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EPH – the NJ-Mandated Replacement for TPH |
Request for reduced sampling/analysis at area D
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On January 14, 2010 the Army submitted to the USEPA and to the NJDEP a proposal to reduce the sampling program at Area D. The proposed reduced sampling frequency had apparently been the topic of discussion at the November 12, 2009 technical meeting between representatives of Picatinny Arsenal, the Army Corps of Engineers, the USEPA, the NJDEP, and ARCADIS. Currently sampling focuses on several different objectives at Area D. They are as follows: performance monitoring of the permeable reactive barrier (PRB), monitored natural attenuation (MNA) sampling, compliance monitoring of surface water in Green Pond Brook, and sampling of a nearby drinking water supply well (Well 131). ARCADIS has proposed changes to the PRB monitoring and MNA sampling programs. Changes to the PRB performance monitoring were proposed on the basis of a contention that the system has reached a steady state and that no seasonal |
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variations in geochemical parameters have been observed. ARCADIS is proposing a change from quarterly to annual frequency starting in Year 3 for geochemical parameters only (those parameters, other than volatile organic compounds, which are associated with the chemical reactions occurring within the PRB and that are indicative of the “functionality” of the PRB). That change in frequency is currently scheduled to occur in Year 6 of the original sampling plan. This MNA program is supposed to demonstrate continued progress in the reduction of volatile organic compounds (VOCs) in Area D by natural attenuation mechanisms. The Year 3 sampling frequency for VOCs is currently semi-annual and it is to be reduced to annually in Year 6. But ARCADIS proposes to reduce the sampling frequency for VOCs to annually immediately andthat for geochemical parameters to once every five years.
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ARCADIS states that VOC concentrations are stable or decreasing “at nearly all MNA network locations” - except for a well downgradient of the PRB where vinyl chloride concentrations increased and at another monitoring location where VOC concentrations increased during the years between 2003 and 2005 only to remain stable since 2005. However, statistical analyses to support thecontention that concentrations are stable are absent from the proposal. |
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The NJDEP recently made changes to that method for analyzing Extractable Petroleum Hydrocarbons (EPH) which it deems to be acceptable. Mr. Joseph Marchesani, P.G. of the NJDEP informed Picatinny Arsenal team members about changes to the method for analysis of petroleum hydrocarbons in a November 19, 2009 e-mail. The Information on the new method can be found at :
http://www.state.nj.us/dep/srp/guidance/srra/eph_method_october
2009.pdf . Two other links provide the protocol and a calculator for determining the correct values.
http://www.state.nj.us/dep/srp/guidance/srra/eph_protocol.pdf
http://www.state.nj.us/dep/srp/guidance/srra/EPHCalculator_v1.0.xls In his e-mail Mr. Marchesani provided a helpful summary of the method’s changes and of its critical aspects. Some of the revised method’s main points (taken largely from Mr. Marchesani’s summary) are as follows: · This method was effective as of Nov. 10, 2009. The regulated community must be in compliance by May 10, 2010. · The EPH table contains two categories: Category 1 (No. 2 fuel oil and/or diesel fuel) and Category 2 (all other petroleum products). Each category is further subdivided into residential and non-residential exposure scenarios. |
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· There are five (5) sub-categories for each of Categories 1 and 2. They are as follows:
1. Health- based EPH value. 2. Contingency analyses - Table 2.1 in regulatory guidance [sample for 2-methylnaphthalene and naphthalene] 3. Product - [For example, at a result of 8,000 mg/kg for Category 1 the sample is considered to contain product] 4. Sheen Evaluation - in accordance with DEP “Sheen Remediation Policy Initiative” 5. Ecological screening criterion - The trigger value for baseline ecological evaluation (BEE). · There is a Soil Remediation Criterion Calculator that can be used to calculate the EPH SRC and compare it to the allowable EPH SRC to determine if results pass (i.e., do not require remediation) or fail (i.e., require remediation). · The calculator does apply where there is product or sheen present but not if there is only an ecological threat. · The ecological screening criterion is the trigger for a baseline ecological evaluation: BEE. This number is obtained from sampling at the RECEPTOR. Therefore there must be a path. · If there is no ecologicalreceptor, there is no requirement for a BEE. |
