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Attachment D.3 - Site management

Volume 3: Investigative approach for VIAP
Attachment D.3 - Site management

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Most strategies and approaches for site management are dependent upon site-specific factors and cannot universally be applied across the entire facility. The need for land or resource use restrictions will be highly dependent on-site conditions, if a vapor source remains, how and where the soil gas samples are collected, especially in relation to the vapor source, and if future land uses can be evaluated with appropriately collected soil gas samples.

Table D.3-1 can be used as a general guide for the evaluation of when land or resource use restrictions or controls, or an alternate evaluation, will be necessary for No Further Action under Part 201. Detailed management strategies, including the use of either a land or resource use restriction, when they may or may not be appropriate, response activity, and more is further described in Volume 5 – Response Activity for the VIAP. If the release that is being addressed is an aerobically biodegradable compound, Volume 4: Investigative approach for Petroleum VIAP should be consulted.

Table D.3-1: Common Land or Use Restrictions for Closure

No Building Present

Data Required

Outcome

Actions for Closure of the VIAP

Shallow Vapor Source
< 3-feet below the ground surface

Soil and groundwater

Soil and groundwater define the vapor source

IC required for evaluation of future buildings over or in the vapor source

Vapor Source
Between 3 and 10-feet below the surface

Soil, groundwater, and soil vapor
  • Vapor source delineated
  • Soil gas sampling in or directly above the vapor source is below all screening levels or SSVIAC

Potential IC required for future building construction limitations if it alters the exposure scenario or use (nonresidential) restriction

Vapor Source
> 10-feet below the surface

Soil, groundwater, and soil vapor
  • Vapor source delineated
  • Soil gas sampling in or directly above the vapor source is below all screening levels or SSVIAC

If soil gas is representative of all reasonably foreseeable future uses, ICs are not required

 

Scenario
(Building Present)

Data Required

Outcome

Actions for Closure of the VIAP for petroleum releases

Shallow Vapor Source
< 10-feet below the ground surface

Soil, groundwater, soil gas, and/or sub-slab soil gas
  • Define vapor source
  • Soil gas sampling with the appropriate number and rounds of data is below all applicable VIAC or screening levels
  • Current building does not pose a risk
  • Potentially IC required for use (nonres) restriction or future use construction limitation

Vapor Source
> 10-feet below the surface

Soil, groundwater, soil gas, and/or sub-slab soil gas
  • Define vapor source
  • Soil gas sampling with the appropriate number and rounds of data is below applicable VIAC or screening levels
  • Current building does not pose a risk
  • If soil gas is representative of all reasonably foreseeable future uses, ICs are not required.

 

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