Department of Health Seal

TGM for the Implementation of the Hawai'i State Contingency Plan
Subsection 9.3


A discussion of target chemicals of potential concern and the evaluation of petroleum releases is included in Volume 1 and Appendix 1 of the EHE guidance document (HDOH, 2016). This guidance is summarized and expanded below.

Petroleum is a complex mixture of hundreds of different compounds composed of hydrogen and carbon or "hydrocarbon" compounds (API 1994). The chemistry and toxicity of petroleum releases depends in part on the type of fuel released and the media tested. The bulk of the compounds are evaluated collectively under the all-inclusive category of Total Petroleum Hydrocarbons (TPH). The concentration of TPH in soil and groundwater is typically reported in terms of "carbon ranges," or the number of carbon molecules in individual hydrocarbon compounds based on the type of fuel released: 1) C5-C12 ("gasoline range" or "TPHg"), 2) C10-C24 ("diesel range" or "TPHd") and 3) C24-C40+ ("residual fuels" or "TPHo"). A number of different terms are applied to these ranges. As discussed below, reference to these ranges is less useful for air and soil vapor data.

"Gasoline-range" TPH is defined as a mixture of petroleum compounds characterized by a predominance of branched alkanes and aromatic hydrocarbons with carbon ranges of C6 to C12 and lesser amounts of straight-chain alkanes, alkenes, and cycloalkanes of the same carbon range (see also NEIWPCC 2003). Vapors from these fuels tend to be dominated by lighter-range, more volatile, C5-C8 aliphatics (HDOH, 2016, 2012). Although not studied in detail, dissolved-phase gasoline in groundwater is also likely to be biased towards more soluble, lighter-range compounds.

Petroleum compounds characterized by a wider variety of straight, branched, and cyclic alkanes, polynuclear aromatic hydrocarbons (PAHs, especially naphthalenes and methylnaphthalenes), and heterocyclic compounds with carbon ranges of approximately C9 to C25 are referred to as "Diesel Range" TPH. These compounds dominate the makeup of diesel and other middle distillates fuels (e.g., kerosene, diesel fuel, home heating fuel, JP-8, etc.). These fuels also contain a small but important amount of lighter, aliphatic compounds. Vapors from the fuels can somewhat counterintuitively be dominated by these "gasoline range," C5-C12, aliphatic compounds (HDOH 2012). As discussed in Subsection below and in Section 7, it is important that these compounds be included in the analysis of TPH in air and soil vapor samples associated with releases of middle distillate fuels. Dissolved-phase, middle-distillate fuel in groundwater could also be biased towards more soluble, "gasoline-range" compounds. A dominance of "TPHg" in groundwater samples does not in itself indicate that the source of the contamination is associated with gasoline. A more detailed review of the chromatograph pattern and site history will be necessary to make this determination.

Residual fuels (e.g., Fuel Oil Nos. 4, 5, and 6, lubricating oils, mineral oil, used oils, and asphalts) are characterized by complex polar PAHs, naphthenoaromatics, asphaltenes, and other high-molecular-weight saturated hydrocarbon compounds with carbon ranges that in general fall between C24 and C40. Compounds associated with these fuels and related products are not considered to be volatile, although methane generated by degradation of the fuels could pose potential hazards at some sites.

Note that the breakdown of heavy petroleum can lead to an increase in volatile petroleum compounds (Chaplin 2002). This necessitates the collection of soil vapor samples at sites contaminated by heavier fuels, as well as gasolines and middle distillates.

Due to the number of sites with residual petroleum contamination, HDOH prepared a guidance document that outlines procedures for long-term management of residual petroleum contamination where full cleanup is not practicable. This guidance, Long-Term Management of Petroleum-Contaminated Soils and Groundwater (HDOH, 2007c) is included in TGM Section 19 as Appendix 19-A. The document includes three, supporting decision trees for determining the need for continued, HDOH oversight. Self-implemented, long-term management by the property owner and closure of the case in the HDOH database is possible in scenarios where the area and volume of contaminated soil and/or groundwater is minimal.

Table 9-5 Target Analytes for Releases of Petroleum Products

Media 1Recommended
Target Analytes
Gasolines Soil TPH, BTEX, naphthalene, MTBE and appropriate additives and breakdown products (e.g., TBA, lead, ethanol, etc.)
Soil Vapor TPH, BTEX, naphthalene and MTBE plus other volatile additives and methane
Groundwater Same as soil
Middle Distillates
(diesel, kerosene, Stoddard solvent, heating fuels, jet fuel, etc.)
Soil TPH, BTEX, naphthalene, and methylnaphthalenes (1- and 2-)
Soil Vapor TPH, BTEX, naphthalene, and methane
Groundwater Same as soil
Residual Fuels
(lube oils, hydraulic oils, mineral oils, transformer oils, Fuel Oil #6/Bunker C, waste oil, etc.)
Soil TPH, 2VOCs, naphthalene, methylnaphthalenes (1- and 2-), the remaining 16 priority pollutant PAHs, PCBs, and heavy metals unless otherwise justified
Soil Vapor TPH, VOCs, naphthalene, and methane
Groundwater same as soil
1.    Include any additional volatile additives in soil vapor samples if suspected to be present.
2.    VOCs includes BTEX and chlorinated solvent compounds.

9.3.1 Recommended Target Analytes

Recommended target analytes for petroleum contaminated soil and groundwater are provided in Table 9-5.

Petroleum contamination in soil, water or air/soil vapors should be evaluated in terms of both TPH and a short list of target "indicator chemicals" that are specific to the type of petroleum product released. As discussed in the previous section, non-specific compounds collectively reported as TPH typically comprise the bulk of petroleum fuels. Target indicator chemicals typically make up only a small fraction of the total petroleum present but are also important players in the assessment of environmental hazards posed to human health and the environment. The toxicity and fate and transport of these chemicals in the environment has been studied in detail. Target Indicator Compounds

Target, indicator compounds for petroleum fuels include benzene, toluene, ethylbenzene, xylenes (total), methyl-tert butyl ether (MTBE), naphthalene and number of individual, polyaromatic hydrocarbon compounds (see Table 9-5). Separate evaluation of these chemicals is based on the availability of adequate toxicity data and the potential for the chemicals to drive risk and the need for remedial actions at contaminated properties in conjunction with TPH. Separate environmental action levels for these compounds are presented in the HEER Office EHE guidance (HDOH 2016).

All other petroleum compounds are collectively reported and evaluated under "TPH," as described above. Volatile components of petroleum that are not specifically identified as target indicator compounds in Table 9-5 but reported as separate compounds by the laboratory using EPA Method 8260 or similar methods do not need to be separately evaluated. Examples include trimethylbenzenes and other aliphatics and aromatics not specifically identified as target indicator compounds (refer to Subsection 2.11 in the EHE guidance document; HDOH, 2016). These compounds are included under the analysis and evaluation of the TPH component of petroleum.

Seventeen, semi-volatile PAHs are recommended as target, indicator compounds for releases of heavier petroleum fuels or waste oils:

  • Acenaphthene
  • Acenaphthylene
  • Anthracene
  • benzo(a)anthracene
  • benzo(b)fluoranthene
  • benzo(g,h,i)perylene
  • benzo(a)pyrene
  • benzo(k)fluoranthene
  • chrysene
  • dibenzo(a,h)anthracene
  • fluoranthene
  • fluorine
  • indeno(1 ,2,3)pyrene,
  • methylnaphthalenes (1 & 2)
  • naphthalene
  • phenanthrene
  • pyrene

In practice, the need for remedial actions at sites impacted with PAHs is typically driven by benzo(a)pyrene. Naphthalene can be reported with either semi-volatile or volatile compounds (see Section 7). Separate Environmental Action Levels (EALs) for 1- and 2- methylnaphthalenes are presented in the EHE guidance document (HDOH, 2016).

The suite of PAHs that should be tested at a given site depends on the type of the petroleum product released (after MADEP 2002). As indicated in the Table 9-5, naphthalene is the only PAH that requires reporting for gasoline release sites. Both methylnaphthalenes and naphthalene should be reported at sites with releases of middle distillates (diesel, jet fuel, etc.). The full suite of PAHs should be considered at sites with releases of heavier petroleum fuels and waste oil, unless site-specific information on the product released justifies eliminating specific PAHs.

Methylnaphthalenes do not need to be reported for soil vapor samples as a default. Based on data reviewed by HDOH, these compounds are unlikely to drive potential vapor intrusion hazards at petroleum release sites over TPH or benzene due to their relatively low volatility and concentration in most middle distillates and residual fuels. Testing for these compounds in soil vapor also requires different sample collection and analytical methods (e.g., sorbent tubes and TO-1 analysis; see Subsection 7.8.2). Reporting of these compounds in soil vapor samples may, however, be required at sites impacted by Manufactured Gas Plant waste. Total Petroleum Hydrocarbons

Soil, groundwater, and soil vapor samples must always be tested for TPH (or equivalent) in addition to targeted, individual chemicals. Laboratory analysis for TPH as gasolines and middle distillates is generally carried out using gas chromatography, modified for "gasoline-range" organics ("Volatile Fuel Hydrocarbons") and "diesel-range" organics ("Extractable Fuel Hydrocarbons"), respectively (e.g., EPA Method 8015). Analysis for TPH as residual fuels up to the C40 carbon range can be carried out by gas chromatography, infrared absorption, or gravimetric methods. The latter methods are rarely used, however, due to their inability to discriminate the type of the petroleum present and interference with organic material in the soil.

The concentration of TPH (or equivalent) in soil vapor should always be reported as the sum of C5-C12 compounds for whole air samples and C5-C18 for sorbent tube samples, regardless of the type of petroleum fuel involved. Refer to Appendix 1 of the HDOH EHE guidance for a detailed discussion on total volatile petroleum hydrocarbons (see also Brewer et al 2013). As discussed above and in Subsection 7.8.2, results from a petroleum vapor study carried out by HDOH study indicate that C5-C8 aliphatic compounds can make up a significant if not dominant fraction of the total TPH present in vapors associated with diesel and other middle distillate fuels (HDOH, 2012, 2012c). This is important, since current laboratory protocols typically require that they report "TPHdiesel" in any media as the sum of C10 to approximately C24 hydrocarbon compounds. Excluding the contribution of C5-C8 aliphatics to the total concentration of TPH reported in air or soil vapor samples associated with middle distillate fuels would be inappropriate, however.

To help address this issue, laboratories should be instructed to report TPH (or equivalent) in air or vapor samples as: 1) The sum of C5-C12 compounds for whole-air samples (e.g., summa canister samples and TO-15 lab methods, with the understanding that aromatics can only be confidently summed to C10) or 2) The sum of C5-C18 for samples collected using a sorbent media (e.g., sorbent tubes and TO-17 lab methods, with the understanding that aromatics can only be confidently summed to C16). This should be done regardless of whether the samples are associated with gasolines or middle distillates.

Laboratory methods for reporting of TPH in indoor air and soil gas are discussed in Subsection 7.13. A combination of both TO-15 (Summa canister samples) and TO-17 (sorbent tube samples) is currently recommended for initial investigation of petroleum-contaminated sites (see HDOH, 2012c). The collection of concurrent, sorbent tube samples can be discontinued if initial data indicate that C12+ compounds make up less than 10% of the total TPH present in vapors.

Designation of chromatogram patterns as "gasoline range" (e.g., C5-C12) or "diesel range" (e.g., C10-C24) with respect to traditional, laboratory methods for TPH in soil or water is not applicable to air and vapor samples and can be misleading. The reported concentration of TPH can then be compared to HDOH soil gas action levels. The sum of concentrations of individual, target analytes such as BTEX and naphthalene that will be evaluated separate can be subtracted from the reported concentration of TPH in order to avoid double counting, although this is not likely to make a significant difference in the final concentration.

As discussed in TGM Subsection 7.8, the initial collection of both Summa canister samples and sorbent tube samples is recommended for soil vapor investigations at diesel and middle distillate sites. This is due to limitations on the ability to extract >C12 compounds from Summa canisters (see Subsection A minimum Summa canister size of one-liter is recommended, in order to help collect a representative sample (tested for both TPH and target, indicator compounds such as BTEX and naphthalene). A maximum, 50ml vapor draw might be required for sorbent tube samples due to limitations of the sorbent material (tested only for TPH). Sorbent tube data are used to evaluate the relative proportion of >C12 compounds associated with TPH.

If the relative fraction of >C12 is less than 10% of the TPH then the concentration of TPH reported for the Summa canister can be used for comparison to action levels and Summa canisters can be relied upon for the collection of future samples. If >10% of the vapor-phase TPH is associated with >C12 compounds then a combined use of Summa data and sorbent tube data should be used to evaluate the site. For example, request that the laboratory report TPH for the sorbent tube sample as the sum of >C12 compounds. Add this to the concentration of TPH reported for the Summa sample (i.e., TPH as sum of C5-C12). The resulting, total TPH concentration can then be compared to soil gas action levels. This approach excludes the concentration of aromatic compounds greater than C10 but less than C12. Based on published information and data collected by the HEER Office, however, these compounds make up an insignificant (i.e., <10%) proportion of TPH vapors at typical, petroleum-release site.

Reported concentrations of unidentified hydrocarbons as gasoline, diesel or oil indicate that the chromatogram generated for the sample does not match standards used to quantify TPH. Reported concentrations of TPH should be considered approximate, but adequate for comparison to HDOH action levels. A more detailed evaluation through petroleum carbon range analysis can be carried out on a site-specific basis as warranted.

Silica gel cleanup of samples, in particular for surface water and groundwater, should not be carried out without consultation with HDOH. Two options are recommended: (1) Directly compare TPH data to HDOH EALs in the absence of silica gel cleanup, and/or (2) Report data both with and without silica gel cleanup. For the second option, compare the nonpolar, TPH fraction to HDOH EALs and evaluate potential hazards posed by TPH-derived, polar breakdown products to drinking water and aquatic habitats in a site-specific EHE (see HDOH, 2016).

Dissolved-phase TPH in water is composed of unaltered, nonpolar compounds originally in the parent fuel and polar compounds associated with the oxidation and biodegradation of the former (e.g., Zemo 1995, 2008, Lang et al 2009, Mohler et al. 2013). Polar compounds can be removed by passing the sample through silica gel prior to analysis, referred to as “silica gel cleanup (SGC).” A column SGC lab method should be used rather than a shake or funnel method (e.g., Method 3630C, USEPA 1996k). If polar compounds are removed, both non-SGC and SGC data should be reported.

In many cases silica gel cleanup will significantly reduce the concentration of TPH reported for the sample. The polar compounds, which can dominate the overall mass of TPH in groundwater at aged-release sites, are primarily organic acids/esters and alcohols with variable amounts of ketones, phenols and aldehydes. These compounds must be taken into account as part of a site investigation. From an environmental hazard standpoint, the sum of the polar compounds and nonpolar compounds (i.e., the concentration of TPH reported in the absence of a silica gel cleanup) represents the concentration of TPH that should be directly compared to HDOH Environmental Action Levels (refer to HDOH EHE guidance; HDOH, 2016).

Methods for development of separate EALs for TPH-related, polar compounds or evaluation of these compounds in a site-specific EHE or human-health risk assessment have not been fully developed. The toxicity of the polar fraction of the TPH to both humans and aquatic organisms has only recently begun to be studied (e.g., Zemo et al. 2013). As a default, and for the purposes of this guidance, the health risk and other potential environmental concerns associated with these compounds (e.g., toxicity to aquatic organisms, taste and odors in drinking water, etc.) is assumed at an initial screening level to be identical to the parent, nonpolar TPH compounds.

If silica gel cleanup of samples for a site is still desired (e.g., evaluation of degradation, fingerprinting of fuel releases, site-specific risk assessment, etc.), then the objectives and methodology to be implemented should be presented to HDOH for review and approval. A quantitative evaluation of potential threats to human health and the environment should be carried out in accordance with the HDOH EHE guidance document for a site-specific EHE. This includes addressing potential aquatic ecotoxicity concerns as well as gross contamination concerns (e.g., drinking water taste and odors). Alternative action levels for each environmental hazard should be presented and supported for comparison to data. In most cases, it is anticipated that long-term management of groundwater contaminated primarily with polar, TPH breakdown compounds above HDOH action levels will still be required due to potential nuisance and aquatic toxicity hazards, even in the absence of apparent risk to human health (e.g., via impacts to drinking water resources).

Comparison of data for groundwater samples tested with and without silica gel cleanup could be useful for assessing the state of natural biodegradation within a plume of petroleum-contaminated groundwater and optimizing remedial and monitoring actions. For example, no further active remediation may be appropriate for areas of the plume where the majority of dissolved-phase hydrocarbons have degraded into polar compounds (i.e., significant reduction of reported TPH concentration in samples processed with silica gel cleanup). Active remediation could focus on areas of the plume where a comparison of data indicates that significant, natural degradation is not occurring. Data can also be used as one line of evidence to support a recommendation for no further monitoring and site closure following the HEER office guidance for long-term monitoring of petroleum-contaminated sites (HDOH, 2007c; see TGM Section 19, Appendix 19-A).

9.3.2 Petroleum Contamination Encountered During Subsurface Soil Excavation

Unanticipated petroleum (free product) or petroleum-contaminated soil is sometimes encountered during construction work where subsurface soil is being excavated. The HEER Office has a Guidance Fact Sheet, consistent with the Hawaiʻi Environmental Response Law (HRS 128D; HDOH 1990), to assist project managers, contract workers, safety and health personnel or anyone involved in construction and excavation of soils when petroleum is encountered on a site. This document, "Guidance Fact Sheet for Use When Petroleum Contamination is Encountered During Subsurface Soil Excavation", is provided in Appendix 9-D.

In rare cases the reported concentration of TPH in soil with strong petroleum odors could fall below HEER Office EALs for gross contamination (refer to HDOH, 2016). This could be due to sampling error in the field, laboratory sample processing error, or the inability of the laboratory method to accurately quantify the amount of TPH in the soil. Even so, soil with an obvious petroleum odor should be considered grossly contaminated and managed appropriately. Removal and/or treatment of vadose-zone soil that exceeds the HEER Office EAL for subsurface gross contamination (e.g. 5,000 mg/kg) is typically recommended at a minimum when complete cleanup cannot be achieved. The HEER Office should be contacted regarding the on-site management or re-use of additional, petroleum contaminated soil. Refer also to the HEER Office Clean Fill Guidance for additional information (HDOH 2017d).

9.3.3 PAHs in Asphalt, Tar and Waste Oil

Understanding the potential source of polyaromatic hydrocarbon compounds (PAHs) in soil is important for decision making. Benzo(a)pyrene, the most potent of the PAHs, is almost always the risk driver in soils contaminated with PAHs. With the possible exception of naphthalene and methylnaphthalenes, these compounds are not present in significant amounts in gasolines and middle distillate fuels or soils impacted by these fuels (API 1994, TPHCWG 1998). They are present, however, in asphalt, waste oil and coal tar.

Samples of soil impacted with waste oil can have concentrations of benzo(a)pyrene and related PAHs in the tens of parts-per-million, well above Tier 1 EALs for potential direct-exposure concerns. Correlative concentrations of TPH up to approximately C40 are usually in the thousands of parts-per-million range (e.g., see API 1994). The concentration of PAHs in Bunker C and similar, residual fuels can also contain similar levels of BaP and other PAHs. Investigation and remediation of these soils is necessary for the protection of human health and the environment.

Soils impacted with asphalt can express similar concentrations of PAHs (e.g., see API 1994). An asphalt source of the PAHs is usually readily identifiable by relatively low concentrations of TPH, usually in the low hundreds of parts-per-million range. The bioavailability of PAHs in asphalt is relatively low and the presence at these levels does not pose a significant health risk. Asphalt is also regulated as an "inert waste" under Hawaiʻi Revised Statutes 342H-1 and does not fall under HEER Office oversight, even if BaP concentrations exceed EALs. If the source of PAHs identified in soil can reasonably be attributed to asphalt, then no further action is required. The inclusion of small particles of asphalt in soil from heavily developed areas or previously paved areas may be unavoidable. The reuse or import of asphalt as fill material is not recommended at remediation sites overseen by the HEER Office (HDOH, 2017d).

Relatively low concentrations of <C40 TPH are also often reported for soils impacted with coal tar, including manufactured as plant waste, older clay pigeons used at skeet ranges and petroleum-based patching material for roads or roofing (API, 1994; EPRI, 1993). The concentration of PAHs associated with these materials is often in the hundreds of parts-per-million range, however, highlighting coal tar or similar material as the likely source of the PAHs. Concentrations of PAHs in soil at these levels could pose potential direct-exposure concerns, even if the bioavailability of the PAHs is relatively low. Investigation and remediation of sites impacted with coal tar and similar material is essential.

In addition to asphalt, parts-per-billion to low, parts-per-million range concentrations of PAHs in soil in urban environments in combination with relatively low concentrations of TPH can also be associated with exhaust from vehicles, ash from fires and other source of combustion (Mauro et al., 2006). Recognition of anthropogenic background as part of a site investigation is necessary in order to correctly define the extent of contamination associated with releases of waste oil, manufactured gas plant waste or other sources that might require remediation.