The Model Toxics Control Act (MTCA) established a process for cleaning up sites that are contaminated with hazardous substances, including Total Petroleum Hydrocarbons (TPH). One step in the cleanup process is defining appropriate cleanup levels. MTCA allows cleanup levels to be set in three different ways, known as Methods A, B, and C.
Under Method A, those cleaning up a petroleum-contaminated site look up the number for a TPH cleanup level and use that number to clean up their site.
Under Methods B and C, those cleaning up a site use a formula based on information about the site and the type of petroleum compounds at the site. Because information about the nature of petroleum compounds was not available, Ecology discouraged the use of Methods B & C for deriving cleanup levels for TPH.
In January, Ecology issued an "Interim Interpretative and Policy Statement--Cleanup of Total Petroleum Hydrocarbons (TPH)" that addresses Methods B and C cleanup levels for TPH contamination. This Interim TPH Policy is the result of a recommendation by the MTCA Policy Advisory Committee. An interim policy was proposed because changes to the Model Toxics Control Act for Method A cleanup levels, or the way levels are derived, would require amending the regulation. This might not occur until 1998, while the Interim Policy is effective now.
To come up with the new policy, Ecology was asked to look at methods being proposed by numerous states and determine whether they could be used as the basis for calculating MTCA Methods B and C risk-based cleanup levels.
Methods B and C take all major potential exposure pathways into account in setting cleanup levels. In the Interim TPH Policy, Ecology has provided guidance on only two pathways:
This new policy does not completely address health effects of TPH vapors, nor does it provide cleanup levels that necessarily address residual odors or environmental protection. These issues and others will be evaluated by Ecology and the Duwamish Coalition TPH Brownfields Project Oversight Group (POG) and if appropriate, will be incorporated into a final TPH Policy and/or amendments to the MTCA regulations. In the meantime, issues not addressed by the Interim TPH Policy should be evaluated on a case-by-case basis using MTCA, appropriate policies and guidance, and professional judgment.
In addition to the policy, new analytical methods for soil have also been developed. Draft methods have been made available to laboratories for review. Ecology will publish them shortly.
After all this, you may be asking, "Are there benefits to using one cleanup method over another?" In answer to your question, using a site-specific approach, such as Methods B and C, will be more costly in the early stages because more sampling is required. However, it will be less costly overall, because the cleanup will be more tailored to the risks at the site. So, if someone has a site with a lot of petroleum-contaminated soil, it would probably be more cost-effective to use Method B and spend more money characterizing the site and less money on soil removal, treatment, or cleanup.
GeoEngineers, Inc. will be sponsoring a workshop on Interim TPH Policy issues in April in Bellevue and in Spokane. Ecology staff will be participating at this workshop with a presentation on the policy. If you would like to receive a registration form for the workshop, please contact Leah Martin, GeoEngineers, Inc., (206) 861-6055.
If you have site-specific questions on how to apply the Interim TPH Policy, please contact the appropriate Ecology office. If you have questions about the policy, please contact Steve Robb, Department of Ecology, (360) 407-7188 or E-mail.
For a copy of the Interim Policy, please call Ecology's Publications Office at (360) 407-7472 or E-mail. Ask for Publication #ECY97-600.
The following people have had technical assistance visits on their tank sites and have passed with flying colors:
In December 1996, the Governor, state legislators, and the Department of Ecology were presented with final recommendations from the Model Toxics Control Act Policy Advisory Committee. The statewide committee was created during Legislative Session 1995 to assess the effectiveness of the state's cleanup law, the Model Toxics Control Act, and suggest changes to improve it. For 18 months, the 22-member committee examined a wide range of issues pertaining to the cleanup of contaminated sites including:
The committee has recommended over 20 changes to the cleanup law, rules, and policies that are used to carry out the law.
After taking a comprehensive look at the state cleanup program, the committee affirmed that, overall, Washington has a program that is working. Even so, obstacles were identified and solutions created to get cleanups done faster and fairer. The recommendations call for a combination of statutory, regulatory changes and development of guidance. For example:
All of the recommendations focus on making the business of cleanup fairer, easier to understand, more flexible, and less expensive. This will help speed cleanups which in turn, protect public health and the environment.
Ecology is fully committed to carrying out the recommendations. We are now charting a course for what can be done now, such as:
As a city grows, it is sometimes necessary to change addresses in order to accommodate the 911 system.
Ecology wants to make sure we are crediting the right person -- such as when we receive "proof of insurance" from a tank owner. If your site address has changed or you anticipate a change, please complete the form below and return to Ecology at P.O. Box 47600, Olympia WA 98504-7600.
UBI or Site Number__________________ Name__________________________________________________
Business Name_____________________________________________________________________________
Old Complete Street Address__________________________________________________________________
New Complete Street Address_________________________________________________________________
Please send mail to new address beginning ________________________
Signature__________________________________________________________________________________
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