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tu-f1-corrective-action-101-ice-&-nailor-2016-02-19-final
- 1. Introduction to Site Mitigation CUPA Conference February 23, 2016 Tuesday 10-11:45 AM
- 2. ∗ New (and not so new) corrective action agency employees ∗ Industry ∗ Consultants ∗ (Potential) Responsible Parties ∗ Students Target Audience
- 3. ∗ Charles Ice, PG, San Mateo County Environmental Health ∗ LOP, voluntary cleanup program, Corrective Action UPA, and well permitting, also biotoxin sampling and groundwater sustainability ∗ Steven Nailor, EIT, Santa Barbara County Environmental Health ∗ LOP, voluntary cleanup program, well permitting Speakers
- 4. ∗ Regulatory authority ∗ Local Oversight Program ∗ Voluntary Cleanup Program ∗ Corrective Action Unified Program Agency ∗ Cleanup Process ∗ Opening a case ∗ Typical field activities and documentation ∗ Financing ∗ Enforcement options ∗ Closing a case ∗ Case Examples Meeting Outline
- 5. Corrective Action Programs Local Agencies/Districts Voluntary Programs all other contaminants Health and Safety Code Section 101480 9 Regional Water Quality Control Boards
- 6. ∗ Petroleum releases from USTs only ∗ Code of Regulations, Title 23, Chapter 16, Article 11, Section 2720 defines Responsible Party (RP) as: ∗ Tank owner and operator (or last known operator) ∗ Business owner and operator ∗ Property owner at time of contaminant discovery ∗ Can be named secondary RP if another RP will remain as primary and potential secondary RP had no direct involvement in discharge Leaking Underground Storage Tanks (LUST)
- 7. ∗ Health & Safety Code 25296 – word for word language for Remedial Action Completion Certificate (i.e. closure letter), appeals process for closure request denial ∗ Health & Safety Code 25299 – the UST Cleanup Fund, currently authorized until 2026 and a fee of 2 cents per gallon Health and Safety Code Sections
- 8. ∗ Local Oversight Program started as pilot program by Resolution 88-23 ∗ Counties contracted directly with SWRCB ∗ Appeals process, RWQCB concurrence ∗ Health & Safety Code 25297 – authorizes the SWRCB to implement the LOP, Responsible Party to identify and notify affected property owners, and requires reimbursement for reasonable cost Local Oversight Program
- 9. ∗ CUPAs had to be certified in 1996 ∗ Local Implementing Agencies (LIAs) ∗ AB1701 (2012) required certification to be an LOP, no more LIAs (or quasi-LIAs) ∗ Certification requirements ∗ Professional Geologist (PG) or Engineer (PE), requirements for minimum education and training for all staff Agency Certification
- 10. ∗ 2009-42 ∗ Immediately review all cases for closure and post impediments for closure by 6/30/10 ∗ 2009-81 ∗ Use decisional framework outlined in resolution 92-49 and previous closure orders ∗ 2012-16 Low Threat UST Petroleum Closure Policy (LTCP) Improvement Resolutions
- 11. ∗ 2012-62 Plan for Implementation of LTCP and Additional Program Improvements ∗ Review all sites against LTCP by 8/16/13, create Path to Closure Plan by 1/1/14 ∗ SWRCB review of all closure denials ∗ 60-day TAT work plans and closure requests ∗ Emphasis on high threat cases ∗ Pushing for well destruction and waste removal of pending closure cases Improvement Resolutions
- 12. ∗ RWQCBs have 2,976 open, 13,686 closed ∗ Another 185 listed as Open - Inactive ∗ 13 local agencies have with 1,356 open, 26,157 closed cases ∗ Another 11 listed as Open - Inactive LUST Case numbers
- 13. ∗ RWQCBs Water Code Sections 13267, 13304, and 13365 ∗ Local agencies Health & Safety Code Section 101480, SB1248 (1996) ∗ Responsible Party [can be anyone] that requests the local officer [county or city health officer or county environmental health director] to supervise remedial action at a site ∗ Must enter into a Remedial Action Agreement specifying assessment, remediation, and cleanup goals Voluntary Cleanup Program
- 14. ∗ Letter certifies completion of activities ∗ Charge RP a fee to recover reasonable costs; no enforcement option ∗ Local agency sites ∗ Must first notify DTSC and RWQCB of site ∗ Either party at any time may ask DTSC or RWQCB to take over through agency referral or RP applies for Site Designation or Brownfield MOA processes Voluntary Cleanup Program
- 15. ∗ RWQCBs have 2,578 open cases, 4,098 closed, 1,501 Listed as Open - Inactive ∗ 32 local agencies with 636 VCP open sites, 3,185 closed cases, 99 sites listed as Open - Inactive ∗ 17 agencies >4 sites each, total of 615 sites Voluntary Cleanup Program
- 16. ∗ Mandated by statue in 1997 ∗ Regulations for designation (i.e. application) developed in 2006 ∗ Allows Health & Safety Code Chapter 6.5 Section 25187, 25200.3, 25200.10, 25407.14 orders at facilities subject to oversight by CUPA ∗ Generators, Conditional Authorization, Conditional Exemption, and Permit by Rule (except TTUs) ∗ Less versus more complex sites for Tier 1 and 2 designations Corrective Action UPA
- 17. ∗ Phase 1 Assessment Checklist (DTSC Form 1151 required be filled out by 1/1/97 identified many corrective action sites ) or 1 year after CA or PBR notification ∗ Delegation to UPAs only applies to Health & Safety Code Chapters 6.5 Corrective Action UPA Regulations
- 18. ∗ PBR facilities that can not obtain clean closure during facility closure must become corrective action UPA site (i.e. plating shops) ∗ Enforcement option is Administrative Enforcement Order (AEO) process through your corresponding CUPA Corrective Action UPA Regulations
- 19. ∗ Los Angeles County, Ventura County, San Mateo County, Sacramento County, San Diego County, and Merced County currently designated ∗ Orange County has applied ∗ Only 3 sites officially so far Implementation
- 20. ∗ Facilities that can not obtain clean closure during facility closure, property or business transfer investigations, and solvent detections at LUST sites identify a majority of corrective action UPA sites ∗ Convincing entities to be RPs in Voluntary program ∗ Indication of potential issue will likely delay liquidation of an asset later on, so find out now if really an issue and start dealing with it ∗ Deal with it now, less likely other PRPs die or dissolve, insurance policies can not be located or forgotten, and deal with a smaller footprint of contamination New non-LUST sites
- 21. Cleanup process
- 22. ∗ Opening a case ∗ Funding ∗ Conceptual site model ∗ Site investigation ∗ Remedy selection ∗ Groundwater monitoring ∗ GeoTracker ∗ Public participation ∗ Enforcement options ∗ Case closure LOP/UST Cleanup Process
- 23. ∗ UST Cleanup Fund for eligible sites ∗ Responsible party funds ∗ Less Common ∗ Emergency, Abandoned, and Recalcitrant (EAR) Account ∗ Orphan Site Cleanup Fund ∗ School District Account ∗ LOPs operate under contract to State Water Resources Control Board Funding
- 24. ∗ Definitions and various forms ∗ Description of sources, distribution, pathways, and receptors. ∗ Process ∗ When is site investigation adequate? Conceptual Site Model
- 25. Example of CSM Pictorial
- 26. Example of CSM Flow Diagram Worker Exposure Residential Exposure Recreational Exposure
- 27. ∗ Definitions and various forms ∗ Description of sources, distribution, pathways, and receptors. ∗ Process ∗ When is site investigation adequate? Conceptual Site Model
- 28. ∗ Various approaches ∗ Fixed scope of work ∗ Flexible or expedited ∗ Methods and technologies ∗ Work plans and reporting Site Investigation
- 29. ∗ When are groundwater monitoring wells installed? ∗ What information do we get? ∗ How long do we monitor? Groundwater Monitoring
- 30. ∗ Interim remedial actions ∗ Pilot tests ∗ Corrective action plans ∗ Public participation ∗ Green and Environmentally Responsible Cleanups Remedy Selection
- 31. ∗ Opening a case ∗ Funding ∗ Conceptual site model ∗ Site investigation ∗ Remedy selection ∗ Groundwater monitoring ∗ GeoTracker ∗ Public participation ∗ Enforcement options ∗ Case closure LOP/UST Cleanup Process
- 32. ∗ Make sure site is claimed and keep it up to date ∗ Site history and case status ∗ Document and EDF submittals ∗ Low Threat Closure Policy checklist ∗ Path to closure plan ∗ Regulatory actions (activities) ∗ Post closure site management requirements ∗ Getting information out of GeoTracker GeoTracker
- 33. ∗ Level of effort based on site ∗ Threshold level for all sites ∗ Adjust level of effort as needed ∗ Categories ∗ Rural/urban ∗ Activities ∗ “Public Participation at Cleanup Sites, Final Draft,” April 2005, State Water Resources Control Board and Regional Boards Public Participation
- 34. ∗ Progressively increase enforcement ∗ Meetings ∗ Notice of Violation ∗ District Attorney ∗ Regional Water Quality Control Boards ∗ State Water Resources Control Board Enforcement Options
- 35. ∗ Opening a case ∗ Funding ∗ Conceptual site model ∗ Site investigation ∗ Remedy selection ∗ Groundwater monitoring ∗ GeoTracker ∗ Public participation ∗ Enforcement options ∗ Case closure Voluntary Cleanup Program Process
- 36. ∗ Full and meaningful public involvement (CEQA) ∗ Site screening (Preliminary Endangerment Assessment) ∗ Site investigation (using DTSC guidance documents) ∗ Selection of remedy and cleanup levels ∗ Adequate resources & oversight ∗ Written documentation of corrective action activities ∗ Enforcement of corrective action completeness ∗ Financial assurance ∗ Land use controls Corrective Action Process
- 37. ∗ Most common ways of site discovery ∗ Tank removal and upgrade sampling or release detected by UST monitoring equipment ∗ Voluntary Phase 2 work requested by banks for property transactions, data voluntarily submitted or as required by drilling permit ∗ CUPA facility closure sampling ∗ Public complaints, usually nuisance based Opening a Case
- 38. ∗ Request any additional info anyone has to help determine if site should be opened and who might be responsible parties (RPs) ∗ Identify RPs (assessor’s records and CUPA files for LUST) or potential RPs (current and perspective property owner and current or most recent facility in CUPA files for VCP), send them initial letter ∗ Open site in GeoTracker and have meeting with RPs or potential RPs to discuss why, what, and how, and request initial work plan Steps for Opening A Case
- 39. ∗ Concentrations versus screening levels (ESLs by SFRWQCB or LARWQCB, RLs by USEPA Region 9) ∗ Location of contamination in relation to sensitive receptors (current and imminent land use involved) ∗ Fate and transport pathways initially assessed Deciding Whether to Open a Case
- 41. ∗ Voluntary Phase II work for redevelopment of a former electronics lab from the 1960s reportedly with electroplating ∗ Grab groundwater 20 feet below ground surface in 5 borings but monitoring wells on other sites in the vicinity have 10 feet depth of groundwater ∗ Analyzed soil and groundwater for TPH, SVOCs, and VOCs Circuitron
- 42. Soil Data (ppb)
- 44. Site Map
- 45. ∗ Max TCE in soil 0.055 mg/kg @ 20 ft bgs @ SB-8 ∗ Soil (SFRWQCB) ESL 0.46 mg/kg ∗ Max TCE in groundwater 870 ug/L @ 25 ft bgs @ SB-6 ∗ Groundwater (SFRWQCB) ESL 1,300 ug/L for vapor intrusion, 5 ug/L drinking water Summary and Screening Information for Voting
- 46. ∗ SFRWQCB TCE Vapor Intrusion acute trigger level in fine soil (or deep groundwater) 460 ug/L ∗ Development plans incorporate 2 levels of parking garages (~20 feet deep) ∗ Any possible additional info they could get to stop agency from opening site? Does This Change Your Vote?
- 47. Case Opening Example - Nailor
- 48. Street View
- 49. ∗ Voluntary Phase II work for real estate transaction. Former gas station circa 1928 – 1983, #1 - 8,000 gal. #2 - 5,000 gal. gasoline USTs & #1 - 550 gal. waste oil UST ∗ USTs removed late 1983, & no samples collected ∗ Nov. 1991 inspection reported pump islands and a fill pipe still present ∗ The station canopy removed circa 1995, & the building was converted into two commercial occupancies ∗ Various businesses since, but no fueling operations. Currently a coffee house. Daily Grind – Background
- 50. ∗ Four Geoprobes® attempted only one (B3) reahced 24 feet bgs, others stopped at 7-10 feet bgs due to shallow refusal ∗ Former dispenser island area: B1 & B2 to 10 & 7 feet bgs ∗ Former UST area: B3 & B4 to 24 & 7 feet bgs ∗ B1, B2 & B4 no odor or staining at 1.5’, 7’ & 7’ bgs ∗ B3 dark gray staining & strong hydrocarbon odor at 24 feet ∗ GW not found at this time, data from other sites indicates varied groundwater flow directions are not uncommon. ∗ Analyzed soil & groundwater for TPH, VOCs, & Oxygenates Daily Grind – Assessment-1
- 51. Daily Grind – Assessment-2
- 52. Loc- aiton Depth TPHg TPHd Benz Tol Ebenz Xyl VOCs Pb B1 5 < 0.5 < 10 NA NA NA NA NA 13.5 B1 10 < 0.5 < 10 <0.001 < 0.001 < 0.001 < 0.002 <0.02 6.5 B2 5 < 0.5 < 10 NA NA NA NA NA 6.0 B2 7 < 0.5 < 10 <0.001 < 0.003 < 0.001 < 0.005 <0.02 31.7 B4 5 < 0.5 < 10 NA NA NA NA NA 6.5 B4 7 < 0.5 < 10 <0.001 < 0.001 < 0.001 < 0.002 0.004 8.4 Daily Grind - Assessment-3 soil results in mg/kg
- 53. Loc- aiton Depth TPHg TPHd Benz Tol Ebenz Xyl VOCs Total Lead B3 10 < 0.5 < 10 NA NA NA NA NA 8.87 B3 15 250J NA <0.001 < 0.001 < 0.001 < 0.002 ND NA B3 20 1,360 < 10 <.186 1.54 59.8 209.3 See “A” 10.6 B3 24 7,300 < 10 3.4 246 277 1,406 See “B” 16.4 Naphthalene 1,2,4-TMB 1,3,5-TMB B3 20 “A” 23.7 259 57.6 B3 24 “B” 3.46J 423 102 Daily Grind - Assessment-4 soil results in mg/kg
- 54. ∗ B3 Lithology: ∗ 0 – 6’ Silty fine sand (SM) no odor/no stain ∗ 6’ - 12’ Silty sand (SM) no odor/no stain ∗ 12’ – 23’ Silty clay (CL) moist, stiff, moderate plasticity, no odor/no stain ∗ 24’ Sandy Silty Clay (CL) very fine, moist, medium stiff, strong hydrocarbon odor Daily Grind - Assessment-5
- 55. ∗ One effective boring to 24 feet bgs ∗ Concentrations of TPHg & BTEX increasing and not laterally delineated ∗ Not sure of groundwater depth ∗ Others borings shallow ∗ Could the data support LTCP and stop the agency from opening as a site? Summary and Screening Information for Voting
- 56. ∗ EHS directed more assessment and approved a work plan for one boring / hydropunch for soil and qualitative groundwater sampling. ∗ Should naphthalene (23.7 mg/kg at 20 feet bgs) be the driver? Next Step
- 57. Site Map
- 58. Sample Depth TPHg Benzene Ethylbenzene Naphthalene ID (ft) (mg/kg) (mg/kg) (mg/kg) (mg/kg) B5-5 5 0.838 ND ND ND B5-10 10 ND ND ND ND B5-15 15 ND ND ND ND B5-20 20 637 ND 7.52 13.1 B5-25 25 917 0.175 2.5 5.26 B5-30 30 5,360 2.76 156 23.1 B5-35 35 1,040 0.965 25.9 5.2 B5-40 40 4,520 10.4 100 21 B5-45 45 8,610 12.8 230 42.6 B5-50 50 5,980 2.64 136 30.6 B5-55 55 981 ND 3.42 1.02 B5-60 60 ND ND 0.001J ND B5-63 63 2.07 0.0064 0.0361 0.0122 Soil Data (mg/kg)
- 59. Sample Depth TPHg Benzene Ethylben zene Naphthal ene ID (ft) (ug/L) (ug/L (ug/L) (ug/L) B5 63 52,200 1,050 2,540 192 Groundwater Data grab sample from hydropunch (ug/L)
- 60. Does This Change Your Vote?
- 61. ∗ Does site meet LTCP? ∗ Is CSM complete? What about other USTs? ∗ Interesting levels of TPHg, benzene & naphthalene in groundwater ∗ Evaluation – delineate water – how? ∗ What data is need to close under LTCP?? Does This Change Your Vote?
- 63. ∗ Low Threat UST Closure Policy ∗ Resolution 92-49 ∗ Relevant State Water Board Orders ∗ Closure requests are tracked on GeoTracker ∗ Denials of closure reviewed by State Water Resources Control Board LOP/UST Case Closure
- 64. ∗ Eight General Criteria ∗ Three Media Specific Criteria ∗ Groundwater – Four prescriptive classes of sites or regulatory agency determination ∗ Vapor – Four scenarios, site-specific risk assessment or regulatory agency determination ∗ Direct Contact and Outdoor Air Exposure –Table 1, site- specific risk assessment, or regulatory agency determination Low Threat UST Closure Policy
- 65. ∗ Provides a framework for the cleanup process. ∗ Establishes the basis for determining cleanup levels of waters of the State and soils that impact waters of the State. ∗ Resolution No. 92-49 requires cleanup to occur in a manner that promotes attainment of either background water quality or that level that is reasonable if background levels of water quality cannot be restored. ∗ Resolution No. 92-49 does not require that the requisite level of water quality be met at the time of case closure; it specifies compliance with cleanup goals and objectives within a reasonable time frame. Resolution 92-49
- 66. Case Closure Example - Nailor
- 67. ∗ Urban site ∗ Active retail hand car wash – no fueling ∗ Gasoline and diesel from old fuel USTs ∗ Multiple releases locations from tank pit and piping Time to Play “Would You Close That Site”
- 68. Hand Car Wash
- 69. Hand Car Wash - close-up
- 70. ∗ Depth to GW now 16 - 24 feet bgs ∗ Nearest water supply well is 1150 feet away ∗ Historic free product in one well was sheen - gone ∗ Limited excavation in tank pit area 35 cu. yds. ∗ Secondary impacts being treated by ozone injection ∗ Water table (drought) has limited effectiveness Example LOP/UST Site
- 71. ∗ Shallow wells MW5 -14, 16, 17 below levels of concern for several years ∗ Shallow wells MW-1, 2, 3, 4, & 15 were only ones with significant impacts - last 5 years ∗ Deep wells installed to evaluate for vertical migrations – appear to be in the same aquifer and never tested for vertical flow, only monitored GW Monitoring Information
- 73. West- East Cross Section
- 75. ∗ GW does not meet LTCP as plume longer than 250’ and concentration of Benzene & MTBE exceed 1,000 ug/L. ∗ Vapor Intrusion does not meet LTCP as benzene under building is > 1,000 ug/L and less than 30 feet to GW. ∗ Direct contact to outdoor air meets LTCP. ∗ Continue active remediation and monitor offsite wells for current GW conditions. August 2015 CUF Review Summary Report
- 76. 4th Qtr. 2015 GW Results Well TPHg Benzene Ethyl- Benzene MTBE TBA MW1A 83 3.1 4.6 38 410 MW2A 14,000 190 420 230 920 MW3A 25,000 470 1,000 610 1,500 MW9B 370 <1.2 <1.2 1,100 170 MW15A 5,800 990 620 650 2,400
- 79. ∗ Within service area of a public water system ∗ Consists only of petroleum ∗ Currently no free product ∗ Primary release stopped – USTs removed ∗ Conceptual site model was developed ∗ Secondary source removal ∗ Soil and groundwater tested for MTBE ∗ No nuisance conditions General LTCP Criteria
- 80. Site Data LTCP Class 1 Criteria (µg/L) LTCP Class 2 Criteria (µg/L) LTCP Class 3 Criteria (µg/L) LTCP Class 4 Criteria (µg/L) Plume Length Benzene 400’ MTBE 600’ <100 feet <250 feet <250 feet <1,000 feet Free Product Currently no free product No free product No free product Removed to maximum extent practicable No free product Plume Stable or Decreasing Appears to be decreasing over long term but GW table down due to drought. Stable or decreasin g Stable or decreasin g Stable or decreasing for minimum of 5 Years Stable or decreasing Distance to Nearest Water Supply Well >1,000 feet >250 feet >1,000 feet >1,000 feet >1,000 feet Distance to Nearest Surface Water and Direction 2,000 feet downgradient >250 feet >1,000 feet >1,000 feet >1,000 feet Property Owner Willing to Accept a Land Use Restriction? Yes Not applicable Not applicable Yes Not applicable Groundwater-Specific Criteria
- 81. Site Data LTCP Class 2 Criteria (µg/L) LTCP Class 3 Criteria (µg/L) LTCP Class 4 Criteria (µg/L) Plume Length Approximately 200 feet from source to edge of plume <250 feet <250 feet <1,000 feet Free Product Currently no free product No free product Removed to maximum extent practicable No free product Plume Stable or Decreasing Appears to be decreasing over long term but GW table down with drought Stable or decreasing Stable or decreasing for minimum of 5 Years Stable or decreasing Distance to Nearest Water Supply Well >1,000 feet >1,000 feet >1,000 feet >1,000 feet Distance to Nearest Surface Water and Direction 2,000 feet downgradient >1,000 feet >1,000 feet >1,000 feet Property Owner Willing to Accept a Land Use Restriction? Yes Not applicable Yes Not applicable Groundwater-Specific Criteria
- 82. Constituent Historic Site Maximum (µg/L) Current Site Maximum (µg/L) LTCP Class 2 Criteria (µg/L) LTCP Class 3 Criteria (µg/L) LTCP Class 4 Criteria (µg/L) Benzene 39,000 990 3,000 No criteria 1,000 MTBE 47,900 1,100 1,000 No criteria 1,000 TBA 29,000 2,4000 No criteria No criteria No criteria Groundwater Concentrations
- 83. ∗ If top 10 feet clean should this be done? ∗ Nearby sites are commercial. ∗ GW is 16 – 24 feet deep. ∗ Are there threats to nearby sites? Vapor-Specific Criteria
- 84. Constituent Residential Commercial/Industrial Utility Worker 0 to 5 feet bgs (mg/kg) Volatilization to outdoor air (5 to 10 feet bgs) mg/kg 0 to 5 feet bgs (mg/kg) Volatilization to outdoor air (5 to 10 feet bgs) mg/kg 0 to 10 feet bgs (mg/kg) Site Maximum Benzene 0.002 < 0.005 <0.002 <0.005 <0.005 LTCP Criteria Benzene ≤1.9 ≤2.8 ≤8.2 ≤12 ≤14 Site Maximum Ethylbenzene 0.137 0.137 0.137 0.137 0.137 LTCP Criteria Ethylbenzene ≤21 ≤32 ≤89 ≤134 ≤314 Site Maximum Naphthalene ---- ---- ---- ---- ---- LTCP Criteria Naphthalene ≤9.7 ≤9.7 ≤45 ≤45 ≤219 Direct Contact and Volatilization to Outdoor Air
- 85. ∗ Does it meet general criteria? ∗ Does it meet scenarios 2, 3, and 4 of groundwater criteria? ∗ Should SVE now be conducted? ∗ Can site be closed after one more similar GWM result? Summary of LTCP Criteria for Voting
- 86. ∗ What about variations in groundwater concentrations? ∗ What about TBA in groundwater at concentrations up to 35,000 µg/L? ∗ TPH mass remaining (estimated 17,600 pounds) ∗ Shallow soil contamination with concentrations that exceed LTCP Table 1 and no naphthalene data Do Any of These Conditions Change Your Vote?
- 89. ∗ Urban site ∗ Active retail truck stop ∗ Gasoline and diesel ∗ Multiple releases from tank pit and piping Time to Play “Would You Close That Site”
- 90. A P A R T M E N T S RESTAURANT AND PARKING LOTRESTAURANT AND PARKING LOT RAILROADRAILROAD Dispensers BUILDING TANK PIT Truck Stop Site Plan
- 91. ∗ Depth to groundwater 2 to 6 feet bgs ∗ Groundwater not used in area of site for water supply ∗ Free product removal until 2006; no free product currently ∗ Overexcavation in tank pit area and scale (2,644 cy) ∗ In-situ Remediation but likely not effective Example LOP/UST Site
- 92. A P A R T M E N T S RESTAURANT AND PARKING LOTRESTAURANT AND PARKING LOT RAILROADRAILROAD Dispensers BUILDING TANK PIT TPHg In Groundwater EW
- 93. East-West Cross Section TPHg In Soil
- 94. A P A R T M E N T S RESTAURANT AND PARKING LOTRESTAURANT AND PARKING LOT RAILROADRAILROAD Dispensers BUILDING TANK PIT Benzene In Groundwater 500 µg/L
- 95. A P A R T M E N T S RESTAURANT AND PARKING LOTRESTAURANT AND PARKING LOT RAILROADRAILROAD Dispensers BUILDING TANK PIT MTBE in Groundwater 500 µg/L
- 96. A P A R T M E N T S RESTAURANT AND PARKING LOTRESTAURANT AND PARKING LOT RAILROADRAILROAD Dispensers BUILDING TANK PIT TBA in Groundwater
- 97. ∗ Within service area of a public water system ∗ Consists only of petroleum ∗ Currently no free product ∗ Primary release has been stopped ∗ Conceptual site model was developed ∗ Secondary source removal ∗ Soil and groundwater tested for MTBE ∗ No nuisance conditions General LTCP Criteria
- 98. Site Data LTCP Class 1 Criteria (µg/L) LTCP Class 2 Criteria (µg/L) LTCP Class 3 Criteria (µg/L) LTCP Class 4 Criteria (µg/L) Plume Length Approximately 200 feet from source to edge of plume <100 feet <250 feet <250 feet <1,000 feet Free Product Currently no free product No free product No free product Removed to maximum extent practicable No free product Plume Stable or Decreasing Appears to be decreasing over long term but sporadic increases observed. Stable or decreasing Stable or decreasing Stable or decreasing for minimum of 5 Years Stable or decreasing Distance to Nearest Water Supply Well >1,000 feet >250 feet >1,000 feet >1,000 feet >1,000 feet Distance to Nearest Surface Water and Direction 2,000 feet downgradient >250 feet >1,000 feet >1,000 feet >1,000 feet Property Owner Willing to Accept a Land Use Restriction? Yes Not applicable Not applicable Yes Not applicable Groundwater-Specific Criteria
- 99. Site Data LTCP Class 2 Criteria (µg/L) LTCP Class 3 Criteria (µg/L) LTCP Class 4 Criteria (µg/L) Plume Length Approximately 200 feet from source to edge of plume <250 feet <250 feet <1,000 feet Free Product Currently no free product No free product Removed to maximum extent practicable No free product Plume Stable or Decreasing Appears to be decreasing over long term but sporadic increases observed Stable or decreasing Stable or decreasing for minimum of 5 Years Stable or decreasing Distance to Nearest Water Supply Well >1,000 feet >1,000 feet >1,000 feet >1,000 feet Distance to Nearest Surface Water and Direction 2,000 feet downgradient >1,000 feet >1,000 feet >1,000 feet Property Owner Willing to Accept a Land Use Restriction? Yes Not applicable Yes Not applicable Groundwater-Specific Criteria
- 100. Constituent Historic Site Maximum (µg/L) Current Site Maximum (µg/L) LTCP Class 2 Criteria (µg/L) LTCP Class 3 Criteria (µg/L) LTCP Class 4 Criteria (µg/L) Benzene 77,000 740 3,000 No criteria 1,000 MTBE 920,000 530 1,000 No criteria 1,000 TBA 310,000 35,000 No criteria No criteria No criteria Groundwater Concentrations
- 101. ∗ Not required for active service stations ∗ No threat to nearby sites Vapor-Specific Criteria
- 102. Constituent Residential Commercial/Industrial Utility Worker 0 to 5 feet bgs (mg/kg) Volatilization to outdoor air (5 to 10 feet bgs) mg/kg 0 to 5 feet bgs (mg/kg) Volatilization to outdoor air (5 to 10 feet bgs) mg/kg 0 to 10 feet bgs (mg/kg) Site Maximum Benzene 3.5 200 3.5 200 200 LTCP Criteria Benzene ≤1.9 ≤2.8 ≤8.2 ≤12 ≤14 Site Maximum Ethylbenzene 9.4 160 9.4 160 160 LTCP Criteria Ethylbenzene ≤21 ≤32 ≤89 ≤134 ≤314 Site Maximum Naphthalene ---- ---- ---- ---- ---- LTCP Criteria Naphthalene ≤9.7 ≤9.7 ≤45 ≤45 ≤219 Direct Contact and Volatilization to Outdoor Air
- 103. ∗ Maximum site concentrations less than Table 1 concentrations ∗ Maximum concentrations less than levels from site-specific risk assessment ∗ As a result of controlling exposure through use of mitigation measures or institutional or engineering controls, regulatory agency determines that petroleum constituents in soil will have no significant risk of adversely affecting human health Three Ways to Meet Direct Contact and Volatilization to Outdoor Air Criteria
- 104. ∗ Does it meet general criteria? ∗ Does it meet scenarios 2, 3, and 4 of groundwater criteria? ∗ Exempt from vapor criteria ∗ Could site meet direct contact criteria with land use controls? Summary of LTCP Criteria for Voting
- 105. ∗ What about variations in groundwater concentrations? ∗ What about TBA in groundwater at concentrations up to 35,000 µg/L? ∗ TPH mass remaining (estimated 17,600 pounds) ∗ Shallow soil contamination with concentrations that exceed LTCP Table 1 and no naphthalene data Do Any of These Conditions Change Your Vote?
- 106. QUESTIONS/DISCUSSION
Editor's Notes
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