Do New Vapor Rules in NJ Affect Your Project?

NJDEP LogoToday, January 17, 2013: NJDEP published major changes to guidance and standards pertaining to Vapor Intrusion. Vapor Intrusion is defined as the migration of volatile chemicals from the subsurface into overlying buildings through subsurface soils or preferential pathways (such as underground utilities). This pathway has been the driver for many off-site investigations, public notifications and costly indoor air testing since the NJDEP’s initial guidance came out in 2007.

Just released on the NJDEP’s Vapor Intrusion web page is the revised Vapor Intrusion Technical Guidance document and updates to the 2007 Vapor Intrusion Screening Levels (VISL). Finally, the web page also features Johnson & Ettinger (J&E) Model spreadsheets that were updated to reflect toxicity changes in the new VISL.

Here are just some of the changes:
Naphthalene and 2-methylnaphthalene have been added to the VISL tables. At this time, the laboratory capacity to analyze naphthalene and 2-methylnaphthalene using the preferred USEPA Method TO-17 is limited (only one certified laboratory). Therefore, the Department will not require the collection and analysis of naphthalene and 2-methylnaphthalene until July 16, 2013.

A factor of 10 has been incorporated into the calculation of the health-based ground water screening values for additional petroleum related contaminants (not reflected in the March 2007 tables) to account for degradation of the contaminants in the unsaturated zone. The additional petroleum related contaminants include: 1, 3-butadiene; cyclohexane; n-hexane; 2-methylnaphthalene; naphthalene; and styrene.

Five contaminants have been eliminated from the VISL tables due to the absence of inhalation toxicity information. These chemicals include: 1, 3-dichlorobenzene; 1, 2- dichloroethene (cis); 1, 2- dichloroethene (total); 2-chlorotoluene; and tertiary butyl alcohol (TBA).

Changes to many previously regulated compounds, including increases in groundwater screening levels for tetrachloroethylene (aka PCE) (up to 31 ug/l from a prior standard of 1 ug/l) and trichloroethylene (TCE) (up to 2 ug/l from a prior standard of 1 ug/l) for example, were also made.

Consult your LSRP regarding how these changes affect your project, or feel free to contact REPSG directly at info@repsg.com.

PCBs in Caulk

CaulkingIn 2012, several school renovation projects were hindered by caulk. The reason: PCBs.

In Connecticut, the towns of Southington and Fairfield discovered PCBs in the window caulking of their middle school and high school, respectively. In both cases, the discovery led to an unexpected increase in cost. The clean-up can also be confusing, since PCBs leach from caulk into surrounding porous building materials, including masonry, wood, and concrete. In October, the USEPA issued a reinterpretation of PCB Bulk Product Waste, specifically to address this issue.

PCBs, short for Polychlorinated Biphenyls, were commonly used in electrical equipment and building materials, until Congress banned manufacture of the toxic chemical in 1979. PCBs were used in caulk to impart flexibility, and can still be present in buildings constructed or renovated in the 1950s through the 1970s. The USEPA states that caulk containing PCBs at levels ≥ 50 parts per million (ppm) must be removed. When disposed, the caulk is to be managed as PCB Bulk Product Waste.

Now, here’s the tricky part. Because PCBs in caulk are known to contaminate adjacent building material, any surrounding building material that is coated by ≥ 50 ppm PCB-containing caulk is also considered PCB Bulk Product Waste if the caulk is still attached to the building material at the time of designation for disposal. To quote the EPA: “if your abatement plan states that you intend to dispose of the PCB caulk and any contaminated building materials together and the PCB caulk becomes separated from the adjacent contaminated building materials during remediation, you may still dispose of all the materials as a PCB Bulk Product Waste.” The plan is what’s important, not what happens between the building and the dumpster. If the caulk and building material are disposed of separately, then the building material is managed as a PCB Remediation Waste. The respective disposal options are outlined here.

With all the nitty gritty of disposal regs, it is easy to lose sight of the big picture: how to minimize exposure to PCBs, especially in schools. Air monitoring in affected schools can determine the inhalation exposure. Diligent housekeeping can minimize ingestion exposure. Encapsulation is effective at very low levels. Ultimately, all PCB-containing caulk should be removed.

Have you discovered PCBs in caulk during renovations, or gotten tangled up in disposal questions? Leave a comment below, or feel free to contact me at Sszymanski@repsg.com. Happy 2013!

Views from the Field: “Call Before You Dig”

811 - PA One Call LogoMachine Operator: Did I just hit that gas line?!

Laborer: We should have just called 8-1-1.

Mistakes happen, but because of Pennsylvania’s One Call System, accidents like this become very avoidable. With a simple five minute phone call, machine operators and ambitious home owners of Pennsylvania can break ground with confidence. REPSG knows from experience how important Pennsylvania’s one call system can be. For example, on one memorable occasion a property owner was shocked when One Call found a high pressure petroleum pipeline running through their backyard.

The service’s slogan, “Call before you dig,” completely sums up its purpose of being. Since its beginnings in 1972, this Pennsylvania Non-Profit has been promoting safety by helping to provide the exact locations of underground utility lines. In doing so, it has helped to minimize utility interruptions, reduce on-the-job injuries, and has encouraged a higher level of public safety. Just three years later, in April 1975, Act 287 went into effect requiring all excavators to call before digging.

While most states offer this great service, each state has its differences regarding the rules and regulations of digging. By calling 8-1-1 a few days before your scheduled excavation you will acquire the information you’ll need to dig safely, without the fear. By just telling the One Call operator where you will be digging and what type of work you are doing, utility companies that may be affected by your dig will be notified. In turn, they will dispatch a locator to mark the underground lines, pipes, and cables within your approximate dig area.

The mark outs that One Call use are even color-coded to indicate which type of utility you will encounter:

  • Red: electric power lines, cables, conduit, and lighting cables
  • Orange: telecommunication, alarm or signal lines, cables, or conduit
  • Yellow: natural gas, oil, steam, petroleum, other gaseous or flammable material
  • Green: sewers and drain lines
  • Blue: drinking water
  • Purple: reclaimed water, irrigation, slurry lines
  • Pink: temporary survey markings, unknown facilities
  • White: proposed excavation limits

To avoid not just injury but expense and embarrassment, call 8-1-1.

Don’t forget to gather all the necessary info such as addresses, nearest intersections, and extent of excavation prior to calling in order to avoid any unnecessary delays.