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9:30 Welcome and General Updates - Paul Locke
9:50 Newton Vapor Intrusion Case Study: Observations and Findings - John Fitzgerald and Steve Johnson
10:45 Update on Executive Order 562, - Beth Card, Deputy Commissioner
11:15 Status of BWSC Guidance Development - Liz Callahan
11:30 Reclamation Soil Policy Implementation- Paul Locke
Waste Site Cleanup Advisory Committee Meeting AgendaOctober 22, 2015
Vapor Intrusion Investigation and Mitigation Studies
John FitzgeraldMassDEP
Newton, MA
2014 - 2015
Former Auto Parts Salvage Yard 1930s- 1990s
History of “Bad Housekeeping”
Audit of DPS site with TCE
Shallow wells only
Upgradient well TCE @ 3.9 µg/L
Downgradient well TCE @ 2700 µg/L
N
5 ft screens
Welded Point
Coupling
Laser-cut slots
5 ft risers
¾” O.D. Steel Pipe
1 ½ “ PVC Pipe/coupling Grout
Alum screw cap at grade
September 2014 – May 2015
MassDEP installs 39 small-diameter direct-push wells
Most Wells 20 – 25 feet deep
Depth to GW 11 to 20+ feet
TCE as high as 3700 µg/L
Indoor Air Testing
57 Residential Dwellings
157 “grab” samples
16 Canister 24 hr TWA
TCE Detected in 19 homes, up to 180 µg/m3
7 Imminent Hazard Conditions Encountered
“Grab” Samples
1 Liter Kynar® Bag (PVDF)
Generally obtained in basement and on first floor
Analyzed on HAPSITE GC/MS < 24 hours
Analyzed on-site in Mobile Lab or at NERO office
TCE Reporting Limit 5.4 µg/m3; “J” value 1 µg/m3
24-hour TWA Canister Samples
Contract Laboratory
6-Liter Passivated Steel Canisters
Separate cans in basement and on first floor
Analyzed via EPA TO-15 SIM
TCE Reporting Limit = 0.1 µg/m3
Vs.
1-Liter Grab Sample in Kynar Bag
HAPSITE GC/MS
24-hour TWA Sample in Passivated Steel Canister
TO-15 SIM
1-Liter Grab Sample in Kynar Bag
HAPSITE GC/MS
24-hour TWA Sample in passivated steel
canister TO-15 SIM Vs.
Sample Integrity
Representativeness
Detection Limits
1-Liter Grab Sample in Kynar Bag
HAPSITE GC/MS
24-hour TWA Sample in Passivated Steel Canister
TO-15 SIM Vs.
Logistics
Data Reports
Costs
Bags are not a perfect sampling container…
They off-gas manufacturing chemicals creating false positives and/or positive biases
They sorb contaminants creating a negative bias
Off-Gassing
Average Percent Recovery TO-14 Std in Kynar Bags 1-100 ppbV
TCE
Sorption2013 MassDEP Study
% Recovery of TCE in TO-14 Mixture in Kynar Bag at Various Concentrations
2013 MassDEP Study
Bottom Line: Kynar Bag Data likely to have low bias, though re-use of bags likely leads to less sorption/less bias
Stability?
How does holding time affect results?
Studies Conducted on Newton Site Samples
Home 2
Home 7
Home 6
Studies Conducted on Newton Site Samples
Inficon HAPSITE GC/MS
Inficon HAPSITE GC/MS
Portable/transportable GC/MS units
MassDEP has 2 units: “SP” and “ER” models
70 eV Electron Impact Ionization Mode
Run on Full Scan mode (45 to 250 AMU)
Capillary Column 30 m x 0.32 mm ID x 1 µ film
Sample introduction via Probe @ 110 cc/min
Activated carbon concentrator for lower detection limits
36 Target Analytes (including TCE)
Two Internal Standards: 1,3,5-Tris; BPFB
6 point calibration (1 to 50 ppbV; 5.4 to 269 µg/m3 for TCE)
%RSD of RRF < 30 (compliant with MassDEP CAM)
Reporting Limit = 1 ppbV (5.4 µg/m3 TCE)
Estimated “J” value down to 0.2 ppbV (1 µg/m3 TCE)
Daily Check Standard @ 5.9 ppbV (32 µg/m3 TCE)
Grab Sample Analytical Method
Comparison of Grab HAPSITE Sample Data to
24-hour TWA Canister/TO-15 Data
All data obtained 11/22/14 to 2/17/15
24-hr TWA Data was Compared to Synoptic or Near-Synoptic Grab Samples
XXXX
X XXX XX X XX
X X X X X-6 -5 -4 -3 -2 -1 0 1 2
Time (Day) when Grab Samples Taken Compared to 24-hr TWA (at Time = 0)
Grab sometime during 24-hr TWA
Grabs taken at beginning and end of
24-hr TWA period
Temporal Variability?
Daily TCE Grab Sample Data From Home 5 (Basement)
Barometric Pressure
Temperature
WindZero ⁰F
45 ⁰F
+/- 50%
Conclusions on Grab vs TWA
Kynar Bag Grab samples likely biased somewhat low, and false positives detection are unlikely
Kynar Bag Grab samples are a good tool to “screen in” potential sites of concern, and, where appropriate, trigger the need for accelerated follow-up actions
….. Not a definitive tool to “screen out” a problem
Mitigation
Air-Purifying Units (APUs)
VOCs removed via sorption onto activated carbon and/or other treatment techniques
Especially important for TCE cases, due to concerns over even short term exposures
Small portable units deployed to impacted homes to reduce infiltrating VOCs until more permanent measures (e.g., SSDS) can be implemented
At Newton Site, 8 Austin Air Healthmate Plus APUs deployed to 6 homes
Austin Air Healthmate Plus
Activated Carbon/Zeolite/KI
12.5 pounds Activated Carbon
3 speed fan47 CFM125 CFM250 CFM
Theoretical Filter Life
Home 1 Bsmt
Home 1
Home 2 Bsmt
Home 2
Home 3 Bsmt
Home 4 Bsmt
Home 5
Home 6
Home 4 Bsmt Apartment
TCE in Basement of Home 5
APUs were able to consistently reduce TCE levels to less than 20 µg/m3
APUs were NOT able to consistently reduce TCE levels to less than 6 µg/m3
Why?
Competitive Adsorption
Carbon Tested at 100 ppmV
4 orders of magnitude!
Questionable Extrapolations
There is virtually no published information or data on the performance of activated carbon
air-purifying systems or filters at low (< 50 ppbV) VOC concentration levels
There may be significant differences in the extent and/or kinetics of VOC sorption onto
activated carbon at low µg/m3 concentrations
Questions?
Guidance/Other Updates• Next Waste Site Cleanup Advisory Committee meeting - Thursday, December 17th, 9:30 am, Boston•Green Remediation Leadership Recognition Program•Finalizing AUL, Vapor Intrusion and LNAPL documents – goal for final documents is “Fall” 2015 Revised draft of LNAPL document to be posted LNAPL meeting date for discussion of how draft has changed scheduled for November 12th, 10 am to noon (tentative – date will be confirmed in BWSC.Information email when draft is posted• Historic Fill public review draft – Fall 2015•Telemetry - DEP follow-up
Soil Management
Paul W. LockeActing Assistant Commissioner
Bureau of Waste Site CleanupOne Winter StreetBoston, MA 02108
(617) [email protected]/dep
SOIL Management
This time last year…
Section 277 of the
2015 Massachusetts Budget
9/16/2014
52
“SimilarSoils”
Similar to“SimilarSoils”
“RemediationWaste”
Similar to“Remediation
Waste”
“Gap Soils”(Between Similar Soils and
Remediation Waste)Similar to
“Gap Soils”
53
Similar to“Remediation
Waste”
“SimilarSoils”
Similar to“SimilarSoils”
“Gap Soils”(Between Similar Soils and
Remediation Waste)Similar to
“Gap Soils”
“RemediationWaste”
Where Can ThisUncontaminated Soil Go??
http://www.mass.gov/eea/agencies/massdep/cleanup/regulations/site-cleanup-policies-guidance.html#1
APPLICABILITY
applicable to any quarry, gravel pit, or sand pit reclamation project that receives, or plans to receive greater than 100,000 cubic yards of soil for the reclamation/filling of said quarry, gravel pit, or sand pit after August 28, 2015
• Reclamation projects that will begin to receive on site more than 100,000 cubic yards of soil after August 28, 2015;
• Reclamation projects that have commenced physically receiving soil on site on an “at risk” basis prior to August 28, 2015 subject to the regulations, policies and procedures in place prior to August 28, 2015 and which will receive more than 100,000 cubic yards after October 31, 2015;
ACO = “Approval” or “Permit”
The Administrative Consent Order is the tool DEP is usingin this context to provide its approval
in a manner that is enforceable.
It is not an indicator of noncompliance.
Why an ACO?
Implications
The use of soil for the reclamation of a quarry, sand pit or gravel pit under the conditions of this policy is considered approved re-use for the purposes of the notification exemption described at 310 CMR 40.0317(13).
and
Soil fill projects to which this policy applies and that are not managed in compliance with this policy may be found to have caused, contributed to, or exacerbated a release of OHM and may be subject to enforcement pursuant to Section 277 of Chapter 165 of the Acts of 2014, M.G.L. c. 21E, § 6 and 310 CMR 40.0000, and/or M.G.L. c. 111, § 150A and 310 CMR 16.00 and 19.000.
Nuts & Bolts
• Come and Talk – Early & Often• Talk to the MassDEP Regional Director• Talk to the municipal officials• Talk with us all together and/or separately
• Listen to Local Concerns & Be a Good Partner
• Work with DEP to develop anapprovable Soil Management Plan
What’s NOT covered by the policy:
•Quarry reclamation projects that involve less than 100,000 yd3 of soil;
•Projects (of any size) needing fill material that are not quarries, sand pits or gravel pits (although DEP would entertain a request should an operator voluntarily choose to come forward for an approval);
•Quarry reclamation projects that choose to operate under the current rules, “at risk” for creating a disposal site requiring notification, assessment and cleanup and/or creating an illegal solid waste dumping ground;
•Excavation Projects
What’s Next?
• Work with proponents to issue new approvals under this policy
• Evaluate the projects (qualitatively? quantitatively?) to see what works and what doesn’t
• Consider development of a permit program (with associated regulations) that would replace the ACO process (see December 12, 2014 Workgroup meeting discussion https://reclamationsoil.wordpress.com/2014/12/15/video-from-121214-meeting/)