At JMS we are proud to participate in stakeholder groups such as the Site Remediation Advisory Group (SRAG), Cooperative Venture Project (CVP), and the Licensed Site Remediation Professionals Association (LSRPA). Our involvement allows us to stay on top of NJDEP guidance and regulations before they actually go into effect. In December of last year, NJDEP issued draft guidance regarding the evaluation of Extractable Petroleum Hydrocarbons (EPH). This guidance provides environmental professionals with updated procedures and compliance options for petroleum-impacted sites. The new EPH guidance will replace the previous EPH guidance dated August 2010.
EPH can include mixtures of #2 heating/fuel oil, diesel, #4/#6 fuel oil, hydraulic oils, cutting oils, crude oil, lubricating oil, waste oil, waste vehicular crankcase oil or waste mineral oil. These petroleum products are divided into two categories, Category 1 and Category 2, and separate EPH product limits have been established for each. In order to apply guidance, EPH categories should be determined based on the current and historical products stored/used at each area of concern being investigated. The guidance does not apply to discharges from more volatile petroleum products (gasoline, kerosene, jet fuels or light petroleum distillates).
The document provides guidance for evaluating the EPH soil data from petroleum storage and discharge areas; applying the EPH soil remediation criteria; evaluating data for additional analysis; evaluating potential ecological concerns; and applying the default EPH product limits or a calculated alternative EPH product limit using an excel worksheet.
With the ability to use the new EPH calculator, the area of concern-specific EPH product limit can be increased based upon the product immobility up to a ceiling limit, which has been established in the new guidance document. If more than one petroleum product is investigated/discharged, an alternative EPH product limit is calculated for each petroleum product. The calculated value is based upon the relationships between soil texture, petroleum viscosity, and density.
To develop an alternative EPH product limit, soil samples will be required for grain size distribution analysis. Samples should be collected as close to source(s) as possible, but not contain petroleum products that could adversely impact laboratory testing equipment. Calculating an alternative EPH product limit should be considered when the soil texture is finer than medium sand, which was the soil type used to establish the default EPH product limits for Category 1 and Category 2 petroleum products. Keep in mind, if the calculated value is more stringent than the default value, the new value becomes the EPH product limit for the site.
The new guidance includes the use of compliance averaging pursuant to the Attainment/Compliance technical guidance document of EPH Category 1 (heating oil and diesel fuel); however, if the EPH exceeds the default/alternative product and ceiling limits, compliance averaging is not an acceptable alternative for remediation. Exceedance of the EPH product limits, default or an alternative value, requires treatment/removal or use of institutional controls (deed notice) and/or containment/cap (engineering control) if treatment/removal is not practicable under a Remedial Action Permit.
Other changes in the guidance document include the use of lower default EPH product limits that were typically associated with Category 1 petroleum discharges, which now apply to some of the Category 2 petroleum products (MGP crude oil, cutting oils, and unknown petroleum products).
When the new guidance goes into effect, JMS will be ready to apply it to sites with petroleum impacts.
Andrew Thomas, LSRP