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GeoInsighter Fall/Winter 2004 Newsletter

ENV-WM 1600 STANDARDS

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The New Hampshire Department of Environmental Services (NHDES) adopted Env-Wm 1600 Standards for Reporting and Remediation of Oil Discharges (Env-Wm 1600) on October 29, 2004, replacing Env-Ws 412. Env-Wm 1600 provides the framework for responsible parties (RPs) to respond to reporting and response actions related to a release of oil to the environment. RPs will continue to refer to Env Wm 1403 Groundwater Management and Release Detection Permits for Ambient Groundwater Quality Standards and Groundwater Management Permit related activities. The Risk Characterization and Management Policy (RCMP) will continue to provide guidance for preparation of Method 2 and Method 3 Risk Assessments. The following summarizes significant changes in Env-Wm 1600.

• Soil guidelines exist as standards in Env Wm 1600. An exceedence requires a 60-day notification to the NHDES by the RP or any person knowledgeable of the discharge.
• A written report must be submitted to the NHDES within 30 days of completing emergency response and initial response actions.
• The S-1 soil standard for methyl-tert-butyl ether was reduced, the total alkylbenzene guideline was replaced with individual standards, and polycyclic aromatic hydrocarbons (PAHs) generally remained the same or were increased over the guidelines found in the RCMP. However, three PAHs (benzo[b]fluoranthene, fluorene, and 2 methylnaphthalene) now have lower standards.
• An Activity and Use Restriction is an option in lieu of soil standards.
• The NHDES can now request an Initial Site Characterization or a Site Investigation (SI), resulting in greater flexibility.
• A Professional Engineer or Professional Geologist is required to oversee activities and stamp SI reports and Annual Summary Reports.
• The SI report must include ground water and soil constituent concentration maps depicting the lateral distribution of predominant ground water and soil constituents.
• A Remedial Action Plan will not be required if the preliminary screening of remedial options contains adequate detail to support the selection of the proposed alternative. Env Wm 1600 requires the evaluation of at least two remedial options, or combination of options, and does not require the evaluation of monitored natural attenuation.
• Non-hazardous oil contaminated soil (NOCS), previously referred to as virgin petroleum contaminated soil, shall either be reused on-site in accordance with a remedial plan approved by the NHDES or removed from the site to an authorized treatment or disposal facility. RPs do not have the option of transporting NOCS to another property owned by the RP for storage or disposal.

For additional information regarding Env-Wm 1600, please call the NHDES at 271-3644 or
GeoInsight, Inc.

Brian D. Kisiel, P.G.
bdkisiel@geoinc.com

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