Replacement of TPH Method 418.1 for the Site Remediation Program
This document has been superseded by the most up-to-date version of the document "Phase-in for the implementation of the 'Protocol for Addressing Extractable Petroleum Hydrocarbons' and the associated analytical method 'Analysis of Extractable Petroleum Hydrocarbon Compounds (EPH) in Aqueous and Soil/Sediment/Sludge Matrices'."
EPH Protocol and EPH Method Phase-in document Version 3.0, 8/9/2010 [pdf 41 Kb] Posted 9 August 2010
In the December 31, 2005 Federal Register, the EPA Office of Water proposed to revise 40 CFR 136 and withdraw all analytical methods that use Freon 113 as a solvent. The methods affected are 413.1, 413.2 and 418.1. The final rule was published in the March 12, 2007 Federal Register and the freon-based methods were withdrawn.
Although the methods were withdrawn, a grace period was granted to laboratories by the NJDEP Office of Quality Assurance (OQA) whereby laboratories currently holding certifications for the freon-based methods would continue to maintain certification. Other states have determined they are not dropping freon-based methods and as such, consistency issues with the National Environmental Accreditation Program (NELAP) would arise should NJDEP drop them from the list of certified methods. Additionally, numerous NJDEP permits exist that specifically require freon-based methods to be used. Currently OQA is involved with the permitting groups in the DEP to determine the magnitude of the issue with respect to permits that contain freon method- specific citations and subsequently, determine an appropriate date to remove all freon-based methods from the certification process.
The Site Remediation Program (SRP) will continue to accept total petroleum hydrocarbon (TPH) analytical data generated from samples analyzed by Method 418.1. However, the grace period offered by NJDEP OQA will not be extended indefinitely. Additionally, the SRP is not affected by the permitting issues and wants to be proactive by promoting alternative methods. As a result, the SRP will not accept Method 418.1 data generated from the analysis of all matrices sampled after September 30, 2007 including those instances where Method 418.1 was cited in an approved sampling plan. For all samples taken after September 30, 2007 (for data submitted to the SRP) there are two methods for which certification exists that would be acceptable alternatives to Method 418.1 and are to be used for the analysis of samples for petroleum products: the Diesel Range Organics (DRO) option under USEPA SW-846 Method 8015B and the NJDEP Method OQA-QAM-025, Rev.7. The methods are used under the following circumstances. When petroleum product contamination at a site is known to be diesel fuel/home heating oil/#2 fuel oil, the DRO option under USEPA Method 8015B or OQA-QAM-025, Rev.7 is to be used. When the identity of the petroleum product contamination at a site is known but other than diesel fuel/home heating oil/#2 fuel oil (including but not limited to #4 fuel oil, #6 fuel oil, hydraulic oil, cutting oil, waste oil) or not known, OQA-QAM-025, Rev.6 must be used. For all analyses, data deliverables, at a minimum, are to be consistent with N.J.A.C. 7:26E, Appendix A, IV, Reduced Laboratory Data Deliverables-Non-USEPA/CLP Methods, Sections 1 and 6. When petroleum product contamination at a site is known to be gasoline, samples are to be analyzed pursuant to N.J.A.C.7:26E, Subchapter 2.
The SRP is developing a new method for the analysis of samples contaminated with non-gasoline petroleum products. The method resembles the Massachusetts Department of Environmental Protection’s Method for the Determination of Extractable Petroleum Hydrocarbons (EPH). The method represents a significant change in the manner in which samples would be analyzed and the subsequent petroleum product data reported. The method focuses on the non-volatile fuel products and therefore, the method will be referred to as an extractable petroleum hydrocarbon (EPH) method. Given the fact the NJDEP is proposing health based soil remediation standards, it was thought to be prudent to pursue a similar track for petroleum contamination. The eventual goal is to establish a soil remediation standard for petroleum contamination using EPH to measure the concentration present. Analytically, the method separates the extract into an aliphatic and aromatic fraction, both of which are analyzed separately. Each fraction is further separated chromatograpically into specific carbon ranges, each with an assigned toxicity factor that can be used separately or in summation. There is currently no expected implementation date for EPH method. Information will be shared on this website as it becomes available.