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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 Agenda October 22, 2015
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Vapor Intrusion Investigation and Mitigation Studies John Fitzgerald MassDEP Newton, MA 2014 - 2015
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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
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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
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Indoor Air Testing 57 Residential Dwellings 157 “grab” samples 16 Canister 24 hr TWA TCE Detected in 19 homes, up to 180 µg/m 3 7 Imminent Hazard Conditions Encountered
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“ 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
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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
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Vs. 1-Liter Grab Sample in Kynar Bag HAPSITE GC/MS 24-hour TWA Sample in Passivated Steel Canister TO-15 SIM
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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
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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
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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
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Off-Gassing
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Average Percent Recovery TO-14 Std in Kynar Bags 1-100 ppbV TCE Sorption 2013 MassDEP Study
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% Recovery of TCE in TO-14 Mixture in Kynar Bag at Various Concentrations 2013 MassDEP Study 1 ppbV 2 ppbV 5 ppbV 10 ppbV 20 ppbV 50 ppbV 100 ppbV
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Bottom Line: Kynar Bag Data likely to have low bias, though re-use of bags likely leads to less sorption/less bias
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Stability? How does holding time affect results?
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Studies Conducted on Newton Site Samples
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Home 2 Home 7 Home 6 Studies Conducted on Newton Site Samples
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Inficon HAPSITE GC/MS
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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
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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/m 3 for TCE) %RSD of RRF < 30 (compliant with MassDEP CAM) Reporting Limit = 1 ppbV (5.4 µg/m 3 TCE) Estimated “J” value down to 0.2 ppbV (1 µg/m 3 TCE) Daily Check Standard @ 5.9 ppbV (32 µg/m 3 TCE) Grab Sample Analytical Method
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Comparison of Grab HAPSITE Sample Data to 24-hour TWA Canister/TO-15 Data All data obtained 11/22/14 to 2/17/15
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24-hr TWA Data was Compared to Synoptic or Near-Synoptic Grab Samples X X X X XXX XX XX XXXXX -6-5-4-3-2012 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
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Temporal Variability?
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Daily TCE Grab Sample Data From Home 5 (Basement) Barometric Pressure Temperature Wind Zero ⁰F 45 ⁰F +/- 50%
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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
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Mitigation
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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
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Austin Air Healthmate Plus Activated Carbon/Zeolite/KI 12.5 pounds Activated Carbon 3 speed fan 47 CFM 125 CFM 250 CFM
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Theoretical Filter Life
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Home 1 Bsmt Home 1 Home 2 Bsmt Home 2 Home 3 Bsmt Home 4 Bsmt Home 5 Home 6 Home 4 Bsmt Apartment
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TCE in Basement of Home 5
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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?
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Competitive Adsorption
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Carbon Tested at 100 ppmV 4 orders of magnitude! Questionable Extrapolations
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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
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Questions?
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Guidance/Other Updates Next Waste Site Cleanup Advisory Committee meeting - Thursday, December 17 th, 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 12 th, 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
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Soil Management Paul W. Locke Acting Assistant Commissioner Bureau of Waste Site Cleanup One Winter Street Boston, MA 02108 (617) 556-1160 Paul.Locke@state.ma.us www.Mass.Gov/dep
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SOIL Management This time last year…
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Section 277 of the 2015 Massachusetts Budget 9/16/2014
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52 “Similar Soils” Similar to “Similar Soils” “Remediation Waste” Similar to “Remediation Waste” “Gap Soils” (Between Similar Soils and Remediation Waste) Similar to “Gap Soils”
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53 Similar to “Remediation Waste” “Similar Soils” Similar to “Similar Soils” “Gap Soils” (Between Similar Soils and Remediation Waste) Similar to “Gap Soils” “Remediation Waste” Where Can This Uncontaminated Soil Go??
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http://www.mass.gov/eea/agencies/massdep/cleanup/regulations/site-cleanup-policies-guidance.html#1
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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
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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;
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ACO = “Approval” or “Permit” The Administrative Consent Order is the tool DEP is using in this context to provide its approval in a manner that is enforceable. It is not an indicator of noncompliance. Why an ACO?
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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.
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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 an approvable Soil Management Plan
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What’s NOT covered by the policy: Quarry reclamation projects that involve less than 100,000 yd 3 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
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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/)
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