9:30 welcome and general updates - paul locke 9:50 newton vapor intrusion case study: observations...

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) 556-1160Paul.Locke@state.ma.uswww.Mass.Gov/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/)