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Likelihood of Release

Observed Release by Direct Observation

  • An observed release by direct observation can be documented when one of the following occurs:
    • Material that contains one or more hazardous substances has been seen entering the atmosphere directly: or
    • Demonstrated adverse effects may establish an observed release when evidence documents that a material containing hazardous substances has been released into the atmosphere.
    • Documentation that the material contains hazardous substances is essential. Such documentation includes: sampling data (e.g., dust samples from piles) and documentary evidence (e.g., permits and compliance records).
    • Observed releases by direct observation can usually be established near any permitted air emitting facility.

Observed Release by Chemical Analysis

  • An observed release to the atmosphere (outdoor air) by chemical analysis is documented when both of the following occur:
    • Analysis of air samples shows that the concentration of ambient hazardous substance(s) has increased significantly over background for the site.
    • Some portion of the release is attributable to the site.
  • Establishing an observed release to air through chemical analysis is difficult due to the variability of the atmosphere. Specialized expertise is needed to design and execute air sampling programs.
  • Methane and similar "landfill gases" are not hazardous substances and cannot be used to establish an observed release through chemical analysis.

Special Considerations for Air Sampling

  • Determination of wind direction during sampling is essential
  • "Background" can be determined using an upwind or cross-wind sample.
  • Longer sampling durations increase likelihood of release detection but also increase likelihood of changes in wind direction.
  • All air samples must be comparable:
    • taken duration the same, approximate time period
    • taken at the same elevation relative to sources at the site
    • collected using comparable equipment under comparable operating conditions (e.g., sampling duration)
    • analyzed with comparable equipment
  • Air sampling is not restricted to the "bearing zone."
  • Soil gas samples cannot be used to demonstrate a significant increase above background level.
  • Soil gas samples can be used to support attribution.
  • In special circumstances, health and safety sampling can be used to establish an observed release through chemical analysis. Special attention must be given to sampling QA/QC in such cases.
  • EPA has prepared specific guidance to support air pathway analyses in the Superfund program. List of Guidances

Potential to Release

  • In a single source, there may be some substances that are gaseous, some substances that are particulate, and some that are both.
  • The release of gaseous substances is governed by different processes than the release of particulate substances. Therefore, two separate evaluations are needed.
  • Separate calculations are performed for each source.
  • For purposes of potential to release evaluations, sources with similar characteristics can be aggregated to form a single "source."
    • same containment factor value
    • same source type
    • significant overlap in hazardous substances
  • Combining sources is advantageous for small sources or for purposes of expediency
  • Factors
    • Containment
    • Source Type
    • Migration Potential

Gas Containment

  • The gas containment value is assigned from HRS Table 6-3.
  • These tables require that specific observations are made during the site visit.
  • Critical Source Features
    • depth of uncontaminated soil cover
    • extent of vegetation
    • releases of biogas (e.g., methane)
    • active fires
    • condition of containers

Gas Source Type

  • The gas source type factor value is assigned from HRS Table 6-4.
  • Different gas and particulate source type factor values may be assigned to any particular source.
  • The minimum size requirement applies to source type rather than containment in the air pathway.
  • If a source does not meet the minimum size requirement (i.e., a hazardous waste quantity value of 0.5 or greater), assign that source a value of 0 for both source type factors.
  • Evidence of releases of biogas (e.g., methane) substantially increases the source type value for containers/tanks, landfills, and buried surface impoundments.

Gas Migration Potential

  • Obtain the gas migration potential value for each gaseous substance found in the source from SCDM.
  • EPA should be consulted whenever values are needed for substances not appearing in SCDM.
  • Take the average of the three highest values.
  • Assign a source gas migration potential to the source from HRS Table 6-7.

Gas Potential to Release

  • For each source, sum the gas source type factor value and gas migration potential factor value and multiply this sum by the gas containment factor value.
  • Select the highest product calculated for the sources evaluated and assign it as the gas potential to release value for the site.

Particulate Containment

  • The particulate containment value is assigned from HRS Table 6-9.
  • These tables require that specific observations are made during the site visit.
  • Critical Source Features
    • depth of uncontaminated soil cover
    • presence of liquids
    • extent of vegetation
    • condition of containers

Particulate Source Type

  • Different source type factor values are assigned to gas and particulate potential from HRS Table 6-4.
  • The minimum size requirement applies to source type rather than containment in the air pathway.
  • If a source does not meet the minimum size requirement (i.e., a hazardous waste quantity value of 0.5 or greater), assign that source a value of 0 for source type.

Particulate Migration Potential

  • This value is the same for all sources at the site and is based on the location of the site.

Particulate Migration Potential Factor Values, Figure 6-2

  • If the site is not located on the map or is too near a boundary on the map, calculate the Thornthwaite precipitation-effectiveness index using mean monthly precipitation and temperature data for the site.

Particulate Potential to Release

  • For each source, sum the particulate source type factor value and particulate migration potential factor value and multiply this sum by the particulate containment factor value.
  • Select the highest product calculated for the sources evaluated and assign it as the particulate potential to release value for the site.

Overall Potential to Release

  • The overall potential to release value is the higher of the gas and particulate potential to release values.

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