Department of Health Seal

TGM for the Implementation of the Hawai'i State Contingency Plan
Section 13.4


Soil, groundwater, soil gas and/or indoor air action levels should be developed and approved by HDOH for chemicals not listed in the current lookup tables but identified during a site investigation. A detailed discussion of the development of action levels presented in this guidance is provided in Appendix 1 of the EHE guidance (see HDOH, 2016). Preparation of the action levels should be coordinated with the HEER office.

An exception are petroleum compounds collectively measured under Total Petroleum Hydrocarbons (see Section 9), With the exception of the target, indicator compounds noted in Section 9, individual petroleum-related compounds that are captured and included in TPH analyses do not need to be evaluated separately in an EHE. Action levels for these compounds do not need to be developed. This includes a host of alkanes, alkenes, alkyl benzenes and other aromatics not specifically identified as target indicator compounds that could be reported separately in analytical methods for volatile organic compounds (e.g., trimethylbenzenes).

Action levels must be developed for all applicable, potential hazards (refer to Section 13.1; see also HDOH, 2016). In particular, the USEPA Regional Screening Levels (RSLs, USEPA, 2012a and updates) cannot be used as standalone criteria for the evaluation of contaminated soil. This is because the RSLs do not consider all potential environmental hazards posed by contaminated soil. In particular, the RSLs do not address potential vapor intrusion, leaching or gross contamination hazards and may not adequately address cumulative health risks.