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Volume 4: Investigative approach for petroleum VIAP

7. Alternative evaluation approaches

There are many different approaches that may be utilized for the evaluation of the potential risks associated with petroleum and the VIAP than what is described in this document. An alternate approach that may be more cost efficient or save time could be considered if the site doesn’t screen out using the steps outlined in Sections 3 through 6. Many of the approaches that can be applied are site-specific and are not likely to be implemented on many sites which is why they are not described in this document. The obligation to identify an alternative approach and provide justification on why the approach meets the obligations of Part 201 is on the person proposing the response activity and not EGLE.

Additional information on alternative evaluation approaches is discussed in Attachment E.

Examples of different site conditions that may warrant an alternative approach if the facility is sufficiently characterized and unable to be screened out using the steps identified above include:     

  • VIAC exceedances within 10x – The VIAC provided by EGLE are based on a set of assumptions that apply to a wide range of sites. Low exceedances of a criterion may indicate that a more site-specific approach based on actual site information may support that the VIAP does not pose an unacceptable human health risk and reduce the amount of data needed for evaluation or limit the need for response activity including land or resource use controls.
  • Age of the Release – Once petroleum is released into the environment, the volatile compounds begin to volatilize, the soluble compounds will dissolve, and biotic and abiotic processes will begin to remove and breakdown the petroleum compounds. Within a relatively short period of time, equilibrium is likely reached (EGLE 2023).
  • Type of Petroleum Release – Different refined petroleum products will have different hazardous substances, and some are less volatile that make them less susceptible to presenting an unacceptable risk for the VIAP.
  • Lithology – The less permeable the lithology, the lower the likelihood of significant mass flux from the lithology. With low permeability of the lithology, the flux from the subsurface becomes the limiting factor for the advective transport, thereby reducing the potential risks and data needs.
  • Structures with Natural Ventilation or High Ventilation Rates – Buildings with consistent high air exchange rates or that are naturally ventilated and freely exchange ambient air are likely to have a lower potential of a risk for the VIAP and the criteria may be conservative based on the assumptions EGLE uses.
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