TDEC Vapor Intrusion Workgroup Flowchart A Work In Progress

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1 TDEC Vapor Intrusion Workgroup Flowchart A Work In Progress May 2, 2013 Ahmet Bulbulkaya TDEC Division of Remediation (615) Ahmet.Bulbulkaya@tn.gov

2 The that started it all Date: 6/8/2012 From: Andy Binford (DOR Division Director) Subject: Work groups to develop consistency We are tasked with developing consistency across cleanup programs and to assure that no matter what program a party falls under, they know what is expected of them. 2

3 Using the LEAN Process A collection of principles, methods, and tools that improve the speed and efficiency of any process by eliminating waste. Originated with the manufacturing industry but has more recently been applied to government processes and functions. 3

4 LEAN Evaluation Value Added Something a customer is willing

knew about it An activity that transforms a product or service

without creating value for the customer Unpredictable in

resources than necessary NVA- Required Required by law or

4 4 LEAN Evaluation Value Added Something a customer is willing to pay for A customer would care about this activity if they knew about it An activity that transforms a product or service Done right the first time Non-Value Added Adds time or costs without creating value for the customer Unpredictable in creating value Too complex - requires more time, effort or resources than necessary NVA- Required Required by law or regulation Reduces financial risk Required by policy Enables valueadd step to happen

5 Vapor Intrusion Workgroup Update Goal - Develop guidelines or framework for the identification, investigation, assessment and mitigation of TDEC vapor intrusion sites Issues: Multiple methodologies for vapor intrusion across the department Can lead to inconsistent decisions One TDEC group played against the other General confusion 5

6 Workgroup Team Members Merrie Embry Division of Remediation (DOR), Memphis Field Office (MFO) Charles Rowan Dry Cleaner Environmental Response Program (DCERP) Dan Hawkins DOR, Knoxville Field Office Eddie Worthington Department of Energy Oversight Division (DOE-O) Cindy Greene Division of Underground Storage Tanks (UST) Herb Nicholson Division of Solid Waste Management (SWM), MFO Roger Donovan SWM Joe George Tennessee Department of Health (TDH) 6

7 Ad Hoc Members Workgroup Members Ricky Cathey - UST Andy Shivas DOR-Voluntary Cleanup Program Ashley Holt DOR-State Remediation Program Team Leader Ahmet Bulbulkaya DOR LEAN Coordinators Elaine Boyd, Ken Nafe, Mike Hoyal Sponsor Andy Binford DOR Executive Sponsor Shari Meghreblian - Deputy Commissioner, Bureau of the Environment 7

8 Timeline of Progress August 2012 Go See Interviews Kick-off meeting Fall of 2012 Winter 2012/ Reviewed 4 existing flow charts ITRC, Massachusetts, New Jersey, California Long Hunter State Park Meeting Early February - worked up flow chart Consensus reached by workgroup March, 2013 April 2013 Briefed DOR, UST, and SWM Division Directors and Deputy Commissioner 8

9 Sub-Goals Ideally, workgroup product will: Be used across TDEC by different divisions Be in sync with existing UST guidance (petroleum compounds) and relevant to chlorinated volatile organic compounds (VOCs) Accommodate rapidly changing state of the science Avoid conflicting with recently released draft VI EPA guidance documents 9

10 What it is A general framework that: Presents basic logic flow of a vapor intrusion investigation and data evaluation Provides process for screening out low-risk sites with a reasonable amount of confidence Leads to the collection of certain types of data (lines of evidence) generally starting with data collected exterior to structures and then proceeding indoors if conditions warrant Presents a decision process including exit points Provides a starting point if more specific technical guidance desired 10

11 What it ain t Not a detailed guidance document Not a detailed cookie cutter approach Does not present acceptable risk criteria or screening values Does not present sampling or analytical methods Does not present information on mitigation techniques Many terms (e.g., imminent hazard, sitespecific evaluation) are undefined. 11

12 Complaint/Spill/Release ID Site Discovery 1 Imminent Hazard? No 4 2 Yes Emergency Remedial Action 3 Evaluate Available Site Data/History 5 Site Candidate for Vapor Intrusion? Yes 7 No 6 No Current Complete Vapor Intrusion Exposure Pathway Collection/Gathering of Screening Data Does the Site Pass a Screening Evaluation? 8 Yes Yes No 9 Are buildings present? No 10a Conduct a Site-Specific Evaluation that may include data collected indoors (i.e, subslab soil gas and indoor air). 10b Conduct a Site-Specific Evaluation using Conduct Site-Specific Evaluation using approved site-specific model (e.g., J&E) site-specific J&E model and/or additional and/or additional exterior soil exterior soil gas/groundwater data gas/groundwater data 13 Assessment of Vapor Intrusion Pathway can end Yes Does the Site Pass a Site- Specific Evaluation? 11a Does the Site Pass a Site- Specific Evaluation? 11b Yes No 12a Mitigate Indoor Air Exposure Remediate Subsurface Contamination Conduct Long Term Monitoring Establish Any Necessary Institutional Controls No 12b Establish Institutional/Engineering Controls Remediate Subsurface Contamination Conduct Long Term Monitoring 12

13 Going Forward Stakeholder Involvement has officially begun Comment Period? Listening Sessions? Etc., Etc. Review of EPA Guidance Documents (Comments due EPA May 24) After Stakeholder Consensus is reached DOR gets to fill in the blanks Screening Levels Action Levels Preferred Sampling Methods 13

14 14 Contact Info Ahmet Bulbulkaya (615)

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