If you attended one of our recent seminars (O.Reg. 511: Environmental Site Investigations & Strategic Decisions) regarding the impending changes to O.Reg. 153/04, you may recall that we suggested that it was only a matter of time until the Ontario Ministry of Environment (MOE) would fully implement the new field preservation techniques (USEPA Method 5035) for soil samples collected for Volatile Organic Compounds (VOCs).
Our prediction was fulfilled on February 25, 2011, when the MOE proposed changes to O.Reg. 153/04 in an amendment posted on the environmental registry (these proposed changes are open for comment until April 11, 2011). This new amendment removes one of the previously-approved methods for collection of soil samples for VOCs (using a glass jar with a Teflon®-lined lid with no headspace and no preservative).
Now if you are collecting soil samples for VOC analysis, only two options remain. One option is using a hermetic sampler (acceptable alternative to USEPA Method 5035). The other option is to field-preserve soil samples using methanol or aqueous sodium bisulphate (consistent with USEPA Method 5035).
As we have previously discussed in our seminars and blogs, when hermetic samplers (no preservative) are employed, the soil samples must be delivered to the laboratory within 48 hours. However, field preservation with sodium bisulphate or methanol does not have the same, short holding time limitations.
So it appears the question of which techniques you should use for collecting soil VOC samples has been answered; however, it does not appear that everyone is “current” on this issue. Accordingly, if your project involves collection of soil samples for VOCs, it might make sense to ask a few questions to make sure your samples are collected properly.
Here are a few other proposed changes to O.Reg. 511 to consider:
- The MOE incorporated higher values for petroleum hydrocarbons (PHC) F1, F3, and F4 in Tables 1, 8, and 9. These changes were a result of MOE’s study “Ontario Typical Range Soil Background Study Project Report” conducted in 2009.
- The definition of a “well” was altered to not include dewatering or remediation wells.
- The “Potentially Contaminating Activities” (PCA) list was reduced from 71 to 59 activities by combining similar activities or by removing activities from the list. Some of the removed activities would likely be captured under the activities that remain on the list. Of note is the removal of “Printing and Duplicating,” “Photographic Processing,” and “Laboratory and Chemical Analysis” activities. These activities do not seem to fit under any of the remaining PCAs. It’s safe to say that these types of activities can result in impacts. So, don’t count on prescriptive lists to define your risks.
- Some of the standards for sodium in groundwater in Tables 3, 5, 7, and 9 were increased. Additionally, some of the standards for mercury and several VOCs in soil were decreased in Tables 4 and 5.
These are just a few observations we have made after reviewing the MOE’s proposed changes. If you have specific technical questions, contact Clifford Lawton (firstname.lastname@example.org) or Christopher Paré (email@example.com) at 519-979-7300.
By the way, don’t forget to sign up for our April 14th seminar on Environmental Remediation in Burlington, Ontario.