A&WMA Regulatory Conference Symposium UST Risk Based Corrective Action April 2019 UST Management Program

USTMP management Lon Revall, Program Manager lon.revall@dnr.ga.gov 404.362.2582 Regulatory Compliance Unit I Shaheer Muhanna shaheer.muhanna@dnr.ga.gov 404.362.2579 Corrective Action Unit I Kelly Adams kelly.adams@dnr.ga.gov 404.362.4526 Regulatory Compliance Unit II Karlene Freeman karlene.freeman@dnr.ga.gov 404.362. 2576 Corrective Action Unit II Jay Kemberling jay.kemberling@dnr.ga.gov 404.362.2577 Enforcement/ATR Unit Vacant 404.362.2635

Georgia RBCA Workbook 1.0 Workbook 2.0 will be available by June 2019! The workbook is available now. https://epd.georgia.gov/underground-storage-tank-technical-guidance Workbook 2.0 will be available by June 2019!

Workbook Purpose Provide a consistent framework for identifying receptors, assessing and remediating contamination. Comprehensive- Identifies inhalation, ingestion and direct exposure pathways and receptors with a suite of petroleum chemicals of concern based on the release. Flexible- Can be applied to sites at any stage of investigation and any age of release with fairly limited data and can be applied at the point of release or at an off-site contaminant plume. Usable- Entering data should be easy.

Comprehensive: Chemicals of concern Selecting the petroleum product released determines the chemicals of concern that will be evaluated.

Comprehensive: Receptors and site characteristics Recognizes the risk of petroleum vapor intrusion and requires identification of structures that are potentially threatened. The critical distance is 500 feet from the point of highest contamination or release point if known. Are there residences? Basements? What are the soil types? How deep is water?

Flexible Can be used with limited data. The analytical information collected at a closure can be enough if receptors are identified. As usual, more data provides a clearer picture and increases the validity of the site conceptual model. Provides Alternate Concentration and Threshold Levels and lets the user know which exposure pathways are most threatened.

Usable Version 1.0 concentrated on making sure the science was in place behind the scenes. Creating the engine was the difficult part. Version 2.0 concentrates on making data easier to input and clearing up confusing entry locations. The UST program is dedicated to improvement and accepts all feedback. Updates to chemicals of concern and concentrations will be discussed annually with the EPD Land Branch Risk Assessment Unit.

Selected References Tennessee Division of Underground Storage Tanks, Technical Guidance Document - 017, Risk-Based Procedure to Determine Clean-up Levels – Exposure Assessment Report Preparation, https://www.tn.gov/environment/program-areas/ust-underground- storage-tanks/ust/ust-forms-guidance.html Revised: September 1, 2006; Risk Analysis Report (workbook), Revised: April 1, 2007 USEPA, Region 4 Human Health Risk Assessment Supplemental Guidance (Draft Final), https://www.epa.gov/sites/production/files/2015- 09/documents/region_4_hhraguidedoc011014.pdf January 2014 Verginelli, J, Capobianco, O. and Baciocchi, R, Role of the source to building lateral separation distance in petroleum vapor intrusion, Journal of Contaminant Hydrogeology 189, Pages 58-67, April 2016 ITRC PVI Guidance, Petroleum Vapor Intrusion, Fundamentals of Screening, Investigation and Management, http://itrcweb.org/PetroleumVI-Guidance/ October 2014

Comments and Questions? We welcome your feedback! Jay Kemberling Jay.Kemberling@dnr.ga.gov Telephone: 404-362-2577 Steven Wilson steven.wilson@dnr.ga.gov Telephone: 404-362-4528