Petroleum Remediation Guidance Updates

This message contains three topics relating Petroleum Remediation policies and guidance documents:

1. Updates to specific guidance documents, posted at http://www.pca.state.mn.us/waste/cleanup-guidance.
2. Issues with implementation of 2017 guidance document updates.
3. Additional observations when implementing guidance documents.

The updates and changes list below should be implemented immediately if possible. Final date for implementation is January 1^st, 2019.

1. - Summary of Guidance Document Changes

Release information worksheet (Guidance Document 2-05)

The release information worksheet has been updated to the MPCA’s newest format. Please use the new form with submittals of Guidance Document 4-06 Investigation Report, and when applicable, with 3-02 General Excavation Report Worksheet and 4-08 Monitoring Report.

Petroleum tank release follow-up notification (Guidance Document 2-08)

The release follow-up notification instructions (Guidance Document 2-07) and the notification template (Guidance Document 2-08) have been combined into a single guidance document. The new template language has been simplified. Please discontinue using the previous version, as it contains outdated web links that no longer work.

Soil and groundwater assessments performed during site investigations (Guidance Document 4-01)

Bad hyperlinks were updated throughout the document. 

On page 5, Section II.C.5 – Laboratory analysis

Clarification has been provided on soil analytical sampling depth in a boring when both groundwater and contamination are encountered.

Soil sample collection and analysis procedures (Guidance Document 4-04)

On page 4, Table B

Mineral spirits, mineral oil, crude oil, and Stoddard solvents were removed from the list of petroleum products.

Groundwater sample collection and analysis procedures (Guidance Document 4-05)

On page 7, Section 6.4.B. – Trip blank samples

GRO analysis was added. Trip blanks must be analyzed for all VOC analyses (e.g., GRO, VOCs, PVOCs, and/or low-level EDB) being completed on samples within a common cooler. For example, if samples within a single cooler are being analyzed for VOCs and GRO, the trip blanks within that cooler must also be analyzed for VOCs and GRO.

On page 11, Analytical parameters and laboratory methods

Mineral spirits, mineral oil, crude oil, and Stoddard solvents were removed from the list of petroleum products in the table.

2. - 2017 Guidance Document Updates

The MPCA has noticed the following issues with implementation of 2017 guidance document updates.

• Some labs are not including naphthalene with PVOC analysis. Make sure your chosen lab understands Minnesota’s requirements. The WI GRO method specifies quantification of PVOCs, but it does not include naphthalene. Labs have to modify their procedures in order to quantify naphthalene using the WI method or complete the analysis using EPA Methods 8021 or 8260. See Guidance Documents 4-04 and 4-05 for specific details.
• Collection of field parameters while sampling from temporary wells is required. A temporary well, as defined for this requirement, is a well that is typically constructed with a PVC casing and screen place in a drilled, cored, driven, or jetted borehole that is sealed with 72 hours of initiating well construction. Temporary wells often do not have an annular space seal and may or may not have a gravel pack placed around the screen. A temporary well does not include sampling through direct-push probe rods. See Guidance Document 4-01.
• When initially defining the extent of soil contamination during a site investigation, soil borings should generally not be drilled more than 50 feet from source-area soil borings. Exceptions include the presence of obstructions such as buildings, utility lines, and possibly roads where drilling is inaccessible. In the absence of obstructions, grossly exceeding this distance may result in the data from such borings being rejected, which could result in Petrofund reimbursement issues for the cost of rejected work. See Guidance Document 4-01.
• The petroleum sheen test is a required field screening procedure for soil sampling during excavation and soil boring completion. Please see Guidance Documents 3-01 and 4-01 for specific application of the requirements.
• New general excavation requirements allow removal of up to 200 cubic yards of petroleum-saturated and grossly contaminated soil during tank removal or installation without MPCA approval. This is a requirement, not an optional course of action. The MPCA expects contaminated soil meeting the criteria to be removed. See Guidance 3-01.

 3. - Additional Observations

• When completing the receptor survey during a site investigation, the first attempt at personal contact with all property owners/occupants within 500 feet must be in person. Mailing a letter or card is not an acceptable first attempt, nor is not attempting any contact. See Guidance Document 4-02.
• During regulated tank system removals when a release has occurred, keep in mind that excavation sidewall and bottom soil samples are required, in addition to samples directly beneath removed tanks, dispensers, and piping. Often sidewall and bottom samples are not being collected for field screening or soil analysis, which could lead to additional work (e.g., soil borings) in order to justify site closure. See Guidance Document 3-01.
• During unregulated tank system removals when a release has occurred, the MPCA strongly encourages tank owners, excavators, and consultants to follow the sampling requirements for regulated tanks. By not doing so, often the MPCA has to require additional work (e.g., soil borings)that may not otherwise have been necessary, in order to justify site closure. See Guidance Document 3-01.

For questions contact Adam Sekely, adam.sekely@state.mn.us  (218-316-3880) or Chris McLain, chris.mclain@state.mn.us  (612-757-2562).