Ontario Ministry of the Environment posts Proposal for Amending Ontario Regulation 153/04, Brownfields Records of Site Condition , including some changes to site condition standards

On February 25th, 2011, the Ontario Ministry of the Environment posted the Proposal for Amending Ontario Regulation 153/04, Brownfields Records of Site Condition for a 45 day comment period, ending April 11th, 2011. This posting included a document entitled Protocol for Analytical Methods Used in the Assessment of Properties under Part XV.1 of the Environmental Protection Act (Analytical Protocol).

Since 2007, AGAT Laboratories has actively participated with the Ministry’s Laboratory Services Branch as part of the Technical Advisory Group (TAG). The TAG is made up of industry stakeholders from commercial laboratories, qualified persons, accrediting bodies and industry organizations whose aim it was to revise and improve the Protocol for Analytical Methods Used in the Assessment of Properties under Part XV.1 of the Environmental Protection Act. The collective efforts of the group are represented in the previously provided link to the relevant documentation.

The updated document illustrates a number of key differences in analytical and field approaches that will have a material impact on the way samples are procured and on the decisions made by qualified persons as a result of analytical determinations in laboratories.

AGAT Laboratories is pleased to present a number of Technical Updates to better inform our clients on these changes.

Volati le Organic Compounds in Soil

A number of key differences are outlined with respect to Volatile Organic Compound determination in soil. Specifically, these changes relate to the way samples are taken in the field.

From the Analytical Protocol:

Table A: Soil and Sediment - Sample Handling and Storage Requirements

Soil Organic Parameters Container Field Preservation Storage

Temp.Preserved Hold Time

Unpreserved Holding Time

VOC7, THM, BTEX8, PHCs (F1)8

40 - 60 mL glass vial (charged with methanol preservative,

pre-weighed)6 and glass jar (for moisture content)

[Hermetic samplers are an acceptable alternative]5,18

Methanol (aqueous NaHSO4 is an

acceptable alternative for

bromomethane)6,7,18

5 ± 3 C 14 Days

Hermetic sample: Stabilize

with Methanol preservative

within 48 hours of sampling18

Technical Update

Laboratories Service Beyond Analysis

■ www.agatlabs.com

Footnotes

The footnotes related to the sample handling and the related explanations from AGAT Laboratories are as follows:

No. 5

As an alternative, the US Environmental Protection Agency (USEPA) has investigated hermetic sampling devices that take and seal a single core sample. The sampler is submitted as is to the laboratory and extruded into an extracting solvent. Samples must be received at the laboratory within 48 hours of sampling. This technique minimizes volatilization losses and is worth consideration for critical sites.

Please note: Replicate samples are necessary for bisulphate and methanol extraction for all samples as well as for laboratory duplicates and spikes.

AGAT Laboratories has signed an agreement with En Novative Technologies to act as the exclusive laboratory distributor in Canada for the En Core® hermetic sampler, the only hermetic sampling device that is approved by the USEPA.

The footnote points to the requirement for more than one En Core® Sampler per sample location. This is not necessary unless there is an inability by the laboratory to reach the required Ministry-mandated reporting limit for Bromomethane specifically. AGAT Laboratories is able to reach the required reporting limit for Bromomethane using a Methanol extraction and therefore requires only one En Core® Sampler per sampling location.

Additional En Core® sampling devices may be required for quality control purposes (duplicates and spikes).

For more information on this device, AGAT Laboratories’ agreement, product availability and use, please contact your AGAT Client Project Manager.

No. 6

The USEPA has also approved field preservation. Pre-weighed vials containing known weights of methanol preservative (or aqueous Sodium Bisulphate if used for Bromomethane) are sent to the field. Sample cores (approximately 5g) are extruded directly into a vial. These vials are sealed and then submitted directly to the laboratory.

In practice, this technique is tedious and losses may occur due to leaking vials or through splashing. AGAT Laboratories provides guidance and specific instruction on the use of pre-charged Methanol vials on our website at www.agatlabs.com.

The footnote calls for the use of aqueous bisulphate for use when Bromomethane is to be determined. This only applies when a laboratory is unable to reach the Ministry-mandated reporting limit for Bromomethane from a Methanol extraction.

As AGAT Laboratories is able to reach the Ministry-mandated reporting limit for Bromomethane, we only require one vial per sample, preserved with Methanol. We are pleased to provide sampling kits that include the appropriate number of vials as well as the Terra Core® or Easy Draw Syringe® Samplers and a per cent moisture jar (if necessary) for all VOC samples taken.

No. 7

Methanol-preserved samples can elevate the detection limit for Bromomethane (VOC). As a result, a separate bisulphate-preserved sample or hermetically sealed sample should be submitted at the time of sampling if Bromomethane is a chemical of concern. To determine if a separate sample should be collected, contact your laboratory.

AGAT Laboratories does NOT require a separate bilsulphate preserved sample for Bromomethane determination. Our determined detection limits for Bromomethane in a Methanol preserved sample meet all the Ministry of the Environment’s Reporting Limit criteria.

No. 8

For BTEX compounds and Petroleum Hydrocarbon (PHC) (F1), pre-charging the soil sampling container with methanol preservative is an accepted deviation from the Canadian Council of Ministers of the Environment (CCME)’s method.

The CCME methodology for hydrocarbon determination is a prescriptive one. Very few variations from the methodology are allowed without written permission from the Ontario Ministry of the Environment.

The CCME hydrocarbon methodology calls for the use of a packed jar in sampling for Fraction 1 / BTEX. This means that the Methanol field preservation requirement represents a deviation from this methodology. By including a footnote indicating that field preservation is allowed and in fact, a required deviation from the original method, the Ontario Ministry of the Environment is indicating to all laboratories that they do not require written permission to use the field preservation approach for light end hydrocarbon determinations.

No. 18

To achieve a longer hold time, hermetic samples may be frozen within 48 hours of sampling as per ASTM method D6418-09. The storage stability must however, be validated by the laboratory with no more than 10 per cent in losses.

AGAT Laboratories is currently evaluating suitable hold times related for the freezing of En Core® Samplers and intends to work with the Ontario Ministry of the Environment in order to extend the potential hold time for the En Core® Sampler.

AGAT Laboratories is the exclusive Canadian laboratory supplier of the En Core® Sampler and associated devices

En Core® Sampler collects, stores and delivers soil samples, all within one easy-to-use device. The airtight sealing cap prevents the loss of volatiles as the En Core® Sampler becomes its own self-contained package. The En Core® Sampler is approved by the Ontario Ministry of the Environment as the only alternative to Methanol field stabilization, thereby eliminating the requirement for chemical stabilization in the field. It also improves quality control in the field by avoiding inconsistent sampling that may otherwise occur during the Methanol stabilization technique.

The En Core® Sampler is also the only device currently approved by the USEPA. The current Protocol for Analytical Methods Used in the Assessment of Properties under Part XV.1 of the Environmental Protection Act indicates that only USEPA hermetic sampling devices are approved for use under Ontario Regulation 153/04 (as amended).

In addition, the Ontario Ministry of the Environment has also approved field preservation. Pre-weighed vials containing known weights of methanol preservative are sent to the field. Sample cores are extruded directly into the vial and the vials are then sealed and submitted directly to the laboratory.

As of March 7th, 2011, AGAT Laboratories requires clients who want to compare VOC data to incoming standard criteria to utilize either the Methanol field stabilization or En Core® sampling techniques. Samples taken via packed jar and compared with the amended standard criteria will be qualified on AGAT Laboratories’ Certificates of Analysis in the Case Narrative section.

Please contact your AGAT Client Project Manager or Business Development Representative with any questions or concerns. Or for more targeted questions, please feel free to contact Marcus Maguire our Senior Vice President and TAG member at 905.712.5071 or via email at maguire@agatlabs.com.

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