Draft EPA External Review Document. Do not cite or quote. v>EPA United States Environmental Protection Agency EPA 510-R-13-xxx This document is an EPA External Review draft. This information is distributed solely for the purpose of pre-dissemination public review. It does not represent an interim or final Agency determination or policy. Do not cite or quote. Guidance For Addressing Petroleum Vapor Intrusion At Leaking Underground Storage Tank Sites U.S. Environmental Protection Agency Office of Solid Waste and Emergency Response Office of Underground Storage Tanks Washington, D.C. April 2013 1 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** Contents Purpose 7 Background 7 Overview 8 EPA Recommended Actions 8 Supporting Technical Information 13 1. Petroleum Vapor Intrusion (PVI) 14 2. Typical PVI Scenarios 31 3. Site Characterization And Conceptual Site Model (CSM) 37 4. Lateral Inclusion Zone 41 5. Vertical Separation Distance 44 6. Mobile And Residual Light Non-Aqueous Phase Liquid (LNAPL) 51 7. Groundwater Flow And Dissolved Contaminant Plumes 55 8. Soil Vapor Profile 59 9. Clean, Biologically Active Soil 65 10. Contaminants Other Than PHCs 70 11. Seasonal And Weather Effects 76 12. Vapor Intrusion Attenuation Factor (a) 80 13. Computer Modeling Of Petroleum Vapor Intrusion 84 Glossary 93 Page 2 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** Tables 1. Components of A PVI Investigation 11 2. Summary Of Characteristics Of Typical Scenarios Of Petroleum Vapor Sources And Potential Receptors 34 3. Required Vertical Separation Distance Between Contamination And Building Foundation, Basement, or Slab 48 Page 3 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** Figures 1. Flowchart Of the Receptor-Specific PVI Assessment And Mitigation Process 12 2. Conceptual Model Of Typical Petroleum Hydrocarbon Release 15 3. Difference In Potential For PVI Based On Type Of Source: a) LNAPL b) Dissolved Phase 32 4. Typical Scenarios Of Potential PVI Sources And Potential Receptors 33 5. Lateral And Vertical Separation Distances Between Source Of PHC Contaminants And Hypothetical Receptor 42 6. Vertical Separation Distances Between Source Of PHC Contaminants And Hypothetical Receptor: (a) Dissolved Source, (b) LNAPL Source 45 7. Conceptual Model Illustrating The Potential For Vapor Intrusion for a) Free-Phase LNAPL Source, b) Residual-Phase LNAPL Source, and c) Dissolved-Phase Source 53 8. Typical Vertical Concentration Profile In The Unsaturated Zone For PHCs, Carbon Dioxide, And Oxygen 60 9. Relationship Between Source Vapor Concentration And Vapor Intrusion Attenuation Factor (a) As A Function Of Vertical Separation Depth Between Contaminant Source And Base Of Building (Receptor) 81 Page 4 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** List Of Acronyms 1,2-DCA 1,2-Dichloroethane BTEX Benzene, toluene, ethylbenzene, xylenes (there are three isomers of xylene) CFR Code of Federal Regulations CSM Conceptual Site Model EDB Ethylene dibromide (also known as 1,1-dibromoethane) ICLR Incremental lifetime cancer risk ITRC Interstate Technology & Regulatory Council JEM Johnson-Ettinger Model LNAPL Light Non-Aqueous Phase Liquid MTBE Methyl tertiary-butyl ether NAPL Non-Aqueous Phase Liquid OIG Office of Inspector General OSWER Office of Solid Waste and Emergency Response OUST Office of Underground Storage Tanks PHC Petroleum Hydrocarbon PVI Petroleum Vapor Intrusion RBCV Risk-based soil vapor concentration TAME Tertiary-amyl methyl ether TBA Tertiary butyl alcohol TEL Tetraethyl lead TML Tetramethyl lead TPH Total Petroleum Hydrocarbons UST Underground Storage Tank VI Vapor Intrusion VOC Volatile Organic Compound Page 5 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** Notice: This document provides guidance to EPA, state, and tribal staff. It also provides guidance to the public and to the regulated community on how EPA intends to exercise its discretion in implementing its regulations as a matter of national policy. The document does not, however, substitute for EPA's statutes or regulations, nor is it a regulation itself. Thus, it does not impose legally- binding requirements on EPA, states, tribes, or the regulated community. This document presents technical information on the phenomenon of petroleum vapor intrusion. EPA may revise this document without public notice. Page 6 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** Purpose This document provides guidance to EPA, states,1 and tribes2 for investigating and assessing petroleum contaminated3 sites where vapor intrusion4 by petroleum hydrocarbons (PHCs) may occur. In this document, intrusion of PHC vapors is referred to as petroleum vapor intrusion (PVI). This PVI guidance focuses on underground storage tanks (USTs), typically located at gas stations and non-marketing facilities regulated under Subtitle I of the Solid Waste Disposal Act.5 Background In November 2002, EPA's Office of Solid Waste and Emergency Response (OSWER) issued draft vapor intrusion guidance, OSWER Draft Guidance for Evaluating the Vapor Intrusion to Indoor Air Pathway from Groundwater and Soils (Draft Vapor Intrusion Guidance) (EPA, 2002). This draft guidance did not address PVI at UST sites regulated under Subtitle I. In 2009, EPA's Office of Inspector General (OIG) released an evaluation report, Lack of Final Guidance on Vapor Intrusion Impedes Efforts to Address Indoor Air Risks (Report No. 10-P- 0042). One of its recommendations is that EPA issue final PVI guidance on how to address risks from petroleum hydrocarbon vapors. In response to OIG's recommendation, EPA is issuing this document: Guidance For Addressing Petroleum Vapor Intrusion At Leaking Underground Storage Tank Sites. In addition, in response to other recommendations in the OIG's evaluation report, EPA is issuing OSWER Final Guidance For Assessing and Mitigating the Vapor Intrusion Pathway From Subsurface Sources to Indoor Air. 1 States refers to states, territories, and the District of Columbia. 2 While this guidance is being provided to tribal governments, EPA by law cannot delegate implementation authority for the UST program, including the corrective action components, to tribal governments. Some tribal governments that carry out corrective action activities under their own regulations may find this guidance useful. 3 For the purposes of the federal UST program, as described under the definition of regulated substance in 40 CFR 280.12, the term petroleum includes "crude oil or any fraction thereof that is liquid at standard conditions of temperature and pressure (60 degrees Fahrenheit and 14.7 pounds per square inch absolute). The term regulated substance includes but is not limited to petroleum and petroleum-based substances comprised of a complex blend of hydrocarbons derived from crude oil through processes of separation, conversion, upgrading, and finishing, such as motor fuels, jet fuels, distillate fuel oils, residual fuel oils, lubricants, petroleum solvents, and used oils." This definition is subject to change if the regulations are revised in the future. 4 Vapor intrusion (VI) is the general term given to migration of hazardous vapors from any subsurface contaminant source, such as contaminated soil or groundwater, through the vadose zone and into indoor air. 5 Non-Subtitle I releases of petroleum (e.g., oil/petroleum releases from terminals and refineries, above ground storage tanks, pipelines), should be assessed and addressed under the OSWER Final Guidance for Assessing and Mitigating the Vapor Intrusion Pathway From Subsurface Sources To Indoor Air. For more information on VI see EPA's Vapor Intrusion website at htto://www.eDo.aov/oswer/vaDorintrusion/. The PVI guidance may, however, be useful in informing decisions at petroleum-only brownfield sites that are similar to a typical Subtitle I release. Page 7 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** Overview PVI is a concern when PHCs emanate from petroleum-contaminated soil or groundwater and migrate into buildings. This can result in indoor air concentrations that pose a risk to building occupants. PVI may pose both immediate threats to safety (e.g., fire/explosion potential from petroleum vapors or methane) and possible adverse health effects from inhalation of toxic chemicals (e.g., exposure to benzene from gasoline). PVI may be associated with three classes of chemicals: • PHCs found in gasoline, diesel, and jet fuel (e.g., benzene, trimethylbenzenes). • Vapor-forming chemicals other than PHCs that may be found in petroleum (e.g., methyl tertiary-butyl ether (MTBE) and other fuel additives). • Methane, which can arise from anaerobic biodegradation of PHCs and other constituents of petroleum fuels, especially ethanol. PHCs can biodegrade aerobically and when biodegradation is complete, produce water and carbon dioxide. Some petroleum hydrocarbons may also degrade anaerobically, which is slower and may produce methane, particularly if the source is from an ethanol-blended gasoline. The potential for human exposure from PVI may be limited because of the biodegradability of PHCs. However, numerous factors may affect the vapor intrusion pathway and potentially impact human health and the environment. These factors are identified and discussed in greater detail in the Supporting Technical Information section of this guidance. EPA Recommended Actions Assessing the potential for PVI is an integral part of the normal response to a suspected or confirmed release from a regulated UST system. At any leaking UST site, it is important to have a thorough understanding of the release (i.e., source, composition, and magnitude) and other factors that may influence the distribution and transport of contaminants and impact human safety and health. EPA's Office of Underground Storage Tanks (OUST) recommends the following actions for situations in which EPA, states, and tribes are either undertaking PVI investigations and corrective action at leaking UST sites or where 40 CFR 280 requires6 UST owners and operators to undertake release investigation and corrective action activities: • Assess and mitigate immediate threats to safety Determine if residents of nearby buildings reported the presence of odors or visible signs of PHC contamination. If so, alert first responders so that they can evacuate these 6 In the case of a suspected or confirmed release from a regulated UST system, Subparts E and F of 40 CFR 280 requires owners and operators to investigate, report, and perform corrective action (including recovery of light non-aqueous phase liquid (LNAPL) to the maximum extent practicable) if contamination is present and submit timely reports of activities and findings to the implementing agency. Page 8 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** buildings until the potential threat to human safety from fire or explosion due to PVI has been assessed and mitigated as necessary. • Conduct a site characterization and develop a conceptual site model (CSM) Integrate all information and data related to the site into a CSM. This includes assessment of the potential for biodegradation of the PHCs. The CSM should then be used as the basis for planning the PVI investigation and making informed risk management decisions about the site and the threat posed by PVI to nearby receptors. To determine whether the vadose zone is comprised of clean soil and capable of supporting microbial populations that facilitate aerobic biodegradation of PHCs, EPA recommends that the site characterization include: o A determination of the full extent and location of contamination, o The nature and characteristics of the contamination. o The hydrologic (e.g., soil moisture) and geological characteristics underneath and near buildings in the lateral inclusion zone. • Delineate a lateral inclusion zone Assess the potential for PVI for each of the buildings within the lateral inclusion zone. The lateral inclusion zone is based on the spacing between clean monitoring points; the closer the spacing of the clean monitoring points, the less extensive the lateral inclusion zone. • Identify preferential transport pathways within the inclusion zone Assess whether preferential contaminant transport pathways are present and could result in PVI into nearby buildings either inside or outside the lateral inclusion zone. If so, assess the potential for PVI. • Determine vertical separation distances for each building within the inclusion zone Determine whether contamination underlies any buildings within the lateral inclusion zone. If contaminated groundwater is within the vertical separation distance (6 feet) between the contamination and the foundation, slab, or basement of any building(s), EPA recommends sub-slab vapor sampling to assess the potential for PVI. If light non- aqueous phase liquid (LNAPL) is within 15 feet of an overlying building, EPA recommends sub-slab vapor sampling. • Mitigate PVI, as appropriate Select a remedial design that is appropriate for the building and site. As necessary, establish institutional controls to limit or prohibit access to affected areas. Remediate the source of the contamination, including recovery of LNAPL (if present) to the maximum extent practicable. Table 1 and Figure 1 briefly outline the recommended actions above. Note that this process is not necessarily linear and some of these activities may occur in a different order or recur throughout the PVI investigation. Additional technical information is presented in the second part of this guidance, Supporting Technical Information. Page 9 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** Community Engagement As you are conducting your assessment and follow-up actions, keep in mind the importance of community engagement. EPA acknowledges there are various ways to engage the community in cleanup decisions and it is not a one-size-fits-all approach. However, it is generally recognized that earlier and more frequent communication yields positive results, particularly for sites that pose a threat to human health or the environment, or when the public expresses an elevated level of concern or interest in the site. Depending on site circumstances, obtaining meaningful community input is a sound approach that may result in better-informed decisions. EPA developed several community engagement resources, which are available on OUST's website: • Community Engagement And The Underground Storage Tank Program. • Guidelines For Tailoring Community Engagement Activities To Circumstances At Leaking Underground Storage Tank Sites. • Community Engagement Resources (Toolbox) For Underground Storage Tank Programs. Page 10 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** Table 1. Components Of A PVI Investigation Recommended Actions Purpose Characteristics/Indicators Procedures Assess and mitigate immediate threats to safety Identifies potential threat of explosion or fire due to petroleum vapors or methane LNAPL visible in building, possibly as sheen Petroleum odor, headache, dizziness, or nausea Potential disagreeable taste of water Methane is odorless and cannot be detected on the basis of odor Investigate all reports of petroleum odors and other indicators within buildings Assess for presence of methane; requires specialized detectors Alert first responders so that they can evacuate building inhabitants until the potential for fire or explosion has been assessed and mitigated as necessary Conduct a site characterization and develop a CSM Determines spatial and temporal relationship between receptors and sources of contamination Determines full extent and location of contamination and its nature and potential for biodegradation of PHCs Defines hydrologic and geologic characteristics of the site Identifies potential receptors Collect sufficient site data and information to construct CSM Identify data gaps Update CSM as new data become available Delineate a lateral inclusion zone Focuses investigation on potential receptors in close proximity to contamination • Based on quality of CSM • The lower the uncertainty, the smaller the lateral inclusion zone • Construct lateral inclusion zone based on distance between clean monitoring points Identify preferential transport pathways Determines rate of movement of contaminants toward potential receptors Includes both natural (i.e., geologic) and man-made (i.e., underground utilities, excavations) features Difficult to detect and map potential preferential transport pathways Determine if presence is likely and locate extent as practicable Exercise caution if presence is known or possible Consider additional sampling to assess transport characteristics Determine vertical separation distances Narrows investigation to potential receptors overlying contamination • Thickness of clean, biologically active soil separating contamination and potential receptors Collect sub-slab vapor samples if (a) contaminated groundwater is within 6 feet of an overlying building or (b) LNAPL is within 15 feet of an overlying building Mitigate PVI as appropriate Interrupts the pathway between the source of contamination and potential receptors Numerous approaches depending on building characteristics Select a remedial design that is appropriate for building and site Establish institutional controls to limit or prohibit access to affected areas of building, as necessary Remediate source of contamination, including recovery of LNAPL (if present) to the maximum extent practicable Page 11 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** Figure 1. Flowchart Of The Receptor-Specific PVI Assessment And Mitigation Process Page 12 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** Supporting Technical Information The following sections provide technical information in support of EPA's recommended actions as outlined in Table 1. Each section presents information in a standardized format, which is easy to follow and allows for future revisions, if necessary. Additional sources of information may be found in the Petroleum Vapor Intrusion Compendium (http://www.epa.eov/oust/cat/pvi/). located on the Office of Underground Storage Tanks (OUST) website (http://www.epa.eov/oust). Page 1. Petroleum Vapor Intrusion (PVI) 14 2. Typical PVI Scenarios 31 3. Site Characterization And Conceptual Site Model (CSM) 37 4. Lateral Inclusion Zone 41 5. Vertical Separation Distance 44 6. Mobile And Residual Light Non-Aqueous Phase Liquid (LNAPL) 51 7. Groundwater Flow And Dissolved Contaminant Plumes 55 8. Soil Vapor Profile 59 9. Clean, Biologically Active Soil 65 10. Contaminants Other Than PHCs 70 11. Seasonal And Weather Effects 76 12. Vapor Intrusion Attenuation Factor (a) 80 13. Computer Modeling Of Petroleum Vapor Intrusion 84 Page 13 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** 1. Petroleum Vapor Intrusion (PVI) Description Petroleum vapor intrusion (PVI) occurs when vapors from petroleum hydrocarbons (PHCs) migrate into buildings. Fuels such as gasoline, diesel, aviation gasoline, and jet fuel are comprised primarily of PHCs with some non-petroleum based additives.7 Under certain circumstances, PVI may result in indoor air concentrations that pose a risk to building occupants. PVI may pose immediate threats to safety (e.g., fire/explosion potential from petroleum vapors or methane) and/or possible adverse health effects from inhalation of toxic chemicals (e.g., exposure to benzene from gasoline). Vapor concentrations generally decrease with increasing distance from a subsurface vapor source, and eventually at some distance the concentrations become negligible. When petroleum fuels are released into the subsurface from a leaking underground storage tank (UST), PHCs may partition into several phases: • Globules of light non-aqueous phase liquid (LNAPL) trapped within soil pore spaces (i.e., residual LNAPL).8 • Dissolved in soil moisture. • Adhered onto the surface of, or absorbed into, soil solids. • Vapors in soil. Phase Partitioning If the volume of a fuel release is sufficient, the fuel may accumulate on the capillary fringe as mobile LNAPL that may accumulate in monitoring wells. The mobile LNAPL may spread laterally in the direction of groundwater flow. Temporal fluctuations in the elevation of the water table typically create a vertical smear zone of residual LNAPL contamination both above and below the average water table elevation. Some of the LNAPL dissolves into the groundwater and is transported down gradient by flowing groundwater as an aqueous phase. PHCs in the residual phase (both above and below the water table), the mobile phase (i.e., free product, LNAPL plume), and the dissolved phase (i.e., contaminant plume) all can serve as sources of PHC vapors. Figure 2 illustrates the typical distribution of petroleum fuels in the subsurface resulting from a leaking UST. See Section 2 for a more detailed discussion of typical PVI scenarios. 7 PHCs present in gasoline belong to one of four major groups: paraffins, olefins, naphthenes, or aromatics. The aromatic PHCs benzene, toluene, ethylbenzene, and the three isomers of xylene are collectively referred to as BTEX. Although BTEX represent the group of PHCs that receive the most attention at typical leaking UST sites, they are not the only compounds that may pose a risk to human health. Additives such as methyl tertiary-butyl ether (MTBE) and tertiary-butyl alcohol (TBA), plus other PHCs (e.g., naphthalene), may be risk-drivers instead of, or in addition to, BTEX and/or other PHCs. 8 Mobile LNAPL is often referred to as "free product", especially in older documents including 40CFR280. Page 14 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** LNAPL {including smear zone/Residual k and Free-Phase) VaporPhase Dissolved-Phase VadoseZone MDxygen^ Transport Oxygen Transport Aerobic i, ~ -Biodegradation W Zone / Water ^ Table F3 Saturated Zone GROUNDWATER FLOW Figure 2. Conceptual Model Of Typical Petroleum Hydrocarbon Release Aerobic biodegradation of PHCs along the perimeter of the vapor and dissolved plumes may limit the spread of subsurface contamination. Effective oxygen transport (dashed arrows) maintains aerobic conditions in the biodegradation zone. Petroleum LNAPL collects at the capillary fringe between the saturated and unsaturated zones (EPA, 2012). Vapor Migration Vapor migration results from two processes: • Diffusion • Advection Diffusion is the process whereby net transport of vapors from a source area of higher concentration (e.g., LNAPL, residual LNAPL, or dissolved plume) to an area of lower concentration occurs as a result of random molecular motion. Diffusion can also lead to chemical migration into buildings directly through a dirt floor or crawlspace, or through openings in the building slab and foundation such as passages for utility lines and sumps. Also, intact concrete has appreciable permeability to gas movement (Kobayashi and Shuttoh, 1991; Sanjuan and Munoz-Martialay, 1996; and Tittarelli, 2009) and the permeability increases substantially when cracks are present (Daoud and Renken, 1999; EPA, 1995). Page 15 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** Advection refers to the movement of soil gas in response to pressure gradients. Advection can be an important mechanism for drawing soil gas and contaminant vapors into or out of (beneath) a building. Heating and cooling systems can create differential pressures inside the building. On the one hand, when the pressure inside the building is lower than the pressure in the subsurface, vapors are drawn into the building. On the other hand, when the pressure inside the building is greater than the pressure in the subsurface, air within the building may be forced into the subsurface causing some degree of reoxygenation. Wind or changes in barometric pressure may also drive advective transport of oxygen into the subsurface beneath the building (Lundegard, Johnson, and Dahlen, 2008; Patterson and Davis, 2009; McHugh, DeBlanc, and Pokluda, 2006; Luo and Johnson, 2011; and Robinson, Sextro, and Riley, 1997; Luo, et al., 2009; and Hong, Holton, and Johnson, 2012). Biodegradation Of PHCs Biodegradation of PHCs is recognized as one of the primary mechanisms by which petroleum and other hydrocarbon pollutants are removed from the environment (Baedecker, Cozzarelli, and Hoppel, 1987; Leahy and Colwell, 1990). Microorganisms that degrade PHCs are widely distributed in the environment and most are recognized as having some ability to metabolize hydrocarbons (Gale, 1951; Ward, Singh, and Van Hamme, 2003; Prince, 2010). Although most microbes only degrade a narrow range of organic compounds, they typically exist as a mixed consortium that collectively can biodegrade a wide range of organic compounds (Wang and Deshusses, 2006; Suflita and Mormile, 1993; Corseuil, et al., 1998; Moyer, et al., 1996; Boopathy, 2004; Alexander, 1980; Prince, Parkerton, and Lee, 2007; Prince, 2010; and Bekins, et al., 2001). Biodegradation progresses through stages with different microbes being predominant until environmental conditions (e.g., availability of specific hydrocarbons, micronutrients, electron acceptors) become unfavorable for them and different microbes then take over. Thus, aerobic and anaerobic microbes may coexist with one class essentially dormant while the other is active. The biodegradability of PHCs often reduces the potential for human exposure from PVI (McHugh, et al., 2010; EPA, 2012; Interstate Technology & Regulatory Council [ITRC], 2007). The end products of complete biodegradation (mineralization) of PHCs are water and carbon dioxide. Mineralization of PHCs is almost always the consequence of microbial activity (Alexander, 1981). Gasoline and diesel fuel (including biodiesel) may be completely biodegraded under aerobic conditions (Hult, 1987; Prince and Douglas, 2010; Prince, Parkerton, and Lee, 2007; Marchal, et al., 2003), though diesel is somewhat less biodegradable (Marchal, et al., 2003). Aerobic biodegradation is well documented for many individual PHCs and classes of PHCs including: • N-alkanes (Bouchard, et al., 2005; Prince, Parkerton, and Lee, 2007; Bailey, Jobson, and Rogers, 1973; Hult, 1989; Baedecker, et al., 2011). • Branched alkanes (Prince and Douglas, 2010; Prince, Parkerton, and Lee, 2007); cycloalkanes (Bouchard, et al., 2005). Page 16 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** • Aromatics (Wang and Deshusses, 2007; Phelps and Young, 1999; Landmeyer and Bradley, 2003; Lahvis, Baker, and Baehr, 2004; Lahvis, Baehr, and Baker, 1999; Bailey, Jobson, and Rogers, 1973; ZoBell, 1946; Corseuil, et al., 1998; Richnow et al., 2003). • Naphthenes (Prince, Parketon, and Lee, 2007; Bailey, Jobson, and Rogers, 1973; Anderson, et al., 1999; ZoBell, 1946). • Phenols (ZoBell, 1946). • Trimethyl benzenes (Chen, et al., 2009). Though aerobic biodegradation has been studied for over a century, anaerobic biodegradation of PHCs has been recognized only within the past three decades (Widdel, Boetius, and Rabus, 2006; Spormann and Widdel, 2000; and Townsend, et al., 2003). Anaerobic microorganisms degrade PHCs by using an electron acceptor other than oxygen (for example, sulfate, nitrate, ferrous iron, or carbon dioxide). Anaerobic biodegradation is a slower process than aerobic biodegradation (Widdel, Boetius, and Rabus, 2006; Bailey, Jobson, and Rogers, 1973) and anaerobes grow slower than their aerobic counterparts (Widdel, Knittel, and Galushko, 2010). Instead of water and carbon dioxide, anaerobic biodegradation of PHCs can produce methane (Zengler, et al., 1999), especially with a release of an ethanol-blended gasoline (Jewell and Wilson, 2011; Ma, et al., 2012). Anaerobic biodegradation is typically the predominant mechanism of biodegradation in the source zone (Anderson and Lovley, 1997). Additional references documenting anaerobic biodegradation of PHCs are listed under Additional Information at the end of this section. Importance Important factors cited by Lahvis and Baehr (1996) and Suarez and Rifai (1999) as being influential for aerobic biodegradation of PHC vapors include: • Vapor source hydrocarbon concentration, flux, and composition (including methane). • Oxygen demand (i.e., the oxygen required to biodegrade the available hydrocarbons and any other organic matter present) and oxygen availability. • Soil type and properties (including texture and moisture content). • Availability of essential micronutrients. • Temperature • pH Additional factors cited by EPA (2012) as influencing the potential for PVI include: • Size and characteristics of the building and adjacent land surface. • Distance between the vapor source and the building. Assessment An assessment of the potential for PVI is not an isolated activity, but rather an integral part of the normal response to a suspected or confirmed release of PHCs from a regulated UST site. At Page 17 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** any leaking UST site (including abandoned sites or those that will be redeveloped for other uses), it is important to have a thorough understanding of the nature and magnitude of the release; the physical, biological, and chemical characteristics of the subsurface environment; an understanding of the preferential pathways for contaminant transport; and locations of receptors in the vicinity of the release. Any other phenomena (e.g., climatological conditions) that may influence the transport of contaminants and potentially impact the safety and health of nearby residents should also be investigated. Vapors emanating from dissolved-phase sources are primarily benzene, toluene, ethylbenzene, xylenes (BTEX) and other aromatic hydrocarbons, and relatively water-soluble PHCs. Vapors emanating from LNAPL sources contain the same constituents plus a sizeable fraction of aliphatic and relatively insoluble hydrocarbons, especially if the source is large or unweathered (Lahvis, et al., 2012; EPA, 2012). Analyses of samples collected during site characterization (see Section 3) will provide information on specific contaminants that may warrant assessment for potential vapor intrusion. Special Considerations Several factors may affect the vapor intrusion pathway. They include: biodegradation, chemical transformation, sorption, contaminant source depletion, geologic heterogeneity (including preferential transport pathways), soil properties (moisture content, permeability, organic carbon content), building properties (basements, sumps, cracked slabs), meteorological conditions, and building ventilation rates (Hers, et al., 2003). In particular, the age and volume of release should be determined or estimated. For large volume releases and more recent releases, there is greater potential for PVI because the source is less weathered and therefore contains a higher percentage of more volatile compounds. Newer releases of ethanol-blended gasoline may result in generation of methane. Large volume releases may require a greater separation distance for biodegradation to be effective. Other factors, such as exceptionally dry soils, areas of extensive impervious paving, and the presence of preferential transport pathways, may reduce the potential for biodegradation of PHC vapors and may warrant additional investigative steps (e.g., collection of soil vapor samples). Preferential transport pathways may be either natural (e.g., fractures in rock, solution channels in karst terrain) or man-made (e.g., utility corridors). Because they increase the speed at which the contaminants move through the subsurface, they can potentially short circuit protectiveness that would otherwise be provided by biodegradation of PHCs and other fuel additives in homogeneous soils. Typically, it is difficult to detect and map natural preferential transport pathways, and contamination may present itself in unexpected locations. Local government offices have maps of utility corridors that can provide information on the presence and location of man-made preferential transport pathways. Page 18 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** Recommended Steps For Investigating The Potential For PVI OUST recommends these actions for situations in which EPA, states, and tribes are either undertaking PVI investigations and corrective action at leaking UST sites or where 40 CFR 280 requires9 UST owners and operators to undertake release investigation and corrective action activities: •S Assess and mitigate immediate threats to safety Many releases from UST systems are discovered through noticeable sensory indicators on neighboring properties. Indicators may include sight, smell, taste, or physiological effects (e.g., dizziness, headache, nausea, vomiting, and confusion). The presence of odors does not necessarily correspond to adverse health and/or safety impacts from PVI, as the odors could be the result of indoor vapor sources. However, it is generally prudent to investigate any reports of odors in close proximity to UST systems as the odor threshold for some chemicals exceeds their respective health-based concentrations. PHC odors are a nuisance and may trigger the need for abatement and/or mitigation even if the concentration in indoor air is below acute or chronic health-based levels. In confined spaces, PHC vapors, including methane may pose a threat of fire or explosion and endanger building occupants. Federal regulations (40 CFR 280.61) require that immediate action be taken to prevent any further release of the regulated substance into the environment and that fire, explosion, and vapor hazards be identified and mitigated (Federal Register, 1988). Section 280.64 requires that free product (mobile LNAPL) be recovered to the maximum extent practicable and that records be kept of the volumes recovered. First responders, typically fire department personnel, should be notified if there are reports of either odor from petroleum or the presence of an oily sheen in basement sumps or floors. Building occupants may need to be evacuated until the threat from fire or explosion has been mitigated. Since methane is odorless, EPA recommends that monitoring devices be used if methane is suspected. Conduct a site characterization10 and develop a conceptual site model (CSM) Once the immediate threats to safety have been mitigated (or it is determined that immediate threats do not exist), focus attention on determining whether there is a long-term threat to human health and the environment from intrusion of petroleum vapors. Site characterization and CSM development provides information about the full extent and location of the contamination; the nature and characteristics of the contamination; the characteristics of the site that influence contaminant migration, including the potential for biodegradation of PHCs; 9 In the case of a suspected or confirmed release from a regulated UST system, Subparts E and F of 40 CFR 280 requires owners and operators to investigate, report, and perform corrective action (including recovery of LNAPL to the maximum extent practicable) if contamination is present, and submit timely reports of activities and findings to the implementing agency. iaThe term site characterization is used throughout this document for consistency. The term site characterization is often used interchangeably with site assessment, site evaluation, site investigation, and sometimes site check as they all mean assembling and collecting information and data about a site. Page 19 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** and the locations of receptors. Information derived from the CSM helps ensure that sources, pathways, and receptors throughout the site are considered; this knowledge can lead to selection of the most appropriate sampling locations and techniques. See Section 3 for more information about site characterization and CSMs. S Delineate a lateral inclusion zone Based on the CSM, delineate a lateral inclusion zone. The lateral inclusion zone is the area surrounding a contaminant mass through which petroleum vapors may travel, intrude into buildings, and potentially pose a threat to human health and the environment. Buildings directly above contamination sources, whether as mobile LNAPL, residual LNAPL, or PHCs dissolved in groundwater, are considered within the lateral inclusion zone. Buildings outside this zone generally may be excluded from further assessment for PVI unless: • Site conditions change (e.g., groundwater flow directions changes, contaminant plume migrates beyond the lateral inclusion zone, development or redevelopment of nearby properties). • Preferential transport pathways (e.g., utility corridors, fractured rock, solution channels in karst) are present. • Impermeable surface cover (e.g., concrete, asphalt, ice, very large buildings) is so extensive that there is concern whether there is sufficient oxygen in the subsurface to support biodegradation. • Soil conditions are inhospitable to microorganisms (e.g., dry soils — less than 2 percent soil moisture — in arid areas) such that biodegradation is insufficient to mitigate the threat of PVI. In such instances, additional investigation (e.g., soil vapor sampling11) may be warranted to more fully evaluate the risk from PVI. See Section 4 for more information on delineating a lateral inclusion zone. S Identify preferential transport pathways Preferential transport pathways are avenues of least resistance to the migration of contaminants whether in the dissolved phase, LNAPL phase, or vapor phase. They include both natural and man-made features such as: 11 Bulk soil samples should be analyzed for Total Petroleum Hydrocarbon (TPH) and BTEX (plus any other potential contaminants). Soil vapor samples should be analyzed for oxygen, carbon dioxide, PHCs, and methane. As a quality assurance/quality control check, nitrogen can be added to the analyte list at a nominal cost. This will enable determination of whether significant concentrations of other gases are unaccounted for as these gases should account for nearly 100 percent of the total present. Page 20 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** Natural Man-made • gravel lenses and channels • solution channels in karst terrain • bedding planes and weathered surfaces • fractures, joints, and faults • utility corridors • trenches • sumps and drainage pits • other types of excavations Preferential transport pathways increase the speed at which contamination moves through the subsurface such that contaminants are not biodegraded by the time they reach receptors. They can also allow atypical movement, which in some cases may be opposite groundwater flow (ITRC, 2007). S Determine vertical separation distances Some buildings within the lateral inclusion zone will overlie contamination that exists as either a mobile LNAPL mass, residual soil contamination (including the smear zone), or dissolved in a groundwater plume. However, not all of these buildings will be threatened by PVI due to aerobic biodegradation of PHCs provided there is sufficient vertical separation distance between the receptor and the vapor source. The vertical separation distance is the depth of clean, biologically active soil between a contaminant mass and the lowest point of an overlying receptor (building basement, foundation, slab, or crawl space). The vertical separation distance between contamination and overlying buildings is determined as part of the normal site characterization process; the full extent and location of contaminant sources should be adequately mapped in the subsurface, and the nature and characteristics of the contamination should be determined. Determine Whether Further Investigation Is Unnecessary. EPA (2013a) analyzed petroleum vapor source data and soil gas data from a number of leaking UST sites across the United States. The findings of the report indicate that for dissolved PHC sources that are separated from overlying buildings by more than 6 feet of clean, biologically active soil, the potential threat of PVI is negligible and further investigation for PVI is generally unnecessary. For LNAPL sources that are separated from overlying buildings by more than 15 feet of clean, biologically active soil, the potential threat of PVI is negligible and further investigation for PVI is generally unnecessary. These separation distances are believed to be sufficiently protective in most situations because they include a number of built-in safety factors, which are discussed in more detail in Section 5. Further Investigation Is Warranted. To rule out the potential for PVI, EPA recommends sub- slab sampling for PHCs, oxygen, carbon dioxide, methane, and any fuel additives when either condition exists: Page 21 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** • A building overlies LNAPL and the vertical separation distance is less than 15 feet. • A building overlies dissolved PHC contamination and the vertical separation distance is less than 6 feet. The purpose of the sampling is to demonstrate that biodegradation of PHCs and volatile organic compounds (VOCs) has attenuated vapor concentrations to acceptable levels. EPA's recent empirical analysis (EPA, 2013a) of a database containing soil vapor and source concentration data recognizes that there are a number of sources of uncertainty that may justify a greater vertical separation distance in some cases. These sources of uncertainty include: • Influence of methanogenesis on oxygen demand (especially for ethanol blends of gasoline). • Effect of extensive high organic matter content soils (e.g., peat) with potentially high natural oxygen demand. • Reduced oxygen flux caused by certain geologic conditions (e.g., wet surface clay underlain by coarse-grained soils). • Limited knowledge of vapor attenuation behavior in fractured rock. • Limited soil vapor data for non-UST (e.g., petroleum refinery, fuel terminal) sites. • Limited data on vapor attenuation behavior of aliphatic compounds. • Lack of soil vapor data for lead scavengers, ethylene dibromide (EDB) and 1,2- dichloroethane (1,2-DCA). Other site characteristics that may warrant additional investigation include exceptionally dry soils (<2 percent soil moisture), areas covered by extensive impervious paving or large buildings, and presence of preferential transport pathways. If the potential for PVI cannot be ruled out based on analysis of exterior soil vapor and bulk soil samples, then EPA recommends sub-slab vapor sampling to demonstrate that PVI is not of potential concern. EPA recommends indoor and outdoor ambient air sampling in cases where sub-slab vapor samples indicate the potential for indoor air concentrations from PVI to exceed applicable human health thresholds.12 Guidance for collecting and analyzing sub-slab vapor samples and ambient indoor and outdoor air samples is beyond the scope of this policy document, but is provided in other documents (ITRC [2007] and EPA [2013b]). 12 The federal UST program does not prescribe human health values for any contaminants. However, EPA provides such information that may be applicable in some instances. For example, the OSWER Final Guidance for Assessing and Mitigating the Vapor Intrusion Pathway From Subsurface Sources To Indoor Air (EPA, 2013b) provides health based screening levels for a variety of contaminants. Page 22 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** Information on historic concentrations of background13 vapors is presented in Background Indoor Air Concentrations of Volatile Organic Compounds in North American Residences (1990 - 2005): A Compilation of Statistics for Assessing Vapor Intrusion (EPA, 2011). The objective of this compilation is to illustrate the ranges and variability of VOC concentrations in indoor air during the study period (1990-2005), resulting from sources other than vapor intrusion. To determine if subsurface sources are responsible for indoor air contamination, EPA recommends distinguishing between PHCs arising from vapor intrusion versus background sources. ITRC (2007) and EPA (2013b) provide information on background sources, techniques, and methods to account for background contributions to indoor air concentrations. See the following sections for more information on the factors discussed in the paragraphs above: • Section 4 on the lateral inclusion zone. • Section 5 on the vertical separation distance. • Section 6 on LNAPL. • Section 7 on groundwater flow and dissolved contaminant plumes. • Section 8 on soil vapor profile. • Section 9 on clean, biologically active soil. S Mitigate petroleum vapor intrusion, as appropriate If contaminant concentrations represent a potential threat of fire or explosion, EPA recommends that active mitigation measures be immediately initiated. Likewise, if indoor air sampling indicates that PVI is occurring, then mitigation and/or remediation is recommended. ITRC (2007) and EPA (2013b) provide information on mitigation and remediation of vapor intrusion. In addition, the source of contamination should be remediated following Subpart F of the Federal Regulations (§280.60 through 280.67) (Federal Register, 1988). In particular, §280.64 requires the recovery of LNAPL to the maximum extent practicable. References Cited Alexander, M. 1981. Biodegradation of chemicals of environmental concern. Science 211(9):132-138. Anderson, R.T., and D.R. Lovley. 1997. Ecology and biogeochemistry of in situ groundwater bioremediation, in Jones, J.G. (ed) Advances in Microbial Ecology, Volume 15, Plenum Press, New York, NY, pp. 289-350. 13lndoor air in many buildings will contain detectable levels of a number of vapor-forming compounds whether or not the building overlies a subsurface source of vapors, because indoor air can be impacted by a variety of indoor and outdoor sources. The composition of outdoor air surrounding a building is referred to as ambient air throughout this document. The combined contribution of indoor and outdoor sources of vapors to indoor air concentrations is referred to as background throughout this document. Page 23 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** Amos, R.T., K.U. Mayer, B.A. Bekins, G.N. Delin, and R.L. Williams. 2005. Use of dissolved and vapor-phase gases to investigate methanogenic degradation of petroleum hydrocarbon contamination in the subsurface. Water Resources Research 41(2):W02001. Baedecker, M.J., I.M. Cozzarelli, and J.A. Hopple. 1987. The composition and fate of hydrocarbons in a shallowglacial-outwash aquifer, in Franks, B.J., ed., U.S. Geological Survey Program on Toxic Waste-Ground-Water Contamination—Proceedings of the third technical meeting, Pensacola, Florida, March 23-27,1987: U.S. Geological Survey Open- File Report 87-109, pp. C-23-C-24. Baedecker, M.J., R.P. Eganhouse, B.A. Bekins, and G.N. Delin. 2011. Loss of volatile hydrocarbons from an LNAPL oil source. Journal of Contaminant Hydrology 126(3- 4):140-152. Bailey, N.J.L., A.M. Jobson, and M.A. Rogers. 1973. Bacterial degradation of crude oil: Comparison of field and experimental data. Chemical Geology 11(3):203-221. Bekins, B.A., I.M. Cozzarelli, E.M. Godsy, E.Warren, H.I. Essaid, M.E. Tuccillo. 2001. Progression of natural attenuation processes at a crude oil spill site: II. Controls on spatial distribution of microbial populations. Journal of Contaminant Hydrology 53(3-4):387- 406. Bouchard, D., D. Hunkeler, P. Hoehener, R. Aravena, M. Broholm, and P. Kjeldsen. 2005. Use of stable isotope analysis to assess biodegradation of petroleum hydrocarbons in the unsaturated zone. Laboratory studies, field studies, and mathematical simulations. Reactive Transport in Soil and Groundwater 1:17-37. Chen, Y.D., L. Gui, J.F. Barker, and Y. Jiang. 2009. Biodegradability of trimethylbenzene isomers under the strictly anaerobic conditions in groundwater contaminated by gasoline. Environmental Geology 56(6):1123-1128. Corseuil, H.X., C. Hunt, R. dos Santos Ferreira, and P.J.J. Alvarez. 1998. The influence of the gasoline oxygenate ethanol on aerobic and anaerobic BTX biodegradation. Water Research 32(7):2065-2072. Daoud, W.Z. and K.J. Renken. 1999. Laboratory Measurements of the Radon Gas Diffusion Coefficient for a Fractured Concrete Sample and Radon Gas Barrier Systems. Proceedings, International Radon Symposium (AARST), Las Vegas, Nevada, pp.14.0- 14.12. EPA. 1995. Laboratory Assessment of the Permeability and Diffusion Characteristics of Florida Concretes: Phase II. Field Samples and Analysis. Project Summary (EPA/600/SR-95/103). Page 24 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** EPA. 2011. Background Indoor Air Concentrations of Volatile Organic Compounds in North American Residences (1990-2005): A Compilation of Statistics for Assessing Vapor Intrusion (EPA 530-R-10-001, June). http://www.epa.gov/oswer/vaporintrusion/documents/oswer-vapor-intrusion- background-Report-062411.pdf EPA. 2012. Petroleum Hydrocarbons And Chlorinated Hydrocarbons Differ In Their Potential For Vapor Intrusion, http://www.epa.gov/oust/cat/pvi/pvicvi.pdf. EPA. 2013a. Evaluation Of Empirical Data To Support Soil Vapor Intrusion Screening Criteria For Petroleum Hydrocarbon Compounds (EPA 510-R-13-001). EPA. 2013b. OSWER Final Guidance for Assessing and Mitigating the Vapor Intrusion Pathway From Subsurface Sources To Indoor Air (EPA xxx-xx-xx-xxx). Federal Register. 1988. 40 CFR Parts 280 and 281: Underground storage tanks; technical requirements and state program approval; final rules. September 23,1988. 53(185): 37082-38344. rd Gale, E.F. 1951. The Chemical Activities of Bacteria (3 Edition). Academic Press, New York. Hers, I., R. Zapf-Gilje, P.C. Johnson, and L. Li. 2003. Evaluation of the Johnson and Ettinger Model for Prediction of Indoor Air Quality. Ground Water Monitoring and Remediation 23(1): 62-76. Hong, L., C. Holton, and P.C. Johnson. 2012. Field Study and Numerical Simulation of Indoor Air Sources Effects on Soil Gas Chemical Concentrations at a Vapor Intrusion Study Site. 22nd Annual International Conference on Soil, Water, Energy, and Air and AEHS [Association for Environmental Health and Sciences] Foundation Meeting March 19-22, San Diego, California. Hult, M.F. 1987. Microbial oxidation of petroleum vapors in the unsaturated zone, in Franks, B.J., ed., U.S. Geological Survey Program on Toxic Waste-Ground-Water Contamination- -Proceedings of the third technical meeting, Pensacola, Florida, March 23-27,1987: U.S. Geological Survey Open-File Report 87-109, pp. C-25-C-26. Hult, M.F. 1989. Mobilization, transport, and fate of hydrocarbon vapors in the unsaturated zone, in Mallard, G.E., and Ragone, S.E., eds., U.S. Geological Survey Toxic Substances Hydrology Program—Proceedings of the technical meeting, Phoenix, Arizona, September 26-30,1988: U.S. Geological Survey Water-Resources Investigations Report 88-4220, p. 53. Page 25 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** Interstate Technology & Regulatory Council (ITRC). 2007. Vapor Intrusion Pathway: A Practical Guideline. Interstate Technology and Regulatory Council, Vapor Intrusion Team, Washington, D.C. January. http://www.itrcweb.org/Documents/VI-l.pdf. Jewell, K.P. and J.T. Wilson. 2011. A New Screening Method for Methane in Soil Gas Using Existing Groundwater Monitoring Wells. Ground Water Monitoring and Remediation 31(3):82—94. Kobayashi, K. and K. Shuttoh. 1991. Oxygen Diffusivity of Various Cementitious Materials. Cement and Concrete Research 21(2-3):274-284. Lahvis, M.A., I. Hers, R.V. Davis, J. Wright, and G.E. DeVaull. 2012 (in press). Vapor Intrusion Screening Criteria for Application at Petroleum UST Release Sites. Groundwater Monitoring and Remediation. Lahvis, M.A., and A.L. Baehr. 1996. Estimation of rates of aerobic hydrocarbon biodegradation by simulation of gas transport in the unsaturated zone. Water Resources Research 32(7):2231-2249. Lahvis, M.A., A.L. Baehr, and R.J. Baker. 1999. Quantification of aerobic biodegradation and volatilization rates of gasoline hydrocarbons near the water table under natural attenuation conditions. Water Resources Research 35(3):753-765. Lahvis, M.A., A.L. Baehr, and R.J. Baker. 2004. Evaluation of volatilization as a natural attenuation pathway for MTBE. Ground Water 42(2):258-267. Landmeyer, J.E., and P.M. Bradley. 2003. Effect of hydrologic and geochemical conditions on oxygen-enhanced bioremediation in a gasoline-contaminated aquifer. Bioremediation Journal 7(3-4):165-177. Leahy, J.G. and R.R. Colwell. 1990. Microbial degradation of hydrocarbons in the environment. Microbiological Reviews 54(3):305-315. Lundegard, P.D., P.C. Johnson, and P. Dahlen. 2008. Oxygen transport from the atmosphere to soil gas beneath a slab-on-grade foundation overlying petroleum-impacted soil. Environmental Science and Technology 42(15):5534-5540. Luo, H., P.Dahlen, P.C. Johnson, T. Peargin, and T. Creamer. 2009. Spatial Variability of Soil-Gas Concentrations Near and Beneath a Building Overlying Shallow Petroleum Hydrocarbon- Impacted Soils. Groundwater Monitoring and Remediation 29(1):81-91. Luo, H., and P.C. Johnson. 2011. Incorporating Barometric Pressure and Wind Effects into Vapor Intrusion Simulations. Association for Environmental Health and Sciences Page 26 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** Conference, Petroleum Hydrocarbon Vapor Intrusion Session, March 16, San Diego, California. Ma, J. W.G. Rixey, G.E. DeVaull, B.P. Stafford, and P.J. J. Alvarez. 2012. Methane Bioattenuation and Implications for Explosion Risk Reduction along the Groundwater to Soil Surface Pathway above a Plume of Dissolved Ethanol. Environmental Science & Technology 46(11):6,013-6,019. Marchal, R., S. Penet, F. Solano-Serena, and J.-P. Vandecasteele. 2003. Gasoline and oil biodegradation. Oil and Gas Science and Technology 58(4):441-448. McHugh, T. E., P.C. DeBlanc, and R.J.Pokluda. 2006. Indoor Air as a Source of VOC Contamination in Shallow Soils Below Buildings. Soil & Sediment Contamination 15(1): 103-122. McHugh, T., R. Davis, G. DeVaull, H. Hopkins, J. Menatti, and T. Peargin. 2010. Evaluation of vapor attenuation at petroleum hydrocarbon sites. Soil and Sediment Contamination: An International Journal 19(6):725-745. New Jersey Department of Environmental Protection (NJDEP). 2012. Vapor Intrusion Technical Guidance. Version 2.0. Site Remediation Division. January. Patterson, B. M. and G. Davis. 2009. Quantification of Vapor Intrusion Pathways into a Slab-on- Ground Building under Varying Environmental Conditions, Environmental Science & Technology 43(3):650-656. Phelps, C.D., and L.Y. Young. 1999. Anaerobic biodegradation of BTEX and gasoline in various aquatic sediments. Biodegradation 10(l):15-25. Prince, R.C. 2010. Eukaryotic hydrocarbon degraders, in Timmis, K.N. (ed) Handbook of Hydrocarbon and Lipid Microbiology: Part 33, Springer-Verlag, Berlin. Prince, R.C. and G.S. Douglas. 2010. Remediation of petrol and diesel in subsurface from petrol station leaks, in Timmis, K.N. (ed) Handbook of Hydrocarbon and Lipid Microbiology: Part 14, Springer-Verlag, Berlin. Prince, R.C., T.F. Parkerton, and C. Lee. 2007. The primary aerobic biodegradation of gasoline hydrocarbons. Environmental Science and Technology 41(9):3316-3321. Richnow, H. H., E. Annweiler, W. Michaelis, and R.U. Meckenstock. 2003. Microbial in Situ Degradation of Aromatic Hydrocarbons in a Contaminated Aquifer Monitored by Carbon Isotope Fractionation. Journal of Contaminant Hydrology 65(1-2):101-120. Page 27 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** Robinson, A.L., R.G. Sextro, and W. J. Riley. 1997. Soil-Gas Entry Into Houses Driven by Atmospheric Pressure Fluctuations-The Influence of Soil Properties. Atmospheric Environment 31(10):1487-1495. Sanjuan, M.A. and R. Munoz-Martialay. 1996. Influence of the Water/Cement Ratio on the Air Permeability of Concrete. Journal of Materials Research 31:2829-2832. Spormann, A.M. and F. Widdel. 2000. Metabolism of alkylbenzenes, alkanes, and other hydrocarbons in anaerobic bacteria. Biodegradation ll(2-3):85-105. Suarez, M.P. and H.S. Rifai. 1999. Biodegradation rates for fuel hydrocarbons and chlorinated solvents in groundwater. Bioremediation Journal 3(4):337-362. Tittarelli, F. 2009. Oxygen diffusion through hydrophobic cement-based materials. Cement and Concrete Research 39(10): 924-928. Townsend, G.T., R.C. Prince, and J.M. Suflita. 2003. Anaerobic oxidation of crude oil hydrocarbons by the resident microorganisms of a contaminated anoxic aquifer. Environmental Science and Technology 37(22):5213-5218. Wang, X. and M.A. Deshusses. 2007. Biotreatment of groundwater contaminated with MTBE: Interaction of common environmental co-contaminants. Biodegradation 18(l):37-50. Ward, O., A. Singh, and J. Van Hamme. 2003. Accelerated biodegradation of petroleum hydrocarbon waste. Journal of Industrial and Microbiological Biotechnology 30(5):260- 270. Widdel, F., K. Knittel, and A. Galushko. 2010. Anaerobic hydrocarbon-degrading microorganisms: An overview, in Timmis, K.N. (ed) Handbook of Hydrocarbon and Lipid Microbiology: Part 24, Springer-Verlag, Berlin. Widdel, F., A. Boetius, and R. Rabus. 2006. Anaerobic biodegradation of hydrocarbons including methane. Prokaryotes 2:1028-1049. Zengler, K., H.H. Richnow, R. Rossello-Mora, W. Michaelis, and F. Widdel. 1999. Methane formation from long-chain alkanes by anaerobic microorganisms. Nature 401(6750) :266-269. ZoBell, C.E. 1946. Action of Microorganisms on Hydrocarbons. Bacteriological Reviews 10(l-2):l-49. Page 28 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** Additional Information Acton, D.W. and J.F. Barker. 1992. In situ biodegradation potential of aromatic hydrocarbons in anaerobic groundwaters. Journal of Contaminant Hydrology 9(4):325-352. Anderson, R.T., and D.R. Lovley. 2000. Hexadecane decay by methanogenesis. Nature 404(6779) :722-723. Anderson, R.T., J.N. Rooney-Varga, C.V. Gaw, and D.R. Lovley. 1999. Aromatic and polyaromatic hydrocarbon degradation under Fe(l 11 )-red ucing conditions, in Morganwalp, D.W., and Buxton, H.T., eds., U.S. Geological Survey Toxic Substances Hydrology Program—Proceedings of the Technical Meeting, Charleston, South Carolina, March 8-12,1999—Volume 3 of 3-Subsurface Contamination from Point Sources. U.S. Geological Survey Water-Resources Investigations Report 99-4018C, pp. 177-186. Boopathy, R. 2004. Anaerobic biodegradation of no. 2 diesel fuel in soil: A soil column study. Bioresource Technology 94(2):143-151. Chakraborty, R. and J.D. Coates. 2004. Anaerobic degradation of monoaromatic hydrocarbons. Applied and Environmental Microbiology 64(4):437-446. Davis, R.V. 2009. Update on recent studies and proposed screening criteria for vapor-intrusion pathway. LUSTLine Bulletin 61:11-14. Davis, R.V. 2011a. Evaluating the Petroleum Vapor Intrusion Pathway: Studies of Natural Attenuation of Subsurface Petroleum Hydrocarbons & Recommended Screening Criteria. AEHS 21st Annual West Coast International Conference on Soil, Sediment, Water & Energy, Mission Valley, San Diego, California, March 15. Davis, R.V. 2011b. Attenuation of Subsurface Petroleum Hydrocarbon Vapors: Spatial and Temporal Observations. AEHS 21st Annual West Coast International Conference on Soil, Sediment, Water & Energy, Mission Valley, San Diego, California, March 16. DeVaull, G. 2007. Indoor vapor intrusion with oxygen-limited biodegradation for a subsurface gasoline source. Environmental Science and Technology 41(9):3241-3248. DeVaull, G., R. Ettinger, and J. Gustafson. 2002. Chemical Vapor Intrusion from Soil or Groundwater to Indoor Air: Significance of Unsaturated Zone Biodegradation of Aromatic Hydrocarbons. Soil and Sediment Contamination 11(4):625-641. Edwards, E.A. and D. Grbic-Galic. 1994. Anaerobic degradation of toluene and o-xylene by a methanogenic consortium. Applied and Environmental Microbiology 60(l):313-322. Page 29 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** EPA. 2008. Brownfields Technology Primer: Vapor Intrusion Considerations for Redevelopment (EPA 542-R-08-001). Fischer, M., A. Bentley, K. Dunkin, A. Hodgson, W. Nazaroff, R. Sextro, and J. Daisey. 1996. Factors Affecting Indoor Air Concentrations of Volatile Organic Compounds at a Site of Subsurface Gasoline Contamination. Environmental Science and Technology 30(10): 2948-2957. Johnson, P., P. Lundegard, and Z. Liu. 2006. Source Zone Natural Attenuation at Petroleum Hydrocarbon Spill Sites-I: Site-Specific Assessment Approach. Ground Water Monitoring and Remediation 26(4):82-92. Lovley, D.R., and D.J. Lonergan. 1990. Anaerobic oxidation of toluene, phenol, and p-Cresol by the dissimilatory iron-reducing organism, GS-15. Applied and Environmental Microbiology 56(6):1858-1864. McHugh, T., D. Hammond, T. Nickels, and B. Hartman. 2008. Use of Radon Measurements for Evaluation of Volatile Organic Compound (VOC) Vapor Intrusion. Environmental Forensics 9(1):107-114. Mills, W., S. Liu, M. Rigby, and D. Brenner. 2007. Time-Variable Simulation of Soil Vapor Intrusion into a Building with a Combined Crawl Space and Basement. Environmental Science and Technology 41(14):4993-5001. Reinhard, M., G.D. Hopkins, E. Steinle-Darling, and C.A. LeBron. 2005. In situ biotransformation of BTEX compounds under methanogenic conditions. Ground Water Monitoring and Remediation 25(4):50-59. Siddique, T., P.M. Fedorak, and J.M. Foght. 2006. Biodegradation of short-chain n-alkanes in oil sands tailings under methanogenic conditions. Environmental Science and Technology 40(17) :5459-5464. Siddique, T., P.M. Fedorak, M.D. Mackinnon, and J.M. Foght. 2007. Metabolism of BTEX and naphtha compounds to methane in oil sands tailings. Environmental Science and Technology 41(7):2350-2356. Solano-Serena, F., R. Marchal, M. Ropars, J.-M. Lebeault, and J.-P. Vandecasteele. 2003. Gasoline and oil biodegradation. Applied and Environmental Microbiology 86(6):1008- 1016. Uhler, A., K. McCarthy, S. Emsbo-Mattingly, S. Stout, and G. Douglas. 2010. Predicting Chemical Fingerprints of Vadose Zone Soil Gas and Indoor Air from Non-Aqueous Phase Liquid Composition. Environmental Forensics ll(4):342-354. Page 30 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** 2. Typical PVI Scenarios Description The potential for PVI is primarily a function of the location of the contamination source relative to a potential receptor, source strength, and the source mass distribution in the subsurface. Source concentrations are typically much higher for LNAPL sources than for dissolved-phase sources. Higher source concentrations will generate higher rates of mass diffusion (flux). The higher mass flux will also be more sustained over time because LNAPL sources will contain significantly more mass compared to dissolved-phase sources. Oxygen demand and the potential for encountering anaerobic conditions are also uniquely different between LNAPL and dissolved-phase sources. For both dissolved and LNAPL sources, the biodegradation reaction front is relatively narrow, but it occurs higher in the unsaturated zone (closer to land surface) over an LNAPL source than it does over a dissolved-phase source (Figure 3). LNAPL sources will tend to be distributed above the capillary fringe as a result of smearing from water-table fluctuations. This phenomenon will tend to enhance mass flux to the unsaturated zone because of direct partitioning between LNAPL (residual) and vapor phases. Conversely, the mass flux will be more limited for dissolved-phase sources because they exist below the capillary fringe which serves as a barrier to vapor transport (Golder Associates, 2006; Lahvis and Baehr, 1996). Vapor diffusion is limited by low effective air-phase porosity (i.e., high moisture saturation) and biodegradation in the capillary zone. Importance A few confirmed occurrences of PVI at petroleum sites are reported in the literature (EPA, 2013). Davis (2009) and McHugh, et al. (2010) both observe that there are no reported cases of vapor intrusion from dissolved-phase petroleum hydrocarbon sources vertically separated from building foundations in the literature. The most likely scenarios for PVI to occur are shallow PHC sources directly beneath buildings and mobile LNAPL or groundwater plumes with high concentrations of PHCs that are in direct contact with buildings. Assessment Recommended steps for investigating PVI are discussed in Section 1. The screening criteria in the assessment and investigation allow for the determination of which buildings are threatened by PVI. Using this approach, resources can be appropriately focused on those buildings potentially impacted by PVI. Figure 4 presents typical scenarios of the spatial relationship between PHC sources and potential receptors. However, it is not intended to be a comprehensive depiction of all possible permutations of such a relationship. Table 2 summarizes the characteristics of these six scenarios relative to lateral and vertical distances from contamination and necessary investigation activities. Page 31 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** a) LNAPL SOURCE UNSATURATEDZONE * * high mass ^ * lV l"" T £ CAPILLARY ZONE ( SATURATED ZONE r"PHCs\ S. sharp reaction front constituent distributions b) DISSOLVED-PHASE SOURCE UNSATURATEDZONE limited mass flux CAPILLARYZONE SATURATEDZONE PHCs 1 Sa- LEGEND LNAPL (free- or resicfual-phase) Dissolved phase ~ Water Table \ PHC Vapors sharp • reaction front constituent distributions Figure 3. Difference In Potential For PVI Based On Type Of Source: a) LNAPL b) Dissolved Phase (source: Lahvis, et al., 2012) Special Considerations While biodegradation may reduce the potential for human exposure to petroleum vapors, its effectiveness in mitigating PVI may be limited by: • Migration of contaminants, especially plumes in flowing groundwater. • Presence of preferential transport pathways, such as fractures and solution channels in karst, • Extensive impermeable surface cover, and/or very large buildings, that may reduce the atmospheric oxygen flux to the subsurface. • Soils with high organic content (e.g., peat) that exert a high oxygen demand. • Soil conditions that are inhospitable to microorganisms such as insufficient soil moisture. • Insufficient thickness of clean, biologically active soil. Recommendation EPA recommends conducting an adequate PVI investigation and following the steps described in Section 1 to determine which buildings may be at risk for PVI. Page 32 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** r ¦ - J Figure 4. Typical Scenarios Of Potential PVI Sources And Potential Receptors Page 33 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** Table 2. Summary Of Characteristics Of Typical Scenarios Of Petroleum Vapor Sources And Potential Receptors. Scenario (as illustrated in Figure 4) Contamination Beneath Building? (building is within lateral inclusion zone) Potential For PVI Sub-Slab Vapor Sampling Recommended? A Yes; residual LNAPL High Yes, if vertical separation distance is less than 15 feet, otherwise No B Yes; residual including smear zone, LNAPL, dissolved in groundwater High Yes, if vertical separation distance is less than 15 feet, otherwise No C Yes; smear zone, LNAPL, dissolved in groundwater Medium Yes, if vertical separation distance is less than 15 feet, otherwise No D Yes; dissolved in groundwater Low Yes, if vertical separation distance is less than 6 feet, otherwise No E Maybe; plume may be diving beneath water table Low - None Yes, if vertical separation distance is less than 6 feet, otherwise No F No None No Page 34 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** References Cited Davis, R.V. 2009. Bioattenuation of petroleum hydrocarbon vapors in the subsurface: Update on recent studies and proposed screening criteria for the vapor-intrusion pathway. LUSTLine Bulletin 61:11-14. New England Interstate Water Pollution Control Commission, Massachusetts. EPA . 2013. Evaluation Of Empirical Data To Support Soil Vapor Intrusion Screening Criteria For Petroleum Hydrocarbon Compounds (EPA 510-R-13-001). Golder Associates. 2006. NJDEP-Golder subsurface vapor intrusion research project: Report on: Investigation of indoor air quality in structures located above VOC-contaminated groundwater, year two, Part 1: Evaluation of soil vapor intrusion at Mount Holly site, New Jersey, 22 pp. Lahvis, M.A., and A.L. Baehr. 1996. Estimating rates of aerobic hydrocarbon biodegradation by simulation of gas transport in the unsaturated zone. Water Resources Research 32(7): 2231-2249. Lahvis, M.A., I. Hers, R.V. Davis, J. Wright, and G.E. DeVaull. 2012 (in press). Vapor Intrusion Screening Criteria for Application at Petroleum UST Release Sites. Groundwater Monitoring and Remediation. McHugh, T., R. Davis, G. DeVaull, H. Hopkins, J. Menatti, and T. Peargin. 2010. Evaluation of vapor attenuation at petroleum hydrocarbon sites. Soil and Sediment Contamination: An International Journal 19(6):725-745. Additional Information Davis, R.V. 2009. Update on recent studies and proposed screening criteria for vapor-intrusion pathway. LUSTLine Bulletin 61:11-14. Davis, R.V. 2011a. Evaluating the Petroleum Vapor Intrusion Pathway: Studies of Natural Attenuation of Subsurface Petroleum Hydrocarbons & Recommended Screening Criteria. Association for Environmental Health and Sciences 21st Annual West Coast International Conference on Soil, Sediment, Water & Energy, Mission Valley, San Diego, California, March 15. Davis, R.V. 2011b. Attenuation of Subsurface Petroleum Hydrocarbon Vapors: Spatial and Temporal Observations. Association for Environmental Health and Sciences 21st Annual West Coast International Conference on Soil, Sediment, Water & Energy, Mission Valley, San Diego, California, March 16. Page 35 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** Roggemans, S., C.L. Bruce, and P.C. Johnson. 2002. Vadose Zone Natural Attenuation of Hydrocarbon Vapors: An Empirical Assessment of Soil Gas Vertical Profile Data. API Technical Bulletin No. 15. American Petroleum Institute, Washington, D.C. http://api- ep.api.org/environment. Roggemans, S. 1998. Natural Attenuation of Hydrocarbon Vapors in the Vadose Zone. M.S. Thesis, Arizona State University. Page 36 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** 3. Site Characterization And Conceptual Site Model (CSM) Description Site characterization is the process by which site-specific information and data are gathered from a variety of sources to characterize the physical, biological, and chemical systems at a contaminated site. A conceptual site model (CSM) integrates all lines of evidence into a three- dimensional picture of site conditions that illustrates contaminant distributions, release mechanisms, migration routes, exposure pathways and, potential receptors (EPA 2012; ITRC, 2007). The CSM uses a combination of text and graphics to portray both known and hypothetical information (EPA, 2011). The CSM documents current site conditions and is supported by maps, cross-sections, and site diagrams that illustrate human and environmental exposure through contaminant release and migration to potential receptors (EPA, 1996a). Frequently, a CSM may be presented as a site map and/or developed as a flow diagram which describes potential migration of contaminants to site receptors (EPA, 1995). The CSM synthesizes data acquired from historical research, site characterization, and remediation system operation. Importance At any leaking UST site, it is important to have a thorough understanding of the full extent and location of contamination, the characteristics of the site that influence contaminant migration, and the locations of potential receptors. A CSM helps ensure that sources, pathways, and receptors throughout the site have been considered; this knowledge can lead to selection of the most appropriate sampling locations and techniques. The CSM assists the site manager in evaluating the interaction of different site features. Risk assessors use conceptual models to help plan for risk assessment activities (EPA, 1995). The CSM is the basis for making informed risk management decisions about the site and the threat posed by PVI to nearby buildings. In addition, remedial action costs are influenced by the quality of the CSM (EPA, 1996b). Assessment A primary objective of site characterization is delineation of the aerial and vertical extent of contamination in the subsurface. This includes changes in plume boundaries, geochemical parameters that affect biodegradation, and contaminant mass and/or concentration. All information and data about the site should be integrated into a CSM. EPA's guidance on conceptual site models lists six basic activities associated with developing a CSM: • Identification of potential contaminants. • Identification and characterization of the source(s) of contaminants. • Delineation of potential migration pathways through environmental media, such as groundwater, surface water, soils, sediment, biota, and air. • Establishment of background levels of contaminants and areas of contamination for each contaminated medium. • Identification and characterization of potential receptors. Page 37 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** • Determination of the limits of the study area or system boundaries. EPA recommends that the CSM include a diagrammatic or schematic presentation that relates the source of contamination to receptors and identifies all potential sources of contamination, the potentially contaminated media, and exposure pathways. Tracking contaminant migration from sources to receptors is one of the most important uses of the CSM (ASTM, 2008). Uncertainties associated with the CSM should also be identified as well as the efforts taken to reduce uncertainties to acceptable levels (ASTM, 2008). Another important use of the CSM is to identify data gaps and locations from which additional information and data should be gathered. As new information and data become available, the CSM should continually be refined (EPA, 1993; ITRC, 2007). ITRC (2007) and EPA (2013) provide additional guidance for developing CSMs for vapor intrusion. Special Considerations The presence and locations of preferential transport pathways should be identified and incorporated into the CSM. All new information and data about a site, including potential future land uses, should also be identified to refine the CSM. Recommendation An adequate site characterization is the key factor in making informed decision. Subparts E and F in 40 CFR 280.50 through 280.67 establish the regulatory foundation for, and describe the fundamental components of an adequate site characterization. Specifically: • §280.52(b) Release Investigation and Confirmation Steps: "Owners and operators must measure for the presence of a release where contamination is most likely to be present at the UST site. In selecting sample types, sample locations, and measurement methods, owners and operators must consider the nature of the stored substance, the type of initial alarm or cause for suspicion, the type of backfill, the depth of ground water, and other factors appropriate for identifying the presence and source of the release." • §280.62(a)(5) Initial Abatement Measures and Site Checks "Measure for the presence of a release where contamination is most likely to be present at the UST site, unless the presence and source of the release have been confirmed in accordance with the site check required by §280.52(b) or the closure site assessment of §280.72(a). In selecting sample types, sample locations, and measurement methods, the owner and operator must consider the nature of the stored substance, the type of backfill, depth to ground water and other factors as appropriate for identifying the presence and source of the release. . ." • §280.63(a)(l-4) Initial Site Characterization . .owners and operators must assemble information about the site and nature of the release, including information gained while confirming the release or completing the initial abatement measures. . . This information must include, but is not necessarily limited to the Page 38 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** following: (1) Data on the nature and estimated quantity of release; (2) Data from available sources and/or site investigations concerning the following factors: surrounding populations, water quality, use and approximate locations of wells potentially affected by the release, subsurface soil conditions, locations of subsurface sewers, climatological conditions, and land use; (3) Results of the site check required under §280.62(a)(5); and (4) Results of the free product investigations. . ." • §280.65(a) Investigation for soil and ground water cleanup "In order to determine the full extent and location of soils contaminated by the release and the presence and concentrations of dissolved product contamination in the groundwater, owners and operators must conduct investigations of the release, the release site, and the surrounding area possibly affected by the release. . ." • §280.66(b)(l-6) Corrective Action Plan "In making this determination, the implementing agency should consider the following factors as appropriate: (1) The physical and chemical characteristics of the regulated substance, including its toxicity, persistence, and potential for migration; (2) The hydrogeologic characteristics of the facility and the surrounding area; (3) The proximity, quality and current and future uses of nearby surface water and ground water; (4) The potential effects of residual contamination on nearby surface water and ground water; (5) An exposure assessment; and (6) Any information assembled in compliance with this subpart." When the information and data described above have been collected, EPA recommends that they be integrated into a CSM and used as the basis for making informed risk management decisions about the site and the threat posed by PVI to nearby receptors. References Cited ASTM. 2008. Standard Guide for Developing Conceptual Site Models for Contaminated Sites. E1689-95. ASTM International, West Conshohocken, Pennsylvania. EPA. 1993. Guidance for Evaluating the Technical Impracticability of the Ground-Water Restoration. Publication 9234.2-25 EPA. 1995. Superfund Program Representative Sampling Guidance. OSWER Directive 9360.4- 10 (EPA 540-R-95-141). EPA. 1996a. Soil Screening Guidance: User's Guide. Publication 9355.4-23 (EPA 540-R-96-018). EPA. 1996b. The Role of Cost in the Superfund Remedy Selection Process. Quick Reference Fact Sheet. Publication 9200.3-23FS (EPA 540-F-96-018). Page 39 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** EPA. 2011. Environmental Cleanup Best Management Practices: Effective Use of the Project Life Cycle Conceptual Site Model. Quick Reference Fact Sheet (EPA 542-F-11-011). EPA. 2013. OSWER Final Guidance for Assessing and Mitigating the Vapor Intrusion Pathway From Subsurface Sources To Indoor Air (EPA xxx-xx-xx-xxx). Federal Register. 1988. 40 CFR Parts 280 and 281: Underground storage tanks; technical requirements and state program approval; final rules. September 23,1988. 53(185): 37082-38344. ITRC. 2007. Vapor Intrusion Pathway: A Practical Guideline. Interstate Technology and Regulatory Council, Vapor Intrusion Team, Washington, D.C. (January). Additional Information EPA. 2003. Improving Decision Quality: Making The Case For Adopting Next-Generation Site Characterization Practices (EPA 542-F-03-012). EPA. 2004. Improving Sampling, Analysis, and Data Management for Site Investigation and Cleanup (EPA 542-F-04-001a). EPA. 2008. Triad Issue Paper: Using Geophysical Tools to Develop the Conceptual Site Model (EPA 542-F-08-007). EPA. 2010. Innovations in Site Characterization, Streamlining Cleanup at Vapor Intrusion and Product Removal Sites Using the Triad Approach: Hartford Plume Site, Hartford, Illinois (EPA 542-R-10-006). Page 40 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** 4. Lateral Inclusion Zone Description The lateral inclusion zone is the area surrounding a contaminant source through which vapor- phase contamination may travel and intrude into buildings. Determining the lateral distance beyond which buildings and other structures may not be threatened by potential PVI is site- specific. In general, as the level of confidence in the site characterization and CSM increases, the distance the lateral inclusion zone extends outward from sources of PHC vapors decreases. All buildings within the lateral inclusion zone should be further assessed to determine if they are separated from vapor sources by an adequate vertical separation distance (see Section 5). Further assessment may be unnecessary for those buildings outside the inclusion zone. If contaminated groundwater is the source of vapors, migration of the contaminant plume (in the longitudinal, transverse, and vertical directions) should be assessed when evaluating the potential for future risks. Importance The lateral inclusion zone is a screening criterion to help determine which sites can reliably be excluded from consideration for further evaluation of PVI potential; which sites might need additional site characterization; and which sites should definitely be assessed further for PVI. All buildings directly over the contamination, whether LNAPL or the dissolved phase, are considered to be within the lateral inclusion zone. Assessment An investigation for PVI potential is not separate from the normal response to a confirmed UST release, which requires an adequate site characterization in order to construct an accurate CSM (see Section 3). Through this investigation, the full extent and location of contamination must be determined (per 40 CFR 280.65(a)) so that lateral and vertical separation distances can be accurately determined. Site characterization generally proceeds in a systematic manner, often beginning in or near the source area and working outward and in the downgradient direction in which groundwater flows. The outward and downgradient investigation should continue until the full extent and location of contamination is determined. Because this process may progress in phases, it may be necessary to assess nearby buildings for PVI before site characterization is complete, when there is still significant uncertainty regarding the full extent and location of contamination. Groundwater elevations fluctuate which may result in changes in the direction and velocity of groundwater flow and changes in the thickness of the vadose zone. These fluctuations may change the vertical separation distance between a potential receptor and source of PHC vapors. The vertical separation distance is measured from the lowest point of the overlying foundation, basement, or slab, and the historic high water table elevation. Both mobile LNAPL and dissolved contaminant plumes are dynamic and may move from one monitoring event to the next. As discussed in Section 2, periodic monitoring of groundwater flow directions and plume migration are needed, possibly over more than one annual cycle. See Section 7 for additional information on groundwater flow and dissolved contaminant plumes. Page 41 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** Lateral separation distance is schematically depicted in Figure 5. In general, the length of the lateral separation distance is on the same scale as the vertical separation distance (EPA, 2013a; ITRC, 2007). However, the lateral boundaries of the plume are more difficult to accurately delineate, in part because plumes migrate down gradient, thus a greater lateral distance is generally warranted (EPA, 2013a). Lateral Separation Distance {ust) VadoseZone Vapors Residual- or Free-Phase LNAPL Dissolved-Phase Water V Table Saturated Zone Figure 5. Lateral Separation Distance Between Source Of PHC Contaminants And Hypothetical Receptor Special Considerations It can be difficult to accurately determine the exact location of contamination relative to potential receptors. This is in part due to the dynamic nature of contaminant plumes (both LNAPL and dissolved PHCs); the presence of heterogeneities and preferential transport pathways in geologic material; and the distance between monitoring points, such as soil borings and monitoring wells. As discussed previously, it is important to consider whether preferential transport pathways are present and could facilitate the migration of petroleum vapors. If the transport of vapors from the source area to the building could occur along preferential transport pathways, such as utility conduits, then vapor sampling inside the utility conduits, including manholes and sumps, should be considered in addition to vadose zone and sub-slab soil vapor sampling. Specific guidance for utility sampling is beyond the scope of this document. However, consideration For additional guidance, see A Practical Strategy for Assessing the Subsurface Vapor-to-Indoor Air Migration Pathway at Petroleum Hydrocarbon Sites. API Publication 4741, November 2005. Accessible at http://www.api.org/ehs/groundwater/NAPL/soilgas.cfm. Page 42 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** should be given to field instrument screening at utility access points as an initial step to determine if the utility is acting as a conduit for vapors. The CSM should establish whether it appears that vapor migration is taking place along the utility backfill or if there is actual vapor transport inside the utility itself. EPA recommends that any utility sampling program include safety precautions to protect personnel (e.g., oxygen and combustible gas monitoring, confined-space entry requirements) and to avoid damage to utilities (American Petroleum Institute (API), 2005). Another consideration is changing site conditions. Factors to consider in deciding whether to exclude sites from further evaluation of PVI may include future land use, construction of utility trenches through or near previous contamination, increased groundwater usage, and additional releases of contaminants. Recommendation One approach to address the uncertainty is to delineate a lateral inclusion zone that is based on an adequate site investigation and CSM. EPA's Office of Research and Development recently published an Issue Paper describing one such approach: An Approach for Developing Site-Specific Lateral and Vertical Inclusion Zones within which Structures Should be Evaluated for Petroleum Vapor Intrusion due to Releases of Motor Fuel from Underground Storage Tanks (EPA, 2013b). If it is determined that inhabited buildings and/or future buildings are not located in the lateral inclusion zone, the vapor intrusion pathway may be considered incomplete and no further consideration of the pathway should be necessary. References Cited API. 2005. A Practical Strategy for Assessing the Subsurface Vapor-to-lndoor Air Migration Pathway at Petroleum Hydrocarbon Sites. API Publication 4741. EPA. 2013a. Evaluation Of Empirical Data To Support Soil Vapor Intrusion Screening Criteria For Petroleum Hydrocarbon Compounds (EPA 510 R-13-001). EPA. 2013b (in press). An Approach for Developing Site-Specific Lateral and Vertical Inclusion Zones within which Structures Should be Evaluated for Petroleum Vapor Intrusion due to Releases of Motor Fuel from Underground Storage Tanks (EPA/600/R-12-xxx). Interstate Technology & Regulatory Council (ITRC). 2007. Vapor Intrusion Pathway: A Practical Guideline. Interstate Technology and Regulatory Council, Vapor Intrusion Team, Washington, D.C. January. http://www.itrcweb.org/Documents/VI-l.pdf. Page 43 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** 5. Vertical Separation Distance Description The vertical separation distance is the thickness of clean, biologically active soil (see Section 9) between the highest vertical extent of a contaminant source and the lowest point of an overlying building. This lowest point could be a basement, foundation, or slab. Importance Aerobic biodegradation will degrade vapor-phase contamination before it intrudes into buildings if the thickness of clean, biologically active soil is sufficient and oxygen is present. EPA (2013) presents a compilation and analysis of soil vapor data from a large number of sites that represent many different hydrogeologic settings where gasoline was released from USTs.15 This analysis builds on the work of Davis (2009, 2010, 2011a, and 2011b). In addition, EPA (2013) summarizes the results of a number of parallel efforts (Lahvis, et al., 2012; Peargin and Kolhatkar, 2011; Wright, 2011, 2012) using somewhat different data sets. There is a high degree of consistency among these studies. This consistency enables determination of a vertical separation distance based on whether contamination is present as LNAPL or dissolved PHCs; that is, the thickness required to aerobically biodegrade PHCs is directly related to the strength of the source. Because LNAPL sources are capable of producing higher concentrations of vapors, the necessary separation distance between receptors and LNAPL is greater than the necessary separation distance between dissolved sources and receptors. In most situations, EPA (2013) finds the vertical separation distance of 5.4 feet from dissolved sources and 13.5 feet for LNAPL sources adequate to eliminate the potential for PVI. Although these distances are believed to be protective in most environmental settings, there are some site-specific factors (e.g., preferential transport pathways, low soil moisture, large areas of impervious paving) that may necessitate further consideration. Because of the difficulty in accurately measuring precise distances to contamination under field conditions, EPA recommends vertical separation distances of 6 feet for dissolved and 15 feet for LNAPL sources. These separation distances are schematically depicted in Figure 6a and 6b, respectively. 15 EPA contracted for a thorough QA/QC evaluation of the data in this database and to then analyze the data and prepare a report on the findings. Subsequently, EPA contracted for an independent, external peer review of the report in accordance with OMB's Final Information Quality Bulletin for Peer Review/EPA's Peer Review Handbook. The final report (EPA, 2013) addresses the peer review comments received. The report, database, and peer review record are accessible on EPA's PVI Compendium Web page at http://www.epa.gov/oust/pvi/index.htm. Page 44 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** 1 ~ S VadoseZone p o rs t >6 ft Water \7 * ^Residual- or Free-Phase LNAP^^^ k * Saturated Zone Table (a) Vertical separation distance for dissolved-phase source of PHCs. VadoseZone >15 ft Vapors Residual-or Free- Phase LNAPL Water Table S Dissolved-Phase Saturated Zone (b) Vertical separation distance for gasoline- LNAPL (residual or liquid phase) source of PHCs. Figure 6. Vertical Separation Distances Between Source Of PHC Contaminants And Hypothetical Receptor: (a) Dissolved Source, (b) LNAPL source Page 45 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** Assessment As part of a normal leaking UST investigation, the potential contaminants of concern should be identified. Although benzene, toluene, ethylbenzene, and the three isomers of xylene (BTEX) represent the group of aromatic hydrocarbons that receive the most attention at typical leaking UST sites, they are not the only compounds that may be a threat to human health. There are three other classes of PHCs in gasoline: paraffins, olefins, and naphthenes. Some of the PHCs in these classes may also present a potential risk of PVI. In addition, gasoline also contains synthetic additives16 such as MTBE and tertiary-butyl alcohol (TBA). Vapors emanating from gasoline sources (either dissolved-phase or LNAPL) will contain many of these compounds; any or all of which may be risk-drivers. Dissolved sources will be comprised primarily of more soluble compounds while LNAPL sources will contain a sizeable fraction of aliphatic and relatively insoluble hydrocarbons (e.g., naphthalene), especially if the source is large or un- weathered (Lahvis, et al., 2012; EPA, 2013). The presence of VOCs other than benzene may result in depletion of oxygen that is necessary for aerobic biodegradation of benzene, potentially resulting in farther migration of benzene vapors. The presence of LNAPL may be determined from direct or indirect evidence. Direct evidence includes measureable accumulations of free product in monitoring wells, an oily sheen or floating globules on the water table, and petroleum hydrocarbon-saturated bulk soil samples. Indirect evidence includes high concentrations of benzene and other PHCs, often measured as TPH. For more information on indirect evidence for LNAPL, see Section 6. In many situations further investigation for PVI may be unnecessary: • For low levels of soil contamination (clean soil; i.e., LNAPL is not present as mobile or residual material) or groundwater contamination: o Groundwater contamination is less than or equal to 30 mg/L TPH (gasoline) or benzene is less than or equal to 5 mg/L; or o Soil contamination is less than or equal to 250 mg/kg TPH (gasoline) or benzene less than or equal to 10 mg/kg, and o The vertical separation distance between contamination and the lowest point of a building foundation, basement, or slab is 6 feet or more. • For high levels of soil or groundwater contamination (i.e., LNAPL is present): o Groundwater contamination is greater than 30 mg/L TPH (gasoline) or benzene is greater than 5 mg/L; or o Soil contamination is greater than 250 mg/kg TPH (gasoline) or greater than 10 mg/kg benzene; and 16 At older sites, where leaded gasoline was released to the subsurface, the lead scavengers ethylene dibromide (EDB) and 1,2-DCA may be present and could represent a potential source of vapors that should be assessed. For more information about lead scavengers, see Appendix F in Evaluation Of Empirical Data To Support Soil Vapor Intrusion Screening Criteria For Petroleum Hydrocarbon Compounds (EPA, 2013). Page 46 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** o The vertical separation distance between contamination and the lowest point of a building foundation, basement, or slab is greater than 15 feet. Special Considerations The presence of preferential transport pathways may circumvent the protectiveness that a sufficiently thick layer of clean, biologically active soil would otherwise provide. Preferential transport pathways such as utility conduits typically enter buildings through holes in the foundation or slab and can facilitate the entry of PHC vapors into the building. Consideration should be given to field instrument screening at utility access point(s) as an initial step to determine if the utility is acting as a conduit for vapors. If the transport of vapors from the source area to the building could occur along utility conduits, then vapor sampling inside the utility conduits, manholes, or sumps should be considered in addition to vadose zone and sub- slab soil vapor sampling. Any utility sampling program should include safety precautions to protect personnel (e.g., oxygen and combustible gas monitoring, confined-space entry requirements) and to avoid damage to utilities. Specific guidance for utility sampling is beyond the scope of this document, but more information is available in A Practical Strategy for Assessing the Subsurface Vapor-to-lndoor Air Migration Pathway at Petroleum Hydrocarbon Sites (API, 2005). Recommendation EPA recommends using the criteria in Table 3 to determine the necessary vertical separation distance between contamination and an overlying building foundation, basement, or slab. These vertical separation distances are consistent with the findings presented in EPA (2013) and consider the practicalities of determining precise depths below ground surface and collecting samples during the course of conducting field work. Page 47 of 98 ------- Draft EPA External Review Document. Do not cite or quote. Table 3. Recommended Vertical Separation Distance Between Contamination And Building Foundation, Basement, Or Slab. Media Benzene TPH Vertical Separation Distance (feet)* Soil (mg/kg) <10 >10 (LNAPL) <250 >250 (LNAPL) 6 15 Groundwater (mg/L) <5 >5 (LNAPL) <30 >30 (LNAPL) 6 15 The thresholds for LNAPL indicated in this table are indirect evidence of the presence of LNAPL. These thresholds may vary depending on site-specific conditions (e.g., soil type, LNAPL source). Investigators may have different experiences with LNAPL indicators and may use them as appropriate. Direct indicators of LNAPL also apply; these include measurable accumulations of free product, oily sheens, and saturated bulk soil samples. For more information, see API (2000). *The vertical separation distance represents the thickness of clean (TPH < 100 mg/kg), biologically active soil between the source of PHC vapors (LNAPL, residual LNAPL, or dissolved PHCs) and the lowest (deepest) point of a receptor (building foundation, basement, or slab). EPA recommends that sub-slab sampling be conducted to evaluate the risk of PVI whenever contamination above the specified threshold is present in any sample and the distance between the contamination and an overlying building is less than these vertical distances. If the potential for PVI cannot be ruled out based on sub- slab vapor sampling, then EPA recommends indoor air sampling. References Cited API. 2000. Non-Aqueous Phase Liquid (NAPL) Mobility Limits in Soil. Soil and Groundwater Research Bulletin No. 9. API. 2005. A Practical Strategy for Assessing the Subsurface Vapor-to-lndoor Air Migration Pathway at Petroleum Hydrocarbon Sites. API Publication 4741. Accessible at: http://www.api.org/environment-health-and-safety/clean-water/ground-water/vapor- intrusion/vi-publications/assessing-vapor-intrusion.aspx. Page 48 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** Bruce, L., T. Miller, and B. Hockman. 1991. Solubility versus Equilibrium Saturation of Gasoline Compounds: A Method to Estimate Fuel/Water Partition Coefficient Using Solubility or Koc. In: Proceedings of the NWWA/API Conference on Petroleum Hydrocarbons in Ground Water, p. 571-582, by National Water Well Association, Dublin, Ohio. http: //info .ngwa. org/gwol/pdf/910155295. PDF. Davis, R.V. 2009. Update on recent studies and proposed screening criteria for vapor-intrusion pathway. LUSTLine Bulletin 61:11-14. Davis, R.V. 2011a. Evaluating the Petroleum Vapor Intrusion Pathway: Studies of Natural Attenuation of Subsurface Petroleum Hydrocarbons & Recommended Screening Criteria. Association for Environmental Health and Sciences 21st Annual West Coast International Conference on Soil, Sediment, Water & Energy, Mission Valley, San Diego, California, March 15. Davis, R.V. 2011b. Attenuation of Subsurface Petroleum Hydrocarbon Vapors: Spatial and Temporal Observations. AEHS 21st Annual West Coast International Conference on Soil, Sediment, Water & Energy, Mission Valley, San Diego, California, March 16. EPA. 2013. Evaluation Of Empirical Data To Support Soil Vapor Intrusion Screening Criteria For Petroleum Hydrocarbon Compounds (EPA 510-R-13-001). Lahvis, M.A., I. Hers, R.V. Davis, J. Wright, and G.E. DeVaull. 2012 (in press). Vapor Intrusion Screening Criteria for Application at Petroleum UST Release Sites. Groundwater Monitoring and Remediation. McHugh, T., R. Davis, G. DeVaull, H. Hopkins, J. Menatti, and T. Peargin. 2010. Evaluation of vapor attenuation at petroleum hydrocarbon sites. Soil and Sediment Contamination: An International Journal 19(6):725-745. Peargin, T. and R. Kolhatkar. 2011. Empirical data supporting groundwater benzene concentration exclusion criteria for PVI investigations. Proceedings of Battelle 8th International Symposium on Bioremediation and Sustainable Environmental Technologies, Reno, Nevada, June 27-30. Wright, J. 2011. Establishing exclusion criteria from empirical data for assessing petroleum hydrocarbon vapour intrusion. CleanUp 2011: Proceedings of the 4th International Contaminated Site Remediation Conference, September 11-15, Adelaide, Australia. Wright, J. 2012. Evaluation of the Australian Petroleum Hydrocarbon VI Database: Exclusion Criteria. Presented at: Recent Advances to VI Application & Implementation—A State- of-the-Science Update. Association for Environmental Health and Sciences West Coast Conference, San Diego, California. March 19-22. Page 49 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** https://iavi. rti.org/WorkshopsAndCo nferences.cfm?PagelD=documentDetails&Attach ID =549. Additional Information DeVaull, G. 2007. Indoor vapor intrusion with oxygen-limited biodegradation for a subsurface gasoline source. Environmental Science and Technology 41(9):3241-3248. Hers, I., J. Atwater, L. Li, and R. Zapf-Gilje. 2000. Evaluation of Vadose Zone Biodegradation of BTX Vapours. Journal of Contaminant Hydrology 46:233-264. Hers, I., D. Evans, R. Zapf-Gilje, and L. Li. 2002. Comparison, Validation and Use of Models for Predicting Indoor Air Quality from Soil and Groundwater Contamination. Journal of Soil and Sediment Contamination ll(4):491-527. Hers, I., P. Jourabchi, M. Lahvis, P. Dahlen., E.H. Luo, P. Johnson, and U. Mayer. 2012 (in preparation). Cold Climate Study of Soil Vapor Intrusion at a Residential House above a Petroleum Hydrocarbon Plume. Lahvis, M.A., A.L. Baehr, and R.J. Baker. 1999. Quantification of aerobic biodegradation and volatilization rates of gasoline hydrocarbons near the water table under natural attenuation conditions. Water Resources Research 35(3):753-765. Lahvis, M.A., A.L. Baehr, and R.J. Baker. 1996. Estimation of rates of aerobic hydrocarbon biodegradation by simulation of gas transport in the unsaturated zone. Water Resources Research 32(7):2231-2249. Leahy, J. G., and R.R. Colwell. 1990. Microbial degradation of hydrocarbons in the environment. Microbiological Reviews 54(3):305-315. Page 50 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** 6. Mobile And Residual Light Non-Aqueous Phase Liquid (LNAPL) Description LNAPLs released from petroleum USTs are typically fuel products such as gasoline and diesel fuel. Fuel products are comprised of a large number of PHCs and synthetic additives. Among these compounds are some that are volatile and some that are semi-volatile. Newer releases (especially gasoline), which have not been subject to weathering for any appreciable length of time, will generate more vapors than older releases since they will contain a higher proportion of more volatile PHCs. Vapors emanating from dissolved-phase sources are primarily BTEX and other aromatic hydrocarbons, and relatively water-soluble PHCs. Vapors emanating from LNAPL sources contain the same constituents in addition to a sizeable fraction of aliphatic and relatively insoluble hydrocarbons, especially if the source is large or un-weathered (Lahvis, et al., 2012; EPA, 2013). Importance Depending upon the volume of the release and the characteristics of the soil, hydrocarbon vapors from LNAPL sources can reach concentrations high enough to deplete oxygen needed by microorganisms to biodegrade them. Compared to a dissolved plume, a LNAPL plume from a leaking UST does not typically migrate far from the site of release (e.g., the leaking UST itself or connected piping). However, the larger the mass of the release the greater the potential for the LNAPL plume to migrate. When LNAPL underlies a receptor or comes into direct contact with a basement, foundation, or slab, there is increased potential for explosive levels of vapors to accumulate within the building or other structure. Residual hydrocarbons are non-mobile in the subsurface and occur when the release stops prior to the accumulation of a sufficient amount of LNAPL for flow to occur, or when a fluctuating water table smears the LNAPL across the water table and reduces the LNAPL saturation of the soil. This smearing, coupled with water-filled porosity, inhibits the lateral migration of LNAPL. Although residual contamination is not free flowing, residual sources represent a large mass of contaminants that can persist for long periods of time and can generate considerable volumes of petroleum vapors as well as dissolved-phase contaminants. Assessment The distinction between the LNAPL and dissolved phases is important, though the precise threshold is difficult to pinpoint.17 As a somewhat conservative estimate, EPA (2013) used a threshold for the benzene groundwater concentration equal to 5 mg/L and a total petroleum hydrocarbon (TPH)-threshold groundwater concentration of 30 mg/L for identification of LNAPL sites. The TPH threshold was adopted based on the calculated approximate average ratio of 17 Table 4 in EPA (2013) presents a variety of direct and indirect indicators of LNAPL For example, Bruce, et al. (1991) suggest groundwater concentrations greater than one-fifth (0.2) of the effective solubility of LNAPL as indirect evidence of the presence of LNAPL. However, because the effective solubility depends on characteristics of the LNAPL mass (e.g., composition, weathering); there is uncertainty in the threshold. Additional discussions of screening concentrations for LNAPL are presented in Non-Aqueous Phase Liquid (NAPL) Mobility Limits in Soil (API, 2000). Page 51 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** the concentration of benzene to TPH in groundwater at UST sites in the PVI database. A site with a LNAPL source was identified on the basis of either the benzene or TPH groundwater concentration exceeding the threshold. The thresholds adopted for identifying LNAPL sites based on soil concentrations are 10 mg/kg benzene and 250 mg/kg TPH (gasoline). Direct means for detecting the presence of LNAPL also apply. These would include measurable accumulations of free product in monitoring wells, an oily sheen on the water, and saturation of bulk soil samples.18 Special Considerations The presence of residual LNAPL may not be recognizable from monitoring well data. This is because the soil is not sufficiently saturated with LNAPL to allow it to flow into wells. Monitoring wells with residual LNAPL (above 30 mg/L TPH and/or 5 mg/L benzene) may not have a measurable accumulation of LNAPL so they look exactly like monitoring wells with only dissolved contamination (that is, there is no measurable LNAPL in the monitoring well). However, due to the presence of residual LNAPL, the vapor source area acts like a free-phase LNAPL source in terms of vapor-generating character (Lahvis, et al., 2012). This situation is depicted in Figure 7. Recommendation As part of site characterization and CSM development, EPA recommends analyzing bulk soil samples collected in the source area for TPH and specific petroleum constituents (e.g., BTEX and other volatile and semi-volatile organic chemicals, and fuel additives). It may be prudent to collect and analyze samples of LNAPL. This information, in addition to providing useful information for assessing PVI potential (such as determining whether the LNAPL has been degraded), can also inform decision making related to subsurface source remediation and risk management. EPA recommends that the full extent and location of LNAPL (both mobile LNAPL and residual) be determined through subsurface sampling as part of site characterization and CSM development. LNAPL may be present even when there is no measureable accumulation of free product in a monitoring well. In addition, federal regulations (40 CFR280.64) require that when free product is present, it must be "removed to the maximum extent practicable as determined by the implementing agency." Effective source removal will mitigate a long term source of contaminant vapors as well as dissolved and residual LNAPL contamination. 18 Consistent with the findings in EPA (2013) EPA recommends that these same thresholds also be applied for PVI investigations conducted using this guidance. Page 52 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** ACTTHESAME LOOK THE SAME MW UNSATURATED ZONE te.iv. ¦( PILLARY ZONEf SATURATED ZONE q) free-phase LNWPl source MW UNSATURATED ZONE I (CAPILLARY Z0NE( SATURATED ZONE b) residual-phase LNAPL source MW UNSATURATED ZONE * CAPILLARY ZONE i SATURATED ZONE c) dissolved-phase source LEGEND LNAPL (free- or residual-phase) Dissolved phase V Water Table \ PHC I Vapors MW Monitoring Well Figure 7. Conceptual Model Illustrating The Potential For Vapor Intrusion For a) Free-Phase LNAPL Source, b) Residual-Phase LNAPL Source, And c) Dissolved-Phase Source (source: Lahvis, et al., 2012) References Cited API. 2000. Non-Aqueous Phase Liquid (NAPL) Mobility Limits in Soil. Soil arid Groundwater Research Bulletin No. 9. EPA. 1996. How To Effectively Recover Free Product At Leaking Underground Storage Tank Sites: A Guide For State Regulators. OUST (EPA 510-R-96-0Q1). EPA. 2013. Evaluation Of Empirical Data Studies To Support Soil Vapor Intrusion Screening Criteria For Petroleum Hydrocarbon Compounds (EPA 510-R-13-001). Federal Register. 1988. 40 CFR Parts 280 and 281: Underground storage tanks; technical requirements and state program approval; final rules, September 23,1988. 53(185): 37082-38344. Lahvis, M.A., I. Hers, R.V. Davis, J. Wright, and G.E. DeVaull. 2012 (in press). Vapor Intrusion Screening Criteria for Application at Petroleum UST Release Sites. Groundwater Monitoring and Remediation. Page 53 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** Additional Information Abdul, A.S., S.F. Kia, and T.L. Gibson. 1989. Limitations of monitoring wells for the detection and quantification of petroleum products in soils and aquifers. Ground Water Monitoring Review 9(2):90-99. Ballestero, T.P., F.R. Fiedler and N.E. Kinner. 1994. An investigation of the relationship between actual and apparent gasoline thickness in a uniform sand aquifer. Ground Water 32(5): 708-718. Cohen, R.M., A.P. Bryda, S.T. Shaw, and C.P. Spalding. 1992. Evaluation of visual methods to detect NAPL in soil and water. Ground Water Monitoring Review 12(4):132-141. Farr, A.M., R.J. Houghtalen and D.B. McWhorter. 1990. Volume estimation of light nonaqueous phase liquids in porous media. Ground Water 28(l):48-56. Kemblowski, M.W. and C.Y. Chiang. 1990. Hydrocarbon thickness fluctuations in monitoring wells. Ground Water 28(2):244-252. Lenhard, R.J. and J.C. Parker. 1990. Estimation of free hydrocarbon volume from fluid levels in monitoring wells. Ground Water 28(l):57-67. Newell, C.J., S.D. Acree, R.R. Ross, and S.G. Huling. 1995. Light Nonaqueous Phase Liquids. USEPA/ORD Robert S. Kerr Environmental Research Laboratory, Ada, Oklahoma (EPA- 540-5-95-500). Page 54 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** 7. Groundwater Flow And Dissolved Contaminant Plumes Description Contaminant plumes are dynamic, three-dimensional distributions of contaminants in groundwater. Contaminants dissolved in groundwater can migrate with flowing groundwater thereby spreading contamination. In some aquifers, where the direction and speed of groundwater flow are stable, the plumes are usually long and narrow. Other plumes appear to spread in both the transverse as well as the longitudinal direction. This apparent transverse dispersion may be the direct result of changes in the direction of groundwater flow. What may appear to be transverse dispersion is actually longitudinal dispersion occurring in different directions as the direction of flow changes (EPA, 2005; Wilson, 2003). Importance The potential for PVI from dissolved PHC contaminant plumes is typically limited to cases where there are high concentrations of dissolved contaminants and/or the plume is in direct contact with a building or other structure. Assessment Contaminant plumes generally necessitate three-dimensional monitoring to assess the transient behavior of groundwater flow and the movement of contaminant plumes (EPA, 2004a, b). Contaminant plumes migrate with flowing groundwater, which can exhibit seasonal variations as well as responses to pumping, tides, or river stage.19 Groundwater flow directions can and often change over time, and may require periodic sampling over more than one annual cycle to understand the groundwater flow regime at a given site. (Note: This should not delay additional investigation activities and measures to mitigate or remediate threats to safety and health.) As the plume migrates, appropriate adjustments to the sampling plan should be made to ensure that potential receptors are protected. If new impacts occur, then appropriate mitigation steps can be implemented. Plume monitoring networks should be able to detect changes in plume boundaries as well as fluctuations in the concentrations of geochemical parameters and contaminant concentrations. 19 Groundwater flow directions can change frequently and relatively quickly. Changes in groundwater flow directions may be more prevalent than is realized, because the variation in the direction of groundwater flow is rarely evaluated in any formal way (EPA, 2005). Wilson (2003) studied data from a site in North Carolina where groundwater flow was influenced by the stage of a nearby river. Over the course of one year of monthly monitoring, groundwater flow directions fluctuated by 120 degrees, and was particularly strong over a range of 90 degrees. Wilson et al. (2005) also studied data from a gas station site in New Jersey. Over a six-year period groundwater monitoring data were collected on 23 occasions; the predominant flow direction was 90-degrees from the presumed direction on which the conceptual model was constructed, and the direction of flow fluctuated by nearly 180 degrees. Mace et al. (1997) studied the variation in groundwater flow directions at 132 gas stations in Texas. Fluctuations in flow directions occurred over a range of 120 degrees. Goode and Konikow (1990) characterized a site where PHCs leaked to the water table. Groundwater flow directions changed nearly 90 degrees in less than four months in response to changing flow conditions in a nearby intermittent stream. Page 55 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** Collection of samples from the contaminant plume is needed to determine the extent of contamination and provide information that can be used to estimate the vapor generation capacity of the dissolved contamination. The contaminant plume should be surrounded by sampling points that are free of contamination. Conventional monitoring wells may provide an incomplete picture of the true distribution of contaminants in groundwater. If the length of the screen in a monitoring well is long compared to the thickness of the plume of contamination, the sample obtained will be diluted by the inflow of clean(er) groundwater from above or below the plume. Also, plumes may dive below the screened interval of the wells leading to the false impression that the plume is shorter than it actually is (EPA, 2005). Special Considerations Dissolved plumes are dynamic and contamination may migrate beneath buildings overtime. This is best evaluated by determining the range of groundwater fluctuations present at the site over at least one annual cycle. However, in the interim, the remaining PVI-related activities should continue. Preferential pathways, if present, may facilitate the intrusion of petroleum vapors into the building. The spread of contamination can be very rapid compared to the velocity of groundwater flow through the soil when preferential transport pathways intersect contaminant plumes. Dissolved petroleum contaminants may threaten building inhabitant's health through their water supply rather than through vapor intrusion. Exposure may occur from wells drawing from a contaminated plume, or contamination permeating the water supply piping. Though fuel constituents generally impart a disagreeable odor and taste, residents may still be exposed to potentially harmful levels of contaminants. Exposure occurs when PHCs volatilize from the dissolved phase during showering, washing, or ingesting contaminated water. Identifying the mechanism of exposure is important because methods for remediation/mitigation of PVI will be different than treatment/remediation of contaminated groundwater. Volatilization of contaminants from the plume into soil vapor is greatly reduced when a plume dives beneath the water table surface. Volatile contaminants are slower to diffuse through the water column than through soil gas. Recommendation EPA recommends groundwater monitoring and sampling to determine the depth to contaminated groundwater in relation to overlying buildings and the concentration of contaminants. Due to the transient nature of groundwater migration, periodic monitoring and sampling over more than one annual cycle is generally needed to fully understand the groundwater flow regime at a given site. If groundwater samples contain greater than 30 mg/L TPH (or greater than 5 mg/L benzene), it is possible that residual LNAPL is present (see Section 6). If the depth to contaminated groundwater directly below a building is less than 6 feet, EPA recommends collecting sub-slab soil vapor samples. If the potential for PVI cannot be ruled out based on sub-slab soil vapor sampling, then EPA recommends indoor air sampling to determine Page 56 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** whether PVI is a health threat. Where there is no threat of PVI from contaminated groundwater, EPA recommends that the plume be assessed to determine if remediation is necessary to protect sources of drinking water. References Cited EPA. 2004a. Performance Monitoring of MNA Remedies for VOCs in Ground Water. Office of Research and Development, National Risk Management Research Laboratory, Ada, Oklahoma. April (EPA/600/R-04/027). EPA. 2004b. Monitored Natural Attentuation. Chapter IX in How To Evaluate Alternative Cleanup Technologies For Underground Storage Tank Sites: A Guide For Corrective Action Plan Reviewers (EPA 510-B-94-003; EPA 510-B-95-007; and EPA 510-R-04-002). EPA. 2005. Monitored Natural Attenuation of MTBE as a Risk Management Option at Leaking Underground Storage Tank Sites (EPA/600/R-04/1790). Goode, D.J. and L.F. Konikow. 1990. Apparent Dispersion in Transient Groundwater Flow. Water Resources Research 26(10):2339-2351. Mace, R. E., R. S. Fisher, D. M. Welch, and S. P. Parra. 1997. Extent, mass, and duration of hydrocarbon plumes from leaking petroleum storage tank sites in Texas. Geological Circular 97-1, Bureau of Economic Geology, University of Texas, Austin, Texas. Wilson, J. T. 2003. Fate and transport of MTBE and other gasoline components. In: MTBE Remediation Handbook, Amherst, Massachusetts: Amherst Scientific Publishers, pp.19- 61. Wilson, J.T., C. Adair, P.M. Kaiser, and R. Kolhatkar. 2005. Anaerobic Biodegradation of MTBE at a Gasoline Spill Site. Ground Water Monitoring & Remediation 25(3):103-115. Additional Information Bredehoeft, J.D. and G.F. Pinder. 1973. Mass Transport in Flowing Groundwater. Water Resources Research 9(1):194-210. Gelhar, L.W., C. Welty and K.R. Rehfeldt. 1992. A Critical Review of Data on Field-Scale Dispersion in Aquifers. Water Resources Research 28(7):1955-1974. Greenkorn, R.A. and D.P. Kessler. 1969. Dispersion in Heterogeneous Nonuniform Anisotropic Porous Media. Industrial and Engineering Chemistry 61(9):14-32. Pickens, J.F. and G.E. Grisak. 1981. Scale-Dependent Dispersion in a Stratified Granular Aquifer. Water Resources Research 17(4):1191-1211. Page 57 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** Scheidegger, A.E. 1954. Statistical Hydrodynamics in Porous Media. Journal of Applied Physics 25(8):994-1001. Scheidegger, A.E. 1961. General Theory of Dispersion in Porous Media. Journal of Geophysical Research 66(10):3273-3278. Schwartz, F.W. 1977. Macroscopic Dispersion in Porous Media: The Controlling Factors. Water Resources Research 13(4):743-752. Zheng, C. and S.M. Gorelick. 2003. Analysis of Solute Transport in Flow Fields Influenced by Preferential Flowpaths at the Decimeter Scale. Ground Water 41(2):142-155. Page 58 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** 8. Soil Vapor Profile Description Shallow soil gas typically contains water vapor and fixed gases: nitrogen, oxygen, carbon dioxide, carbon monoxide, and argon. These gases infiltrate into the soil from the atmosphere. Vapor phase PHC contamination may be the result of volatilization from mobile LNAPL released into the subsurface, residual soil contamination (including the smear zone), and dissolved phase contamination. In contrast to gasoline sources, the composition of diesel fuel leads to relatively minimal vapor phase contamination (Prince and Douglas, 2010; Marchal, et al., 2003). In addition to PHCs, soil vapor may also contain degradation products from the breakdown of naturally occurring organic matter and contaminants. The principal gases resulting from the biodegradation of PHCs are carbon dioxide (under aerobic conditions) or methane (under anaerobic conditions). Figure 8 presents a characteristic vertical concentration profile in the unsaturated zone; oxygen concentrations decrease with depth and PHCs (including methane) and carbon dioxide concentrations increase with depth toward the source of contamination. With aerobic biodegradation in unsaturated soils, PHCs degrade, oxygen is consumed, and carbon dioxide is produced. The aerobic biodegradation zone is within oxygenated soil (generally greater than 1 percent oxygen). The impacted (source) zone, which is anaerobic, is characterized by the maximum PHC concentrations (and often LNAPL) and little biodegradation (EPA, 2012). PHC vapor concentrations will generally be much greater adjacent to a LNAPL source than adjacent to a dissolved hydrocarbon plume. If PHC concentrations are high enough, available oxygen may be depleted, which in turn limits aerobic biodegradation. In the oxygenated soil zone (where aerobic biodegradation occurs) the decrease in PHC concentrations is typically quite rapid and occurs over a narrow interval (Abreu, Ettinger, and McAlary, 2009). T his profile may vary somewhat in shape depending on site-specific conditions (Roggemans, Bruce, and Johnson, 2002). The core of any PHC contaminant mass is typically depleted with respect to oxygen, thus anaerobic biodegradation of LNAPL or other organic sources (e.g., ethanol) can produce significant amounts of methane (Anderson and Lovley, 1997; Wiedemeier, et al., 1999; Koenigsberg and Norris, 1999). Methane readily biodegrades under aerobic conditions and, when present, will create an additional oxygen demand (Jewell and Wilson, 2011; Ma, et al, 2012). High concentrations of methane, oxygen, and a source of ignition can create a fire or explosion hazard in confined spaces (such as utility vaults and passages, basements, or garages). Page 59 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** Land Surface A / Oxygenated Soil / / Impacted Soil PHCs + CH I Oxygen Flux PHC + CH4 Flux Increasing Concentration Figure 8. Typical Vertical Concentration Profile In The Unsaturated Zone For PHCs, Carbon Dioxide And Oxygen Importance Aerobic biodegradation of PHC vapors occurs in many subsurface environments (Lahvis, Baker, and Behr, 1998; McHugh, et al. 2010, Roggemans, 1998; Roggemans, Bruce, and Johnson, 2002; ZoBell, 1946; Atlas, 1981; Leahy and Colwell, 1990; DeVaull, 2007). The soil vapor profile can provide confirmation that aerobic biodegradation is occurring in the subsurface. Decreasing oxygen concentration and increasing carbon dioxide and methane concentrations indicate biodegredation of PHCs (Hult and Grabbe, 1988). The potential for PVI is a function of the oxygen demand exerted by all biodegradable vapors, not just the key chemicals of potential concern (Jewell and Wilson, 2011; Ma, et al., 2012). When present, volatile PHCs and methane also exert an oxygen demand that may limit the biodegradation of benzene (Abreu, Ettinger, and McAlary, 2009; Wilson, 2011). Biodegradation rates are stoichiometrically related to the flux of oxygen, carbon dioxide, and methane, which allows for estimation of the biodegradation rate (Lahvis and Baehr, 1996). Vapor concentrations generally decrease with increasing distance from a subsurface vapor source. At a relatively short distance from the source, concentrations of PHCs become negligible primarily due to aerobic biodegradation. Lahvis, Baehr, and Baker (1999) observed that PHCs vapors from a dissolved plume were almost completely degraded within 1 meter above the water table and that significant transport of PHC vapors may only be significant if the vapor source is LNAPL. Page 60 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** Assessment Soil gas samples provide information on the distribution of contamination near the source area, whether biodegradation is occurring, and how effective it is in reducing the potential for PVI. When there is an impermeable surface cover adjacent to a building, soil gas probes should be installed beneath the surface in order for the soil vapor profile to adequately characterize conditions below the surface. For very large buildings, and/or where there is extensive impermeable surface cover, and the vapor source is relatively shallow, sub-slab vapor sampling is recommended to verify that biodegradation is occurring beneath the building. Vapor samples should be analyzed for PHCs, methane, oxygen, and carbon dioxide to assess biodegradation of PHCs (Lahvis, Baehr, and Baker, 1999). Relative depletion and enrichment in argon and nitrogen are indicators of methanogenic and methanotrophic zones (Amos, et al., 2005). An estimate of the total oxygen demand can be determined in two ways: sample for methane and petroleum hydrocarbons (PHCs), or sample and measure the oxygen demand for all the organic compounds in the soil gas at the source. If sampling for all the organic compounds, a simple explosimeter calibrated to methane or a field methane meter equipped with an electrochemical cell can be used. If methane and all the PHCs in soil gas are measured, these concentrations should be converted to an equivalent concentration of benzene and summed (see Section 12 and Figure 9). The total oxygen demand of the aggregate of methane and the PHCs (expressed as an equivalent concentration of benzene) can be used to determine an attenuation factor (a) that can be used along the actual concentration of benzene in soil gas at the source to determine whether aerobic biodegradation is capable of degrading the PHC vapors to acceptable concentrations. In some cases, relatively shallow soil gas samples (less than five feet) will be needed to characterize active biodegradation zones in the shallow soil (e.g., in the presence of shallow contamination sources). Some state regulatory programs do not allow soil gas sampling at depths less than 5 feet based on the misimpression that accurate sampling may not be possible at shallow depths because air from the surface may leak into the sample. However, recent research has shown that the collection of accurate shallow-soil gas samples is possible at depths as shallow as 2 feet below ground surface using appropriate field methods (e.g., leak testing), such as those documented in Temporal Variation ofVOCs in Soils from Groundwater to the Surface (EPA, 2010). Special Considerations There are several factors that can limit replenishment of oxygen to deep soils. These include presence of low permeable layers, concrete or asphalt covering at the surface, high soil moisture from recent rainfall event or from irrigation, and buildings that are so large that oxygen is depleted beneath the center of the building (Patterson and Davis, 2009). However, a recent study by EPA (2013) indicates that for an oxygen shadow20 to form beneath a building, the building must be very large (including the surrounding impermeable cover), and the source 20 For the purposes of this modeling study, an oxygen shadow is defined as less than 1% oxygen. Page 61 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** of vapors must be highly concentrated and in relatively close proximity to the bottom of the building. At sites with a new release or unweathered LNAPL source, the oxygen demand will be high. It is important to determine whether temporal variations in oxygen flux into the vadose zone will limit the effectiveness of aerobic biodegradation, potentially resulting in intermittent vapor intrusion impacts. For such sites, more than one round of soil vapor monitoring may be needed to confirm that aerobic biodegradation consistently prevents PVI impacts at the site. Recommendation EPA recommends that soil vapor samples be analyzed for volatile PHCs, methane, oxygen, and carbon dioxide. Sampling for nitrogen (and other fixed gases) in soil vapor can provide a check on the quality of the analyses since the sum of these gases should be 100 percent. If they are substantially less than 100 percent, then some constituents are unaccounted for and the analyses should be interpreted with caution. EPA recommends that sub-slab soil gas samples be collected for buildings within the lateral inclusion zone if the vertical separation distance between the building basement, foundation, or slab is less than 6 feet for dissolved contamination. For buildings that directly overlie LNAPL masses, and the vertical separation distance is less than 15 feet, EPA recommends sub-slab soil vapor sampling. If the potential for PVI cannot be ruled out based on these sub-slab vapor samples, then indoor air sampling is recommended to determine whether PVI poses a threat to building inhabitants. In addition, for very large buildings and/or where there is extensive impermeable surface covering, EPA recommends that soil vapor samples be collected if there is concern that these conditions may impede the flux of oxygen to the subsurface and create an oxygen shadow. The oxygen content should be greater than 1 percent throughout the thickness of clean, biologically active soil necessary for aerobic biodegradation of PHC vapors emanating from the source. References Cited Abreu, L.D.V, R. Ettinger, and T. McAlary. 2009. Simulated Soil Vapor Intrusion Attenuation Factors Including Biodegradation for Petroleum Hydrocarbons. Ground Water Monitoring and Remediation 29(1):105-117. Amos, R.T., K.U. Mayer, B.A. Bekins, G.N. Delin, and R.L. Williams. 2005. Use of dissolved and vapor-phase gases to investigate methanogenic degradation of petroleum hydrocarbon contamination in the subsurface. Water Resources Research 41(2):W02001. Anderson, R.T., and D.R. Lovley. 1997. Ecology and biogeochemistry of in situ groundwater bioremediation, in Jones, J.G. (ed) Advances in Microbial Ecology, Volume 15, Plenum Press, New York, New York, pp.289-350. Page 62 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** Atlas, R.M. 1981. Petroleum Microbiology. Microbiological Reviews 45(l):180-209. DeVaull, G.E. 2007a. Indoor Vapor Intrusion with Oxygen-Limited Biodegradation for a Subsurface Gasoline Source. Environmental Science & Technology 41(9):3241-3248. EPA. 2010. Temporal Variation of VOCs in Soils from Groundwater to the Surface/Subslab (EPA/600/R-10/118). EPA. 2012. Petroleum Hydrocarbons And Chlorinated Hydrocarbons Differ In Their Potential For Vapor Intrusion. March, http://www.epa.gov/oust/cat/pvi/pvicvi.pdf. EPA. 2013 (manuscript in preparation). Vapor Transport Modeling Simulations to Assess the Impact of Building Footprint on Underlying Oxygen Shadow (EPA 510-R-13-xxx). Jewell, K.P. and J.T. Wilson. 2011. A New Screening Method for Methane in Soil Gas Using Existing Groundwater Monitoring Wells. Ground Water Monitoring and Remediation 31(3):82—94. Koenigsberg, S.S. and R.D. Norris (eds). 1999. Accelerated Bioremediation Using Slow Release Compounds: Selected Battelle Conference Papers 1993-1999. California: Regenesis Bioremediation Products. Lahvis, M.A., and A.L. Baehr. 1996. Estimation of rates of aerobic hydrocarbon biodegradation by simulation of gas transport in the unsaturated zone. Water Resources Research 32(7):2231-2249. Lahvis, M., A. Baehr, and R. Baker. 1999. Quantification of Aerobic Biodegradation and Volatilization Rates of Gasoline Hydrocarbons near the Water Table under Natural Attenuation Conditions. Water Resources Research 35(3):753-765. Leahy, J.G., and R.R. Colwell. 1990. Microbial Degradation of Hydrocarbons in the Environment. Microbiological Reviews 54(3):305-315. Ma, J. W.G. Rixey, G.E. DeVaull, B.P. Stafford, and P.J. J. Alvarez. 2012. Methane Bioattenuation and Implications for Explosion Risk Reduction along the Groundwater to Soil Surface Pathway above a Plume of Dissolved Ethanol. Environmental Science & Technology 46(11):6013-6019. Marchal, R., S. Penet, F. Solano-Serena, and J.-P. Vandecasteele. 2003. Gasoline and oil biodegradation. Oil and Gas Science and Technology 58(4):441-448. McHugh, T., R. Davis, G. DeVaull, H. Hopkins, J. Menatti, and T. Peargin. 2010. Evaluation of vapor attenuation at petroleum hydrocarbon sites. Soil and Sediment Contamination: An International Journal 19(6):725-745. Page 63 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** Patterson, B.M., and G.B. Davis. 2009. Quantification of vapor intrusion pathways into a slab- on-ground building under varying environmental conditions. Environmental Science and Technology 43(3):650-656. Prince, R.C. and G.S. Douglas. 2010. Remediation of petrol and diesel in subsurface from petrol station leaks, in Timmis, K.N. (ed) Handbook of Hydrocarbon and Lipid Microbiology: Part 14, Springer-Verlag, Berlin. Roggemans, S. 1998. Natural Attenuation of Hydrocarbon Vapors in the Vadose Zone. M.S. Thesis, Arizona State University. Roggemans, S., C.L. Bruce, and P.C. Johnson. 2002. Vadose Zone Natural Attenuation of Hydrocarbon Vapors: An Empirical Assessment of Soil Gas Vertical Profile Data. API Technical Bulletin No. 15. American Petroleum Institute, Washington, D.C. Wiedemeier, T.H., H.S. Rifai, C.J. Newell, and J.T. Wilson. 1999. Natural Attenuation of Fuels and Chlorinated Solvents. New York: John Wiley & Sons. Wilson, J.T. 2011. Impact of Methane at Gasoline Spill Sites on the Potential for Vapor Intrusion. Webinar on January 11th, sponsored by the Groundwater Resources Association of California, Sacramento, California. ZoBell, C.E. 1946. Action of Microorganisms on Hydrocarbons. Bacteriological Reviews 10(l-2):l-49. Additional Information Brenner, D. 2010. Results of a Long-Term Study of Vapor Intrusion at Large Buildings at the NASA Ames Research Center. Journal of the Air and Waste Management Association 60(6):747-758. Kristensen, A., T. Poulsen, L. Mortensen, and P. Moldrup. 2010. Variability of Soil Potential for Biodegradation of Petroleum Hydrocarbons in a Heterogeneous Subsurface. Journal of Hazardous Materials 179(l-3):573-580. Lahvis, M., A. Baehr, and R. Baker. 1999. Quantification of Aerobic Biodegradation and Volatilization Rates of Gasoline Hydrocarbons near the Water Table under Natural Attenuation Conditions. Water Resources Research 35(3):753-765. Luo, H., P. Dahlen, P. Johnson, T. Peargin, and T. Creamer. 2009. Spatial Variability of Soil-Gas Concentrations near and beneath a Building Overlying Shallow Petroleum Hydrocarbon- Impacted Soils. Ground Water Monitoring and Remediation 29(1):81-91. Page 64 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** 9. Clean, Biologically Active Soil Description For a PVI investigation, clean soil does not necessarily mean that it is contaminant-free, but rather that the level of any contamination present is low enough so that the biological activity of the soil is not diminished and the subsurface environment will support sufficient populations of microorganisms to aerobically biodegrade PHC vapors. The oxygen demand of the contamination present in the soil must be low enough so that aerobic microorganisms are not inhibited from biodegrading PHC vapors in less time than it would take for vapors to migrate from the contaminant source into a building. Effective aerobic biodegradation of PHCs depends on the soil having sufficient oxygen and enough moisture to provide a habitat for adequate populations of active microorganisms. Although most soils contain indigenous microorganisms capable of degrading PHC vapors, typically there is an acclimation period between the time they are exposed to the PHC vapors and the time they begin to biodegrade the vapors. Prior exposure to PHCs has been observed to both increase the number of microbes and the microbial mass available for biodegradation of the PHCs and consequently speed up the degradation rate (ZoBell, 1946; Moyer, et al., 1996; Phelps and Young, 1999; and Siddique, et al., 2007). The actual habitat of soil bacteria is the thin film of water held to the surface of soil particles by capillary attraction. EPA (2013) notes that soil moisture content greater than 2 percent is adequate to support biodegradation activity (Leeson and Hinchee, 1996), although it is limited when the moisture content is at or below the permanent wilting point (Zwick, et al., 1995; Holden, Halverson, and Firestone, 1997). Adequate soil moisture is also indicated if the landscape supports the growth of indigenous vegetation (Riser-Roberts, 1992). Certain geologic materials do not qualify as biologically active soil. These geologic materials include: • Coarse sand and gravel with a low content of silt, clay, or organic matter. • Fractured consolidated rock. • Consolidated rock with solution channels (i.e., karst). Importance Effective aerobic biodegradation of PHCs depends on a thick layer of soil having sufficient oxygen and enough soil water to provide a habitat for adequate populations of active microorganisms. If oxygen is present, these organisms will generally consume available PHCs. Furthermore, aerobic biodegradation of petroleum compounds can occur relatively quickly, with degradation half-lives as short as hours or days under some conditions (DeVaull, 2007). Some petroleum compounds can also biodegrade under anaerobic conditions; however, above the water table, where oxygen is usually available in the soil zone, this process is less important because it is generally much slower than aerobic biodegradation (Widdel, Boetius, and Rabus, 2006; Bailey, Jobson, and Rogers, 1973; and Bruce, Kolhatkar, Cuthbertson, 2010). Page 65 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** Assessment Scientific research and site characterizations have demonstrated that microorganisms capable of aerobically degrading many PHCs are present in nearly all subsurface soil environments (ZoBell, 1946; Atlas, 1981; Wilson, et al., 1986; Leahy and Colwell, 1990; Bedient, Rifai, and Newell, 1994; EPA, 1999). A number of well-characterized field studies demonstrate extensive aerobic biodegradation of PHC vapors in unsaturated soils (Kampbell, et al., 1987; Ostendorf and Kampbell, 1991; Ririe and Sweeney, 1995; Ririe, et al., 1998; Ostendorf, et al., 2000; Hers, et al., 2000; Roggemans, Bruce, and Johnson, 2002; Sanders and Hers, 2006; Davis, Patterson, and Trefry, 2009; Patterson and Davis, 2009; Lahvis, Baehr, and Baker, 1999; and Lavhis and Baehr, 1996). Several of these studies document vapor concentrations at least two to three orders of magnitude lower than would be predicted to occur merely by simple diffusion in the absence of biodegradation. As previous discussed in Section 5, EPA (2013) presents findings of an analysis of a large number of vapor samples from leaking UST sites across the United Sates These results, which are consistent with several recent analyses of different PVI databases (and which are summarized in the report), indicate that in most settings, PHC vapors are biodegraded over relatively short distances in clean, biologically active soil. The vertical separation distances adequate to eliminate the potential for PVI identified in EPA (2013) are 5.4 feet for dissolved sources, and 13. 5 feet for LNAPL sources. These distances are believed to be conservative in most environmental settings. Special Considerations Coarse sand and gravel with a low content of silt, clay, organic matter, fractured consolidated rock, or consolidated rock with solution channels, may not have enough soil moisture in contact with soil gas to support adequate densities of biologically active microorganisms. Particularly in cases with shallow contamination, site investigations should evaluate whether a sufficiently thick layer of clean, biologically active soil is present below buildings in the lateral inclusion zone. In addition, beneath very large buildings or under areas of extensive impermeable surface cover, soil moisture content may be lower than optimal to support an adequate population of biologically active microorganisms necessary to degrade PHC vapors and prevent PVI (see Tillman and Weaver, 2007). Recommendation EPA (2013) recommends a threshold concentration 100 mg/kg TPH for clean soil. Except for the geological materials identified above, most soils contain indigenous microorganisms, sufficient oxygen, and adequate soil moisture necessary for degrading PHC vapors. Thus, it is typically not necessary to run microcosm studies or plate counts to test for microbial presence. If the conditions at the site are uncertain for supporting aerobic biodegradation, EPA recommends that appropriate samples be collected and analyzed to verify conditions at the site. Page 66 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** The vertical separation distances described in this guidance (see Section 5) should not be used at sites where the geologic materials listed above occur because they may not have enough soil moisture in intimate contact with soil gas to support adequate densities of biologically active microorganisms necessary to biodegrade PHCs. References Cited Atlas, R.M. 1981. Microbial degradation of petroleum hydrocarbons: an environmental perspective. Microbiological Reviews 45(l):180-209. Bailey, N.J.L., A.M. Jobson, and M.A. Rogers. 1973. Bacterial degradation of crude oil: Comparison of field and experimental data. Chemical Geology 11(3):203-221. Bedient, P.B., H.S. Rifai, and C.J. Newell. 1994. Ground Water Contamination: Transport and Remediation. PTR Prentice-Hall, Inc., Englewood Cliffs, New Jersey. Bruce, L., A. Kolhatkar, and J. Cuthbertson. 2010. Comparison of BTEX Attenuation Rates Under Anaerobic Conditions. International Journal of Soil, Sediment and Water 3(2): Article 11. DeVaull, G. 2007. Indoor vapor intrusion with oxygen-limited biodegradation for a subsurface gasoline source. Environmental Science and Technology 41(9):3241-3248. EPA. 1999. Monitored Natural Attenuation of Petroleum Hydrocarbons. Remedial Technology Fact Sheet (EPA/600/F-98/021). EPA. 2002. Draft Guidance for Evaluating the Vapor Intrusion to Indoor Air Pathway from Groundwater and Soils (EPA 530-D-02-004). EPA. 2013. Evaluation Of Empirical Data To Support Soil Vapor Intrusion Screening Criteria For Petroleum Hydrocarbon Compounds (EPA 510-R-13-001). Hers, I., J. Atwater, L. Li, and R. Zapf-Gilje. 2000. Evaluation of vadose zone biodegradation of BTX vapours. Journal of Contaminant Hydrology 46(3-4):233-264. Holden, P.A., L.J. Halverson, and M.K. Firestone. 1997. Water Stress Effects on Toluene Biodegradation by Pseudomonas putida. Biodegradation 8(3):143-151. Kampbell, D.H., J.T. Wilson, H.W. Read, and T.T. Stocksdale. 1987. Removal of volatile aliphatic hydrocarbons in a soil bioreactor. Journal of the Air Pollution Control Association 37:1236-1240. Page 67 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** Lahvis, M.A., A.L. Baehr, and R.J. Baker. 1999. Quantification of aerobic biodegradation and volatilization rates of gasoline hydrocarbons near the water table under natural attenuation conditions. Water Resources Research 35(3):753-765. Lahvis, M.A., A.L. Baehr, and R.J. Baker. 1996. Estimation of rates of aerobic hydrocarbon biodegradation by simulation of gas transport in the unsaturated zone. Water Resources Research 32(7):2231-2249. Leahy, J. G., and R.R. Colwell. 1990. Microbial degradation of hydrocarbons in the environment. Microbiological Reviews 54(3):305-315. Leeson, A., and R.E. Hinchee. 1996. Principles and Practices of Bioventing. Volume 1: Bioventing Principles and Volume 2: Bioventing Design. Battelle Memorial Institute. September. Moyer, E.E., D.W. Ostendorf, R.J. Richards, and S. Goodwin. 1996. Petroleum hydrocarbon bioventing kinetics determined in soil core, microcosm, and tubing cluster studies. Groundwater Monitoring and Remediation 16(1):141-153. Ostendorf, D.W., E.S. Hinlein, A.J. Lutenegger, and S.P. Kelley. 2000. Soil gas transport above a jet fuel/solvent spill at Plattsburgh Air Force Base. Water Resources Research 36(9): 2531-2547. Ostendorf, D.W., and D.H. Kampbell. 1991. Biodegradation of hydrocarbon vapors in the unsaturated zone. Water Resources Research 27(4):453-462. Patterson, B.M., and G.B. Davis. 2009. Quantification of vapor intrusion pathways into a slab- on-ground building under varying environmental conditions. Environmental Science and Technology 43(3):650-656. Phelps, C.D., and L.Y. Young. 1999. Anaerobic biodegradation of BTEX and gasoline in various aquatic sediments. Biodegradation 10(l):15-25. Ririe, T., and R. Sweeney. 1995. Fate and transport of volatile hydrocarbons in the vadose zone. In: Proceedings of the 1995 Petroleum Hydrocarbon and Organic Chemicals in Groundwater Conference, American Petroleum Institute and the National Ground Water Association, Houston, Texas, pp. 529-542. Ririe, T., R. Sweeney, S. Daughery, and P. Peuron. 1998. A vapor transport model that is consistent with field and laboratory data. In: Proceedings of the 1998 Petroleum Hydrocarbon and Organic Chemicals in Groundwater Conference, American Petroleum Institute and the National Ground Water Association, Houston, Texas. Page 68 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** Riser-Roberts, E. 1992. Bioremediation of Petroleum Contaminated Sites. Florida: CRC Press, Inc. Roggemans, S., C.L. Bruce, and P.C. Johnson. 2002. Vadose Zone Natural Attenuation of Hydrocarbon Vapors: An Empirical Assessment of Soil Gas Vertical Profile Data. API Technical Bulletin No. 15. American Petroleum Institute, Washington, D.C. Sanders, P.F., and I. Hers. 2006. Vapor intrusion into homes over gasoline-contaminated ground water in Stafford, New Jersey. Groundwater Monitoring and Remediation 26(l):63-72. Siddique, T., P.M. Fedorak, M.D. Mackinnon, and J.M. Foght. 2007. Metabolism of BTEX and naphtha compounds to methane in oil sands tailings. Environmental Science and Technology 41(7):2350-2356. Tillman, F. and J. Weaver. 2007. Temporal Moisture Content Variability Beneath and External to a Building and the Potential Effects on Vapor Intrusion Risk Assessment. Science of the Total Environment 379:1-15. Wang, X. and M.A. Deshusses. 2007. Biotreatment of groundwater contaminated with MTBE: Interaction of common environmental co-contaminants. Biodegradation 18(l):37-50. Widdel, F., A. Boetius, and R. Rabus. 2006. Anaerobic biodegradation of hydrocarbons including methane. Prokaryotes 2:1028-1049. Wilson, J.T., L.E. Leach, M. Henson, and J.N. Jones. 1986. In situ biorestoration as a ground water remediation technique. Ground Water Monitoring Review 6(4):56-64. ZoBell, C.E. 1946. Action of microorganisms on hydrocarbons. Bacteriological Reviews 10(1-2): 1-49. Zwick, T.C., A. Leeson, R.E. Hinchee, L. Hoeppel, and L. Bowling. 1995. Soil Moisture Effects During Bioventing in Fuel-Contaminated Arid Soils. Third International In-Situ and On- Site Bioreclamation Symposium. In-Situ Aeration, v. 3, Battelle Press, San Diego, California. Page 69 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** 10. Contaminants Other Than PHCs Description Petroleum fuels are comprised of hundreds of compounds, both natural components of petroleum as well as a number of synthetic organic additives intended to improve certain performance properties of the fuel. Contaminants other than PHCs may be present at a site as the result of releases of petroleum fuels that contain additives, including alcohols (e.g., ethanol and tertiary-butyl alcohol [TBA]), ethers (e.g., MTBE), organic lead (e.g., the tetraalkyl lead compounds: tetraethyl lead [TEL], and tetramethyl lead [TML]), and lead scavengers (e.g., EDB and 1,2-DCA). Non-petroleum contaminants may be from releases of substances other than petroleum fuels (e.g., solvents). Their presence may be from prior uses of the site or as the result of migration from off-site sources (e.g., dry cleaner, chemical plant, landfill).21 Importance Biodegradation of many PHCs and some fuel additives (such as alcohols, ethers, organic lead, and lead scavengers) is well recognized, and occurs under both aerobic and anaerobic conditions.22 Specifically, aerobic biodegradation has been observed for several classes of compounds that are, or have been, constituents of petroleum fuels, including: • Alcohols, in particular: o Ethanol (Powers, et al., 2001; Corseuil et. al, 1998). o TBA (Wang and Deshusses, 2007; Landmeyer, et al., 2010). o Methanol (Powers, et al., 2001). • Ethers, in particular: o MTBE (Prince and Douglas, 2010; Wang and Deshusses, 2007; Phelps and Young, 1999; Landmeyer and Bradley, 2003; Landmeyer, etal., 2010; Bradley and Landmeyer, 2006; Kuder, 2005; Lesser, et al., 2008; Baehr, Charles, and Baker, 2001). o Tertiary-amyl methyl ether (TAME) (Landmeyer, et al., 2010). • Organic lead compounds (Prince and Douglas, 2010; Gallert and Winter, 2004). • The lead scavengers23, in particular: o EDB (Prince and Douglas, 2010; Pignatello, 1986). o 1,2-DCA (Falta, 2004). 21 While these substances are not the primary focus of a petroleum UST investigation (including site characterization and subsequent cleanup, if necessary), there is the possibility that their presence may be detected through the use of certain analytical methods for identification of contaminants in groundwater, soil, and vapor samples. In particular, both EPA methods 8260B (EPA, 1996a) and 8021B (EPA, 1996b) can detect a number of volatile chlorinated solvents that are not associated with petroleum fuels or typically stored in USTs. As federal monies from the Leaking Underground Storage Tank Trust Fund cannot be used to assess or cleanup contamination from non-UST and non-petroleum sources, should any contaminants from non-UST sources be discovered at a site, the appropriate state and/or federal cleanup agency should be notified. 22 Although anaerobic biodegradation is slower than aerobic biodegradation, anaerobic biodegradation may be a significant mechanism for destruction of PHCs, especially in source areas. Some selected references on anaerobic biodegradation of various non-petroleum compounds are listed under "Additional Information" at the end of this section. 23 For more information about EDB and 1,2-DCA see EPA (2006) and Appendix F in EPA (2013). Page 70 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** Alternative fuels, especially those that contain higher percentages of non-petroleum constituents (ethanol in particular), present a different type of vapor intrusion problem (Jewell and Wilson, 2011; Ma, et al., 2012; Freitas, et al., 2010). On the one hand, alcohols have a greater tendency than ethers to remain in the dissolved phase, and they readily biodegrade to create methane. Methane generation may be more significant at sites where large volumes of ethanol-blended gasoline (and higher ethanol content fuels) have been released into the subsurface. As the ethanol content increases, so does the potential for creating larger volumes of methane. Methane production can increase soil gas pressures and may result in advective soil gas flow toward receptors. In such situations, intrusion of methane into confined spaces may result in the accumulation of very high concentrations creating a risk of fire and explosion. On the other hand, methane also biodegrades under aerobic conditions and consumes oxygen that otherwise could be available for the biodegradation of the PHC contaminants. The depletion of oxygen may result in PHC vapors being transported farther than they otherwise would be, possibly increasing the threat of PVI. Assessment Federal UST regulations stipulate that when conducting an investigation of a release from a regulated UST, investigators "must measure for the presence of a release where contamination is most likely to be present. In selecting sample types, sample locations, and measurement methods [investigators] must consider the nature of the stored substance, the type of initial alarm or cause for suspicion, the type of backfill, the depth of groundwater, and other factors appropriate for identifying the presence and source of release" (40 CFR 280.52(b)). Results of this sampling should also indicate which contaminants should be assessed for potential vapor intrusion. See Section 3 for a more detailed discussion of site characterization and CSMs. Special Considerations The literature is relatively sparse in regard to ethanol releases at leaking UST sites in the United Sates. Most of the releases that have been studied have been E-10 (10 percent ethanol and 90 percent gasoline), though some E-85 (85 percent ethanol and 15 percent gasoline) releases in the Midwest have also been studied. It is anticipated that as the proportion of ethanol increases in gasoline, the methane generation potential will also increase, though specifics are as yet unknown. Other potential concerns with increasing ethanol content are in relation to (re)mobilization of LNAPL (McDowell, et al., 2003; Yu, et al., 2009) and increased solubility of PHCs (Powers, et al., 2001). Though the use of lead scavengers and ethers (e.g., MTBE) in gasoline have been reduced or eliminated in recent years, these compounds may still be present at some older petroleum release sites (Weaver, et al., 2005, 2008, 2009). Ethers tend to remain in the dissolved phase as indicated by their relatively low Henry's Law constants. Therefore, though they may be a problem from the perspective of groundwater-pollution, they are not likely to be a common vapor intrusion problem at leaking UST sites (McHugh, et al., 2012). Page 71 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** Recommendation EPA recommends that soil and groundwater samples be analyzed for PHCs typically found in petroleum-based fuels, in addition to other volatile additives (e.g. ethers and alcohols- especially ethanol) that are constituents of petroleum-based fuels. Soil vapor samples should be collected and analyzed for PHCs, VOCs, methane, oxygen, carbon dioxide (and optionally nitrogen), and any fuel additives. From these data, assess whether the non-PHC constituents exert an oxygen demand that could result in less aerobic biodegradation of PHCs, and/or present a potential vapor intrusion threat themselves. References Cited Baehr, A.L., E.G. Charles, and R.J. Baker. 2001. Methyl tert-butyl ether degradation in the unsaturated zone and the relation between MTBE in the atmosphere and shallow groundwater. Water Resources Research 37(2):223-233. Bradley, P.M., and J.E. Landmeyer. 2006. Low-temperature MTBE biodegradation in aquifer sediments with a history of low, seasonal ground water temperatures. Ground Water Monitoring and Remediation 26(1):101-105. Corseuil, H.X., C. Hunt, R. dos Santos Ferreira, and P.J.J. Alvarez. 1998. The influence of the gasoline oxygenate ethanol on aerobic and anaerobic BTX biodegradation. Water Research 32(7):2065-2072. EPA. 1996a. Method 8021B: Aromatic and Halogenated Volatiles by Gas Chromatography using Photoionization and/or Electrolytic Conductivity Detectors. EPA. 1996b. Method 8260B: Volatile Organic Compounds by Gas Chromatography/Mass Spectrometry (GC/MS). EPA. 2006. Lead Scavengers Compendium: Overview Of Properties, Occurrence, And Remedial Technologies, http://www.epa.gov/oust/cat/pbcompnd.htm. EPA. 2008. Natural attenuation of the lead scavengers 1,2-dibromoethane (EDB) and 1,2- dichloroethane (1,2-DCA) at motor fuel release sites and implications for risk management (EPA 600/R-08/107). http://nepis.epa.gov/Exe/ZyPDF.cgi?Dockey=P1002UTI.PDF. EPA. 2013. Evaluation Of Empirical Data To Support Soil Vapor Intrusion Screening Criteria For Petroleum Hydrocarbon Compounds (EPA 510-R-13-001). Falta, R.W. 2004. The potential for ground water contamination by the gasoline lead scavengers ethylene dibromide and 1,2-dichloroethane. Ground Water Monitoring and Remediation 24(3):76-87. Page 72 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** Freitas, J.G., B. Fletcher, R. Aravena, and J.F. Barker. 2010. Methane production and isotopic fingerprinting in ethanol fuel contaminated sites. Ground Water 48(6):844-857. Gallert, C. and J. Winter. 2004. Degradation of alkyllead compounds to inorganic lead in contaminated soil. Water Research 38(19):4204-4212. Jewell, K.P. and J.T. Wilson. 2011. A New Screening Method for Methane in Soil Gas Using Existing Groundwater Monitoring Wells. Ground Water Monitoring and Remediation 31(3):82-94. Kuder, T., J.T. Wilson, P. Kaiser, R. Kolhatkar, P. Philp, and J. Allen. 2005. Enrichment of Stable Carbon and Hydrogen Isotopes during Anaerobic Biodegradation of MTBE: Microcosm and Field Evidence. Environmental Science and Technology 39(l):213-220. Landmeyer, J.E., and P.M. Bradley. 2003. Effect of hydrologic and geochemical conditions on oxygen-enhanced bioremediation in a gasoline-contaminated aquifer. Bioremediation Journal 7(3-4):165-177. Landmeyer, J.E., P.M. Bradley, D.A. Trego, K.G. Hale, and J.E. Haas, II. 2010. MTBE, TBA, and TAME attenuation in diverse hyporheic zones. Ground Water 48(1):30-41. Lesser, L. E., P.C. Johnson, R. Aravena, G.E. Spinnler, C.L. Bruce, and J.P. Salanitro. 2008. An evaluation of compound-specific isotope analyses for assessing the biodegradation of MTBE at Port Hueneme, California. Environmental Science and Technology 42(17) :6637-6643. Ma, J. W.G. Rixey, G.E. DeVaull, B.P. Stafford, and P.J. J. Alvarez. 2012. Methane Bioattenuation and Implications for Explosion Risk Reduction along the Groundwater to Soil Surface Pathway above a Plume of Dissolved Ethanol. Environmental Science & Technology 46(11):6013-6019. McDowell, C.J., T. Buscheck, and S.E. Powers. 2003. Behaviour of gasoline pools following a denatured ethanol spill. Ground Water 41(6):746-757. McHugh, T.E., R. Kamath, P.R. Kilkarni, C.J. Newell, J.A. Connor, and S. Garg. 2012. Remediation progress at California LUFT sites: insights from the Geotracker database. Soil and Groundwater Research Bulletin No. 25; API: Washington, D.C. Phelps, C.D., and L.Y. Young. 1999. Anaerobic biodegradation of BTEX and gasoline in various aquatic sediments. Biodegradation 10(l):15-25. Pignatello, J.J. 1986. Ethylene dibromide mineralization in soils under aerobic conditions. Applied and Environmental Microbiology 51(3):588-592. Page 73 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** Powers, S.E., C.S. Hunt, S.E. Heermann, H.X. Corseuil, D. Rice, and P.J.J. Alvarez. 2001. The transport and fate of ethanol and BTEX in groundwater contaminated by gasohol. Critical Reviews in Environmental Science and Technology 31(1):79-123. Prince, R.C. and G.S. Douglas. 2010. Remediation of petrol and diesel in subsurface from petrol station leaks, in Timmis, K.N. (ed) Handbook of Hydrocarbon and Lipid Microbiology: Part 14, Springer-Verlag, Berlin. Wang, X. and M.A. Deshusses. 2007. Biotreatment of groundwater contaminated with MTBE: Interaction of common environmental co-contaminants. Biodegradation 18(l):37-50. Weaver, J.W., L. Jordan and D.B. Hall. 2005. Predicted Ground Water, Soil and Soil Gas Impacts from US Gasolines, 2004: First Analysis of the Autumnal Data, United States Environmental Protection Agency, Washington, D.C. (EPA/600/R-05/032). Weaver, J.W., L.R. Exum, L.M. Prieto. 2008. Gasoline Composition Regulations Affecting LUST Sites, United States Environmental Protection Agency, Washington, D.C. (EPA/600/R- 10/001). Weaver, J.W., S. A. Skaggs, D.L. Spidle, and G.C. Stone. 2009. Composition and Behavior of Fuel Ethanol, United States Environmental Protection Agency, Washington, D.C. (EPA/600/R- 09/037). Yu, S., J.G. Freitas, A.J.A. Unger, J.F. Barker, and J. Chatzis. 2009. Simulating the evolution of an ethanol and gasoline source zone within the capillary fringe. Journal of Contaminant Hydrology 105(1-2):1-17. Additional Information Donaldson, C.B., J.F. Barker, and I. Chatzis. 1994. Subsurface Fate and Transport of a Methanol/Gasoline Blend (M85). Report prepared for the American Petroleum Institute, Washington D.C., Publication number 4569. Eichler, B. and B. Schink. 1984. Oxidation of primary aliphatic alcohols by Acetobacterium carbinolicum sp. nov., a homoacetogenic anaerobe. Archives of Microbiology 140(1- 2):147-152. Henderson, J. K., D.L. Freedman, R.W. Falta, T. Kuder, and J.T. Wilson. 2008. Anaerobic Biodegradation of Ethylene Dibromide and 1,2-Dichloroethane in the Presence of Fuel Hydrocarbons. Environmental Science and Technology 42(3):864-870. Mormile, M.R., S. Liu, and J. Suflita. 1994. Anaerobic biodegradation of gasoline oxygenates: extrapolation of information to multiple sites and redox conditions. Environmental Science and Technology 28(9):1727-1732. Page 74 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** Peargin, T. and R. Kolhatkar. 2011. Empirical data supporting groundwater benzene concentration exclusion criteria for petroleum vapor intrusion investigations. Proceedings of Battelle 8th International Symposium on Bioremediation and Sustainable Environmental Technologies, Reno, Nevada, June 27-30. Suflita, J.M. and M.R. Mormile. 1993. Anaerobic biodegradation of known and potential gasoline oxygenates in the terrestrial subsurface. Environmental Science and Technology 27(6):976-978. Vogel, T. M. and M. Reinhard. 1986. Reaction-products and rates of disappearance of simple bromoalkanes, 1,2-dibromopropane, and 1,2-dibromoethane in water. Environmental Science and Technology 20(10):992-997. Widdel, F. 1986. Growth of methanogenic bacteria in pure culture with 2-propanol and other alcohols as hydrogen donors. Applied Environmental Microbiology 51(5):1056-1062. Page 75 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** 11. Seasonal And Weather Effects Description The generation and movement of petroleum vapors is subject to seasonal effects such as temperature trends and fluctuations; and weather effects such as precipitation, barometric pressure changes, and wind (Lundegard, Johnson, and Dahlen, 2008). Importance Biological processes slow down with decreasing temperatures, though microorganisms continue to biodegrade PHCs at environmentally significant rates even when temperatures are near freezing (Bradley and Chapelle, 1995; Bradley, Richmond, and Chapelle, 2005; Hers, et al., 2011). Bradley and Landmeyer (2006) documented microbial degradation of MTBE in the wintertime when groundwater temperatures were below 5°C. There is conflicting evidence as to whether frozen soil or ice-covered soil reduces the movement of oxygen into the subsurface. Hers, et al. (2011) studied a residential site in Canada where subsurface oxygen readings taken throughout the winter did not indicate a decrease in oxygen content of soil vapor and there was evidence that biodegradation was occurring throughout the winter. However, the house was above a crawl space and the soil below the house was never covered by ice or snow. In addition, Rike (2003) observed ongoing biodegradation in frozen arctic soils. In that study, a lengthy period of subfreezing soil temperatures at a petroleum contaminated site did not result in decreasing oxygen concentrations. However, the air permeability of a snow layer is a complex function of pore size, grain size, ice fraction, and density (Armstrong, 2008, Bender 1957, Conway and Abrahamson 1984). In contrast, oxygen depletion has been observed in other studies of soils under ice sheets and snow cover (Freyman, 1967; Yanaia 2010). More study is needed to resolve this issue. Precipitation events can impact biodegradation of petroleum vapors. A certain amount of soil moisture is necessary for microorganisms to live; not enough and they are not actively degrading PHC vapors; too much and re-oxygenation is impeded, possibly leading to anaerobic conditions at greater depths (Silver, 1999; Ludemann, 2000; Pezeschki, 2001). Changes in barometric pressure can result in enhanced intrusion of PHC vapors into buildings and other structures. Similarly, wind can create differential pressures that can accelerate intrusion of PHC vapors into buildings. Wind and barometric pressure changes can also have the opposite effect, creating positive pressure gradients in basements that both prevent intrusion of PHC vapors into buildings and allow oxygen to enter the soil through cracks, allowing re-oxygenation of the soil beneath the building that would otherwise be depleted in oxygen. Heating systems in buildings, which operate most frequently during winter months, can create a chimney effect whereby PHC vapors are pulled into buildings at much higher rates than they would ordinarily. Cooling systems, which operate only during summer months, can have the opposite effect, creating positive pressure gradients in basements that both prevent intrusion of PHC vapors into buildings and allow oxygen to enter the soil. Page 76 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** Assessment During site characterization activities, weather conditions such as temperature, barometric pressure, and wind speed/direction should be recorded so trends or anomalies in the PVI data may be identified and not attributed to unknown factors. This information may be obtained from the National Oceanic and Atmospheric Administration (NOAA) or a nearby airport where weather data are recorded hourly. In addition, site characteristics that may indicate susceptibility to the effects of seasonal and weather factors should be assessed. These include: • Poor drainage around the building indicated by flooded soils. • Area subject to permafrost/long lasting snow cover (based on altitude or latitude). • Shallow and highly variable water table. Special Considerations Seasonal effects may also influence the formation and migration of dissolved plumes and LNAPL. Groundwater levels in the vicinity of USTs are normally subject to the influence of water within the tank pit. After rainfall events (and potentially snowmelt) water levels within tank pits are typically above the level of ambient groundwater; consequently a groundwater recharge mound forms beneath them. This mound disrupts the local groundwater flow field and contaminants can migrate away from the tank excavation, potentially in all directions. Seasonal changes in water table elevation can also create a smear zone of residual LNAPL contamination that acts as a long-term source of dissolved contamination during periods of high water (as in spring and fall rainy seasons) and as a source of petroleum vapors during periods of low water (typically in the summer) when contaminants reemerge from a previously submerged condition. Recommendation Seasonal and weather conditions are transient, and although typically short-lived, can influence the characteristics of PHC vapor migration over time. Data on temporal changes in these conditions can aid in correctly identifying the cause of trends and result in a more accurate CSM. References Cited Armstrong, R.L., and E. Brun. 2008. Snow and climate: physical processes, surface energy exchange and modeling. Cambridge University Press. Bender, J.A. 1957. Air Permeability of Snow. Res. Rep. 37 Snow, Ice and Permafrost Research Establishment (US Army Corps of Engineers) Wilmette, Illinois p 46-62. Page 77 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** Bradley, P. M., and F. H. Chapelle. 1995. Rapid toluene mineralization by aquifer microorganisms at Adak, Alaska: Implications for intrinsic bioremediation in cold environments. Environmental Science and Technology 29(11) :2778-2781. Bradley, P.M., and J.E. Landmeyer. 2006. Low-temperature MTBE biodegradation in aquifer sediments with a history of low, seasonal ground water temperatures. Ground Water Monitoring and Remediation 26(1):101-105. Bradley, P. M., S. Richmond and F. H. Chapelle. 2005. Chloroethene biodegradation in sediments at 4°C. Applied Environmental Microbiology 71(10):6414-6417. Conway, H. and J. Abrahamson. 1985. Air Permeability as a Textural Indicator of Snow. Journal of Glaciology 30(106):328-333. Freyman, S. 1967. The Nature of Ice Sheet Injury to Forage Plants. Ph.D. Thesis, University of British Columbia, https://circle.ubc.ca/handle/2429/37752. Hers, I., Lahvis, M., Dahlen, P., Luo, E.H., DeVaull, G., and P. Johnson. 2011. Cold climate vapor intrusion research study - results of seasonal monitoring of house at North Battleford, Saskatchewan, in Proceedings 21st Annual International Conference on Soil, Water, Energy and Air and AEHS [Association for Environmental Health and Sciences] Foundation Annual Meeting, March 14-17, 2011, San Diego, California. Ludemann, H. I. Arth, and W. Liesack. 2000. Spatial Changes in the Bacterial Community Structure along a Vertical Oxygen Gradient in Flooded Paddy Soil Cores. Applied Environmental Microbiology 66(2):754-762. Lundegard, P.D., P.C. Johnson, and P. Dahlen. 2008. Oxygen transport from the atmosphere to soil gas beneath a slab-on-grade foundation overlying petroleum-impacted soil. Environmental Science and Technology 42(15):5534-5540. Luo, H., P. Dahlen, P.C. Johnson, T. Peargin, and T. Creamer. 2009. Spatial Variability of Soil- Gas Concentrations Near and beneath a Building Overlying Shallow Petroleum Hydrocarbon-Impacted Soils. Ground Water Monitoring & Remediation 29(1):81-91. Pezeshki, S.R. 2001. Wetland plant responses to soil flooding. Environmental and Experimental Botany 46(3):299-312. Rike, A.G., K.B. Haugen, M.B0rresen, B. Engenec, P. Kolstad. 2003. In situ biodegradation of petroleum hydrocarbons in frozen arctic soils. Cold Regions Science and Technology 37(2):97- 120. Page 78 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** Silver, W.L., A.E. Lugo, and M.Keller. 1999. Soil oxygen availability and biogeochemistry along rainfall and topographic gradients in upland wet tropical forest soils. Biogeochemistry 44(3):301-328. Yanaia,Y., T. Hirotab, Y. Iwataa, M. Nemotob, 0. Nagatac, N. Kogaa. 2011. Accumulation of nitrous oxide and depletion of oxygen in seasonally frozen soils in northern Japan - Snow cover manipulation experiments. Soil Biology and Biochemistry 43(9):1779-1786. Additional Information Hintenlang, E.E., and K.K Al-Ahmady. 1992. Pressure differentials for radon entry coupled to periodic atmospheric pressure differentials. Indoor Air 2:208-215. Luo, H., and P.C. Johnson. 2011. Incorporating Barometric Pressure and Wind Effects into Vapor Intrusion Simulations. Association for Environmental Health and Sciences Conference, Petroleum Hydrocarbon Vapor Intrusion Session, March 16, San Diego, California. Tillman, F. and J. Weaver. 2007. Temporal Moisture Content Variability Beneath and External to a Building and the Potential Effects on Vapor Intrusion Risk Assessment. Science of the Total Environment 379:1-15. U.S. Geological Survey. 1998. Assessment of the Potential for Biodegradation of Petroleum Hydrocarbons in the Railroad Industrial Area, Fairbanks, Alaska, 1993-1994. Open-File Report 98-287. Fairbanks, Alaska. lOp. Web-based Resources: U.S. Geological Survey's soil surveys http://websoilsurvey.nrcs.usda.gov/app/HomePage.htm.. U.S. Department of Homeland Security Federal Emergency Management Agency's flood plain maps https://msc.fema.gov/webapp/wcs/stores/servlet/FemaWelcomeView?storeld=10001&cat alogld=10001&langld=-l. 2012 U.S. Department of Agriculture Plant Hardiness Zone Map http://planthardiness.ars.usda.gov/PHZMWeb/. Page 79 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** 12. Vapor Intrusion Attenuation Factor (a) Description Johnson and Ettinger (1991) introduced their vapor intrusion model and a parameter to relate the vapor concentration of a volatile chemical inside a building to its vapor concentration at the subsurface source. The parameter, designated alpha (a), is also called the vapor intrusion attenuation factor. It is defined mathematically as the concentration in indoor air divided by the concentration in soil gas at the source (with concentrations in the same units), and thus it is a ratio.24 The source is defined as the region of highest vapor concentration in the vadose zone. Therefore, a values are always less than one when vapors are attenuated even if only by a small amount. Where there is no attenuation, the a value would be equal to one. Importance Attenuation is the reduction in the amount of contaminants in a plume as it migrates away from the source. The vapor intrusion attenuation factor is an inverse measurement of the attenuation. Large a values (i.e., values approaching one) indicate that little attenuation is taking place, whereas small a values (i.e., values much smaller than one) indicate that significant attenuation is taking place. Assessment The vapor intrusion attenuation factor can be either measured, when background sources do not contribute significantly to indoor air concentrations, or estimated, using a mathematical model. On a building-specific basis, if both the source vapor concentration and the indoor air concentration arising from PVI are known, calculation of a is straightforward. If the indoor air concentration is not known, but concentration at the source is known and a suitable value for a can be estimated, the indoor air concentration may be estimated by multiplying the measured concentration at the source with the estimated value of a. Abreu, Ettinger, and McAlary (2009) used a series of computer simulations to estimate semi- generic values of a from site-specific information on the vertical separation between the receptor building and the source, and the total concentration of biodegradable compounds in soil gas. The simulations assume the building is surrounded by homogeneous, uniform sandy soil that is directly exposed to the atmosphere and that preferential pathways for vapor migration into the building or through the vadose zone are not present. As a result, the concentration of oxygen in the soil gas in the topmost layer of exposed soil is the concentration of oxygen in the atmosphere. Compared to silty or clayey soils, sandy soils have more air filled porosity and as a result, vapors diffuse more rapidly through them (and they also allow more oxygen to diffuse from the atmosphere). In the simulations, the first order rate constant for biodegradation of vapors (A.) was set at 0.0 h 1 (no biodegradation), or 0.079 h"1, or 0.79 h"1, or 2 h"1. The simulations assumed that the square building was 10 meters (33 feet) on each side. 24 a can be understood as the concentration in indoor air normalized to the soil gas source concentration. Page 80 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** One set of simulations assumed that the building had a basement, while another set assumed the building had a slab on grade, From the computer simulations of a vapor migration beneath a building with a basement, Abreu, Ettinger, and McAlary (2009) generated what is effectively a nomograph (Figure 9) from which a can be estimated if the total concentration of vapors and the vertical separation distance between the contaminant source and the building are known. In this particular set of simulations, the first order rate constant (A) was set at 0.79 h"1, a reasonable average rate based on the range of rates published in the literature (DeVaull 2007). In the example below, for a source vapor concentration of 10 mg/L and a vertical separation distance of 2 meters (6.6 feet), the estimated value of a would be 1 x 10 ' . l.E-02 No Biodegradation; L = 1 m l.E-03 No Biodegradation; L = 10 m l.E-04 L = 1 ni l.E-05 L = 2 ill l.E-08 l.E-09 L = 10 ill L = 3 in l.E-10 1 f 10) 100 Source Vapor Coffee ritration (mg/L) A= 0.79 tr1 1000 0.1 Figure 9. Relationship Between Source Vapor Concentration And Vapor Intrusion Attenuation Factor (a) As A Function Of Vertical Separation Depth Between Contaminant Source And Base Of Building (Receptor) (source: modified from Abreu, Ettinger, and McAlary, 2009, Figure 7, page 114) Page 81 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** DeVaull (2007) conducted a modeled sensitivity analysis using a broad range of specified scenario parameters (variation of more than nine orders of magnitude) for a specified attenuation factor of 1 x 10~8 while the corresponding vertical separation distance between the vapor source and the building foundation varied within a factor of only three. He concluded that the attenuation factor is much more variable due to the insensitivity of the model input parameters and thus less robust as a screening criterion than is the vertical separation distance. Lahvis, et al. (1999) reached a similar conclusion. Special Considerations The nomograph (Figure 9) should only be used for UST sites with the same conditions that were simulated by Abreu, Ettinger, and McAlary (2009). If this method is to be used accurately on a site-specific basis, a similar nomograph can be constructed for the soil type(s) encountered at the site(s) in question. Also, while the assumed bioattenuation rate coefficient (i.e., 0.79 h"1) may be appropriate for many situations, it might be optimistically high for areas of low soil moisture, where extensive impermeable surface cover restricts oxygen flux to the subsurface, and where the thickness of the clean, biologically active soil is thin. Some documents define the vapor intrusion attenuation factor differently than described in this section (and Section 13), which is the same as used by Johnson and Ettinger (1991). When used in this PVI guidance, the Greek letter alpha (a) refers strictly to attenuation during vapor intrusion, which might be observable if there were no background (ambient) vapor sources. The Johnson-Ettinger model (JEM) (see Section 13) ignores background sources when estimating the indoor air concentration arising from vapor intrusion. In contrast, some empirical attenuation factors (sometimes designated AF) are based on indoor air concentrations that include a contribution from background sources in addition to vapor concentrations that intrude into the building from a subsurface vapor source. Thus, when there is a measurable contribution from an ambient source, an attenuation factor such as AF—which includes the contribution of ambient sources—would be somewhat greater than the Johnson & Ettinger alpha (a), which would indicate less attenuation than is actually occurring. Recommendation An estimated vapor intrusion attenuation factor may help support screening decisions, although EPA recommends that it not be the sole basis for excluding sites from consideration of potential PVI. Also, it should be noted that generation of site-specific nomographs may be prohibitively complex and expensive and, thus, limit the usefulness of this approach. References Cited Abreu, L.D.V, R. Ettinger, and T. McAlary. 2009. Simulated Soil Vapor Intrusion Attenuation Factors Including Biodegradation for Petroleum Hydrocarbons. Ground Water Monitoring and Remediation 29(1): 105-117. Page 82 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** DeVaull, G. 2007. Indoor vapor intrusion with oxygen-limited biodegradation for a subsurface gasoline source. Environmental Science and Technology 41(9):3241-3248. Johnson, P.C. and R.J. Ettinger. 1991. Heuristic Model for Predicting the Intrusion Rate of Contaminant Vapors into Buildings. Environmental Science and Technology 25(8):1445- 1452. Lahvis, M.A., Baehr, A.L., and R.J. Baker. 1999. Quantification of aerobic-biodegradation and volatilization rates of gasoline hydrocarbons near the water table during natural- attenuation conditions. Water Resources Research 35(3):753-765. Additional Information Abreu, L.D., and P.C. Johnson. 2005. Effect of Vapor Source, Building Separation and Building Construction on Soil Vapor Intrusion as Studied with a Three-Dimensional Numerical Model. Environmental Science & Technology 3(12):4550-4561. Abreu, L.D., and P.C. Johnson. 2006. Simulating the Effect of Aerobic Biodegradation on Soil Vapor Intrusion into Buildings: Influence of Degradation Rate, Source Concentrations. Environmental Science & Technology 40(7):2304-2315. EPA. 2002. Draft Guidance for Evaluating the Vapor Intrusion to Indoor Air Pathway from Groundwater and Soils. Office of Solid Waste and Emergency Response (EPA 530-D-02- 004). Johnson, P., R.A. Ettinger, J. Kurtz, R. Bryan, and J.E. Kester. 2002. Migration of Soil Gas Vapors to Indoor Air: Determining Vapor Attenuation Factors Using a Screening-Level Model and Field Data from the CDOT-MTL Denver, Colorado Site. API Soil and Groundwater Research Bulletin No. 16. Page 83 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** 13. Computer Modeling of Petroleum Vapor Intrusion Description A number of models have been developed and applied in estimating transport of volatile chemicals from subsurface soil and groundwater to indoor air. Lahvis (2011) presents a summary of 35 different analytical screening-level models, including a discussion of features, and assumptions. Models generally used for simulation of PVI are either the Johnson-Ettinger model (JEM) or BioVapor. Johnson-Ettinger Model (JEM) The JEM was introduced in a publication by Johnson and Ettinger (1991).25 Features of the JEM include: • A steady or transient source of subsurface vapors from groundwater or residual chemicals. • Gaseous-phase diffusive vapor flow through a layer of soil. • Vapor transport through a slab-on-grade or basement foundation. • Building air exchange. The original JEM does not include biodegradation, although later versions have incorporated certain aspects of biodegradation (Johnson, Kemblowski, and Johnson, 1998; Ririe, et al., 1998; Johnson, Hermes, and Roggemans, 2000; Spence and Walden, 2001; Parker, 2003; Environmental Systems and Technologies, 2004; DeVaull, 2007a; Mills, et al., 2007; Turczynowicz and Robinson, 2007; API, 2010; Lahvis, 2011). For sites where PHCs are present and aerobic biodegradation of PHCs occurs in the vadose zone, comparisons to JEM consistently show the model to over-predict indoor air concentrations by at least several orders of magnitude (Fitzpatrick and Fitzgerald, 2002; Sinke, 2001; Ririe, Sweeny, and Daugherty, 2002; Hers, et al., 2003; Davis, 2006; Golder Associates, 2008; Davis 2009). The potential for over-prediction is greatest for sites with low concentrations of PHCs in soil and groundwater (API, 2009; Davis, 2009; Energy Institute, 2009). The JEM presumes that the concrete foundation is impermeable and vapor movement occurs only through cracks and other openings. However, concrete is permeable to vapors and gases. Effective diffusion rates for intact air-dry concrete have been measured for hydrocarbons, oxygen, methane, and radon with an overall measured range from 1.08 to 15.6 cm2/hr (Haghighat, et al., 2002; Patterson and Davis, 2009; Kobayashi and Shuttoh, 1991; Tittarelli, 2009; Yu, et al., 1993). Thus, diffusive vapor flow for typical foundation areas and thicknesses can be significant (McHugh, de Blanc, and Pokluda, 2006; Luo, et al., 2012). Actual measurement of differential pressure across varied building foundations show a significantly 25 EPA has revised the original model by Johnson and Ettinger (1991) a number of times since it was first published. The most current information on EPA's revised model may be found on EPA's web site at http://www.epa.gov/oswer/riskassessment/airmodel/johnson_ettinger.htm Page 84 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** variable component over time (Nazaroff, et al., 1985; Hintenlang and Al-Ahmady, 1992; Robinson, et al., 1997a,b; McHugh , de Blanc, and Pokluda, 2006; Lundegard, Johnson, and Dahlen, 2008; Patterson and Davis, 2009; Luo and Johnson, 2011). BioVapor The BioVapor model (DeVaull, 2007a; API, 2010) uses a conceptual model similar to the JEM, including the following features: • A steady subsurface petroleum vapor source. • Gaseous-phase diffusive vapor flow through a layer of soil. • Vapor transport through a slab-on-grade or basement foundation. • Building air exchange. In contrast to JEM, BioVapor accounts for oxygen-limited, aerobic biodegradation. Aerobic biodegradation is included as a coupled reaction between petroleum vapors and oxygen. Oxygen availability in the subsurface is dictated by transport through and around the building foundation, and by diffusion into the soil. The BioVapor model requires estimates of chemical- specific aerobic degradation rates for vadose zone soils. DeVaull (2007a,b) provides default values based on measured data. DeVaull (2011) provides improved estimates of both median values and observed ranges for an expanded set of specific chemicals. Importance Vapor intrusion models that include oxygen limited biodegradation support development of petroleum-specific exclusion distance criteria (i.e., lateral inclusion zone—see Section 4, vertical separation distance—see Section 5). Model results are consistent with empirical exclusion distance values derived from several PVI field investigations. These include Lahvis, et al. (2012); Davis (2009); Peargin and Kolhatkar (2011); Wright (2011); and McHugh, et al. (2010). Site assessment and field data including the depth to contamination, source strength, and type (LNAPL or dissolved) are key parameters for determining these exclusion distance criteria. Estimates using the BioVapor model indicate that for moderate or weak sources (especially dissolved plumes), biodegradation effectively eliminates the potential for PVI. Conversely, where vapor sources are both high in concentration and in close proximity to the bottom of a foundation, the BioVapor model predicts significant potential for PVI. Notably, in these cases the BioVapor model predicts significantly higher potential for PVI below a foundation, where oxygen availability is more limited, than adjacent to the foundation where the soil surface is open to air and oxygen availability is greater. This prediction is consistent with measured vertical profiles of hydrocarbons and oxygen for high concentration vapor sources taken both below a foundation and beside a foundation (Patterson and Davis, 2009; Laubacher, et al., 1997). Weaver (2012) presents results of a sensitivity analysis that indicates when biodegradation occurs, it dominates the other processes included in the BioVapor model. In these cases, the parameters representing aerobic biodegradation, source depth, and source strength dominate Page 85 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** the model results. In the other cases where biodegradation is insignificant, building parameters become more important, as they are in the JEM (Tillman and Weaver, 2007). More complex numerical models including oxygen-limited biodegradation have been developed and applied. Abreu and Johnson (2006) present results for a three dimensional model. With matched model parameters, agreement between the three dimensional results and those predicted with the BioVapor model (DeVaull, 2007b) are favorable. Both sets of model results show similar sensitivities to changes in model parameters, and both support the use of exclusion distances such as those recommended in this guidance document (see Section 4, lateral inclusion zone, and Section 5, vertical separation distance). Assessment When selecting an appropriate computer model, the mathematical formulation needs to be consistent with conditions at the site and the CSM. If the computer model is not matched to conditions at the site, then error is likely introduced into the computer model results. This means that input parameters for the computer model should be representative of the actual physical, chemical, and biological properties of the site. A common limitation with computer models is that field measurements of all the input parameters (e.g., biodegradation rates, soil moisture content beneath buildings, air exchange rates) are typically not available, and those that are (e.g., source concentration) may be spatially or temporally variable. Literature values are typically substituted for site-specific data. This leads to uncertainty as to whether parameter values are truly representative of the site conditions. Therefore, EPA recommends that an uncertainty analysis be conducted to provide error bounds on predictions of the computer model. In addition, EPA recommends that predicted indoor air concentrations be verified with field data in making a determination as to whether buildings are impacted by PVI. Special Considerations When evaluating the potential for PVI, consider background sources of PHCs in indoor air, which cannot be attributed to subsurface vapor sources. Recommendation An appropriate framework for the use of a mathematical model and understanding of model characteristics is needed when using the results of mathematical models for regulatory purposes (Hers, et al., 2003). For PVI, this can include using models to improve a site-specific sampling strategy, validation (or refutation) of concept by comparing a model to measured soil vapor data, and in estimating the effect of varied or changed site conditions (e.g., including construction of a new building on a brownfields site). References Cited Abreu, L. D. V. and P. C. Johnson. 2006. Simulating the Effect of Aerobic Biodegradation on Soil Vapor Intrusion into Buildings: Influence of Degradation Rate, Source Concentration, and Depth. Environmental Science and Technology 40(7):2304-2315. Page 86 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** American Petroleum Institute (API). 2009. Simulating the Effect of Aerobic Biodegradation on Soil Vapor Intrusion into Buildings—Evaluation of Low Strength Sources Associated with Dissolved Gasoline Plumes. Publication No. 4775; American Petroleum Institute: Washington, D.C. American Petroleum Institute (API). 2010. BioVapor Indoor Vapor Intrusion Model. Davis, R.V. 2009. Bioattenuation of petroleum hydrocarbon vapors in the subsurface: Update on recent studies and proposed screening criteria for the vapor-intrusion pathway. LUSTLine Bulletin 61:11-14. New England Interstate Water Pollution Control Commission, Massachusetts. Davis, R. 2006. Vapor attenuation in the subsurface from petroleum hydrocarbon sources: An update and discussion on the ramifications of the vapor-intrusion risk pathway. LUSTLine Bulletin 52:22-25. New England Interstate Water Pollution Control Commission, Massachusetts. DeVaull, G.E. 2007a. Indoor Vapor Intrusion with Oxygen-Limited Biodegradation for a Subsurface Gasoline Source. Environmental Science and Technology 41(9):3241-3248. DeVaull, G. 2007b. Indoor Air Vapor Intrusion: Predictive Estimates for Biodegrading Petroleum Chemicals. Presentation at: Air and Waste Management Association (A&WMA) Specialty Conference: Vapor Intrusion: Learning from the Challenges, Providence, Rhode Island. September 26-28. DeVaull, G. E. 2011. Biodegradation rates for petroleum hydrocarbons in aerobic soils: A summary of measured data. Proceedings of Battelle 8th International Symposium on Bioremediation and Sustainable Environmental Technologies, Reno, Nevada, June 27-30. Energy Institute. 2009. Screening the potential for hydrocarbon vapour intrusion risks, Petroleum Review August 2009, Energy Institute, London, United Kingdom, p. 40-42. Environmental Systems and Technologies, Inc. 2004. VAPEX4. 3708 South Main Street, Suite D, Blacksburg, Virginia. Fitzpatrick, N.A. and J.J. Fitzgerald. 2002. An Evaluation of Vapor Intrusion Into Buildings through a Study of Field Data. Soil and Sediment Contamination ll(4):603-623. Golder Associates. 2008. Report on evaluation of vadose zone biodegradation of petroleum hydrocarbons: Implications for vapour intrusion guidance. Research study for Health Canada and the Canadian Petroleum Products Institute. Golder Associates Ltd., Burnaby, British Columbia, July. Page 87 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** Haghighat, F., C.S. Lee, and W.S. Ghaly. 2002. Measurement of diffusion coefficients of VOCs for building materials: review and development of a calculation procedure. Indoor Air 12(2): 81-91. Hers, I., R. Zapf-Gilje, P.C. Johnson, and L. Li. 2003. Evaluation of the Johnson and Ettinger Model for Prediction of Indoor Air Quality. Ground Water Monitoring and Remediation 23(1): 62-76. Hintenlang, D. E. and K. K. Al-Ahmady. 1992. Pressure Differentials for Radon Entry Coupled to Periodic Atmospheric Pressure Variations. Indoor Air 2(4):208-215. Johnson, P.C. and R.J. Ettinger. 1991. Heuristic Model for Predicting the Intrusion Rate of Contaminant Vapors into Buildings. Environmental Science and Technology 25(8):1445- 1452. Johnson, P.C., M.W. Kemblowski, R.L. Johnson. 1998. Assessing the significance of subsurface contaminant vapor migration to enclosed spaces: Site-specific alternatives to generic estimates, Publication No. 4674, API, Washington, D.C., December, 44p. Johnson, P.C., V.A. Hermes, S. Roggemans. 2000. An oxygen-limited hydrocarbon vapor migration attenuation screening model, written communication, Paul C. Johnson, Department of Civil and Environmental Engineering, Arizona State University, Tempe, Arizona. Kobayashi, K. and K. Shuttoh. 1991. Oxygen diffusivity of various cementitious materials. Cement and Concrete Research 21(2-3):273-284. Lahvis, M.A.; I. Hers; R.V. Davis, J. Wright, G.E. DeVaull. 2012. Screening Criteria for Application at Petroleum UST Release Sites, Groundwater Monitoring and Remediation [submitted, 2012], Lahvis, M. 2011. Vapour Transport from Soil and Groundwater to Indoor Air: Analytical Modeling Approach, Chapter 5., in Vapor Emissions to Outdoor Air and Enclosed Spaces for Human Health Risk Assessment: Site Characterization, Monitoring, and Modeling. S. Saponaro, E. Sezenna, L. Bonomo, Eds., Nova Science Publishers, Inc., New York. pp. 91- 112. Laubacher, R.C., Bartholomae, P., Velasco, P., Reisinger, H.J. 1997. An evaluation of the vapour profile in the vadose zone above a gasoline plume. Proceedings of 1997 Petroleum Hydrocarbon and Organic Chemicals in Ground Water, Houston, Texas, November, pp. 396-409. Page 88 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** Lundegard, P.D., P.C. Johnson, and P. Dahlen. 2008. Oxygen Transport From the Atmosphere to Soil Gas Beneath a Slab-on-Grade Foundation Overlying Petroleum-Impacted Soil. Environmental Science and Technology 42(15):5534-5540. Luo, H. and P.C. Johnson. 2011. Incorporating Barometric Pressure and Wind Effects into Vapor Intrusion Simulations, Association for Environmental Health and Sciences Conference Session, March 16, San Diego - Petroleum Hydrocarbon Vapor Intrusion. Luo, E.H., C. Holton, Y. Guo, and P.C. Johnson. 2012. Field and Modeling Studies of Indoor Air Source Effects on Subslab Soil Gas Concentrations. 22nd Annual International Conference on Soil, Water, Energy, and Air. March 19-22, 2012, San Diego, California. McHugh, T.E., P.C. de Blanc, and R.J. Pokluda. 2006. Indoor Air as a Source of VOC Contamination in Shallow Soils Below Buildings. Soil and Sediment Contamination 15(1):103-122. McHugh, T.E., R. Davis, G. DeVaull, H. Hopkins, J. Menatti, and T. Peargin. 2010. Evaluation of vapor attenuation at petroleum hydrocarbon sites: Considerations for site screening and investigation. Soil and Sediment Contamination 19(1):1-21. Mills, W.B., S. Liu, M.C. Rigby, and D. Brenner. 2007. Time-variable simulation of soil vapor intrusion into a building with a combined crawl space and basement. Environmental Science and Technology 41(14):4993-5001. Nazaroff, W. W., H. Feustel, A.V. Nero, K.L. Revzan, D.T. Grimsrud, M.A. Essling, and R.E. Toohey. 1985. Radon Transport into a Detached One-Story House with a Basement. Atmospheric Environment 19(l):31-46. Parker, J.C. 2003. Modeling volatile chemical transport, biodecay, and emission to indoor air. Ground Water Monitoring and Remediation 23(1):107-120. Patterson, B. M. and G.B. Davis. 2009. Quantification of Vapor Intrusion Pathways into a Slab- on-Ground Building under Varying Environmental Conditions. Environmental Science and Technology 43(3):650-656. Peargin, T. and R. Kolhatkar. 2011. Empirical data supporting groundwater benzene concentration exclusion criteria for petroleum vapor intrusion investigations. Proceedings of Battelle 8th International Symposium on Bioremediation and Sustainable Environmental Technologies, Reno, Nevada, June 27-30. Ririe, G.T., R.E. Sweeney, S.J. Daugherty, and P.M. Peuron. 1998. A vapor transport model that is consistent with field and laboratory data, in, Petroleum Hydrocarbons and Organic Chemicals in Ground Water: Prevention, Detection, and Remediation Conference, Ground Water Association Publishing, Houston, Texas, pp.299-308. Page 89 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** Ririe, G.T., R.E. Sweeney, and S.J. Daugherty. 2002. A comparison of hydrocarbon vapor attenuation in the field with predictions from vapor diffusion models. Soil and Sediment Contamination ll(4):529-544. Robinson, A. L., R.G. Sextro, and W.J. Fisk. 1997a. Soil-Gas Entry into an Experimental Basement Driven by Atmospheric Pressure Fluctuations - Measurements, Spectral Analysis, and Model Comparison. Atmospheric Environment 31(10):1477-1485. Robinson, A. L., R.G. Sextro, and W.J. Fisk. 1997b. Soil-Gas Entry into Houses Driven by Atmospheric Pressure Fluctuations-The Influence of Soil Properties. Atmospheric Environment 31(10):1487-1495. Sinke, A.J.C. 2001. Risk reduction of volatile compounds by degradation in the unsaturated zone, Project no. 96-030, Dutch Research Programme on Biotechnological In-Situ Remediation, (NOBIS). Spence, L.R. and T. Walden. 2001. RISC4 - Risk Integrated Software for Cleanups - Version 4.0, GroundwaterSoftware.com, Groton, Massachusetts. Tillman, F.D. and J.W. Weaver. 2007. Parameter sets for upper and lower bounds on soil-to- indoor-air contaminant attenuation predicted by the Johnson and Ettinger vapor intrusion model. Atmospheric Environment 41(27):5797-5806. Tillman, F.D. and J.W. Weaver. 2006. Uncertainty from Synergistic Effects of Multiple Parameters in the Johnson and Ettinger (1991) Vapor Intrusion Model. Atmospheric Environment 40(22):4098-4112. Tillman, F.D., and J.W. Weaver. 2005. Review of recent research on vapor intrusion., U. S. Environmental Protection Agency Office of Research and Development, Washington, D.C., September (EPA/600/R-05/106). Tittarelli, F. 2009. Oxygen diffusion through hydrophobic cement-based materials. Cement and Concrete Research 39(10):924-928. Turczynowicz, L. and N. I. Robinson. 2007. Exposure assessment modeling for volatiles- towards an Australian indoor vapor intrusion model. Journal of Toxicology and Environmental Health Part A 70(19):1619-1634. Weaver, J. 2012. BioVapor Model Evaluation in Bio-Vapor Hands-On Workshop. 23rd National Tanks Conference Pre-Conference Workshop, St. Louis, Missouri, March 18. Page 90 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** Wright, J. 2011. Establishing exclusion criteria from empirical data for assessing petroleum hydrocarbon vapour intrusion. CleanUp 2011: Proceedings of the 4th International Contaminated Site Remediation Conference, September 11-15, Adelaide, Australia. Yu, C., C. Loureiro, J.-J. Cheng, L.G. Jones, Y.Y. Wang, Y.P. Chia, and E. Faillace. 1993. Data Collection Handbook to Support Modeling Impacts of Radioactive Material in Soil, Environmental Assessment and Information Sciences Division, Argonne National Laboratory, Argonne, Illinois. Additional Information Abreu, L. D. V., P. C . Johnson. 2005. Effect of Vapor Source-Building Separation and Building Construction on Soil Vapor Intrusion as Studied with a Three-Dimensional Numerical Model. Environmental Science and Technology 39(12):4550-4561. Bozkurt, 0., K. Pennell, and E. Suuberg. 2009. Simulation of the Vapor Intrusion Process for Nonhomogeneous Soils Using a Three-Dimensional Numerical Model. Ground Water Monitoring and Remediation 29(1):92-104. Davis, G.B., M.G. Trefry, and B.M. Patterson. 2009. Petroleum vapour model comparison, CRC for Contamination Assessment and Remediation of the Environment, Technical Report Number 9, 24p. EPA. 2005. Uncertainty and the Johnson-Ettinger Model for Vapor Intrusion Calculations (EPA/600/R-05/110). Hers, I., R. Zapf-Gilje, D. Evans, and L. Li. 2002. Comparison, Validation, and Use of Models for Predicting Indoor Air Quality from Soil and Groundwater Contamination^ Soil and Sediment Contamination ll(4):491-527. Interstate Technology & Regulatory Council (ITRC). 2007. Vapor intrusion: A practical guideline. Interstate Technology & Regulatory Council, Washington, D.C., January. 74p. Johnson, P. 2005. Identification of Application-Specific Critical Inputs for the 1991 Johnson and Ettinger Vapor Intrusion Algorithm. Ground Water Monitoring and Remediation 25(l):63-78. Park, H. 1999. A Method For Assessing Soil Vapor Intrusion From Petroleum Release Sites: Multi-Phase/Multi-Fraction Partitioning^ Global Nest l(3):195-204. Page 91 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** Pennell K.G., 0. Bozkurt, E.M. Suuberg. 2009. Development and Application of a Three- Dimensional Finite Element Vapor Intrusion Model. Journal of Air and Waste Management 59(4):447-460. Provoost, J., A. Bosman, L. Reijnders, J. Bronders, K. Touchant, and F. Swartjes. 2009. Vapour Intrusion from the Vadose Zone - Seven Algorithms Compared. Journal of Soils and Sediments 10(3):473-483. Sanders, P. and N. Talimcioglu. 1997. Soil-to-lndoor Air Exposure Models for Volatile Organic Compounds: The Effect of Soil Moisture. Environmental Toxicology and Chemistry 16(12):2597-2604. Schreuder W. 2006. Uncertainty approach to the Johnson and Ettinger vapor intrusion model. Proceedings of the 4th Annual National Ground Water Association Ground Water And Environmental Law Conference, July 6-7, Chicago, Illinois, pp. 164-173. Tillman, F.D. and J.W. Weaver. 2006. Uncertainty from Synergistic Effects of Multiple Parameters in the Johnson and Ettinger (1991) Vapor Intrusion Model. Atmospheric Environment 40(22):4098-4112. Van Wijnen, H.J. and J.P.A. Lijzen. 2006. Validation of the VOLASOIL model using air measurements from Dutch contaminated sites: Concentrations of four chlorinated compounds RIVM Report 711701041/2006, Rijksinstituut Voor Volksgezondheid en Milieu, Bilthoven, 68 pp. Yao, Y., R. Shen, K. Pennell, and E. Suuberg. 2011. Comparison of the Johnson-Ettinger Vapor Intrusion Screening Model Predictions with Full Three-Dimensional Model Results. Environmental Science and Technology 45(6):2227-2235. Page 92 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** GLOSSARY absorption: the penetration of atoms, ions, or molecules into the bulk mass of a substance. In contrast, adsorption is the retention of atoms, ions, or molecules onto the surface of another substance. advection: the process of transfer of fluids (vapors or liquid) through a geologic formation in response to a pressure gradient that may be caused by changes in barometric pressure, water table levels, wind fluctuations, or infiltration. aerobic: able to live, grow, or take place only when free oxygen is present. anaerobic: able to live, grow, or take place where free oxygen is not present. analyte: the element, ion, or compound that an analysis seeks to identify; the element of interest. attenuation: the reduction or lessening in amount (e.g., a reduction in the amount of contaminants in a plume as it migrates away from the source). biodegradability (or biodegradation potential): the relative ease with which organic chemicals will degrade as the result of biological metabolism. With respect to petroleum hydrocarbons, although virtually all petroleum hydrocarbons are biodegradable, biodegradability is highly variable and dependent somewhat on the specific type of hydrocarbon. In general, biodegradability increases with increasing solubility; solubility is inversely proportional to molecular weight. biodegradation: a process by which microbial organisms transform or alter (through metabolic or enzymatic action) the structure of chemicals introduced into the environment. biologically active soil: in the context of a PVI investigation means that the subsurface soil environment will support populations of microorganisms that are present in sufficient quantities to aerobically degrade PHC vapors before they intrude into a receptor. Effective aerobic biodegradation of petroleum hydrocarbons depends on the soil having sufficient oxygen and enough soil water to provide a habitat for adequate populations of active microorganisms. The presence of sufficient oxygen must be determined by the collection and analysis of soil gas. Soil that is too dry will not support microbial life. The soil generally will not be too dry for bacteria if the depth to the water table is less than 300 feet, or if the soil around the receptor supports the growth of plants characteristic of temperate climates. (NOTE that in hot, arid climates lack of soil moisture may inhibit biodegradation of PHCs) Concentrations of carbon dioxide which are ten-fold higher than concentrations in the atmosphere are an acceptable indication that conditions support microbial respiration. The actual habitat of soil bacteria is the thin film of water held to the surface of soil particles by capillary attraction. Coarse sand and gravel with a low content of silt or clay or organic matter, or fractured consolidated rock, or consolidated rock with solution channels, may not have enough soil water in intimate contact with soil gas to support adequate densities of biologically active microorganisms. These geological materials do not qualify as "biologically active soil." BTEX: Acronym for the aromatic hydrocarbons benzene, toluene, ethylbenzene, and xylenes (three isomers). Page 93 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** capillary fringe: the zone of a porous medium above the water table within which the porous medium is saturated by water under pressure that is less than atmospheric pressure. See also vadose zone. clean: in the context of a PVI investigation does not necessarily mean that the soil is free from all contamination, but rather that any contamination present is at concentrations low enough that the biological activity of the soil is sufficient to biodegrade PHC vapors before they reach a receptor. Concentration thresholds for "clean" are: the BTEX concentration in groundwater is equal to or less than the respective maximum contaminant level; the TPH concentration in soil is less than 100 mg/kg; there is no potential presence of liquid or residual phase LNAPL; the oxygen concentration is greater than 1 percent; and the combustible gas concentration in soil gas is less than 100 ppm (v/v). computer model: a mathematical representation of a physical process or system. Computer models are based upon sound conceptual site models to provide meaningful information. As the complexity of computer models increases, so does the amount of data required, and the quality of the output from computer models is directly related to the quality of the input data. Because of the complexity of natural systems, models necessarily rely on simplifying assumptions that may or may not accurately represent the dynamics of the natural system. Calibration and sensitivity analyses are important steps in the appropriate use of models. conceptual site model (CSM): a three-dimensional representation that conveys what is known or suspected about potential contamination sources, release mechanisms, and the transport and fate of those contaminants. The conceptual model provides the basis for assessing potential remedial technologies at the site. "Conceptual site model" is not synonymous with "computer model"; however, a computer model may be helpful for understanding and visualizing current site conditions or for predictive simulations of potential future conditions. contamination: in the context of a PVI investigation means that: the BTEX concentration in groundwater is greater than the respective MCL; or the TPH concentration in soil is greater than 100 mg/kg; or there is potential presence of liquid or residual phase LNAPL; or the combustible gas concentration in soil gas is greater than 100 ppm (v/v). diffusion: the process by which molecules in a single phase equilibrate to a zero concentration gradient by random molecular motion (Brownian motion). The flux of molecules is from regions of high concentration to low concentration and is governed by Fick's Second Law. dispersion: the process by which a substance or chemical spreads and dilutes in flowing groundwater or soil gas. down gradient: in the direction of decreasing static head (potential). first responder: refers to those individuals who in the early stages of an incident are responsible for the protection and preservation of life, property, evidence, and the environment. Typically these are police, firefighters, or emergency medical personnel. fixed gases: refers to the gases nitrogen, oxygen, argon, carbon dioxide, carbon monoxide. The volume of these gases together accounts for virtually 100 percent of the composition of the atmosphere. Presence and concentration of these gases are determined using gas chromatography (GC). Page 94 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** flux: the rate of movement of mass through a unit cross-sectional area per unit time in response to a concentration gradient or some advective force. free product: a petroleum hydrocarbon in the liquid ("free" or non-aqueous) phase (see also light non- aqueous phase liquid, LNAPL). gradient: the rate of change in value of a physical or chemical parameter per unit change in position. For example, hydraulic gradient is equal to the difference in head measured at two points (usually wells) divided by the distance separating the two points. The dimensions of head and distance are both lengths, therefore the gradient is expressed as a dimensionless ratio (L/L). groundwater: the water contained in the pore spaces of saturated geologic media. Henry's law constant: the ratio of the concentration of a compound in air (or vapor) to the concentration of the compound in water under equilibrium conditions. Henry's law: the relationship between the partial pressure of a compound and the equilibrium concentration in the liquid through a proportionality constant known as the Henry's law constant. heterogeneous: varying in structure or composition at different locations in space. homogeneous: uniform in structure or composition at all locations in space. hydraulic gradient: the change in total potentiometric (or piezometric) head between two points divided by the horizontal distance separating the two points. hydrocarbon: chemical compounds composed only of carbon and hydrogen. inclusion zone: the area surrounding a contaminant mass through which vapor-phase contamination may travel and intrude into buildings and potentially result in adverse health effects to inhabitants. Indian country: (1) All land within limits of any Indian reservation under the jurisdiction of the United States government, notwithstanding the issuance of any patent, and, including rights-of-way running through the reservation; (2) All dependent Indian communities within the borders of the United States whether within the original or subsequently acquired territory thereof, and whether within or without the limits of a state; and (3) All Indian allotments, the Indian titles to which have not been extinguished, including rights-of-way running through the same. indigenous: living or occurring naturally in a specific area or environment; native. isotropic: the condition in which hydraulic properties of an aquifer are equal when measured in any direction. lateral inclusion zone: the area surrounding a contaminant mass and for which all buildings within its boundaries should be assessed for potential PVI. By definition, all buildings that overlie contamination in any phase are within the lateral inclusion zone. Page 95 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** light non-aqueous phase liquid (LNAPL): contaminants that remain as the original bulk liquid with a density less than that of water (see also free product). microorganisms: microscopic organisms including bacteria, protozoans, yeast, fungi, mold, viruses, and algae. permeability: a qualitative description of the relative ease with which rock, soil, or sediment will transmit a fluid (liquid or gas). Often used as a synonym for hydraulic conductivity or coefficient of permeability. petroleum hydrocarbons: hydrocarbons that are components of petroleum (crude oil), including the various products that result from distillation of crude oil. porosity: the volume fraction of a rock or unconsolidated sediment not occupied by solid material but usually occupied by water and/or air (gas). preferential transport pathways: pathways through which contaminants may be transported at a higher rate than through surrounding materials. Preferential transport pathways are heterogeneities within geologic media and include features that are natural (such as facies changes, sand or gravel stringers, solution channels in karst, bedding planes and weathered surfaces, fractures, and joints) as well as man- made (such as utility corridors, trenches, other types of excavations). regulated substance: (a) Any substance defined in section 101(14) of the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) of 1980 (but not including any substance regulated as a hazardous waste under subtitle C), and (b) Petroleum, including crude oil or any fraction thereof that is liquid at standard conditions of temperature and pressure (60 degrees Fahrenheit and 14.7 pounds per square inch absolute). The term "regulated substance" includes but is not limited to petroleum and petroleum-based substances comprised of a complex blend of hydrocarbons derived from crude oil through processes of separation, conversion, upgrading, and finishing, such as motor fuels, jet fuels, distillate fuel oils, residual fuel oils, lubricants, petroleum solvents, and used oils. semi-volatile: a semi-volatile organic compound is an organic compound which has a boiling point higher than water and which may vaporize when exposed to temperatures above room temperature. Semi-volatile organic compounds include phenols and polynuclear aromatic hydrocarbons (PAHs). site assessment: see site characterization. site characterization: (verb) the process by which site-specific information and data are gathered from a variety of sources to characterize the physical, biological, and chemical systems at a contaminated site. A primary objective of site characterization is delineation of the areal (both horizontal—longitudinal and lateral—transverse) and vertical extent of contamination. This includes changes in plume boundaries, changes in geochemical parameters that affect biodegradation, and contaminant mass (and/or concentration) increases or decreases, (noun) The product (e.g., CSM, report) resulting from the site characterization process. (NOTE: Site assessment, site investigation, site evaluation, and site check are all synonyms of site characterization.) site check: see site characterization. Page 96 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** site evaluation: see site characterization, site investigation: see site characterization. soil moisture: the water contained in the pore spaces in the unsaturated zone. solubility: the amount of mass of a compound that will dissolve in a unit volume of solution. sorption: a general term used to encompass the processes of absorption, adsorption, ion exchange, and chemisorption. source material: material that includes or contains hazardous substances, pollutants or contaminants that act as a reservoir (either stationary or mobile) for migration of contamination to the ground water, to surface water, to air, (or other environmental media), or acts as a source for direct exposure. Contaminated ground water generally is not considered to be a source material although non-aqueous phase liquids (NAPLS [occurring either as residual- or free-phase]) may be viewed as source materials. (United States Environmental Protection Agency. 1991b. A guide to principal threat and low level threat wastes, Superfund Publication 9380.3-06FS, Office of Emergency Remedial Response. Washington, D.C.). total petroleum hydrocarbons (TPH): a measure of the concentration or mass of petroleum hydrocarbon constituents present in a given amount of air, soil, or water. (NOTE: The term total is a misnomer, in that few, if any, of the procedures for quantifying hydrocarbons are capable of measuring all fractions of petroleum hydrocarbons present in the sample. Volatile hydrocarbons are usually lost in the process and not quantified. Additionally, some non-petroleum hydrocarbons may be included in the analysis.) travel time: the time it takes a contaminant to travel from the source to a particular point downgradient. tribe: Indian tribe or tribe means an Indian or Alaska Native tribe, band, nation, pueblo, village, or community that the Secretary of the Interior acknowledges to exist as an Indian tribe pursuant to the federally Recognized Indian Tribe List Act of 1944, 25 U.S.C. 479a. unsaturated zone: the zone between land surface and the capillary fringe within which the moisture content is less than saturation and pressure is less than atmospheric. Soil pore spaces also typically contain air or other gases. T he capillary fringe is not included in the unsaturated zone. vadose zone: the zone between land surface and the water table within which the moisture content is less than saturation (except in the capillary fringe) and pressure is less than atmospheric. Soil pore spaces also typically contain air or other gases. The capillary fringe is included in the vadose zone. vapor intrusion attenuation factor (a): a parameter defined by Johnson and Ettinger (1991) to relate the vapor concentration of a volatile chemical inside the building to its vapor concentration at the subsurface source. This parameter, designated "alpha" (a), is defined mathematically as the vapor concentration in indoor air divided by the vapor concentration in soil gas at the "source" (with concentration being in the same units), and thus it is a ratio. The source is defined as the region of highest vapor concentration. T herefore, a values are always less than one. The vapor intrusion Page 97 of 98 ------- *** Draft EPA External Review Document. Do not cite or quote. **** attenuation factor is an inverse measurement of the attenuation: a values decrease with increasing attenuation and a values increase with decreasing attenuation. In other words, a values represent the fraction of soil gas contaminant that reaches indoor air. Large a values (i.e., values approaching 1) indicate that a large fraction of the soil gas contaminant has reached the indoor air; therefore, little attenuation is taking place, whereas small a values indicate that a small fraction of the soil gas contaminant has reached the indoor air; therefore, significant attenuation is taking place. vapor pressure: the force per unit area exerted by a vapor in an equilibrium state with its pure solid, liquid, or solution at a given temperature. Vapor pressure is a measure of a substance's propensity to evaporate. Vapor pressure increases exponentially with an increase in temperature. vertical separation distance: the thickness of clean, biologically active soil that separates the source of contamination from a building basement, foundation, or slab. volatile: is a tendency of a substance to vaporize or the speed at which it vaporizes. Volatility is indicated by a substance's vapor pressure. Substances with a higher vapor pressure will vaporize more readily at a given temperature than substances with a lower vapor pressure. A volatile organic compound is an organic compound which has a boiling point below that of water and which can easily vaporize or volatilize. volatilization: the process of transfer of a chemical from the aqueous or liquid phase to the gas phase. Solubility, molecular weight, and vapor pressure of the liquid and the nature of the gas-liquid interface affect the rate of volatilization. water table: the water surface in an unconfined aquifer at which the fluid pressure in the pore spaces is at atmospheric pressure. weathering: the process during which a complex compound is reduced to its simpler component parts, transported via physical processes, or biodegraded overtime. wilting point: the minimal point of soil moisture the plant requires not to wilt. Wilting point values under field conditions are not constant for any given soil, but are determined by the integrated effects of plant, soil and atmospheric conditions. Page 98 of 98 ------- |