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Env-Or 600 Contaminated Site Management Rule Update

Env-Or 600 Contaminated Site Management Rule Update

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Env-Or 600 Contaminated Site Management Rule Update

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  1. Env-Or 600 Contaminated Site Management Rule Update Waste Management Division Updates September 12, 2008

  2. Env-Or 600 Update • Effective July 23, 2008 • Ambient Ground Water Quality Standards • Soil Remediation Standards • Groundwater Management Permit Procedures • Expedited Review Fees

  3. Env-Or 600 Update

  4. Env-Or 600 Update

  5. Env-Or 600 Update

  6. Env-Or 600 Update • Env-Or 607.02 Groundwater Management Permit Procedures. (2) Provide notification on a form provided by the department by certified mail, return receipt requested, to all owners of properties specified in Env-Or 607.03(a)(20) that their property is proposed for inclusion within the GMZ; http://www.des.nh.gov/orcb/doclist/prop_gd_ma_permit.doc

  7. Env-Or 600 Update • Env-Or 607.03 Groundwater Management Permit Application. (16) Certification that notification has been provided to all owners of lots proposed for inclusion in the GMZ as required by Env-Or 607.02(b)(2);

  8. Env-Or 600 Update • Env-Or 607.08 Permit Notification. (a) Within 3015 days after the department issues the groundwater management permit, the permittee shall provide notice of the permit by certified mail, return receipt requested, to all owners of lots of record within the GMZ. (b) Within 6045 days after the department issues the groundwater management permit, the permittee shall submit documentation of the notification required by (a), above, to the department.

  9. Env-Or 600 Update Fees for Expedited Reviews as specified in RSA 485:3-b, I

  10. Env-Or 600 Update Summary • Effective July 23, 2008 • Ambient Ground Water Quality Standards • Soil Remediation Standards • Groundwater Management Permit Procedures • Expedited Review Fees

  11. Env-Or 600 NHDES Contact Robin Mongeon, P.E. Waste Management Division 29 Hazen Drive Concord, NH 03301 Tel: (603) 271-7378 Fax: (603) 271-2181 E-mail: Robin.Mongeon@des.nh.gov

  12. Env-Or 607.09, Recordation Groundwater Management Recordation Procedures

  13. Env-Or 607.09, Recordation • Updates - Private Sector Feedback • Registry Index - Grantor/Grantee • New Notice & Release of Notice Forms • Links • Contact Info

  14. Grantor/Grantee Index

  15. Grantor/Grantee Search

  16. Form NOTICE OF GROUNDWATER MANAGEMENT PERMIT GWP-_________-A-001 TO BE RECORDED AGAINST: [IDENTIFY OWNER OF PARCEL AND BOOK AND PAGE OF DEED IN TO THAT PARTY] NOTICE IS HEREBY GIVEN THAT: The New Hampshire Department of Environmental Services (Department) has issued Groundwater Management Permit #GWP-_________-A-001 (“Permit”) to [Permittee]. Pursuant to Env-Or 607.09(a) this notice is recorded for each property located within the groundwater management zone identified in the Permit at the Registry of Deeds for the county in which the property is located. The Permit establishes a Groundwater Management Zone (“GMZ”), an area within which groundwater use must be controlled and monitored due to the presence of groundwater contaminants that exceed the State’s Ambient Groundwater Quality Standards (“AGQS”). The Permit may include conditions to and restrictions upon the use of the properties within the GMZ, including restrictions on the use of groundwater. The Permit was issued on [Date] and expires on [Date], unless renewed for subsequent five-year period(s). This Notice will remain in effect until such time as the AGQS are restored within the GMZ and the Department issues a Release of Recordation to the Permittee. The Permit is available for review at the New Hampshire Department of Environmental Services, 29 Hazen Drive, Concord, NH 03301 or can be viewed by searching under our OneStop Data Retrieval Site at http://www2.des.nh.gov/OneStop/ORCB_Query.aspx?Project+CCST . The following properties are located within the GMZ: Property Owner/Property AddressTax Map/LotDeed Reference Book/Page /s/ [Permittee Name], Permittee ______________ [Company Name] Date

  17. Form DISCHARGE AND RELEASE OF NOTICE OF GROUNDWATER MANAGEMENT PERMIT TO BE RECORDED IN FAVOR OF [CURRENT OWNER OF PARCEL IDENTIFIED IN ORIGINAL OR AMENDED NOTICE] at [BOOK /PAGE OF DEED IN TO THAT PARTY] For value received, the State of New Hampshire Department of Environmental Services, issuer of a groundwater management permit GWP-_________-A-_ to [name of Permittee] and recorded by Notice of Groundwater Management Permit, dated ____, against the real property of [name of property owner], in __________ County Registry of Deeds at Book __________, Page __________, hereby discharges and releases the said Notice of Groundwater Management Permit. Subscribed, sworn to and acknowledged before me by ______________, the issuer, this __________ day of __________, 20__________. ____________________________ Carl W. Baxter, P.E., Administrator Hazardous Waste Remediation Bureau Waste Management Division _________________________ Printed Name_______________ Notary Public/Justice of the Peace My commission expires_________

  18. Env-OR 607.09 Recordation Link to Notice Forms: http://www.des.state.nh.us/ORCB/DOCLIST/notice_of_gmp.doc http://www.des.state.nh.us/ORCB/DOCLIST/landfill_notice_of_gmp.doc

  19. Env-Or 607.09 Recordation NHDES Contact Karlee Kenison, P.G. Waste Management Division 29 Hazen Drive Concord, NH 03301-0095 Tel: (603) 271-6542 Fax: (603) 271-2181 Email: karlee.kenison@des.nh.gov

  20. Low-Level Ethylene Dibromide (EDB) Screening Program Update Kenneth Richards, P.G. NH Department of Environmental Services

  21. Low-Level Ethylene Dibromide (EDB) Screening Program Update Kenneth Richards, P.G. NH Department of Environmental Services

  22. Ethylene Dibromide (EDB) • Also known as 1,2-dibromomethane and numerous trade names and acronyms • Used in the past as a leaded gas additive (phased out in 1985) and soil fumigant (banned in 1984) for crops and turf (golf courses). Also as a solvent, waterproofing agent, in dyes & pharmaceuticals • Still used in aviation and racing fuels and chemical formulations • Released to the environment by leaded gasoline spills and land applications as a pesticide

  23. Ethylene Dibromide (EDB) (cont.) • EDB is a volatile organic compound (VOC) and is included on the U.S. EPA SW-846 Method 8260 list of analytes • The Method 8260 detection limit for EDB in relatively clean samples is generally 0.5 – 1.0 ug/l • The Federal Maximum Contaminant Level (MCL) and New Hampshire AGQS for EDB is 0.05 ug/l

  24. Program Goals • Identify EDB presence/absence at NH Sites • Identify potential EDB impacts to drinking water wells • Provide basis to formulate modified monitoring programs at identified EDB sites to include low-level EDB analysis

  25. Site & Sampling Point Selection • Release sites with known gasoline storage in 1985 or earlier • Sampling points selected along transect of contaminant plume • In general, samples collected from one source area well, one mid-plume well & one distal well

  26. Analytical Methods For Low-Level EDB Detection • US EPA SW-846 Method 8011 • US EPA SW-846 Method 504.1 • US EPA SW-846 Method 8260 SIM (Selective Ion Method)

  27. Preliminary Results • 200 sites during Spring, 2008 groundwater sampling rounds; 700 groundwater samples analyzed • EDB positively detected at 15% of sites sampled • Detections ranged up to 650 ug/l • 45% of the EDB detections were <1.0 ug/l

  28. Preliminary Results (cont.) • EDB detections primarily found at sampling points within or immediately downgradient of source areas • EDB not identified in water supply wells included in program

  29. U.S. EPA LNAPL Screening Study • EPA analyzed LNAPL collected from 28 older release sites in 8 states • DES coordinated the submittal of 23 LNAPL samples from 8 NH sites • EDB identified in LNAPL samples from 4 of the 8 NH sites • EDB detected at levels ranging from 0.15mg/l to 255.28 mg/l

  30. Path Forward • Second round of low-level EDB screening to be conducted during the Fall 2008 groundwater sampling rounds • DES has been requesting field pH measurements on wells included in Fall screening round • Individual EDB site strategy should be developed in consultation with DES project managers

  31. 1,4-Dioxane and 1,2-Dibromoethane (EDB) Analytical Methods Review Lou Barinelli, Assistant Director, NHDES Laboratory

  32. 1,4-Dioxane • MW=88.11 • Density=1.03 • BP=101.1 • Soluble in water

  33. Available Methods • EPA Method 8260B (C) • Purge and Trap-GC/MS • EPA Method 8270C (D) • Liquid/Liquid Extraction-GC/MS • EPA Method 8261A • Vacuum Distillation-GC/MS

  34. EPA Method 8260 • In order to meet low level reporting limits on the order of 3 ppb, must make modifications • Heat sample during purge cycle (80-90 oC) • Acquire data in SIM Acquisition Mode • Use 1,4-dioxane-d8 as an internal or surrogate standard

  35. EPA Method 8270C • Extract 1L of water • Concentrate Extract • Use Isotope Dilution (1,4-dioxane-d8) • Acquire data in SIM Acquisition Mode

  36. EPA Method 8261A • Sample is placed in a distillation chamber • The chamber is placed under vacuum • The vapor is passed through a chilled coil at 5 oC to condense the water • The uncondensed distillate is cryogenically trapped at -196 oC (liquid nitrogen temp) • Analytes transferred to GC/MS

  37. EPA Method 8260B Advantages • Most labs familiar with P&T technique • Minimal sample prep • Automation possible • Can achieve reporting limits 2-5 ppb

  38. EPA Method 8260B Disadvantages • 1,4-Dioxane has poor purging efficiency, can be compensated for by heated purge and isotope dilution • If Method not managed correctly can encounter problems with carry over or poor reproducibility

  39. Method 8270C Advantages • Most labs familiar with technique • Can achieve reporting limits 1-3 ppb • Modified to use isotope dilution

  40. Method 8270C Disadvantages • Possible losses during extraction procedure • Possible losses during collection and transport (samples collected with headspace) • Labor intensive for some labs

  41. EPA Method 8261 Advantages • Easily achieve 1-2 ppb reporting limit • Potential for sub-ppb reporting limits with SIM • Minimal sample prep • Isotope dilution is standard procedure

  42. Method 8261A Disadvantages • New Technique • Not common for most labs • Only 1 Instrument Manufacturer • Requires liquid nitrogen • Cost of equipment and operation

  43. Misc. Info • Ref: "1,4-Dioxane - Environmental and Measurement issues" - Timothy W. Fitzpatrick & Kerry Tate, State of Florida Department of Environmental Protection“

  44. 1,2-Dibromoethane • Available Methods • Purge & Trap GC/MS (SIM Acquisition) • Micro-Extraction GC/ECD

  45. Purge & Trap GC/MS • Method 8260 • 5 or 25 mL purge volume • SIM acquisition allows for lower reporting limit

  46. GC/ECD • Methods 8011 or 504 • Micro extraction with hexane • Direct injection on GC/ECD • Dual column confirmation • ECD selective for halogenated compounds

  47. 1,4 Dioxane – Background Sampling Requirements, Treatment Technologies and Initial ResultsFrederick J. McGarry, P.E., DEE, Assistant Director, WMD

  48. 1,4 Dioxane O H2C CH2 Background, Sampling Requirements, Treatment and Initial Results Sept. 12, 2008 H2C CH2 O

  49. 1,4 Dioxane • What is it? • Why are we concerned about it? • What are the sampling requirements? • How can it be treated?

  50. Characteristics of 1,4-Dioxane • Solubility – Infinite solubility in water • Low Koc therefore low affinity for activated carbon • Low vapor pressure • Most mobile contaminant @ solvent release sites • Footprint may be many times greater than TCA plume (up to 6X greater)