Repurposing brownfield sites via remediation inevitably involves some degree of aerosols and particulate matter being released into the air. While monitoring dust levels and safeguarding public health is an essential part of responsible remediation, dust is not the only airborne hazard environmental consultants and site remediators need to be closely tracking. In addition to particulates, earth-moving projects have the potential to cause volatile organic compounds (VOCs) trapped in soil and groundwater to be released into our breathable airspace. Overexposure to VOCs can cause, among other maladies, headaches, lung irritation, or even permanently damage internal organs. Certain VOCs are known air toxics and are carcinogenic.

To reduce these risks, strict environmental monitoring regulations have been established, setting clear guidelines around VOC emissions monitoring. Failure to abide by these rules could result in fines, temporary shutdown, or even project closure. Here, we examine key aspects of these regulations, the role of VOCs, and steps you can take to maintain compliance, protect the health of the community and off-site workers, and ensure project completion.

While each region may have its own geographically specific regulations, there are a couple of foundational texts worthy of special consideration here. The first is DER-10, enacted by the New York State Department of Environmental Conservation (NYSDEC) and administered by the Division of Environmental Remediation (DER). Covering monitoring requirements from site selection through to post-cleanup work, DER-10 sets out strict rules for protecting sensitive receptors from poor-quality air. Project managers or consultants are obligated to file a Community Air Monitoring Plan (CAMP), requiring “real-time monitoring for volatile organic compounds (VOCs) and particulates at the downwind perimeter of each designated work area when certain activities are in progress at contaminated sites.”

Out on the West Coast, California’s South Coast Air Quality Management District (SCAQMD) has established Rule 1166 – Volatile Organic Compound Emissions from Decontamination of Soil. Rule 1166 sets requirements to “control the emission of Volatile Organic Compounds (VOCs) from excavating, grading, handling and treating VOC-contaminated soil.” This regulation sits alongside Rule 1466, working to minimize off-site fugitive dust emissions from earth-moving activities.

Both DER-10 and Rules 1166 & 1466 have been referred to and recognized throughout several states and territories, making them essential reading for consultants, remediators, and anyone involved in earth-moving activities where VOCs are likely to be present.

An example of a VOC-focused remediation monitoring framework is set out in Appendix 1A of DER-10, covering the creation of a generic CAMP. While some sites “known to be contaminated with heavy metals alone may only require particulate monitoring,” simultaneous monitoring of both VOCs and particulate will be required in most cases. Appendix 1A includes details on monitoring equipment and calibration requirements, while also setting out guidelines for safe limits of VOCs in air. For example, if VOC levels at the downwind perimeter of the site persist:

However, if VOC levels were to rise above 25 ppm, “activities must be shut down.” Additionally, all recordings must be made “available for State (DEC and NYSDOH) personnel to review.” Failure to manage emissions, execute correct monitoring procedures, or carry out reporting requirements could put the surrounding community at risk, jeopardize the future of the project, and cause irreparable reputational damage. Or to put it another way – maintaining compliance helps protect public health and ensures worker safety, paving the way for project success and reduced risk to stakeholders.

Both Rule 1166 and DER-10 set out a series of effective mitigation strategies for maintaining VOC levels within regulatory limits. Incorporating these actions into your daily practice will go a long way toward creating a safe, compliant work site. For example, under the “Requirements” section of Rule 1166, the rule states that:

(2) A person handling VOC-contaminated soil at or from an excavation or grading site shall:

A. Segregate VOC-contaminated stockpiles from non-VOC-contaminated stockpiles such that mixing of the stockpiles does not take place.

B. Spray VOC-contaminated soil stockpiles with water and/or approved vapor suppressant and cover them with plastic sheeting for all periods of inactivity lasting more than one hour.

C. Conduct a daily visual inspection of all covered VOC-contaminated soil stockpiles to ensure the integrity of the plastic-covered surfaces. A daily inspection record must be maintained on-site.

Appendix 1B of DER-10 outlines a proposed methodology for limiting the spread of airborne dust particles. These strategies can also be applied to VOCs and other pollutants contained in soil. The regulation states:

7. The following techniques have been shown to be effective for the controlling of the generation and migration of dust during construction activities:

a. Applying water on haul roads;
b. Wetting equipment and excavation faces;
c. Spraying water on buckets during excavation and dumping;
d. Hauling materials in properly tarped or watertight containers;
e. Restricting vehicle speeds to 10 mph;
f. Covering excavated areas and material after excavation activity ceases; and
g. Reducing the excavation size and/or number of excavations.

It’s important to note that while defensible and actionable air quality data serves an important role in maintaining compliance and initiating a swift response when mitigation or corrective action is needed, the benefits don’t stop there. Accurate real-time data can also be used to help locate the source of emissions, calculate site contributions, track the effectiveness of mitigation strategies, and save significant time across the life cycle of a remediation project. To get the most out of your air monitoring system, you’ll want to tailor the technology to the specific needs of your project.

You’ve done your due diligence, you’re across all the relevant legislation and you’re ready to break ground – so, what happens next? For measuring VOCs alongside particulate matter, you’ll need an integrated monitoring solution designed to comply with any remediation air monitoring regulation. The Aeroqual AQS 1 Remediation Air Quality Monitor is fit for purpose and used by environmental consultants in every corner of the globe, producing accurate, defensible real-time data with excellent correlation to US EPA reference analyzers.

Looking to optimize your site remediation air monitoring reporting in line with industry best practices? Check out Aeroqual Site Contribution – our automated remediation monitoring software. Featuring selectable air quality regulations (including simplified NY DER-10 and SC AQMD Rule 1466, with more to follow), customizable averaging periods and exceedance levels, and automatic calculations, Aeroqual Site Contribution helps reduce on-site visits, maintain compliance, and save you both time and money.

Searching for a solution that enables you to effortlessly maintain accurate record-keeping? Satisfy regulators and create a bird’s-eye view of monitoring data with Aeroqual Cloud. Record daily observations and mitigation actions in Aeroqual Cloud’s online journal, compatible with thousands of monitor configurations. Connect your Aeroqual monitoring system in minutes, plug in your third-party device, or integrate your existing software with Aeroqual Cloud via API and centralize your monitoring data in one convenient location – accessible anywhere. Grant customized viewing rights to share data with key stakeholders, record data on the go with the Cloud mobile app and streamline your reporting in line with all regulatory requirements.

Our expert team is adept at designing the perfect air monitoring solution to suit any site assessment and remediation – get in touch to learn more.