Adec CSM Guidance 222017

State of Alaska
DEPARTMENT OF
ENVIRONMENTAL
CONSERVATION
DIVISION OF SPILL PREVENTION AND RESPONSE

CONTAMINATED SITES PROGRAM
Guidance on Developing
Conceptual Site Models
January 2017
Alaska Department of Environmental Conservation, Spill Prevention and Response – Contaminated Sites
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Guidance on Developing ii January 2017

TABLE OF CONTENTS
1 BACKGROUND ................................................................................................ 1
1.1 Exposure Pathways................................................................................................... 2
1.2 Complete pathways................................................................................................... 2
1.3 Graphical and Pictorial CSMs ................................................................................. 3
1.4 CSM Submittal to DEC ........................................................................................... 4
1.5 Site Characterization ................................................................................................. 7
2 COMMON ELEMENTS, HUMAN AND ECOLOGICAL CSMS ................. 8
Exposure Pathway Terms and Examples ........................................................................... 8
2.1 Source ......................................................................................................................... 9
2.2 Release Mechanism................................................................................................... 9
2.3 Impacted Media......................................................................................................... 9
2.4 Transport Mechanisms ............................................................................................ 9
2.5 Exposure Media ...................................................................................................... 11
2.6 Exposure Routes ..................................................................................................... 11
3 HUMAN HEALTH CONCEPTUAL SITE MODELS ..................................12
3.1 Direct Contact with Soil ........................................................................................ 12
3.1.1 Incidental Soil Ingestion........................................................................... 13
3.1.2 Dermal Absorption of Contaminants from Soil .................................. 13
3.2 Water Ingestion ....................................................................................................... 13
3.2.1 Ingestion of Groundwater ....................................................................... 13
3.2.2 Ingestion of Surface Water ...................................................................... 14
3.2.3 Ingestion of Wild and Farmed Foods .................................................... 14
3.3 Inhalation ................................................................................................................. 15
3.3.1 Inhalation of Outdoor Air ....................................................................... 15
3.3.2 Inhalation of Indoor Air .......................................................................... 16
3.3.3 Additional Pathways ................................................................................. 17
3.4 Human Receptors ................................................................................................... 18
3.4.1 Determining Current and Future Land Use .......................................... 19
3.4.2 Determining Insignificant Exposure ...................................................... 19
3.5 Default Cleanup Levels CSM ................................................................................ 20
4 ECOLOGICAL CONCEPTUAL SITE MODELS ......................................... 23
4.1 Introduction ............................................................................................................. 23
4.2 Ecological Characterization ................................................................................... 23
4.3 Identification of Potential Exposure Pathways .................................................. 24
5 REFERENCES ................................................................................................ 27
Guidance on Developing iii January 2017

FIGURES
1 Example Human Health Conceptual Site Model (Graphical) ......................................... 5
2 Example Human Health Conceptual Site Mode (Pictorial) ............................................. 6
3 Default Human Health Conceptual Site Model for Tabled Cleanup Levels ............... 22
4 Example Ecological Risk Assessment Conceptual Model ............................................. 26
TABLES
1 Exposure Pathway Terms and Examples ........................................................................... 8
2 Examples of Common Chemical Sources, Transport Mechanisms, and Exposure
Media at Contaminated Sites ............................................................................................. 10
APPENDICES
A Human Health Scoping Form and Standardized Graphic ...........................................A-1
B Soil Contaminants Evaluated for Dermal Exposure ..................................................... B-1
C Bioaccumulative Compounds of Potential Concern ..................................................... C-1
D Volatile Compounds of Potential Concern ................................................................... D-1
E Contaminant Properties Used to Evaluate Transport Mechanisms .......................... E-1
Guidance on Developing iv January 2017

1 BACKGROUND
A conceptual site model (CSM) is a way to describe and evaluate how people, animals, and
plants might come in contact with contaminants at a location. It shows the current and
possible future spread of contamination in the environment. Developing a CSM is a critical
step in evaluating a contaminated site, and must be prepared 1 during the initial stage of the
cleanup process, the site characterization phase. The CSM identifies all:
 Present and future ways people, plants, or animals may be exposed to contamination
(exposure pathways),
 Routes the contaminants may take as they move through the environment - migration
routes (through soil, groundwater, and/or surface water, or plants and animals (biota),
and
 Possible types of people, plants, and animals that could be exposed to contamination
(potential receptors) for further analysis at a site.
A CSM guides the site characterization process, since it helps identify:

 The goals for gathering data to provide clear information (data quality objectives),
 Needs for more sampling, and
 Risk management decisions which may need to be made, such as cleanup levels and
institutional controls.
A CSM is designed to show real or possible exposure pathways, not quantify the exposure or
health risks presented by that exposure, as is done in a risk assessment. A CSM should be
prepared for every site cleanup. The much more detailed effort of conducting a risk
assessment is usually performed when proposing an alternative cleanup level for soil or
groundwater based upon site specific conditions.
The preparation of a CSM does not need to be a complicated process. The CSM is used to
assist project managers in properly evaluating a site. It should be continually revised as new
site investigations produce updated and more accurate information. In general, a CSM can be
developed with only the most basic information about the site. The less information on hand,
the more the preparer needs to err on the conservative side, assuming that a person, plant or
animal could be exposed to the contamination. As more information is gathered, however, the
CSM can be refined. At closure, text accompanying the CSM should describe how exposure is
being managed or minimized across all complete or potentially complete pathways.
This document provides guidance on how to develop both human health and ecological
Conceptual Site Models for contaminated sites addressed under 18 Alaska Administrative
Code (AAC) 75. It can also be used for leaking underground storage tank sites addressed
under 18 AAC 78.
1
Cumulative Risk Guidance, ADEC September 15, 2016, adopted by reference in 18 AAC 75
Guidance on Developing 1 January 2017

1.1 Exposure Pathways
A listing of all the ways in which exposure could take place, or the “exposure pathways”, is
essential to an accurate description of whom and what may be exposed to contamination.
Consultation with any possible users of the land may be necessary to get a clear picture.
Whether rural or urban, any site can have uses that are not obvious to someone unfamiliar
with the site and the community. Evaluation of exposure pathways should start with
identification of the many different kinds of potential users, including people that live at, visit,
or gather food from the site and plants and animals that may be present.
An appropriate form of public consultation or involvement may be required of the responsible

party to identify exposure pathways. Alaska’s statutes (see AS 46.03.020) give the department
broad powers to involve the public at its discretion. However, mechanisms of public
involvement are not mandated in contaminated sites cleanup regulations so that the
department can tailor its approach to public and community involvement to the needs of each
site. Project managers should recognize the importance of involving interested people and
groups to obtain the most accurate information about current and future land use. When the
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)
applies, methods of public participation are established by federal guidance.
1.2 Complete pathways
In the CSM, the distinction should be made between pathways which are complete and those
which are incomplete. A complete pathway is a way by which a receptor, human, plant or
animal, is or could be exposed to contamination.
Complete pathways should include both currently complete pathways and any that may be
complete in the future based on contaminant migration or changes in land use. Remember that
identifying a pathway as complete does not automatically mean there is actual harm or risk to
humans or the environment. It means that exposure across the pathway needs further
evaluation to determine if it presents a risk. Future restrictions placed on access to the site or
the water on site does not make a pathway incomplete, although at closure it is acceptable to
explain how exposure across a pathway will be controlled. Also, neither the quantity nor the
concentration of a given chemical at the site makes any difference in determining if a pathway
is complete. If chemical concentrations are below screening levels (1/10th of the ADEC
health-based cleanup levels specific to that pathway) then the exposure across that pathway
may be described as insignificant and no further evaluation of the pathway is necessary.
Often there will be insufficient information to determine if a pathway is complete. Take for
example a family living on a site with subsurface soil and groundwater contamination. If
contamination is measured in a drinking water well, then ingestion of the groundwater would
be a complete pathway. However, if it’s not clear whether the contaminants could evaporate
from soil into outdoor air (because, for example, the source is small, the contamination is
deep, or frozen ground limits volatilization of certain compounds) then breathing in
(inhalation) of volatiles in the outdoor air pathway still has the potential to be complete and
should be treated as such until further data is collected or approved modeling has been
performed.

Complete and potentially complete pathways should be considered complete for development
of the preliminary CSM. The preliminary CSM forms the basis of:
1. Further investigation (i.e., further site characterization), or

2. A risk assessment, or
3. Development of risk management decisions (i.e., institutional controls, engineering
controls, or application of cleanup levels).
Comparison of concentrations of chemicals in

Steps in the Cleanup Process
soil or water with DEC cleanup levels or any
other screening level is not sufficient 1. Investigation
justification for eliminating a pathway. If all a. Site characterization workplan: is
developed by a qualified environmental
contaminant concentrations are below 1/10th
professional.* It includes initial and more
of the risk based screening levels that are detailed subsequent investigation, and must
appropriate to both media (soil, water, air, include a CSM. DEC approval of the
food) and exposure route (ingestion, workplan is required.
inhalation, dermal absorption) then the b. Site characterization report:
pathway can be considered insignificant. There summarizes the investigation and
recommends remediation for the site as
may be multiple routes of exposure to
necessary. An updated CSM may be
contaminants in a single media, so necessary if conditions affecting the CSM
contamination in the media should not be evaluation change. A risk assessment, if
considered insignificant until all pathways are conducted, is part of this step. DEC
evaluated. approval of the report is required.
2. Cleanup/risk management
A CSM must be submitted as part of the site
a. Actions taken
characterization step in the cleanup process b. Report submitted to DEC
(see Section 1.4 for more detail on site
characterization). Throughout the rest of the 3. DEC determines closure, with or without
process, the CSM is updated and continues to conditions
be used as information is gained. A potentially
complete pathway may be dropped from * A “qualified environmental professional” is
further evaluation if sufficient evidence is defined in 18 AAC 75.333.
presented to demonstrate, to the satisfaction
of the State of Alaska Department of Environmental Conservation (DEC), that it is not a
complete pathway. Sufficient evidence may include, for example, identification of
impermeable, confining layers in the ground; or determining bioaccumulative compounds are
not present at the site (such as for the ingestion of wild and farmed foods pathway).
1.3 Graphical and Pictorial CSMs

A CSM consists of a graphical flow chart of the exposure pathways at a site, with text
describing each element. An example graphical CSM is provided in Figure 1. Information
should also be included on the physical setting, the land’s surface and subsurface, contaminant
source, routes by which the contaminant may spread, potentially exposed populations, land
use, and exposure pathways. It is necessary to document what evidence and reasoning was
used to determine which exposure pathways were complete or incomplete. Developing and
documenting a CSM does not need to be a long and complicated process, but should provide

the user with enough information to understand how decisions on complete pathways at a site
were made. A pictorial representation of a CSM may be used in addition to the graphical one.
A pictorial CSM is useful in explaining possible exposure at the site to interested members of
the public as well as those involved in the cleanup. An example pictorial CSM is shown in
Figure 2.
1.4 CSM Submittal to DEC

A preliminary CSM depicts the knowledge of complete or potentially complete exposure
pathways at the site at the time it is developed. Unless there is sufficient evidence to
eliminate a pathway, consider it complete in this CSM. Please note: designating a pathway
as complete simply means that the pathway needs to be investigated. Preliminary CSMs should
be updated as additional information becomes available through site investigation. Later
versions of CSMs incorporate all additional information or results of site investigation that
were not available at the time the preliminary CSM was developed.
Preliminary and Revised CSMs must be submitted as required in 18 AAC 75.335. If a risk
assessment is being conducted it is the first document that must be approved by DEC as part
of the risk assessment process. This requirement does not supersede the CSM submittal
requirements at the workplan stage in 18 AAC 75.335.
For consistency between contaminated site projects, DEC has developed a preliminary
scoping form to assist consultants and contractors with a CSM (Appendix A). The preliminary
scoping form can be used at any point in the investigation; however, the best use of the
scoping form is to gain concurrence with the DEC project manager about the potential
pathways that need to be investigated at the site.

FIGURE 1. EXAMPLE – HUMAN HEALTH CONCEPTUAL SITE MODEL (GRAPHICAL)
Contamination Release Impacted Transport Exposure Exposure Human Receptors
Sources Mechanisms Media Mechanisms Media Route
Residential Site Worker Site Visitors Subsistence
Ingestion
Surface Dermal
Soil
Soil
Inhalation
Spills
Ingestion
Migration to
Subsurface
Subsurface Dermal
Soil
Soils
Inhalation
Volatilization
Sediments
Indoor
Inhalation
Tanks, Drums, Air
Contaminated Migration to
Debris, Leaks Groundwater
Outdoor
Unknown Inhalation
Air
Sources
Runoff
Groundwater Fish Ingestion

Animal
Biota Meat Ingestion
Uptake
Plant Ingestion
Direct Plant Ingestion

Discharge Uptake
Groundwater Dermal
Inhalation
Ingestion
Groundwater Surface
Flow Water
Dermal
Surface Water
Ingestion
KEY: Surface Water
Sediment
Transport
Dermal
Complete Exposure Pathway
Pathway Not Complete
Guidance on Developing Conceptual Site Models 5 January 2017

FIGURE 2. EXAMPLE – HUMAN HEALTH CONCEPTUAL SITE MODEL (PICTORIAL)
EPA 2015
Guidance on Developing Conceptual Site Models 6 January 2017

1.5 Site Characterization
The first step toward cleaning up contamination
and reducing risk of exposure is to thoroughly Information to be described in
investigate and then describe the site and the a site characterization
contamination. The investigation plus the
description in a report together comprise site  Surface area of the site;
characterization.  Description of engineered structures
and facilities on site, including
In a relatively simple situation, the level of effort buildings, access roads, storage tanks,
will be fairly simple. Here’s an example: the etc.;
 Past and present uses of the site and
contamination covers a small area, will be nearby properties;
completely removed, treated elsewhere, and  Known and potential sources of
replaced with clean soil. In a case where multiple contamination;
contaminants are involved, they have been there  Types of hazardous substances
for some time, their complete removal is reportedly released at the site;
unlikely, and they have spread to groundwater,  Environmental media potentially
impacted by past and ongoing
site characterization may involve searching past releases; and
records, multiple rounds of sampling, and even a  Site topography and surface water
risk assessment to fully describe how people may bodies on and near the site
be at risk. In the case where a site is divided into
multiple operable units, a CSM should be The magnitude and extent of migration of any
submitted for each one. hazardous substances reportedly released at
the site.
First of all, it is necessary to understand both the
site’s past uses and its current condition to
evaluate the risks it may pose.
To the extent possible, this information should be compiled from existing site characterization
reports, if any, and other historical documents and records. A site reconnaissance may be
necessary if the available reports are old and/or provide incomplete information. A site map
should be prepared showing the locations of engineered structures, past sampling locations,
spill locations, water bodies on and near the site, site topography, and other significant
features. For additional natural features which must be described and displayed on the site
map or on supplemental maps for an ecological CSM, see Section 3.2.
A preliminary list of compounds of potential concern (COPCs) should be developed based on

site-specific history and/or laboratory analysis of environmental media. Early in the site
characterization process, the history of site-specific use is more typically the source of
information on COPCs. However, any available analytical data also should be used. For
metals, it is important to understand the contribution of naturally occurring background
sources to concentrations present on site.

2 COMMON ELEMENTS, HUMAN AND

ECOLOGICAL CSMS
Exposure Pathway Terms and Examples
Conceptual Site Models identify exposure pathways and outline the course a chemical takes
from the source of contamination to a potentially exposed person, animal, or plant (receptor).
Complete exposure pathways consist of four necessary elements; if one of these elements is
missing, the pathway is not complete:
1. A source of contamination and the way it was released into the environment;
2. An environmental medium (i.e., soil, water, or air) and the way in which the chemical
moves through the medium;
3. A location at which a receptor may come in contact with the impacted environmental
medium; and
4. A way a chemical comes in contact with a receptor (i.e., ingestion, inhalation, and
dermal exposure).
Characterization of the physical setting of a site is essential in developing the CSM.

Information on the physical setting can be found in preliminary investigations, site
characterization reports, historical documents, site visits, and interviews with community
members. Special attention should be paid to precipitation, erosion, wind speed and direction,
vegetation, soil type, groundwater hydrology, and location of surface water.
Terms of a CSM, including examples of each term, are shown in Table 1. This guidance will
help identify each of the terms listed in the table and how the elements fit together to develop
a CSM for a site.
Table 1. Exposure Pathway Terms and Examples
Term
(Defined below) Examples
Source Tanks, drums, transformers, landfills
Release Mechanism Spills, leaks, direct discharge, burning
Impacted Media Soil, sediment, groundwater, surface water, air, biota (plants and animals)
Uptake by plants, uptake by animals/fish, volatilization to indoor air,

Transport Mechanisms deposition from fugitive dust, migration through groundwater flow
Exposure Media Soil, sediment, groundwater, surface water, air, biota (plants and animals)
Exposure Routes Ingestion, inhalation, dermal contact
Receptors Human: Adult residents, child residents, short-term workers, long-term

workers, site visitors, trespassers, subsistence users.
Ecological: Invertebrates, plants, fish, mammals, birds, etc.

2.1 Source
All sources of contamination at the site need to be identified. Many times the source is from a
tank, drum, transformer, garage, shop, storage area, or landfill. Other sources may include
discarded batteries, deteriorating buildings, or pesticide application. Information on how the
contaminant was released into the environment will be described next.
2.2 Release Mechanism

The release mechanism describes how contaminants were released from the source into the
environment. For instance, the source of contamination at a site may be an underground
storage tank, but the release mechanism was a leak from that tank. Common release
mechanisms include spills, leaks, direct discharge, and burning, etc. In some instances the
release mechanism is unknown and may need to be an educated guess based on the available
information.
2.3 Impacted Media

The impacted media at a site is the environmental substance to which a contaminant is in
contact with. The impacted media primarily includes soil, sediment, groundwater, surface
water, air, or biota. For instance, oil from a leaking underground storage tank would be
released to the soil. Soil would be the impacted media.
It is important to keep in mind soil, groundwater, surface water, and sediment have specific
definitions which should be considered when determining what type of media has been
impacted. Definitions for each type of media are included below:
 Soil is unconsolidated geologic material, including clay, loam, loess, silt, sand, gravel,
tills, or a combination of these materials (18 AAC 75.990[117]).
 Groundwater is :
o Subsurface water in the saturated zone, for purposes of evaluating whether the
groundwater is a drinking water source under 18 AAC 75.346; or
o Water beneath the surface of the soil, for purposes of evaluating whether the
water will act as a transport medium for hazardous substance migration (18
AAC 75.990[46]).
 Surface water is water of the state naturally open to the atmosphere, including rivers,
lakes, ponds, reservoirs, streams, wetlands, impoundments, and seas (18 AAC
75.990[128]). Groundwater that is closely connected hydrologically to nearby surface
water (i.e. groundwater that daylights through seeps or springs) should also be
evaluated as surface water.
 Sediment is material of organic or mineral origin that is transported by, suspended in,
or deposited from water. Sediments occur in both the freshwater and marine
environments and can include the area along the coastline that is exposed at low tide
and covered at high tide. Sediment includes chemical and biochemical precipitates and
organic material, such as humus (18 AAC 70.990[51]).
2.4 Transport Mechanisms

Transport mechanisms show how contaminants in the impacted environmental media may be
moved to other media. For example, a transport mechanism explains how contamination from
the soil migrates to the groundwater at a site. After a chemical is released in the environment it
may be:
 Physically transported (e.g., volatilization, precipitation, movement
downstream in water or on suspended sediment, or movement through the
atmosphere);
 Chemically transformed (e.g., photolysis, hydrolysis, oxidation, reduction, etc.);
 Biologically transformed (e.g., biodegradation);
 Accumulated in one or more media.
Examples of common sources, transport mechanisms, and exposure media that are found at
contaminated sites are shown in Table 2. Other transport mechanisms are possible and should
be investigated on a case-by-case basis (see Section 3.2.3).
Table 2. Examples of Common Chemical Sources, Transport Mechanisms, and

Exposure Media at Contaminated Sites.
Source or Impacted Transport Mechanisms Exposure Media
Media
Contaminated Surface Volatilization Air
Soil Fugitive Dust Air
Surface Runoff Surface water
Leaching Groundwater
Tracking Soil
Biota Uptake Biota
Surfaces Wastes – spills Volatilization Air
and lagoons Overland flow Surface water or soil
Leaching Groundwater
Subsurface Soil or Leaching Groundwater/ soil
Buried Wastes Volatilization Air (indoor or outdoor)
Surface Water / Water flow Surface water
Wetlands Sorption to particles and deposition Sediment
Biota uptake Biota
Groundwater Seepage Soil , sediment, surface water
Volatilization Air (indoor)
Biota Uptake Other biota
Leaking Containers Overland flow Soil, water
Source: Risk Assessment Guidance for Superfund, Volume 1, Part A, Exhibit 6-3 (EPA 1989).
A complete pathway may not mean that there is a significant risk from exposure.
Exposure may not be significant in some cases because of the extent to which a contaminant
can be transported through a particular media. The CSM narrative should explain why the
pathway is considered insignificant. For example, how well a contaminant dissolves in water,
clings to soil, moves through water or air, or accumulates in biota may determine whether
there is potential for exposure to a particular media. Therefore, consideration of a specific
contaminant’s chemical and physical properties may be helpful in developing the CSM. Once a
pathway is considered complete, more work can be done to determine if exposure via the
pathway is going to pose a significant risk. For more information on this, see Appendix E.

2.5 Exposure Media

Exposure media is the environmental substance an individual (receptor) is exposed to.
Exposure media may include soil, sediment, groundwater, surface water, air, and biota (plants
and animals). Exposure media includes all impacted media that receptors may contact.
2.6 Exposure Routes

An exposure route is the way a contaminant comes in contact with a receptor and the way a
chemical enters the body (i.e. inhalation, ingestion, dermal contact). See Section 3 for Human
CSMs and Section 4 for Ecological CSMs for information on specific routes.

3 HUMAN HEALTH CONCEPTUAL SITE MODELS

The main exposure routes for humans are eating/drinking (ingestion), breathing (inhalation),
and skin (dermal) contact. In this section each exposure route is discussed, including the
scenario or pathway in which it is commonly found. For instance, ingestion is a main exposure
route and is commonly associated with the ingestion of soil, sediment, groundwater, surface
water, and wild or farmed foods.
Not all of the following exposure routes are expected to be encountered at every site. Also,
unique site-specific conditions may require additional exposure routes be investigated.
Complete pathways should include both currently complete pathways and any that may be
complete in the future based on contaminant migration or changes in land use. Remember that
identifying a pathway as complete does not
mean that negative health outcomes are
anticipated, but that the route of exposure Is the soil ingestion pathway complete?
may need evaluation. Consultation with
 Are contaminants present or potentially present in
the public is recommended as an
surface soil between 0 and 15 feet below the
important method to help determine ground surface (ft bgs)?*
exposure routes.
If you answered “yes” to this question, the soil
3.1 Direct Contact with Soil ingestion pathway is complete.
Direct contact with soil comprises two Is the dermal contact with soil pathway
exposure routes, ingestion of soil and complete?
dermal absorption of contaminants from
soil. It is unusual for one of these  Are contaminants present or potentially present in
pathways to be complete without the other surface soil between 0 and 15 ft bgs?*
being complete as well. For this reason  Can the soil contaminants permeate the skin (see
Appendix B)?
they are often considered one pathway.
If you answered “yes” to the questions above, the
This pathway must be investigated if dermal contact pathway is complete.
contamination is found or suspected in the
surface soil (0 to 2 feet below the ground * Contamination at deeper depths may require
surface [ft bgs]) and/or the subsurface soil evaluation on a site specific basis.
down to a depth of at least 15 ft bgs.
Consider the pathway complete for
subsurface soil between 2 and 15 ft bgs unless permafrost, bedrock, or site conditions prohibit
excavation. Generally, 15 feet is the depth from which subsurface soil is brought to the surface
by excavation. In most cases it is unlikely the direct contact exposure pathway will be complete
for contaminated soil below 15 feet. However, contamination at deeper depths may require
evaluation on a site- specific basis (e.g., where deeper excavation is possible such as in areas
were utilities are located below 15 feet, or where the surface grade may be lowered such as on
hill slopes or bluffs). Please note that instituting dig restrictions to prevent exposure to
subsurface soil is not a basis for identifying this pathway as incomplete.
Once the above criteria have been used to determine if the direct contact pathway (ingestion
and dermal) is complete, concentrations of contaminants can be compared to human health
soil cleanup levels in Table B1 of 18 AAC 75. The pathway is still complete regardless of
concentration, but may be considered insignificant if concentrations are below 1/10th the

Table B1 human health soil cleanup values. The human health soil cleanup level is considered
protective of both ingestion of soil and dermal exposure to soil.
3.1.1 Incidental Soil Ingestion

The soil ingestion pathway includes both the incidental ingestion of soil through everyday
hand-to-mouth activities and the ingestion of soil as airborne dust particles. See Section 3.3.3
for further information on the evaluation of fugitive dusts.
3.1.2 Dermal Absorption of Contaminants from Soil

Contaminants may be absorbed into the body through the skin, thus making the dermal
absorption of contaminants in soil a complete pathway. The dermal pathway for soil is
considered a complete exposure pathway for compounds with the ability to permeate the skin
and reach the bloodstream. Common contaminants of concern for dermal exposure to soil are
shown in Appendix B. Non-residential activities, such as construction or trenching activities,
can result in dermal exposure to subsurface soil and should be investigated. Although during
months of cold weather, soil contact with skin may be minimal because the soil is either
covered with snow or the skin may be covered due to the cold temperatures; this is not the
case year round and, therefore, is not sufficient reason to eliminate this exposure pathway.
3.2 Water Ingestion
3.2.1 Ingestion of Groundwater

The ingestion of contaminants in groundwater should be considered a complete pathway if
contaminants are detected in groundwater or could migrate to groundwater and the
groundwater is considered a drinking water source. Groundwater at a site is assumed to be a
current or future drinking water source unless it can be demonstrated, to DEC’s satisfaction,
that it will not be used as such, consistent with pertaining items in 18 AAC 75.350.
Determining that the ingestion of

groundwater pathway is complete does not Is the ingestion of groundwater pathway
complete?
mean that there is current exposure resulting
in unacceptable risk. Information on  Have contaminants been detected or are
chemical concentration can be compared to they expected to be detected in
groundwater cleanup levels in Table C of 18 groundwater, or are contaminants expected
AAC 75. Concentrations below cleanup to migrate to groundwater in the future?
levels do not mean the pathway is  Could the potentially affected groundwater
be used as a current or future drinking
incomplete, but it may be considered water source? (Please note, this question
insignificant if concentrations are below can only be answered “no” if DEC has
1/10th of Table C values. determined the groundwater is not a
currently or reasonably expected future
If soil is contaminated and groundwater is source of drinking water based on 18 AAC
present, soil contaminants may migrate to 75.350.)
groundwater. Ingestion of groundwater is a If you answered “yes” to all the questions above
complete pathway in this case as well, unless the ingestion of groundwater pathway is
the requirements of 18 AAC 75.350 have complete.
been met to determine that groundwater is
not a current or future drinking water source.

Lack of current contamination in groundwater alone may not be sufficient evidence to

determine if contaminants could migrate in the future. Characterization of site conditions (e.g.,
presence of impermeable layers, attenuation of contaminants with depth) or modeling, subject
to DEC approval, may also be used to determine the likelihood that contamination in
groundwater could occur in the future. If contaminants in soil are less than 1/10 Table B1 and
B2 Cleanup Levels for the human health exposure pathways in addition to being less than the
migration to groundwater cleanup level, then the migration to groundwater pathway may be
deemed insignificant.
3.2.2 Ingestion of Surface Water

Surface water can become affected by site Is the ingestion of surface water pathway
contaminants from direct discharge, overland complete?
flow, or migration from groundwater. It is
important to know if a contaminated surface For contaminants in surface water:
water body, such as a lake or stream, is used as  Have contaminants been detected or are
a drinking water source. Use of the drinking they expected to be detected in surface
water, or are contaminants expected to
water could be seasonal, such as during
migrate to surface water in the future?
recreational or subsistence activities, but this is  Could potentially affected surface water
not preclude it from being considered a bodies be used, currently or in the future,
complete exposure pathway. as a drinking water source? Consider both
public water systems and private use (i.e.,
Exposure to surface water while swimming is during residential, recreational or
subsistence activities).
addressed in the additional pathways section.
If you answered “yes” to all the questions above
Even if ingestion of surface water is not a the ingestion of surface water pathway is
complete pathway, Alaska’s water quality complete.
standards for surface water (18 AAC 70) must
be met during cleanup.
3.2.3 Ingestion of Wild and Farmed Foods

Many of Alaska’s contaminated sites are located in areas where people rely on wild plants and
animals as their primary source of food.
This is an important part of the rural Is the ingestion of wild and farmed foods
economy and one of the most highly pathway complete?
valued parts of a rural lifestyle. The use
 Is the site in an area that is used or reasonably
of traditional foods provides a basis for
could be used for hunting, fishing, or harvesting of
nutritional, cultural, spiritual, medicinal, wild or farmed foods?
and economic well being among  Do the site contaminants have the potential to
indigenous peoples and those who have bioaccumulate (see Appendix C)?
adopted a similar lifestyle. In other areas  Are site contaminants located where they would
of the state, gardens, small-scale have the potential to be taken up into biota? (i.e.
agriculture, and aquaculture are soil within the root zone for plants or burrowing
depth for animals, in groundwater that could be
important recreational and economic connected to surface water, etc.)
pursuits as well.
Exposure to site-related contaminants ingestion of wild and farmed foods pathway is
through the ingestion of wild or farmed complete.
foods should be investigated if the site is

used for hunting, fishing, or harvesting of Bioaccumulate and Biomagnify

wild or farmed foods. It should also be
investigated if hunting or fishing is Bioaccumulation is a general term for the build-up
conducted near the site and animals are of substances over time within an organism. An
exposed to the site. This pathway is of organism may be exposed to these substances in
particular concern when contaminants soil, air, or water. Examples of some substances that
may bioaccumulate include some pesticides, some
have the potential to bioaccumulate (see
metals, and some other organic chemicals.
definition in text box, as well as Appendix Bioaccumulation occurs when an organism absorbs
C) in the food chain. Other scenarios exist a toxic substance at a rate greater than that at
which are less common, but still can which the substance is lost.
present a health hazard, such as fish coated
in free product from a spill to surface The term biomagnification refers to the progressive
water; berries coated in contaminated dust; build-up of persistent substances up the food chain.
or plants taking up contaminants from soil It relates to the concentration ratio in a tissue of a
predator organism as compared to that in its prey.
or water. Compounds that biomagnify also bioaccumulate.
Current and future land use should be

considered. This pathway is of particular concern to residents, subsistence users, and
recreational users at a site. The parts and quantities of animals and plants consumed by
subsistence harvesters vary greatly across Alaska. Consultation with subsistence users to
determine relevant pathways is strongly recommended.
Contaminants from soil, sediment, surface water, or other plant and animal life can accumulate
in plants and animals that are eaten by people. Although there are many ways to determine a
chemical’s ability to bioaccumulate or biomagnify in the food chain, DEC considers the
compounds listed in Appendix C to be bioaccumulative. An explanation of how this list was
developed is also included in Appendix C.
DEC does not have cleanup levels specifically designed to be protective of the ingestion of
wild and farmed foods pathway. If this pathway is complete, further evaluation -- either
qualitative or quantitative -- may be necessary to aid risk management decisions.
3.3 Inhalation Is the inhalation of outdoor air pathway

complete?
3.3.1 Inhalation of Outdoor Air
The inhalation of contaminants in outdoor  Are contaminants present or potentially
air is a complete pathway for volatile present in surface soil between 0 and 15 feet
below the ground surface (ft bgs)?*
chemicals that are present in surface and
 Are the contaminants in soil volatile (see
subsurface soil to a depth of 15 feet below Appendix D)?
ground surface (ft bgs). Again, investigating
this pathway to that depth accounts for the If you answered “yes” to the questions above, the
possibility that subsurface soil can be inhalation of outdoor air pathway is
excavated and brought to the surface where complete.
exposure can occur. In addition, compounds
* Contamination at deeper depths may require
are able to volatilize from the subsurface soil evaluation on a site specific basis.
and into outdoor air.

This pathway should only be eliminated if there are no volatile compounds in soil. Those
chemicals listed in the cleanup tables in 18 AAC 75 that meet the definition of volatile are
listed in Appendix D. This pathway should also be investigated for gasoline range organics
(GRO) and diesel range organics (DRO).
A complete pathway does not mean that the exposure results in unacceptable risk at
the site. Information about chemical concentrations is necessary to make that determination.
Low concentrations of contaminants do not imply that the pathway is incomplete, but if they
are below 1/10th of the human health cleanup level, the pathway may be considered
insignificant. The CSM should display all complete pathways, even if they are considered
insignificant.
3.3.2 Inhalation of Indoor Air

Vapor intrusion is the migration of volatile Is the inhalation of indoor air pathway
compounds from the subsurface soil or complete?
groundwater into overlying buildings. People
may inhale the contaminant vapors that  Are occupied buildings on the site or
migrate into buildings. reasonably expected to be placed on the site
in an area that could be affected by
contaminant vapors? (Within 30 feet of
The vapor intrusion pathway should be
petroleum contamination; within 100 feet of
considered complete if petroleum non-petroleum contamination; or subject to
contamination is found within 30 feet, or “preferential pathways.”)
other non-petroleum contamination is found  Are volatile compounds present in soil or
within100 feet (horizontally or vertically) of a groundwater (see Appendix D)?
building or potential location for a building.
This pathway may be important for buildings
inhalation of indoor air pathway is complete.
both with and without a basement. However,
this pathway is typically not complete for
buildings on pilings where airflow is not restricted (e.g., by air-tight skirting).
Significant “preferential pathways” could allow vapors to migrate into a building at distances
greater than 100 feet. In general, petroleum vapors are not expected to migrate as far because
these contaminants are less persistent and degrade more readily than halogenated compounds.
Preferential pathways may include subsurface fractures, utility conduits, and drains that
intersect subsurface vapors. In Alaska, the presence of permafrost or seasonal frost may result
in additional concerns about vapor intrusion into structures. A frozen surface in conjunction
with the thaw bulb that is typically present beneath buildings may create a preferential pathway
to the building.
Volatile contaminants that are of concern for this pathway are listed in Appendix D. DEC will
generally not require an evaluation for vapor intrusion if the only chemicals of concern at a site
are the GRO, DRO, and residual range organic (RRO) petroleum fractions. Other volatile
compounds to evaluate when petroleum contamination is present are shown in bold in
Appendix D.
DEC does not have regulatory cleanup levels for the vapor intrusion pathway; however, the
DEC Vapor Intrusion Guidance for Contaminated Sites (2016) provides target levels for
groundwater, soil gas, and indoor air. Soil data are not good predictors of soil gas

concentrations, and are therefore not used by DEC to predict risk posed by the indoor air
pathway. Once chemical concentrations are measured in groundwater, soil gas, and indoor air,
risk from the vapor intrusion pathway can be estimated using the target levels. Decisions about
site characterization, assessment, management and cleanup should take this additional pathway
under consideration. Absence of existing buildings on site does not necessarily preclude the
elimination of the vapor intrusion pathway from possible consideration.
3.3.3 Additional Pathways

Although the above pathways are the most common ones found at contaminated sites, there
may be additional pathways of concern. These may include dermal exposure to groundwater
or surface water, inhalation of volatiles from groundwater, inhalation of fugitive dust,
incidental ingestion of sediment, or others. Standard DEC cleanup levels for soil and
groundwater are protective of the pathways in this section (Section 3.3.3), but in some
instances, as described below, these additional pathways should be further investigated. It may
also be important to consider the contribution to cumulative risks posed by exposure through
additional pathways. DEC’s risk assessor should be contacted for guidance when additional
pathways are a concern.
Dermal exposure to contaminants in groundwater and surface water may be a complete

pathway if:
 Climate permits recreational use of waters for swimming.
 Climate permits exposure to groundwater during activities, such as construction.
 Groundwater or surface water is used for household purposes such as bathing or
cleaning.
Generally, DEC groundwater cleanup levels in 18 AAC 75, Table C, are deemed protective of
this pathway because dermal absorption is incorporated into the groundwater exposure
equation for residential uses.
Inhalation of volatile compounds in tap water may be a complete pathway if:

 The contaminated water is used for indoor purposes such as showering, laundering, or
dish washing.
 The contaminants of concern are volatile (common volatile contaminants are listed in
Appendix D).
DEC groundwater cleanup levels in 18 AAC 75, Table C are protective of this pathway
because the inhalation of vapors during normal household activities is incorporated into the
groundwater exposure equation.
Inhalation of fugitive dust may be a complete pathway if:

 Nonvolatile compounds are found in the top 2 centimeters of soil. The top 2
centimeters of soil are likely to be dispersed in the wind as dust particles.
 Dust particles are less than 10 micrometers (Particulate Matter - PM10). Particles of this
size are called respirable particles and can reach the pulmonary parts of the lungs when
inhaled.
DEC human health soil cleanup levels in Table B1 of 18 AAC 75 are protective of this
pathway because the inhalation of particulates is incorporated into the soil exposure equation.

Direct contact with sediment involves people coming into contact with sediment, such as
during some recreational, subsistence, or industrial activities. People then incidentally ingest
sediment from normal hand-to-mouth activities. In addition, dermal absorption of
contaminants may be of concern if the contaminants are able to permeate the skin (see
Appendix B). This type of exposure should be investigated if:
 Climate permits recreational activities around sediment.
 The community has identified subsistence or recreational activities that would result in
exposure to the sediment, such as clam digging.
Generally, DEC direct contact soil cleanup levels in 18 AAC 75, Table B1, are assumed to be
protective of direct contact with sediment.
Exposure to contaminants that have been taken up from sediment into plants and
animals that are eaten by humans is addressed under Ingestion of Wild and Farmed Foods,
Section 3.2.3.
3.4 Human Receptors

Types of people called “receptors”, who may be exposed to contamination at a site, are
selected based on the locations and activities of people currently using the site and people
reasonably anticipated to use it in the future. When determining human receptors for a site, it
is important to keep in mind both current and future land use. This information should be
included in the human health CSM. Potential receptors may include the following:
 Resident (adult and child);

 Commercial or industrial worker;
 Construction/trench worker;
 Site visitor;
 Trespasser;
 Recreational user;
 Farmer;
 Subsistence harvester, or
 Subsistence consumer
Residential receptors are addressed through DEC’s default cleanup levels (Section 3.5) or by
developing soil cleanup levels under method four (18 AAC 75.340). Method three soil cleanup
levels can also be developed for commercial or industrial workers. For all other receptors,
DEC requires evaluation through a risk assessment.
Special subpopulations that could potentially be exposed to contaminants should also be

identified. Special subpopulations may be at increased risk from chemical exposure due to
increased sensitivity or behavior patterns, for example, infants and children, elderly people,
pregnant or nursing women, or people with chronic illnesses. Subpopulations of potential
concern can be identified by determining the location and proximity of the site to schools, day
care centers, hospitals, nursing homes, and retirement communities. Consultation with the
public is recommended, including neighbors and others who would know about
subpopulations of people who may be exposed.

3.4.1 Determining Current and Future Land Use

The current and anticipated future use of the site should be used to determine the human
receptors at a site and to develop the CSM. The reasonably expected future use of the site may
differ from the current use. For instance, even if groundwater in the area is not currently used
for drinking water, it may be in the future. Therefore, ingestion of the groundwater should be
considered as a complete pathway at the site. The CSM should note which pathways are
current and which are future, even though both are considered complete.
Assuming that people will live at the site (residential land use) means that they are assumed to
have the most exposure. Therefore, assuming the land use is residential is protective of most
other land uses. However, an assumption of future residential land use may not be necessary if
residential use in the future is highly unlikely, such as in areas zoned for commercial or
industrial land use.
Before it can be assumed in the CSM that future land use will be commercial or industrial, a
formal determination of land use is necessary. DEC ultimately makes that determination,
which needs to be consistent with the definition in 18 AAC 75.990(19) and the process
outlined in 18 AAC 75.340(e)(3). DEC will base a land-use determination upon the following:
 Consultation with the public, including the local zoning authority, if any;
 A determination that the site does not serve a residential land use;
 A determination that the site will not serve a future residential land use based on
consideration of the factors in the EPA’s Land Use in the CERCLA Remedy Selection
Process, OSWER Dir. No. 9355.7-04, dated May 25, 1995 (EPA 1995); land in an
undeveloped area for which it would be difficult to determine a future use pattern is
capable of being a residential area, unless demonstrated otherwise; and
 Consent of each landowner of property with contamination left in place above cleanup
levels
3.4.2 Determining Insignificant Exposure

When a pathway is complete, but exposure is unlikely to result in unacceptable levels of risk
due to conditions present at the site, the CSM can refer to the pathway as insignificant. If
DEC concurs with this decision, no further evaluation of the pathway will be required.
As noted in Section 1.2, if chemical concentrations are below screening levels (1/10th of DEC
health-based cleanup levels specific to that pathway) then the exposure across that pathway
may be described as insignificant and no further evaluation of the pathway is necessary. Other
considerations that may lead to identification of an insignificant pathway include:
 The site is located in a remote area and is expected to remain remote (e.g., not
accessible by road) and short term exposure to contaminant levels present at the site
are not expected to cause effects;
 People are not expected to be on the site for more than 10 days a year and short term
exposure to contaminant levels present at the site are not expected to cause effects; or
 Contaminants are limited in extent, volume, and toxicity and are not expected to cause
a significant exposure threat

3.5 Default Cleanup Levels CSM

It is important to understand the exposure pathways on which the cleanup levels are based.
Cleanup levels for soil and groundwater can be found in 18 AAC 75 tables. These values are
based on a default Conceptual Site Model and are primarily risk-based. 2 If the exposure
pathways, exposure routes, or assumptions used in the cleanup level equations do not match
the site of interest or are not protective of the site’s conditions, further evaluation may be
necessary. The default CSM used for the development of cleanup levels is shown in Figure 3.
The values in 18 AAC 75 assume contaminants were released from a source to soil and/or
groundwater. The source and release mechanism are not defined in this default CSM. The
tabled cleanup levels are protective of long-term (chronic) exposure in a residential setting,
consistent with unrestricted land use. These receptors include both adult and child residents.
In general, other receptors are less exposed to contaminants than residents and, therefore,
these cleanup levels also would be protective for other types of receptors. However, the 18
AAC 75 cleanup levels do not take into account subsistence use (Section 3.2.3), vapor
intrusion into a building (Section 3.3.2), other less common human exposures (Section 3.3.3),
Alaska’s water quality standards for surface water (18 AAC 70) (3.2.2) or ecological effects
(Section 4). If there is a potential for exposure through any of these pathways, then further
evaluation is required.
For soil, the cleanup levels are developed for incidental ingestion, dermal contact and
inhalation of volatiles and particulates emitted from soil for a combined human health cleanup
level, and potential migration of contaminants to groundwater. Specific exposure scenarios,
chemical properties, and soil and aquifer parameters used to develop the cleanup levels are
outlined in the Procedures for Calculating Cleanup Levels (2016).
The cleanup levels for the human health pathway are designed to be protective for exposures
through three pathways: the incidental ingestion of soil, dermal exposure to soil, and the
inhalation of volatile and particulates. The assumptions used in the equations are for a
residential exposure scenario. The cleanup levels are calculated separately for each pathway
and a sum of ratio is used as the final cleanup level. The cleanup levels for the individual
pathways reflect the following:
a. The cleanup levels for incidental ingestion of soil is based off upper bound rates
from the general population and accounts for soil ingestion.
b. The cleanup levels for dermal contact is based off contact with chemicals in
contaminated soil and is calculated using parameters associated with the exposure
event (i.e. skin surface area, dermal absorbed dose, body weight etc.).
c. The cleanup levels for the inhalation pathway were developed to be protective of
the inhalation of chemicals volatilizing from soil to outdoor air and contaminants
adsorbed onto respirable particulates (PM10). Some of these cleanup levels are
capped at the soil saturation concentration where it is lower than the risk-based
value.
2
These cleanup levels are calculated using standard risk equations and back-calculating a cleanup level that is
associated with DEC’s risk standards (cancer risk of 1 in 100,000 and a HQ = 1.0).

2. The cleanup levels for the migration to groundwater pathway are developed to be protective
of residential domestic use of the groundwater from a well located at the downgradient edge
of the contaminated soil source. The equations used to develop the tabled values for this
pathway incorporate a three-phase partitioning equation that estimates the contaminant
concentration in soil leachate and a water-balance equation that calculates a dilution factor that
accounts for the dilution of soil leachate in an aquifer. This exposure pathway is not evaluated
in the arctic zone because of the presence of permafrost and the lack of use of groundwater as
a source of drinking water. The migration to groundwater cleanup level equations make the
following assumptions:
 The source is infinite;
 There is uniform distribution of contaminants in the soil;
 The soil contamination extends from the surface to the water table, but is not in
contact with groundwater or below the groundwater;
 No chemical or biological degradation takes place in the unsaturated zone or
aquifer;
 Equilibrium is instantaneous;
 The aquifer is homogenous;
 Non-aqueous phase liquids are not present at the site; and
 The drinking water well is located (or could be located) at the edge of the
contamination source (i.e., there is no dilution from recharge downgradient of the
site; EPA 1996b).
The target groundwater concentration used in the migration to groundwater pathway

equations is set at the groundwater cleanup levels. The groundwater cleanup levels are
protective of the domestic use of the groundwater by ingestion, dermal contact and inhalation
of volatiles by residents.
Please note, cleanup levels for two compounds listed in the cleanup tables, polychlorinated
biphenyls (PCBs), and lead, are not derived from the CSM described above, but were
developed based on other considerations. They are still assumed to be protective of human
health.

FIGURE 3. DEFAULT – HUMAN HEALTH CONCEPTUAL SITE MODEL FOR TABLED CLEANUP LEVELS
Contamination Release Impacted Transport Exposure Exposure Receptors

Sources Mechanisms Media Mechanisms Media Route
Residential
Ingestion
Soil/
Soil Inhalation
Dust
Dermal
Tanks, Spills,
Drums, Leaks, Outdoor
Volatilization Inhalation
Unknown Direct Air
Sources Discharge
Migration to
Groundwater
Ingestion
Groundwater Groundwater
Inhalation
Dermal
KEY:
Complete Exposure Pathway
22 January 2017
Guidance on Developing Conceptual Site Models
4 ECOLOGICAL CONCEPTUAL SITE MODELS

4.1 Introduction
An ecological conceptual site model identifies sources of contamination, routes of
contaminant transport, contaminated media, routes of exposure, and potentially exposed
plant and animal receptors. A CSM is presented in the form of a flow chart and descriptive
narrative.
This section discusses the types of information that should be collected and reviewed to
develop an ecological CSM for a contaminated site. Development of the CSM from this
information relies on training and professional judgment to qualitatively evaluate both the
potential exposure of ecological receptors to site-related contaminants and the site-specific
conditions. Not every site will require an ecological CSM. DEC’s Ecological Scoping
Guidance (March 2014) should be used to determine if an ecological CSM is necessary at a
site and in turn aid in the development of the ecological CSM.
The sections below describe the information typically found in an ecological CSM. Early in
the process, it is not necessary to fully develop all of the information listed below regarding
the characteristics of the site and surrounding habitats; it is acceptable to develop a simple
CSM based on readily available information.
For example, an initial ecological CSM for a site may consist of:
 A site map;
 Photographs of nearby habitats; and
 One or two pages of text describing sources of contamination, transport pathways,
affected media, and potential receptors and exposure routes.
If warranted based on site concerns, the initial CSM can be supplemented and refined.
4.2 Ecological Characterization

In order to develop an ecological CSM, it is necessary to identify the terrestrial and aquatic
habitat and the plants and animals (biota) that use them. The following elements should be
considered during ecological characterization of the site:
 Vegetative communities and water bodies found on the site.

 Off-site vegetative communities and water bodies that have the potential to be
impacted by site-related contaminants.
 Locations of all wildlife areas, preserves, reserves, sanctuaries, parks, natural areas,
conservation areas, and other protected natural areas near the site.
 Species (non-human) and types of communities present or potentially present at the
site. Species and communities should be considered to be potentially present if they
are known to have been present historically at the site, or if they are present or have
historically been present in similar habitats in the ecoregion (see DEC’s Users Guide
for Selection and Application of Default Assessment Endpoints and Indicator
Species in Alaskan Ecoregions).
 Special species and their habitats at and near the site. Special species include: (1)

state and federally listed rare, threatened, and endangered species; (2) species that are
proposed or recommended for state or federal listing; and (3) other Alaska “species
of special concern.”
To the extent possible, this information should be acquired from existing site reports and by
communication with state and federal agencies, including the United States Fish and Wildlife
Service (USFWS), the National Oceanic and Atmospheric Administration National Marine
Fisheries Service (NOAA Fisheries), and the Alaska Department of Fish and Game
(ADF&G). A site visit by an ecological risk assessor and/or trained ecologist may be
warranted to verify and supplement the information gained from these sources.
A habitat map should be drawn for the site and surrounding area. It may be based on such
sources as aerial photographs, United States Geological Survey (USGS) topographic maps,
or soil maps. Vegetative communities, wetlands, aquatic habitats, and other habitat types
should be shown. The site perimeter should be drawn on the habitat map. Alternatively,
habitat types can be illustrated on the site map described in Section 1.5 if the overall amount
of information displayed is not excessive.
4.3 Identification of Potential Exposure Pathways

Section 2 of this guidance discusses the movement of contamination from source and
impacted media to exposure media. This section applies equally to ecological CSMs.
Once the vegetative communities, water bodies, and species likely to be impacted are
identified, the next step is to identify complete exposure pathways. Any contact between
biota and COPCs in any medium by any route should be considered a complete pathway. In
general, a complete exposure pathway exists when:
 A release to the environment has occurred as documented by site history or
preliminary characterization data;
 Transport of the contaminant to a point of contact is possible;
 A point of contact exists for the contaminant and potential ecological receptor; and
 An exposure route, such as ingestion or inhalation, exists at the point of contact.
Current and future exposure pathways should be considered complete unless there is
evidence that the COPC will not enter the medium or the receptor will not contact the
medium, either directly or indirectly.
Complete exposure pathways for ecological receptor groups should be summarized in a

CSM figure similar to Figure 4. The figure should include sources, transport mechanisms
from sources to exposure media, routes of exposure, and receptors (see Table 1, Exposure
Pathway Terms). A narrative should accompany the CSM figure and should describe the
contents of the diagram in sufficient detail to ensure that the user can understand it.
The following points should be considered when developing the ecological CSM:
 Wildlife exposure routes usually include ingestion of food, drinking water, and

incidental ingestion of soil or sediment. 3

 Plants, soil invertebrates, and soil microbes are assumed to be directly exposed to
soil.
 Benthic invertebrates are assumed to be directly exposed to whole sediment, which
consists of sediment particles and pore water. However, for simplicity, the graphic
version of the CSM need not depict this distinction.
 Dermal exposure of terrestrial wildlife usually is considered to be minor due to
protection provided by fur and feathers.
 In most cases, respiratory exposure of wildlife usually is considered to be
insignificant. However, in some instances this pathway may be significant (e.g.,
exposure of burrowing rodents to volatile organic chemicals in soil).
 Rigorous quantitative methods for estimated risk are not available for all receptor
groups, such as amphibians and reptiles. Nonetheless, if such receptors are present at
a site and potentially exposed to site-related chemicals, they should be included in the
CSM.
 Bioaccumulation potential varies greatly among chemical groups. As a starting point,
the chemicals listed in Appendix C should be considered as bioaccumulative when
developing the ecological CSM for a site.
 Dietary exposure is not routinely evaluated for fish, aquatic invertebrates, reptiles,
and amphibians due to a lack of standardized evaluation methods for these receptor
groups. Nonetheless, for highly hydrophobic organic compounds (e.g., PCBs) and
some metals (e.g., methyl mercury), food chain exposure is likely to be of great
importance for these receptor groups and should be indicated as such in the
ecological CSM.
 Complete pathways should be included in the ecological CSM, even if there is no
standard method of assessing exposure across those pathways.
3
Soil or sediment exposure can be assumed negligible for species that have little exposure to soil
or sediment.
FIGURE 4. EXAMPLE – ECOLOGICAL RISK ASSESSMENT CONCEPTUAL MODEL
Primary Release Secondary Transport Exposure Exposure Ecological Receptors

Sources Mechanisms Sources Mechanisms Media Route Reptiles & Birds &
Vegetation Invertebrates Fish
Amphibians Mammals
Stored
Historic
Surface &
Groundwater
Direct Contact
& Uptake – – –
Materials &
Landfill Wastes
Releases,
Leaching,
Subsurface
Soils
Flow/Seepage,
Runoff, &
Surface
Soil
Incidental
Ingestion – –
Infiltration Volatilization Food Chain – –
Absorption/
Direct Contact –
Surface
Water
Ingestion – – – –
Food Chain –
Absorption/
Direct Contact – –
Sediment Ingestion – –
Food Chain – –
KEY:
Complete Exposure Pathway Groundwater Evaluate as surface water at discharge points
– Not Applicable or Minor Exposure Pathway
* Possible exposure route but vigorous

evaluation methods not available Air Inhalation – – * – *
26 January 2017
Guidance on Developing Conceptual Site Models
5 REFERENCES
Alaska Department of Environmental Conservation (DEC), September 2016, Procedures for
Calculating Cleanup Levels, Contaminated Sites Program.
DEC, September 2016, Procedures for Calculating Cumulative Risk. Contaminated Sites Program.
DEC, March 2014, Ecoscoping Guidance: A Tool for Developing an Ecological Conceptual Site Model.
Contaminated Sites Program.
DEC, November 2016, Guidance on Evaluating the Vapor Intrusion for Contaminated Sites,
Contaminated Sites Program.
DEC, January 2013, Sediment Quality Guidelines (SQG), Contaminated Sites Program.
OECD (Organization for Economic Co-operation and Development). 2002. Hazard

Assessment of Perfluorooctane Sulfonate (PFOS) and its Salts.
ENV/JM/Rd(2002)17/FINAL. Joint Meeting of the Chemicals Committee and the
Working Party on Chemicals, Pesticides and Biotechnology.
Thomann, R.V. 1989. Bioaccumulation model of organic distribution in aquatic food chains. Environ.
Sci. Technol. 23:699-707.
UNEP (United Nations Environmental Program). 2015. Proposal to list pentadecafluorooctanoic

acid (CAS No: 335-67-1, PFOA, perfluorooctanoic acid), its salts and PFOA-related
compounds in Annexes A, B and/or C to the Stockholm Convention on Persistent Organic
Pollutants.
United States Environmental Protection Agency (EPA), June 2015, OSWER Technical Guide
for Assessing and Mitigating the Vapor Intrusion Pathway from Subsurface Vapor Sources to
Indoor Air.
__________, December 2004a, Region 9’s Preliminary Remediation Goals.
__________, September 2016, Persistent, Bioaccumulative, and Toxic (PBT) Profiler, Office of
Pollution Prevention and Toxics, http://www.pbtprofiler.net/.
__________, July 2004c, Risk Assessment Guidance for Superfund, Volume I: Human Health
Evaluation Manual (Part E, Supplemental Guidance, Dermal Risk Assessment), interim,
Office of Emergency and Remedial Response, Washington, D.C.,
EPA/540/R/99/005.
__________, February 2000, Appendix to Bioaccumulation Testing and Interpretation for the Purpose
of Sediment Quality Assessment Status and Needs, Office of Water, Washington D.C.,
EPA-823-R-00-002.

__________, 1998, Guidelines for Ecological Risk Assessment, Risk Assessment Forum,
Washington, D.C., EPA/630/R-95/002F.
__________, 1997, Ecological Risk Assessment Guidance for Superfund: Process for Designing and
Conducting Ecological Risk Assessments, Interim Final, Environmental Response Team,
Edison, New Jersey.
__________, May 1995, Land Use in the CERCLA Remedy Selection Process, Office of Solid
Waste and Emergency Response, Washington D.C., OSWER Dir. No. 9355.7-04.
__________, December 1989, Risk Assessment Guidance for Superfund Volume 1 Human Health
Evaluation Manual (Part A), Office of Emergency and Remedial Response,
Washington, D.C., EPA/540/1-89/002.

APPENDIX A
HUMAN HEALTH SCOPING FORM
Guidance on Developing Conceptual Site Models A-1

January 2017
Print Form
Appendix A - Human Health Conceptual Site Model
Scoping Form and Standardized Graphic
Site Name:
File Number:
Completed by:
Introduction
The form should be used to reach agreement with the Alaska Department of Environmental Conservation (DEC)
about which exposure pathways should be further investigated during site characterization. From this information,
summary text about the CSM and a graphic depicting exposure pathways should be submitted with the site
characterization work plan and updated as needed in later reports.
General Instructions: Follow the italicized instructions in each section below.
1. General Information:
Sources (check potential sources at the site)
USTs Vehicles
ASTs Landfills
Dispensers/fuel loading racks Transformers
Drums Other:
Release Mechanisms (check potential release mechanisms at the site)

Spills Direct discharge
Leaks Burning
Other:
Impacted Media (check potentially-impacted media at the site)

Surface soil (0-2 feet bgs*) Groundwater
Subsurface soil (>2 feet bgs) Surface water
Air Biota
Sediment Other:
Receptors (check receptors that could be affected by contamination at the site)

Residents (adult or child) Site visitor
Commercial or industrial worker Trespasser
Construction worker Recreational user
Subsistence harvester (i.e. gathers wild foods) Farmer
Subsistence consumer (i.e. eats wild foods) Other:
* bgs - below ground surface 1 revised January 2017

2. Exposure Pathways: (The answers to the following questions will identify complete
exposure pathways at the site. Check each box where the answer to the question is "yes".)
a) Direct Contact -
1. Incidental Soil Ingestion
Are contaminants present or potentially present in surface soil between 0 and 15 feet below the ground surface?
(Contamination at deeper depths may require evaluation on a site-specific basis.)
If the box is checked, label this pathway complete:
Comments:
2. Dermal Absorption of Contaminants from Soil

Are contaminants present or potentially present in surface soil between 0 and 15 feet below the ground surface?
(Contamination at deeper depths may require evaluation on a site specific basis.)
Can the soil contaminants permeate the skin (see Appendix B in the guidance document)?
If both boxes are checked, label this pathway complete:
Comments:
b) Ingestion -
1. Ingestion of Groundwater
Have contaminants been detected or are they expected to be detected in the groundwater,
or are contaminants expected to migrate to groundwater in the future?
Could the potentially affected groundwater be used as a current or future drinking water
source? Please note, only leave the box unchecked if DEC has determined the ground-
water is not a currently or reasonably expected future source of drinking water according
to 18 AAC 75.350.
Comments:
2 revised January 2017

2. Ingestion of Surface Water
Have contaminants been detected or are they expected to be detected in surface water,
or are contaminants expected to migrate to surface water in the future?
Could potentially affected surface water bodies be used, currently or in the future, as a
drinking water source? Consider both public water systems and private use (i.e., during
residential, recreational or subsistence activities).
Comments:
3. Ingestion of Wild and Farmed Foods
Is the site in an area that is used or reasonably could be used for hunting, fishing, or
harvesting of wild or farmed foods?
Do the site contaminants have the potential to bioaccumulate (see Appendix C in the guidance
document)?
Are site contaminants located where they would have the potential to be taken up into
biota? (i.e. soil within the root zone for plants or burrowing depth for animals, in
groundwater that could be connected to surface water, etc.)
If all of the boxes are checked, label this pathway complete:
Comments:
c) Inhalation-
1. Inhalation of Outdoor Air
Are contaminants present or potentially present in surface soil between 0 and 15 feet below the
ground surface? (Contamination at deeper depths may require evaluation on a site specific basis.)
Are the contaminants in soil volatile (see Appendix D in the guidance document)?
Comments:

2. Inhalation of Indoor Air
Are occupied buildings on the site or reasonably expected to be occupied or placed on
the site in an area that could be affected by contaminant vapors? (within 30 horizontal
or vertical feet of petroleum contaminated soil or groundwater; within 100 feet of
non-petroleum contaminted soil or groundwater; or subject to "preferential pathways,"
which promote easy airflow like utility conduits or rock fractures)
Are volatile compounds present in soil or groundwater (see Appendix D in the guidance
document)?
Comments:

3. Additional Exposure Pathways: (Although there are no definitive questions provided in this section,
these exposure pathways should also be considered at each site. Use the guidelines provided below to
determine if further evaluation of each pathway is warranted.)
Dermal Exposure to Contaminants in Groundwater and Surface Water
Dermal exposure to contaminants in groundwater and surface water may be a complete pathway if:
o Climate permits recreational use of waters for swimming.
o Climate permits exposure to groundwater during activities, such as construction.
o Groundwater or surface water is used for household purposes, such as bathing or cleaning.
Generally, DEC groundwater cleanup levels in 18 AAC 75, Table C, are deemed protective of this pathway because
dermal absorption is incorporated into the groundwater exposure equation for residential uses.
Check the box if further evaluation of this pathway is needed:
Comments:
Inhalation of Volatile Compounds in Tap Water
Inhalation of volatile compounds in tap water may be a complete pathway if:

o The contaminated water is used for indoor household purposes such as showering, laundering, and dish
washing.
o The contaminants of concern are volatile (common volatile contaminants are listed in Appendix D in the
guidance document.)
DEC groundwater cleanup levels in 18 AAC 75, Table C are protective of this pathway because the inhalation of
vapors during normal household activities is incorporated into the groundwater exposure equation.

Comments:

Inhalation of Fugitive Dust
Inhalation of fugitive dust may be a complete pathway if:

o Nonvolatile compounds are found in the top 2 centimeters of soil. The top 2 centimeters of soil are
likely to be dispersed in the wind as dust particles.
o Dust particles are less than 10 micrometers (Particulate Matter - PM10). Particles of this size are called
respirable particles and can reach the pulmonary parts of the lungs when inhaled.
DEC human health soil cleanup levels in Table B1 of 18 AAC 75 are protective of this pathway because the
inhalation of particulates is incorporated into the soil exposure equation.
Comments:
Direct Contact with Sediment
This pathway involves people's hands being exposed to sediment, such as during some recreational, subsistence,
or industrial activity. People then incidentally ingest sediment from normal hand-to-mouth activities. In
addition, dermal absorption of contaminants may be of concern if the the contaminants are able to permeate the
skin (see Appendix B in the guidance document). This type of exposure should be investigated if:
o Climate permits recreational activities around sediment.
o The community has identified subsistence or recreational activities that would result in exposure to the
sediment, such as clam digging.
Generally, DEC direct contact soil cleanup levels in 18 AAC 75, Table B1, are assumed to be protective of direct
contact with sediment.

Comments:

4. Other Comments (Provide other comments as necessary to support the information provided in this
form.)

Print Form
HUMAN HEALTH CONCEPTUAL SITE MODEL GRAPHIC FORM

Site: ____________________________________________________________________ Instructions: Follow the numbered directions below. Do not
____________________________________________________________________ consider contaminant concentrations or engineering/land
use controls when describing pathways.
Completed By: ______________________________________
Date Completed: _____________________________________ (5)
Identify the receptors potentially affected by each
exposure pathway: Enter “C” for current receptors,
“F” for future receptors, “C/F” for both current and
(1) (2) (3) (4) future receptors, or “I” for insignificant exposure.
Check the media that For each medium identified in (1), follow the Check all exposure Check all pathways that could be complete.
could be directly affected top arrow and check possible transport media identified in (2). The pathways identified in this column must Current & Future Receptors
by the release. mechanisms. Check additional media under agree with Sections 2 and 3 of the Human
rs,
(1) if the media acts as a secondary source. Health CSM Scoping Form.
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Media Transport Mechanisms Exposure Media Exposure Pathway/Route
orke
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or re isitors, tr
or su
Direct release to surface soil check soil
trial w
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(adu ents
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Surface Migration to subsurface check soil
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Resid
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Farm
Soil
Cons
check groundwater
Othe
Subs
Com
harv
Site
(0-2 ft bgs) Volatilization check air
Runoff or erosion check surface water Incidental Soil Ingestion
Uptake by plants or animals check biota
soil Dermal Absorption of Contaminants from Soil
Other (list):___________________________________
Inhalation of Fugitive Dust
Direct release to subsurface soil check soil
Subsurface Migration to groundwater check groundwater
Soil Volatilization check air Ingestion of Groundwater
(2-15 ft bgs) Uptake by plants or animals check biota groundwater Dermal Absorption of Contaminants in Groundwater
Other (list):___________________________________
Direct release to groundwater check groundwater
Volatilization check air Inhalation of Outdoor Air
Ground-
water Flow to surface water body check surface water
air Inhalation of Indoor Air
Flow to sediment check sediment
Uptake by plants or animals check biota Inhalation of Fugitive Dust
Other (list):___________________________________
Direct release to surface water check surface water Ingestion of Surface Water
Surface Volatilization check air surface water Dermal Absorption of Contaminants in Surface Water
Water Sedimentation check sediment
Uptake by plants or animals check biota
Other (list):___________________________________
sediment Direct Contact with Sediment

Direct release to sediment check sediment
Resuspension, runoff, or erosion check surface water
Sediment
Uptake by plants or animals check biota biota Ingestion of Wild or Farmed Foods
Other (list):___________________________________
Revised,
Revised, 4/11/2010
10/01/2010
APPENDIX B
SOIL CONTAMINANTS EVALUATED FOR DERMAL EXPOSURE
Soil contaminants are evaluated for dermal exposure when a specific absorption factor is available (EPA, 2004c). Where specific absorption factors were not
available for an organic compound and it is not considered a volatile, an absorption fraction of 0.10 is applied. It is generally accepted that volatile compounds
evaporate from skin before significant absorption occurs and are addressed through the inhalation exposure pathway.
Acenaphthene Dichlorophenol, 2,4- Naphthalene

Acenaphthylene Dichlorophenoxy Acetic Acid, 2,4- Nitroglycerin
Anthracene Dieldrin Nitroguanidine
Arsenic, Inorganic Diethyl Phthalate Nitroso-di-N-propylamine, N-
Benz[a]anthracene Dimethylphenol, 2,4- Nitrosodiphenylamine, N-
Benzo[a]pyrene Dimethylphthalate Nitrotoluene, m-
Benzo[b]fluoranthene Dinitrobenzene, 1,2- Nitrotoluene, p-
Benzo[g,h,i]perylene Dinitrobenzene, 1,3- Octahydro-1,3,5,7-tetranitro-1,3,5,7-tetrazocine (HMX)
Benzo[k]fluoranthene Dinitrobenzene, 1,4- Octyl Phthalate, di-N-
Benzoic Acid Dinitrophenol, 2,4- Pentachlorophenol
Benzyl Alcohol Dinitrotoluene, 2,4- Pentaerythritol tetranitrate (PETN)
Bis(2-ethylhexyl)phthalate Dinitrotoluene, 2,6- Perfluorooctane Sulfonate (PFOS)
Butyl Benzyl Phthalate Dinitrotoluene, 2-Amino-4,6- Perfluorooctanoic acid (PFOA)
Cadmium (Diet) Dinitrotoluene, 4-Amino-2,6- Phenanthrene
Chlordane Diphenylamine Phenol
Chlordecone (Kepone) Endrin Polychlorinated Biphenyls (high risk)
Chloroaniline, p- Ethylene Glycol Pyrene
Chloronaphthalene, Beta- Fluoranthene TCDD, 2,3,7,8-
Chrysene Fluorene Tetryl (Trinitrophenylmethylnitramine)
Cresol, m- Hexachlorocyclohexane, Alpha- Toxaphene
Cresol, o- Hexachlorocyclohexane, Beta- Trichlorophenol, 2,4,5-
Cresol, p- Hexachlorocyclohexane, Gamma- (Lindane) Trichlorophenol, 2,4,6-
DDD Hexahydro-1,3,5-trinitro-1,3,5-triazine (RDX) Trichlorophenoxyacetic Acid, 2,4,5-
DDT Indeno[1,2,3-cd]pyrene Trichlorophenoxypropionic acid, -2,4,5
Dibenz[a,h]anthracene Isophorone Trinitrobenzene, 1,3,5-
Dibenzofuran Methoxychlor Trinitrotoluene, 2,4,6-
Dibutyl Phthalate Methylnaphthalene, 1-
Dichlorobenzidine, 3,3'- Methylnaphthalene, 2-
Guidance on Developing Conceptual Site Models B-1

January 2017
APPENDIX C
BIOACCUMULATIVE COMPOUNDS OF POTENTIAL CONCERN
Bioaccumulation factors (BAFs) and bioconcentration factors (BCFs) provide a direct

indication of a chemical’s ability to bioaccumulate, although they can vary widely depending
on their basis (estimated or measured), the species used, and the measurement method. A
BAF is the ratio of contaminants in tissues to the concentration in the surrounding
environment (e.g., via food, sediment and water). A BCF is the ratio of the concentration of
a chemical in an organism to its concentration in the surrounding water only.
In addition, it is common practice to use the log Kow to characterize the hydrophobicity,
and thereby bioaccumulation potential, of organic compounds (EPA, 2000). The minimum
criteria defining bioaccumulation potential for nonionic organic compounds is a log Kow
greater than 3.5. The value of 3.5 was used as a minimum threshold based on observed
relationships between the Kow of an unmetabolized chemical and its potential for
biomagnification. Specifically, uptake efficiency tends to increase with increasing log Kow
for values between 3 and 6 (Thomann, 1989). For inorganic compounds, the BCF approach
has not been shown to be effective in estimating the compound’s ability to bioaccumulate.
Information available, either through scientific literature or site-specific data, regarding the
bioaccumulative potential of an inorganic site contaminant should be used to determine if
the pathway is complete.
The ADEC list was developed by including organic compounds that either have a BAF or
BCF equal to or greater than 1,000 from the 2015 EPA national bioaccumulation factor
supplemental information table (Excel) (January 2016) for human health water quality
criteria. Compounds without a BCF or BAF were retained when the log Kow generated
from the ADEC cleanup level calculator was greater than 3.5. These compounds were
entered into EPA’s Persistent, Bioaccumulative, and Toxic (PBT) Profiler (EPA 2016) to
estimate the BCF. Compounds were included in the list when the BCF was greater than
1,000 and excluded when the BCF was less than 1000. The PBT Profiler is located at
http://www.pbtprofiler.net/. Compounds with a log Kow greater than 3.5 that are not found
in the PBT Profiler are included in the list of bioaccumulative compounds below.
Inorganic compounds are also identified as bioaccumulative if they are listed as such by EPA
(2000).
Guidance on Developing Conceptual Site Models C-1

January 2017
Compounds from Table B-1 of 18 AAC 75.341 determined bioaccumulative based on

the process above or otherwise footnoted.
Aldrin DDT Methoxychlor
Arsenic, Inorganic Dibenz[a,h]anthracene Methyl Mercury
Benz[a]anthracene Dibutyl Phthalate Nickel
Benzo[a]pyrene Dieldrin Perfluorooctane Sulfonate (PFOS)1
Benzo[b]fluoranthene Dimethylphthalate Perfluorooctanoic acid (PFOA)2
Benzo[g,h,i]perylene Endrin Phenanthrene
Benzo[k]fluoranthene Fluoranthene Polychlorinated Biphenyls
Butyl Benzyl Phthalate Heptachlor Selenium
Cadmium Heptachlor Epoxide Silver
Chlordane Hexachlorobenzene TCDD, 2,3,7,8-
Chlordecone (Kepone) Hexachlorobutadiene Toxaphene
Chromium(VI) Hexachlorocyclohexane, Alpha- Trichlorobenzene, 1,2,4-
Chrysene Hexachlorocyclohexane, Gamma- (Lindane) Tri-n-butyltin
Copper Hexachloroethane Zinc
DDD Indeno[1,2,3-cd]pyrene
DDE Lead
1The weight of evidence for trophic magnification was deemed sufficient to consider PFOS to be
bioaccumulative by the Stockholm Convention Persistent Organic Pollutants Review Committee (OECD
2002).
2The weight of evidence for trophic magnification was deemed sufficient to consider PFOA to be
bioaccumulative by the Stockholm Convention Persistent Organic Pollutants Review Committee (UNEP
2015).
Guidance on Developing Conceptual Site Models C-2

January 2017
APPENDIX D
VOLATILE COMPOUNDS OF POTENTIAL CONCERN
A chemical is identified here as sufficiently volatile and toxic for further evaluation if the
Henry’s Law constant is greater than 1 x 10-5 atm-m3/mol or vapor pressure is greater than 1
millimeter of mercury (mm HG), and the vapor concentration of the pure component
exceeds the indoor air target risk level when the subsurface vapor source is in soil or
saturated vapor concentration exceeds the target indoor air risk level, when the subsurface
vapor source is in groundwater (EPA, 2015).
Acenaphthene* Fluorene*
Acenaphthylene* Formaldehyde
Acetone Heptachlor
Aldrin Heptachlor Epoxide
Anthracene* Hexachlorobenzene
Benz[a]anthracene Hexachlorobutadiene
Benzaldehyde* Hexachlorocyclopentadiene
Benzene Hexachloroethane
Bis(2-chloroethyl)ether Hexane, N-
Bromobenzene Hexanone, 2-
Bromodichloromethane Hydrazine
Bromoform Isopropanol
Bromomethane Mercury (elemental)
Butadiene, 1,3- Methanol
Butanol, N-* Methyl Ethyl Ketone (2-Butanone)
Butylbenzene, n-* Methyl Isobutyl Ketone (4-methyl-2-pentanone)
Butylbenzene, sec-* Methyl tert-Butyl Ether (MTBE)
Butylbenzene, tert-* Methylene Chloride
Carbon Disulfide Methylnaphthalene, 1-*
Carbon Tetrachloride Methylnaphthalene, 2-*
Chlordane Naphthalene
Chlorobenzene Nitrobenzene
Chloroform Nitrosodimethylamine, N-
Chloromethane Nitrotoluene, o-*
Chloronaphthalene, Beta-* Phenanthrene*
Chlorophenol, 2-* Phosphorus, White*
Cumene Polychlorinated Biphenyls
Cyanide (CN-) Propyl benzene
Cyclohexane Pyrene*
DDE, p,p'- Styrene
Dibenzofuran* TCDD, 2,3,7,8-
Dibromochloromethane* Tetrachloroethane, 1,1,1,2-
Dibromoethane, 1,2- Tetrachloroethane, 1,1,2,2-
Dibromomethane (Methylene Bromide) Tetrachloroethylene
Guidance on Developing Conceptual Site Models D-1

January 2017
Dichlorobenzene, 1,2- Toluene

Dichlorobenzene, 1,3- Trichloro-1,2,2-trifluoroethane, 1,1,2-
Dichlorobenzene, 1,4- Trichlorobenzene, 1,2,3-*
Dichlorodifluoromethane Trichlorobenzene, 1,2,4-
Dichloroethane, 1,1- Trichloroethane, 1,1,1-
Dichloroethane, 1,2- Trichloroethane, 1,1,2-
Dichloroethylene, 1,1- Trichloroethylene
Dichloroethylene, 1,2-cis-* Trichlorofluoromethane*
Dichloroethylene, 1,2-trans-* Trichloropropane, 1,2,3-
Dichloropropane, 1,2- Trimethylbenzene, 1,2,4-
Dichloropropene, 1,3- Trimethylbenzene, 1,3,5-*
Dioxane, 1,4- Tri-n-butyltin*
Endosulfan* Vinyl Acetate
Ethyl Chloride Vinyl Chloride
Ethylbenzene Xylenes
Notes:
1. Bolded chemicals should be investigated when petroleum is present. If fuel was spilled that
contained additives (e.g., 1, 2-dichloroethane, ethylene dibromide, methyl tert-butyl ether), these
chemicals should also be investigated.
2. The chemicals listed here are found in Table B1 of 18 AAC 75.341 and Table C of 18
AAC 75.345 and are volatile compounds as defined in DEC’s Procedures for Calculating
Cleanup Levels. If a chemical is not on this list, contact DEC to determine if a target level
should be calculated.
3. At this time, DEC does not require evaluation of total petroleum ranges (GRO, DRO, or RRO)
for the indoor air inhalation (vapor intrusion) pathway.
4. “*” indicates DEC has not calculated an inhalation screening level for this chemical due to a lack
of toxicity information for the inhalation exposure pathways. The DEC project manager may
require further evaluation of this chemical. Contact the DEC risk assessor for additional
assistance.
Guidance on Developing Conceptual Site Models D-2

January 2017
APPENDIX E
CONTAMINANT PROPERTIES USED TO EVALUATE TRANSPORT MECHANISMS

These parameters describe chemical properties of the site contaminants. Important chemical
parameters used to evaluate transport mechanisms are shown below. The values specific to
each chemical determine how easily a chemical is transported by various mechanisms. The
default values used by the DEC can be found in the DEC’s Procedures for Calculating
Cleanup Levels (September 2016).
Important Physical and Chemical Parameters Used to Evaluate Transport

Mechanisms.
Purpose Parameter Symbol Meaning
Organic Koc Provides a measure of the extent of

carbon chemical partitioning between organic
partition carbon and water at equilibrium. The higher
coefficient the Koc, the more likely a chemical is to bind
to soil or sediment than to remain in water.
Soil/water Kd Provides a soil or sediment-specific measure

partition of the extent of chemical partitioning
Does the
coefficient between soil or sediment and water,
contaminant
unadjusted for dependence upon organic
cling to
carbon. The higher the Kd, the more likely a
organic
chemical is to bind to soil or sediment than
matter or
to remain in water.
does it move
with water?
Octanol Kow Provides a measure of the extent of
coefficient chemical partitioning between water and
octanol at equilibrium. The greater the Kow,
the more likely a chemical is to partition to
octanol than to remain in water. Octanol is
used as a surrogate for lipids (fat), and Kow
can be used to predict bioconcentration in
aquatic organisms.
Does it Solubility Is the upper limit on a chemical’s dissolved

dissolve in concentration in water at a specified
water? temperature? Aqueous concentrations in
excess of solubility may indicate sorption
onto sediments, the presence of solubilizing
chemicals such as solvents, or the presence
of a non-aqueous phase liquid.
Henry’s H1 Provides a measure of the extent of

Does it
Law chemical partitioning between air and water
vaporize?
Constant at equilibrium. The higher the Henry’s Law
Guidance on Developing Conceptual Site Models E-1

January 2017
Purpose Parameter Symbol Meaning
constant, the more likely a chemical is to

volatize than to remain in water.
Vapor Is the pressure exerted by a chemical vapor
Pressure in equilibrium with its solid or liquid form at
any given temperature? It is used to
calculate the rate of volatilization of a pure
Does it
substance from a surface or in estimating a
vaporize?
Henry’s Law constant for chemicals with
low water solubility. The higher the vapor
pressure, the more likely a chemical is to
exist in a gaseous state.
Movement Diffusivity Describes the movement of a molecule in a

of liquid or gas medium as a result of
molecules differences in concentration. It is used to
Does it calculate the dispersive component of
spread? chemical transport. The higher the
diffusivity, the more likely a chemical is to
move in response to concentration
gradients.
Bioconcentration Provides a measure of the extent of

Factor (BCF) chemical partitioning at equilibrium
Does it
between a biological medium such as fish
accumulate
tissue or plant tissue and an external
in living
medium such as water. The higher the BCF,
tissue?
the greater the accumulation in living tissue
is likely to be.
Persistence Media-Specific Provides a relative measure of persistence of

How easily Half-Life a chemical in a given medium, although
does it actual values can vary greatly depending on
break down site-specific conditions. The greater the
over time? half-life, the more persistent a chemical is
likely to be.
Source: Risk Assessment Guidance for Superfund, Volume 1, Part A, Exhibit 6-4 (EPA 1989).
Guidance on Developing Conceptual Site Models E-2

January 2017

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State of Alaska

DIVISION OF SPILL PREVENTION AND RESPONSE

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Guidance on Developing ii January 2017

Guidance on Developing iii January 2017

Guidance on Developing iv January 2017

A CSM guides the site characterization process, since it helps identify:

Guidance on Developing 1 January 2017

1.1 Exposure Pathways

An appropriate form of public consultation or involvement may be required of the responsible

1.2 Complete pathways

Guidance on Developing 2 January 2017

1. Further investigation (i.e., further site characterization), or

Comparison of concentrations of chemicals in

1.3 Graphical and Pictorial CSMs

Guidance on Developing 3 January 2017

1.4 CSM Submittal to DEC

Guidance on Developing 4 January 2017

Groundwater Fish Ingestion

Direct Plant Ingestion

Pathway Not Complete

Guidance on Developing Conceptual Site Models 5 January 2017

Guidance on Developing Conceptual Site Models 6 January 2017

A preliminary list of compounds of potential concern (COPCs) should be developed based on

Guidance on Developing 7 January 2017

2 COMMON ELEMENTS, HUMAN AND

Characterization of the physical setting of a site is essential in developing the CSM.

Source Tanks, drums, transformers, landfills

Release Mechanism Spills, leaks, direct discharge, burning

Uptake by plants, uptake by animals/fish, volatilization to indoor air,

Exposure Routes Ingestion, inhalation, dermal contact

Receptors Human: Adult residents, child residents, short-term workers, long-term

Guidance on Developing 8 January 2017

2.2 Release Mechanism

2.3 Impacted Media

2.4 Transport Mechanisms

Table 2. Examples of Common Chemical Sources, Transport Mechanisms, and

Guidance on Developing 10 January 2017

2.5 Exposure Media

2.6 Exposure Routes

Guidance on Developing 11 January 2017

3 HUMAN HEALTH CONCEPTUAL SITE MODELS

Guidance on Developing 12 January 2017

3.1.1 Incidental Soil Ingestion

3.1.2 Dermal Absorption of Contaminants from Soil

3.2 Water Ingestion

3.2.1 Ingestion of Groundwater

Determining that the ingestion of

Guidance on Developing 13 January 2017

Lack of current contamination in groundwater alone may not be sufficient evidence to

3.2.2 Ingestion of Surface Water

3.2.3 Ingestion of Wild and Farmed Foods

Guidance on Developing 14 January 2017

used for hunting, fishing, or harvesting of Bioaccumulate and Biomagnify

Current and future land use should be

3.3 Inhalation Is the inhalation of outdoor air pathway

Guidance on Developing 15 January 2017

3.3.2 Inhalation of Indoor Air

Guidance on Developing 16 January 2017