Ohio EPA Issues Guidance for Response Action Levels and Timeframes at Vapor Intrusion Sites In August 2016, Ohio EPA’s Division of Environmental Response and Revitalization (DERR) released guidance specifically for sites with a potentially complete pathway for trichloroethene (TCE) concentrations in the groundwater or sub-slab vapors to migrate to indoor air and where sensitive receptors (i.e., women of childbearing age) may be exposed. Background June 2015, the U.S. EPA’s Office of Solid Waste and Emergency Response (OSWER) issued final guidance for the evaluation of vapor intrusion (VI) to indoor air (U.S. EPA VI guidance). The U.S. EPA VI guidance is similar to Ohio’s 2010 VI guidance1 with emphasis on multiple-lines of evidence to evaluate whether the VI pathway is complete. However, while Ohio’s 2010 VI guidance includes use of mathematical models for evaluating the VI pathway (e.g., J&E models), while U.S. EPA refers to the Vapor Intrusion Screening Level Calculator (VISL) as a primary screening method. If concentrations exceed screening levels, further action (sampling or mitigation) is emphasized. In May 24, 2016, Ohio’s Division of Environmental Response and Revitalization (DERR) rescinded parts of its 2010 VI guidance and currently recommends the use of the VISL when evaluating sites in Ohio. DERR further evaluated the VI pathway leading to the recent release of the August 2016 updated guidance. Guidance Details The August 2016 Ohio EPA Guidance (“Guidance Document for Common Contaminants of Concern at Vapor Intrusion Sites in Ohio”) establishes action levels (ALs) for concentrations of common chemicals encountered during VI investigations, emphasizes the need for expedited timeframes for assessing VI risks, and outlines updated investigation and response actions for the VI pathway. DERR indicated that ALs and expedited time frames for TCE are particularly aggressive due to the potential for cardiac malformations in developing fetuses as a result of short term exposures. The response times and ALs established for TCE concentrations in indoor air, sub-slab soil gas, or groundwater as listed below. 1 Sample Collection and Evaluation of Vapor Intrusion to Indoor Air for Remedial Response and Voluntary Action Programs” (May 2010) www.trcsolutions.com Accelerated Response AL Urgent Response AL Imminent Hazard Response AL Indoor Air (ug/m3) Residential Commercial > 2.1 > 8.8 > 6.3 > 26 > 20 > 60 Subslab/Soil Gas (ug/m3) Residential Commercial > 70 > 290 Residential > 11 to > 21 Commercial > 44 to > 89 > 210 > 880 Groundwater (ug/L) > 32 to > 63 > 130 to > 270 na na na na Response actions may include sampling, mitigation, or receptor relocation. In all cases, the appropriate state, local, and health authorities should be notified. The accelerated timeframe for required action ranges from immediate to within a few weeks. Accelerated Response Action Level: Early or interim response measures evaluated and implemented within a few weeks. Urgent Response Action Level: Early or interim response measures evaluated and implemented within a few days. Imminent Hazard Response Action Level: Relocate receptors until post-remedy indoor air are demonstrated below the accelerated response action levels. For other chemicals of concern, action within days or weeks may not be warranted for concentrations exceeding chronic response action levels. However, response actions may be accelerated beyond typical remedial action. Next Steps Although this guidance does not have the force of law, Ohio EPA recommends its use to stakeholders, including the Voluntary Action Program (VAP), in evaluating the concentrations of volatile compounds in ground water, soil gas, or indoor air for residential and commercial scenarios. As a result of this revised guidance, projects should re-evaluate the vapor intrusion pathway to ensure on and off-property receptors are not at risk from the vapor intrusion pathway. Projects currently under review may be re-evaluated against these changes in guidance and closed TCE sites that used modeling only are being re-opened. www.trcsolutions.com How Can TRC Help? TRC’s professionals have been assessing issues related to vapor intrusion into indoor air since the early 1980s. TRC’s experience includes the following: • • • • • • • Developing a conceptual site model (source identification and exposure pathway evaluations) Site screening and modeling Soil vapor, sub-slab, and indoor air testing Vapor intrusion risk assessment Vapor intrusion mitigation design Remedy implementation Coordination with USEPA and Ohio EPA TRC utilizes its expertise from decades of contamination investigation and remediation experience, along with our knowledge of industrial sites and processes, to identify and characterize the sources, investigate exposure potential pathways (including preferential pathways) to the constituents of concern (COCs), and develop riskbased VI mitigation and remediation solutions. Contact Us For more information, please contact: Kathleen Teuscher Senior Project Manager/Risk Assessor 216-505-8189 [email protected] Don Fay, PG Vice President, Ohio VAP Certified Professional 513-489-2255 [email protected] Dave Kreeger, PG Project Manager, Ohio VAP Certified Professional 614- 423.6359 [email protected] www.trcsolutions.com
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