “true” RME exposure scenario. Thus, great care must
assessment modeling. For example, with the exception of be exercised, when using combinations of these default values
exposures and impacts to environmental resources, it is diffi- in risk assessments, to avoid a gross overestimation of expo-
cult to calibrate exposure assessment models unless very sure for a specific site.
expensive epidemiological studies are conducted. X3.9 Report—The purpose of the model report is to
X3.8.11 Typically, the models used to estimate uptake are communicate findings, to document the procedures and as-
simplistic algebraic expressions, such as those contained in Ref sumptions inherent in the study, and to provide detailed
(27). Application of these equations is illustrated in Appendix information for peer review. The report should be a complete
X2. document allowing reviewers and decision makers to formulate
X3.8.12 In many cases, exposure parameter values are their own opinion as to the credibility of the model. The report
available in Ref (27), but other more recent information is also should describe all aspects of the modeling study outlined in
available in peer-reviewed publications, and all sources should this appendix.

X4. INSTITUTIONAL CONTROLS

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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X4.3.2.1 The first requirement is that of a writing. It is a rule controls. These arrangements may have to be put in a deed
of law that conveyances of land must be documented in a restriction in order to run with the land from owner to owner,
writing. The same rule holds for deed restrictions affecting but responsible parties can also be required to sign a contract
land. Ideally, a deed restriction used as an institutional control making these promises. Of course, almost every state has
would be written down with particularity and then recorded in authority to issue administrative orders to accomplish some or
the local land records office, in much the same fashion as the all of these arrangements.
documentation and recordation of a sale of land. Parties may X4.3.6 The preceding arrangements can also set out proce-
also encounter the requirement that the deed restriction be dures that will be followed if some emergency requires that the
executed “under seal,” a legal formality that has been aban- remediation site be disturbed. If, for example, underground
doned in most states. utility lines must be repaired, the landowner would follow this
X4.3.2.2 The second requirement is that the deed restriction protocol for handling the soil and alerting the state authority.
should precisely reflect what the parties’ intentions are in
X4.4 Use Restrictions:
regard to the scope and the duration of the restrictions.
Explicitly stating in the deed restriction that the parties intend X4.4.1 Use restrictions are usually the heart of what is in a
the restriction to “run with the land” (that is, last forever and deed restriction. Use restrictions describe appropriate and
bind subsequent owners) is strongly recommended. inappropriate uses of the property in an effort to perpetuate the
X4.3.2.3 The third requirement, privity of estate, arises benefits of the remedial action and ensure property use that is
from a concern that only persons with a certain relationship to consistent with the applicable cleanup standard. Such tech-
the land should be able to enforce a deed restriction. Normally, niques also prohibit any person from making any use of the site
deed restrictions are promises between the buyer and the seller in a manner that creates an unacceptable risk of human or
or between neighbors; therefore, the state or a third party may environmental exposure to the residual concentrations of
not enforce a deed restriction. However, even in states that chemical(s) of concern.
require privity of estate, this concern is addressed if the X4.4.2 Use restrictions address uses that may disturb a
landowner took the land with knowledge that the restrictions containment cap or any unremediated soils under the surface or
existed and might be enforced by these third parties. Thus, it is below a building. A prohibition on drinking on-site (or off-site
also strongly recommended that the deed restriction explicitly by means of well restriction areas discussed as follows) ground
state that the state environmental authority may enforce the water may also be appropriate.
restriction. Recording of the deed restriction serves as notice to X4.4.3 As an example, a program may allow a restriction of
anyone who later purchases or acquires an interest in the land. record to include one or more of the following:
Therefore, privity of estate should not be a barrier to state X4.4.3.1 Restriction on property use;
enforcement of the deed restriction if the proper steps are X4.4.3.2 Conditioning the change of use from nonresiden-
taken. tial on compliance with all applicable cleanup standards for a
residential property;
X4.3.2.4 Finally, a deed restriction is only enforceable if the
X4.4.3.3 Restricting access; or
promise “touches and concerns the land.” A rough rule of
X4.4.3.4 Restricting disturbance of department-approved
thumb to decide this point is whether the landowner’s legal
remedial effects.
interest in the land is decreased in value due to the deed
X4.4.4 Well restriction areas can be a form of institutional
restriction. If the land is devalued in this way, then the
control by providing notice of the existence of chemical(s) of
restriction could be said to “touch and concern the land.” Note
concern in ground water, and by prohibiting or conditioning the
that the focus of the inquiry is on the land itself; promises that
construction of wells in that area.
are personal in nature and merely concern human activities that
X4.4.4.1 This technique preserves the integrity of any
happen to take place on the land are least likely to be
ground water remedial action by prohibiting or conditioning
enforceable. Thus, any deed restriction used as an institutional
the placement and use of any or all types of wells within the
control should be written so that it centers on the land and the
area.
use of the land.
X4.4.4.2 Well restrictions of this nature would be subject to
X4.3.3 Due to the potential enforcement hurdles encoun- agency approval and public notice, and may include the
tered by a governmental agency in enforcing a deed restriction, restriction on constructing or locating any wells within a
it may be appropriate for an individual state to seek statutory particular designated area. Notice of the well restriction is
and regulatory amendments to ensure that such authority exits recorded on the land records and with various health officials
in regard to all deed restrictions for environmental purposes. and municipal officials. The restrictions can only be released
X4.3.4 Remedies for noncompliance with deed restrictions upon a showing that the concentrations of the chemical(s) of
comes in two forms: (1) persons or agencies may sue to obtain concern in the well restriction area is remediated in accordance
a court order (injunction) requiring compliance or (2) if the with state standards.
state statute allows for it, the state’s attorney general can seek
enforcement of civil penalties, such as fines, for noncompli- X4.5 Access Controls:
ance. X4.5.1 Another subset of institutional controls is the control
X4.3.5 A state program can require a landowner to continue of access to any particular site. The state uses the following
monitoring activities and to allow state environmental officials criteria to determine the appropriate level and means of access
access to the site to monitor compliance with institutional control:
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X4.5.1.1 Whether the site is located in a residential or wastes on the property, and may also include a classification of
mixed use neighborhood; the level of health or environmental danger presented by the
X4.5.1.2 Proximity to sensitive land-use areas including conditions on the property. The state agency may be required to
day-care centers, playgrounds, and schools; and perform detailed inspections of the site to determine its priority
X4.5.1.3 Whether the site is frequently traversed by neigh- relative to other registered sites.
bors. X4.7.4 Owners of sites proposed for inclusion on the
X4.5.2 Access can be controlled by any of the following: registry have rights of hearing and appeal, and owners of sites
fencing and gates, security, or postings or warnings. on the registry have rights to modify or terminate their listing.
In some cases, the owner of a site proposed for inclusion on the

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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:

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X4.9.1 One system for ensuring the future restriction on use X4.11.1.2 References for Use Restrictions:
of a site, or the obligation to remediate a site, is to require 24 New Jersey Regulations 400 (New Jersey Administration Code §
private parties to restrict use by contract. While this method is 7.26D-8.2 (d))
Michigan Administration Code 299.5719 (3) (a), (b), (g)
often negotiated among private parties, it will be difficult, if not New Jersey Regulation 7.26D-8.4
impossible, to institutionalize some control over that process
without interfering with the abilities and rights of private X4.11.1.3 References for Access Controls:
parties to freely negotiate these liabilities. Iowa Administration Code r. 133.4 (2) (b)
Michigan Rule 299.4719 (3) (f)
X4.9.2 Another avenue is for the landowner or responsible New Jersey Regulations § 7.26D-8.2
party to obligate itself to the state by contract. The state may
X4.11.1.4 References for Notice:
require a contractual commitment from the party to provide
California Health and Safety Code § 25359.7 (1981)
long-term monitoring of the site, use restrictions, and means of Illinois Responsible Property Transfer Act (1985)
continued funding for remediation. Indiana Code §§13-7-22.5-1–22 (1989) (“Indiana Environmental Hazardous
Disclosure and Responsible Party Transfer Law”)
Massachusetts Regulations Code Title §§ 40.1071-1090 (1993)
X4.10 Continued Financial Responsibility—Another as- Michigan Rule 299.5719 (3) (c)
pect of institutional controls is the establishment of financial
mechanisms by which a responsible party ensures continued X4.11.1.5 References for Registry Act Requirements:
Iowa Code Ann. §§ 455B.426–455B.432, 455B.411 (1) (1990)
funding of remediation measures and assurance to the satisfac-
Missouri Code Regulations Title 10, §§ 25-10.010, 25-3.260 (1993)
tion of the state.
X4.11.1.6 References for Transfer Act Requirements:
X4.11 References: Connecticut General Stat.§ 22a-134 et seg
Illinois Responsible Property Transfer Act (1985)
X4.11.1 The following references serve as examples and are Indiana Code §§ 13-7-22.5-1–22 (1989) (“Indiana Environmental Hazard-
ous Disclosure and Responsible Party Transfer Law”)
current as of the fourth quarter of 1993:
New Jersey Senate Bill No. 1070, the Industrial Site Recovery Act, amend-
X4.11.1.1 References for Deed Restrictions: ing the environmental cleanup Responsibility Act, N.J.S.A. 13:1K-6 et seg
New Jersey Spill Compensation and Control Act, N.J.S.A. 58:10-23.11 et
24 New Jersey Regulations 400 (1992) (New Jersey Administration Code
seg
§ 7.26D-8.2 (e) (2))
24 New Jersey Regulations 400-02 (1992) (New Jersey Administration
Code §§ 7.26D-8.1–8.4) X4.11.1.7 Reference for Contractual Obligations:
24 New Jersey Regulations 401 (1992) (New Jersey Administration Code Michigan Rule 299.5719 (2)
§ 7.26D Appendix A, Model Document, Declaration of Environmental Re-
strictions and Grant of Ease ment, Item 8) X4.11.1.8 Reference for Continued Financial Responsibil-
Illinois Responsible Property Transfer Act § 7(c) (1985)
Massachusetts Regulations Code Title § 40.1071 (2) (1) & (k) ity:
Massachusetts Regulations Code, Title § 40.1071(4) Michigan Rule 299.5719 (2)
Michigan Administration Code 299.5719 (3) (e) (1990)
Michigan Rules 299.5719 (2), (3) (d)

X5. EXAMPLE APPLICATIONS OF RISK-BASED CORRECTIVE ACTION

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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X5.2.2.4 No other sources are present, associated with the leaching pathway are the most restrictive of
X5.2.2.5 The site is underlain by layers of fine to silty sands, the two. As this aquifer is currently being used as a drinking
X5.2.2.6 Ground water, which is first encountered at 32 ft water supply, RBSL values based on meeting drinking water
(9.7 m) below ground surface, is not impacted, MCLs are selected. In the case of naphthalene, for which there
X5.2.2.7 Maximum depth at which hydrocarbons are de- is no MCL, the RBSL value corresponding to a residential
tected is 13 ft (3.9 m). Maximum detected soil concentrations scenario and a hazard quotient of unity is used.
are as follows: X5.2.5 Exposure Pathway Evaluation—Based on current
Depth Concentration, and projected future use, the only two potential complete
Compound Below Ground Surface, mg/kg
ft (m)
exposure pathways at this site are: (1) the inhalation of ambient
Benzene 8 (2.4) 10 vapors by on-site workers, or ( 2) the leaching to ground water,
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Ethylbenzene 4 (1.2) 4 ground water transport to the down-gradient drinking-water


Toluene 6.5 (1.9) 55
Xylenes 3.5 (1.01) 38 well, and ingestion of ground water (see Fig. X5.1).
Naphthalene 2 (0.6) 17 X5.2.6 Comparison of Site Conditions With Tier 1 RBSLs—
X5.2.2.8 A receptor survey indicates that two domestic Based on the data given in X5.2.2.7 and the RBSLs given in
water wells are located within 900 ft (273.6 m) of the source Look-Up Table X2.1 in Appendix X2, exceedences of Tier 1
area. One well is located 500 ft (152.4 m) hydraulically RBSLs are noted only for benzene and toluene.
down-gradient from the impacted soil zone, the other well is X5.2.7 Evaluation of Tier 1 Results—The responsible party
hydraulically up-gradient. Both wells produce water from the decides to devise a corrective action plan to meet Tier 1
first encountered ground water zone. standards after considering the following factors:
X5.2.3 Site Classification and Initial Response Action— X5.2.7.1 The shallow aquifer is not yet affected,
Based on classification scenarios given in Table 1, this site is X5.2.7.2 Quick (relative to rate of chemical migration)
classified as a Class 3 site because conditions are such that, at removal of the source will eliminate the need for ground water
worst, it is a long-term threat to human health and environ- monitoring,
mental resources. The appropriate initial response is to evalu-
X5.2.7.3 The new owner plans to install new tanks within
ate the need for a ground water monitoring program (see Table
six months,
X5.1). At most, this would consist of a single well located
immediately down-gradient of the impacted petroleum soils. X5.2.7.4 Limited excavation of soils to meet Tier 1 criteria
The responsible party recommends deferring the decision to could be performed quickly and inexpensively when the tanks
install a ground water monitoring system until the Tier 1 are removed, relative to the cost of proceeding to a Tier 2
evaluation is complete, and justifies this recommendation analysis, and
based on no detected ground water impact, the limited extent of X5.2.7.5 An excavation proposal will facilitate the real
impacted soils, and the separation between impacted soils and estate deal.
first-encountered ground water. The regulatory agency concurs X5.2.8 Tier 1 Remedial Action Evaluation—Excavate all
with this decision. impacted soils with concentrations above the Tier 1 RBSLs
X5.2.4 Development of Tier 1 Look-Up Table of Risk-Based when the current tanks are replaced. Subsequently resurface
Screening Level (RBSL)—Assumptions used to derive example the area with new concrete pavement to reduce future infiltra-
Tier 1 RBSL Look-Up Table X2.1 in Appendix X2 are tion and leaching potential through any remaining impacted
reviewed and presumed valid for this site. A comparison of soils. It is agreed that ground water monitoring is not necessary
RBSLs for both pathways of concern indicates that RBSLs and the governing regulatory agency agrees to issue a No

TABLE X5.1 Example 1—Site Classification and Initial Response Actions


Criteria and Prescribed Scenarios Example Initial Response Actions
3. Long-term (>2 years) threat to human health, safety, or sensitive Notify appropriate authorities, property owners, and potentially affected parties,
environmental receptors and evaluate the need to
• Subsurface soils (>3 ft (0.9 m) BGS) are significantly impacted, and • Monitor ground water and determine the potential for future migration of
the depth between impacted soils and the first potable aquifer is less the chemical(s) of concern to the aquifer.
than 50 ft (15 m).
• Ground water is impacted, and potable water supply wells producing • Monitor the dissolved plume and evaluate the potential for natural
from the impacted interval are located >2 years ground water travel attenuation and the need for hydraulic control.
time from the dissolved plume.
• Ground water is impacted, and non-potable water supply wells • Identify water usage of well, assess the effect of potential impact, monitor
producing from the impacted interval are located >2 years ground the dissolved plume, and evaluate whether natural attenuation or hydraulic
water travel time from the dissolved plume. control are appropriate control measures.
• Ground water is impacted, and non-potable water supply wells that • Monitor the dissolved plume, determine the potential for vertical migration,
do not produce from the impacted interval are located within the notify the user, and determine if any impact is likely.
known extent of chemical(s) of concern.
• Impacted surface water, storm water, or ground water discharges • Investigate current impact on sensitive habitat or surface water body,
within 1500 ft (457 m) of a sensitive habitat or surface water body restrict access to area of discharge (if necessary), and evaluate the need
used for human drinking water or contact recreation. 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.

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FIG. X5.1 Example 1—Exposure Evaluation Flowchart

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Further Action and Closure letter following implementation of X5.3.2.7 Ground water flow gradient is very shallow, and
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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.

TABLE X5.2 Example 2—Site Classification and Initial Response Actions


Criteria and Prescribed Scenarios Example Initial Response Actions
3. Long-term (>2 years) threat to human health, safety, or sensitive Notify appropriate authorities, property owners, and potentially affected parties,
environmental and evaluate the need to
receptors
• Subsurface soils (>3 ft (0.9 m) BGS) are significantly impacted, and • Monitor ground water and determine the potential for future contaminant
the depth between impacted soils and the first potable aquifer is less migration to the aquifer.
than 50 ft (15 m).
• Ground water is impacted, and potable water supply wells producing • Monitor the dissolved plume and evaluate the potential for natural
from the impacted interval are located >2 years ground water travel attenuation and the need for hydraulic control.
time from the dissolved plume.
• Ground water is impacted, and non-potable water supply wells • Identify water usage of well, assess the effect of potential impact, monitor
producing from the impacted interval are located >2 years ground the dissolved plume, and evaluate whether natural attenuation or hydraulic
water travel time from the dissolved plume. control are appropriate control measures.
• Ground water is impacted, and non-potable water supply wells that • Monitor the dissolved plume, determine the potential for vertical migration,
do not produce from the impacted interval are located within the notify the user, and determine if any impact is likely.
known extent of chemical(s) of concern.
• Impacted surface water, storm water, or ground water discharges • Investigate current impact on sensitive habitat or surface water body,
within 1500 ft (457 m) of a sensitive habitat or surface water body restrict access to area of discharge (if necessary), and evaluate the need
used for human drinking water or contact recreation. 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.

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X5.3.4 Development of Tier 1 Look-Up Table of Risk-Based X5.3.9 Remedial Action Evaluation—Based on the demon-
Screening Level (RBSL) Selection—Assumptions used to de- stration of dissolved plume attenuation with distance, the
rive example Tier 1 RBSL Look-Up Table X2.1 in Appendix owner negotiates a corrective action plan based on the follow-
X2 are reviewed and presumed valid for this site. Due to the ing: (1) compliance with the Tier 1 RBSLs at the monitoring
very low probability of the exposure pathway actually being well located in the street center divider, provided that deed
completed in the future, MCLs are not used and the site owner restrictions are enacted to prevent the use of ground water
is able to negotiate Tier 1 RBSLs based on a 10 −5 risk to within that zone until dissolved levels decrease below drinking
human health for carcinogens and hazard quotients equal to water MCLs, (2) deed restrictions are enacted to ensure that
unity for the noncarcinogens (based on ground water inges- site land use will not change significantly, (3) continued
tion). sampling of the sentinel/compliance ground water monitoring
X5.3.5 Exposure Pathway Evaluation—Based on current well on a yearly basis, (4) should levels exceed Tier 1 RBSLs
and projected future use, and the soil gas survey results, there at that point for any time in the future, the corrective action
are no potential complete exposure pathways at this site. The plan will have to be revised, and ( 5) closure will be granted if
down gradient residential neighborhood is connected to a dissolved conditions remain stable or decrease for the next two
public water supply system, and there is no local use of the years.
impacted aquifer. However, being concerned about future
X5.4 Example 3—RBCA With Emergency Response and In
uncontrolled use of the aquifer, the regulatory agency requests
Situ Remediation:
that the owner evaluate the ground water transport to residen-
tial drinking water ingestion pathway, recognizing that there is X5.4.1 Scenario—A 5 000-gal (18 925-L) release of super
a low potential for this to occur (see Fig. X5.2). unleaded gasoline occurs from a single-walled tank after
X5.3.6 Comparison of Site Conditions With Tier 1 RBSLs repeated manual gaging with a gage stick. Soils are sandy at
—Based on the data given in X5.3.2.10 and the RBSLs given this site, ground water is shallow, and free-product is observed
in example Look-Up Table X2.1 in Appendix X2, exceedences in a nearby monitoring well within 24 h. The site is located
of Tier 1 soil and ground water RBSLs are noted only for next to an apartment building that has a basement where
benzene. coin-operated washers and dryers are located for use by the
X5.3.7 Evaluation of Tier 1 Results—The responsible party tenants.
decides to proceed to a Tier 2 evaluation for benzene and the X5.4.2 Site Assessment— In this case the initial site assess-
pathway of concern, rather than devise a corrective action plan ment is conducted rapidly and is focussed towards identifying
to meet Tier 1 standards after considering the following factors: if immediately hazardous conditions exist. It is known from
X5.3.7.1 The shallow aquifer is impacted, but the dissolved local geological assessments that the first encountered ground
plume appears to be stable and ground water movement is very water is not potable, as it is only about 2 ft (0.6 m) thick and
slow, is perched on a clay aquitard. Ground water monitoring wells
in the area (from previous assessment work) are periodically
X5.3.7.2 Excavation of soils to meet Tier 1 criteria would be
inspected for the appearance of floating product, and vapor
expensive, due to the depth of impacted soils. Excavation
concentrations in the on-site utility corridors are analyzed with
would shut down the facility, and require all tanks and new
an explosimeter. While this flurry of activity begins, a tenant of
lines to be removed and reinstalled,
the apartment building next door informs the station operator
X5.3.7.3 Costs for application of other conventional treat-
that her laundry room/basement has a strong gasoline odor.
ment methods, such as vapor extraction and pump and treat, are
Explosimeter readings indicate vapor concentrations are still
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estimated to exceed $300 000 over the life of the remediation,


lower than explosive levels, but the investigation team notes
and
that “strong gasoline odors” are present.
X5.3.7.4 A tier 2 analysis for this site is estimated to require X5.4.3 Site Classification and Initial Response Action—
minimal additional data, and is anticipated to result in equally This limited information is sufficient to classify this site as a
protective, but less costly corrective action. Class 2 site (strong potential for conditions to escalate to
X5.3.8 Tier 2 Evaluation—The owner collects additional immediately hazardous conditions in the short term), based on
ground water monitoring data and verifies that: the observed vapor concentrations, size of the release, and
X5.3.8.1 No mobile free-phase product is present, geological conditions (see Table X5.3). The initial response
X5.3.8.2 The dissolved plume is stable and ground water implemented is as follows:
concentrations appear to be decreasing with time, X5.4.3.1 Periodic monitoring of the apartment basement
X5.3.8.3 Extent of the dissolved plume is limited to within begins to ensure that levels do not increase to the point where
50 ft (15.2 m) of the property boundaries, evacuation is necessary (either due to explosion or acute health
X5.3.8.4 Dissolved oxygen concentrations are higher out- effects). In addition, the fire marshall is notified and building
side of the dissolved plume, indicating some level of aerobic tenants are informed of the activities at the site, potential
biodegradation, hazards, and abatement measures being implemented,
X5.3.8.5 Ground water movement is less than 50 ft/year X5.4.3.2 A free-product recovery/hydraulic control system
(15.2 m), and is installed to prevent further migration of the mobile liquid
X5.3.8.6 Simple ground water transport modeling indicates gasoline, and
that observations are consistent with expectations for the site X5.4.3.3 A subsurface vapor extraction system is installed
conditions. to prevent vapor intrusion to the building.

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FIG. X5.2 Example 2—Exposure Evaluation Flowchart

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TABLE X5.3 Example 3—Site Classification and Initial Response Actions
Criteria and Prescribed Scenarios Example Initial Response Actions
2. Short-term (0 to 2 years) threat to human health, safety, or sensitive Notify appropriate authorities, property owners, and potentially affected parties,
environmental receptors and 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 modeling) and remove source (if necessary), or install vapor
building. migration barrier.
• Shallow contaminated surface soils are open to public access, and • Remove soils, cover soils, or restrict access.
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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 sufficient, or if hydraulic control is required.
projected ground water travel distance down gradient of the known
extent of chemical(s) of concern.
• Ground water is impacted, and a public or domestic water supply well • Monitor ground water well quality and evaluate if control is necessary
producing from a different interval is located within the known extent of 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 discharge, and evaluate the magnitude and impact of the discharge.
human drinking water or contact recreation.

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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FIG. X5.3 Example 3—Exposure Evaluation Flowchart

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X5.5.2.6 Ground water velocity is 0.008 ft/day (0.0024 X5.5.8.1 For the pathways considered, approaches for the
m/day) based on slug tests and ground water elevation survey Tier 2 table are consistent with guidelines contained in Ref
and assumed soil porosity of 50 %, (26).
X5.5.2.7 A receptor survey indicates that the nearest down X5.5.8.2 The equations, assumptions, and parameters used
gradient water well is greater than 1.0 mile (1.6 km) away and to construct the Tier 1 Look-Up Table and Tier 2 table are
the nearest surface water body is 0.5 miles (0.8 km). The similar, except as noted as follows:
distance to the nearest sensitive habitat is greater than 1.0 mile; ((1) Ground Water: Ingestion of Ground Water—A one-
however, there is a forest preserve frequented by day hikers dimensional analytical mass balance equation with attenuation
and picnickers next to the site. The nearest home is 1000 ft mechanisms of retardation, dispersivity, and first-order biologi-
(305 m) away. The commercial building on site is 25 ft (7.6 m) cal decay (in sandy soil only) was applied in conjunction with
from the area of hydrocarbon-impacted soil. the equations in Tables X2.2 and X2.3 to calculate SSTLs. The
X5.5.3 Site Classification and Initial Response Action— analytical model is limited to steady-state conditions and
Based on the classification scenarios given in Table 1, this site longitudinal dispersion. The analytical solution to the mass
is classified as a Class 4 site, with no demonstrable long-term balance equation is presented in Ref (44).
threat to human health, safety, or sensitive environmental ((2) Ground Water: Inhalation of Outdoor Vapors—This
receptors, because the hydrocarbon-impacted soils are covered pathway was not considered because exposure concentrations
by asphalt or concrete and cannot be contacted, only non- were very low.
potable perched water with no existing local use is impacted, ((3) Ground Water: Inhalation of Enclosed-Space (Indoor)
and there is no potential for explosive levels or concentrations Vapors—A one-dimensional mass balance equation following
that could cause acute effects in nearby buildings. The appro- Jury, et al (31) has been used to model vapor transport (43).
priate initial response is to evaluate the need for a ground water This model was used in conjunction with the equations in
monitoring program. Tables X2.2 and X2.3 to calculate SSTLs. The model includes
X5.5.4 Development of Tier 1 Look-Up Table of Risked- concentration attenuation between the source and the building
Based Screening Level (RBSL)—The assumptions used to by partitioning into immobile pore water, adsorption onto soil,
derive the example Tier 1 RBSL Look-Up Table are presumed and biological degradation (in sandy soil only).
valid for this site. ((4) Subsurface Soils: Inhalation of Outdoor Vapors—This
X5.5.5 Exposure Pathway Evaluation—The complete path- pathway was not considered because exposure concentrations
ways are ground water and soil volatilization to enclosed were very low.
spaces and to ambient air, and direct exposure to impacted soil ((5) Subsurface Soils: Inhalation of Enclosed-Space (In-
or ground water by construction workers. A comparison of door) Vapors—The SSTLs were calculated using the Jury
RBSLs for these pathways of concern indicates that RBSLs model (31) as discussed in Paragraph ( 3) of X5.5.8.2.
associated with soil volatilization to an enclosed space are the ((6) Subsurface Soils: Leaching to Ground Water—The
most restrictive RBSLs. SSTLs were calculated using the one-dimensional mass-
X5.5.6 Comparison of Site Conditions with Tier 1 RBSLs— balance equation described in Paragraph (1) of X5.5.8.2, in
Based on the data given in X5.5.2 and the RBSLs given in conjunction with the lechate factor, LFSW, as discussed in
Table X2.1, exceedances of Tier 1 RBSLs are noted for X2.9.4.1.
benzene in soil and ground water and toluene for ground water. ((7) All exposure parameter values listed in Table X2.4,
soil, building surface, and subsurface parameter values listed in
X5.5.7 Evaluation of Tier 1 Results—The responsible party
Table X2.6, and chemical-specific properties listed in Table
decided to proceed to a Tier 2 evaluation for the pathways of
X2.7 have not been changed.
concern rather than develop a corrective action plan for the
((8) First-order decay rates in sandy soil were assumed to
following reasons:
be 0.2 % per day for all BTEX compounds. These rates are
X5.5.7.1 Only shallow perched water is impacted, and the
considered conservative. Chiang, et al (38) determined that a
dissolved plume is moving very slowly in tight clay,
DO of 2.0 mg/L is required for rapid and complete biodegra-
X5.5.7.2 Excavation of soils to meet Tier 1 criteria would be dation of benzene. Chiang, et al (38) measured a biodegrada-
expensive and would disrupt activities of the on-site business. tion rate of 0.95 % per day, and Barker, et al (36) measured a
Off-site excavation would be impractical and may not be able biodegradation rate of 0.6 % per day for benzene. In general,
to clean up ground water to Tier 1 criteria, published biodegradation rates range from 0.6 to 1.25 % per
X5.5.7.3 Other conventional treatment methods, such as day. Chiang, et al (38) also determined that biodegradation
pump and treat and vapor extraction, would be relatively rates may be slower and incomplete at DO concentrations
ineffective in the heavy clay, and below 2.0 mg/L. This is a conservative value since aerobic
X5.5.7.4 A Tier 2 evaluation for this site requires no biodegradation continues at DO concentrations as low as 0.7
additional data and is expected to be an equally protective but mg/L (44).
less costly corrective action. ((9) Clay properties are as follows:
X5.5.8 Development of a Tier 2 Table of Site-Specific Target Total soil porosity, cm3/cm3 0.05
Levels (SSTLs)—The Tier 2 table is similar to the Tier 1 Volumetric water content, cm3/cm3 0.40
Look-Up Table with the exception that SSTLs for the pathways Ground water Darcy velocity, cm/s 25

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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to the very conservative assumptions used to calculate expo- X5.5.10.1 Annual compliance monitoring of ground water
sure and the small number of people potentially exposed, the at down gradient monitoring wells will be performed to
Tier 2 SSTLs are based on a 10−5 risk to human health for demonstrate decreasing concentrations,
carcinogens and hazard quotients equal to unity for noncar- X5.5.10.2 Should levels exceed Tier 2 SSTLs at any of
cinogens. these monitoring points at any future time, the corrective action
X5.5.9 Comparison of Site Conditions with Tier 2 Table plan will be reevaluated, and
SSTLs—Based on the data given in X5.5.2 and the SSTLs
given in the example of Table X5.4, no exceedances of Tier 2 X5.5.10.3 Closure will be granted if dissolved concentra-
soil or ground water SSTLs are noted. tions remain stable or decrease for the next two years.
X5.5.10 Tier 2 Remedial Action Evaluation—Based on the
fact that Tier 2 soil or ground water SSTLs are not exceeded,
the responsible party negotiates a corrective action plan based
on the following:
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TABLE X5.4 Example Tier 2 Site-Specific Target Level (SSTL) Table—Soil and Ground Water
Distance to SSTLs at Source Sandy Soil, Natural Biodegradation SSTLs at Source Clay Soil, No Natural Biodegradation
Exposure Receptor Carcinogenic Risk = 1 3 10−5, HQ = 1 Carcinogenic Risk = 1 3 10−5, HQ = 1
Source, ft
Pathway Scenario
(m) Benzene Ethylbenzene Toluene Xylene Benzene Ethylbenzene Toluene Xylene
Soil Soil vapor residential 10 (3) 0.052 18 11 450 1.7 570 300 9500
intrusion 25 (7.6) 0.47 160 160 1.7A 65 11A 10A RESB
from soil to 100 (30) 3.1A RES RES RES RES RES RES RES
buildings, commercial/ 10 (3) 0.13 39 24 980 4.3 1200 650 2.0A
mg/kg industrial 25 (7.6) 1.2 340 340 3.6A 950 24A 22.5A RES
100 (30) 8.0A RES RES RES RES RES RES RES
Surficial soil residential 22 5100 5400 280 22 5100 5400 280
ingestion and
commercial/ 120 9600 1.7A 1500 117 9600 1.7A 1500
dermal,
industrial
mg/kg
Soil lechate
to protect residential 0 (0) 0.17 47 130 2200 0.17 47 130 2200
ground water 100 (30) 0.32 88 250 4200 0.20 130 760 RES
ingestion 500 (152) 4.0 1200 6300 RES RES RES RES RES
target level, commercial/ 0 (0) 0.58 130 350 6200 0.58 130 350 6200
mg/kg industrial 100 (30) 1.1 250 670 1.2A 0.70 380 2100 RES
500 (152) 13 3300 1.75A RES RES RES RES RES
Ground Ground residential 0 0.029 3.6 7.3 73 0.029 3.6 7.3 73
Water water 100 0.054 6.8 14 140 0.035 10 43 >SC
ingestion, 500 0.68 90 350 >S >S >S >S >S
mg/L commercial/ 0 0.099 10 20 200 0.099 10 20 200
industrial 100 0.185 19 38 >S 0.12 29 120 >S
500 2.3 250 >S >S >S >S >S >S
Ground
water vapor residential 10 0.11 32 17 510 5.0 >S >S >S
intrusion 25 0.72 210 160 >S 1200 >S >S >S
from ground 100 >S >S >S >S >S >S >S >S
water to commercial/ 10 0.28 70 36 >S 13 >S >S >S
buildings, industrial 25 1.9 >S 350 >S >S >S >S >S
mg/L 100 >S >S >S >S >S >S >S >S
A
Weight percent.
B
RES—Selected risk level is not exceeded for pure compound present at any concentration.
C
>S—Selected risk level is not exceeded for all possible dissolved levels.

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