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GeoInsighter Spring
2000 Newsletter
Volume 5 Number 1
New Hampshire Implements VOCs in Soils Preservation Policy
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New Hampshire's finalized policy for the Preservation of Volatile Organic Compounds (VOCs) in Soil Samples (VOCs in Soil Policy) became effective on March 30, 2000, making New Hampshire one of a handful of states, including Massachusetts, to adopt sampling protocol specifically aimed at minimizing the loss of VOCs prior to soil sample analysis. Issues relating to VOC loss in soil were summarized in the Winter 1999 issue of the GeoInsighter. New Hampshire's VOCs in Soil Policy will be applicable to all volatile soil analyses, including United States Environmental Protection Agency (USEPA) Methods 8015A, 8021B, 8260B, or equivalent USEPA Standard Methods. The VOCs in Soil Policy is not applicable to same-day on-site mobile laboratory analyses or to field screening methodologies using a PID/FID or other direct field measurement techniques.
Since Massachusetts instituted its Implementation of MADEP VPH/EPH Approach policy in 1997 and Preservation Techniques for VOC Soil Sample Analyses (WSC #99-415) policy in 1999, consultants and laboratories in the area are accustomed to the required field practices and analytical methodologies.
The policy will not be phased in. Data obtained from improperly preserved soil samples after March 30, 2000 will be considered by the NHDES to be invalid and may be rejected. The NHDES will only reopen sites that were closed based upon data collected using previous sampling practices under certain circumstances: 1) new data becomes available, 2) VOC headspace or other screening data indicate significant VOC levels, 3) persistent dissolved VOC levels that suggest the existence of a VOC source, and/or 4) the existence of a sensitive receptor or exposure pathway.
Possibly the greatest impacts of the policy will be noticed in gasoline-range total petroleum hydrocarbons (TPH) soil results. Our experience has been that the current New Hampshire Risk Management Policy TPH soil standard of 10,000 milligrams per kilogram (mg/kg) was infrequently exceeded in soil samples collected using the previous sampling practices, particularly for sandy soils. Soil samples collected using field preservation techniques at gasoline-impacted sites will be more likely to exceed the TPH standard. Based upon the noted effects from implementing VOC preservation policies in Massachusetts, New Hampshire businesses and industries can anticipate conducting additional remedial actions to reduce compound specific and TPH VOC levels in soil. More reliance on Method 2 and 3 risk assessments to demonstrate no significant risk from residual VOC concentrations is also anticipated.
Michael F. Dacey
mfdacey@geoinc.com
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