Telemetry & the MCP

Remote Monitoring of Active Exposure Pathway Mitigation Measures

Isaac Anderson Project Manager

Cooperstown Environmental978-470-4755

Presentation Overview

• Regulation and Guidance Takeaways

• Achievement of AEPMM and Telemetry Standards

• Case Study• Telemetry Setup and Implementation at Temporary Solution

Site

40.1025:   Requirements for Active Exposure Pathway Mitigation Measures Implemented as a Permanent Solution with Conditions

(1)   Purpose and Scope.  310 CMR 40.1025 specifies requirements for an Active Exposure Pathway Mitigation Measure Implemented as part of a Permanent Solution with Conditions. (2)   Demonstration of Effectiveness.  An Active Exposure Pathway Mitigation Measure implemented as part of a Permanent Solution with Conditions shall be designed and demonstrated to eliminate exposure to OHM to the extent feasible and ensure, at a minimum, that a condition of No Significant Risk is achieved and maintained for the Receptor(s) of concern.  Demonstration of the effectiveness of Active Exposure Pathway Mitigation Measure shall be made prior to the achievement of a Permanent Solution with Conditions and shall be based on the measurement of Exposure Point Concentrations representative of exposures for the Receptor(s) of concern during operation of the Active Exposure Pathway Mitigation Measure under normal operating conditions and over a period of time sufficient to account for temporal variability. (3)   Operation of an Active Exposure Pathway Mitigation Measure Implemented as part of a Permanent Solution with Conditions. • (a)   The necessity of operating and maintaining the Active Exposure Pathway Mitigation Measure according to the operating regimen documented in the Permanent Solution Statement shall be specified in an Activity and Use Limitation that is

recorded on the deed of the property where the Active Exposure Pathway Mitigation Measure is located that includes the requirements of 310 CMR 40.1025 as terms and conditions for maintaining a Permanent Solution;• (b)   The operating regimen for the Active Exposure Pathway Mitigation Measure documented in the Permanent Solution Statement shall be designed to ensure a level of No Significant Risk is maintained for the Receptor(s) of concern under normal

operating conditions;• (c)   The operating regimen shall document the parameters for operating the Active Exposure Pathway Mitigation Measure and the methods and frequency for monitoring such Measure to ensure that it is operating consistently within such

parameters;• (d)   An Active Exposure Pathway Mitigation Measure implemented as part of a Permanent Solution with Conditions shall employ remote monitoring technology that will alert the owner and operator of the building protected by the Active Exposure

Pathway Mitigation Measure and the Department immediately upon failure of the system, such as loss of power, mechanical failure or other significant disruption of the effectiveness of the system;• (e)   The operating regimen shall document the longest duration of a shutdown that would be consistent with:• 1.   a level of exposure that does not pose an Imminent Hazard; and• 2.   a level of exposure that poses No Significant Risk; and• (f)   Following submittal of a Permanent Solution Statement, the Active Exposure Pathway Mitigation Measure shall be consistently operated and maintained at a level of effectiveness that ensures a level of No Significant Risk is maintained for the

Receptor(s) of concern and in accordance with the provisions of 310 CMR 40.1025.(4)   An Active Exposure Pathway Mitigation Measure shall not be used to support a Permanent Solution with Conditions if suspension or failure of such measure lasting 60 consecutive days would result in a Receptor exposure to OHM that would pose an Imminent Hazard. (5)   An Active Exposure Pathway Mitigation Measure shall not be used to support a Permanent Solution with Conditions unless the owner of the property where the Active Exposure Pathway Mitigation Measure is located certifies at the time that the Permanent Solution with Conditions is implemented that financial resources have been made available for the immediate repair and/or replacement of components of the Active Exposure Pathway Mitigation Measure in the event that the Measure experiences failure.  (6)   In the event of any suspension or failure of an Active Exposure Pathway Mitigation Measure implemented as part of a Permanent Solution with Conditions, the owner of the property where the Active Exposure Pathway Mitigation Measure is located shall undertake immediate steps to return the Active Exposure Pathway Mitigation Measure to full operating condition.  If such suspension or failure of the system lasts 30 consecutive days, the owner of the property where such Measure is located shall notify both the Department and any non-transient occupants of the building protected by such Measure who may have experienced exposure to oil and/or hazardous material as the result of the system suspension or failure on the 30 th day from the start of the suspension or failure period.  This notice shall document the reason for the suspension or failure of the Active Exposure Pathway Mitigation Measure, any efforts made or steps to be taken to resume operation of such Measure, and the expected timeframe for resuming operation of such Measure.(7)   The owner of the property where an Active Exposure Pathway Mitigation Measure is implemented as part of a Permanent Solution with Conditions shall annually certify in response to receipt of a form provided by the Department that:• (a)   the property owner is aware of his or her obligation to operate and maintain the Active Exposure Pathway Mitigation Measure, including repairing or replacing components of the Measure to resume operation in the event the Measure

experiences suspension or failure;• (b)   the property owner is aware that the Department may upon reasonable notice inspect the Active Exposure Pathway Mitigation Measure to ensure that it is operating pursuant to the regimen established at 310 CMR 40.1025;• (c)   financial resources are available to the property owner for the immediate repair and/or replacement of components of the Active Exposure Pathway Mitigation Measure in the event that the Measure experiences failure; and• (d)   the Active Exposure Pathway Mitigation Measure is operating pursuant to the regimen established at 310 CMR 40.1025.  (8)   Where a Permanent Solution with Conditions is based upon the operation of an Active Exposure Pathway Mitigation Measure, the operation of such a measure may be terminated following documentation provided in a revised Permanent Solution Statement pursuant to 310 CMR 40.1000 that the measure is no longer necessary to maintain a Permanent Solution. Such documentation shall include a Risk Characterization conducted pursuant to 310 CMR 40.0900 that evaluates and documents exposure to OHM for Receptor(s) of concern in the absence of the Active Exposure Pathway Mitigation Measure over a period of time sufficient to account for temporal variability and supports a conclusion that a condition of No Significant Risk exists in the absence of such Measure.

40.1026:   Requirements for Active Exposure Pathway Mitigation Measures Implemented as Part of a Temporary Solution or Remedy Operation Status

•  (1)   Purpose and Scope.  310 CMR 40.1026 specifies requirements for an Active Exposure Pathway Mitigation Measure implemented as part of a Temporary Solution or Remedy Operation Status.

•  (2)   Demonstration of Effectiveness.  An Active Exposure Pathway Mitigation Measure implemented as part of a Temporary Solution or Remedy Operation Status shall be designed and demonstrated to eliminate exposure to OHM to the extent feasible and ensure, at a minimum, that a condition of No Significant Risk is achieved and maintained for the Receptor(s) of concern.  Demonstration of the effectiveness of Active Exposure Pathway Mitigation Measure shall be based on the measurement of Exposure Point Concentrations representative of exposures for the Receptor(s) of concern during operation of the Active Exposure Pathway Mitigation Measure under normal operating conditions and over a period of time sufficient to account for temporal variability. 

•  (3)   Operation of an Active Exposure Pathway Mitigation Measure implemented as part of a Temporary Solution or Remedy Operation Status. • (a)   The operating regimen for the Active Exposure Pathway Mitigation Measure implemented as part of a Temporary Solution or Remedy Operation Status shall be specified in

Temporary Solution Statement or Phase IV Operation, Maintenance and Monitoring Plan developed as part of the Remedy Implementation Plan, respectively;• (b)   The operating regimen for the Active Exposure Pathway Mitigation Measure shall be designed to ensure a level of No Significant Risk is maintained for the Receptor(s) of concern

under normal operating conditions;• (c)   The operating regimen shall document the parameters for operating the Active Exposure Pathway Mitigation Measure and the methods and frequency for monitoring such

Measure to ensure that it is operating consistently within such parameters;• (d)   An Active Exposure Pathway Mitigation Measure implemented as part of a Temporary Solution or Remedy Operation Status shall employ remote monitoring technology that will

alert the owner and operator of the building protected by the Active Exposure Pathway Mitigation Measure and the Department immediately upon failure of the system, such as loss of power, mechanical failure or other significant disruption of the effectiveness of the system;

• (e)   The operating regimen shall document the longest duration of a shutdown that would be consistent with:• 1.   a level of exposure that does not pose an Imminent Hazard; and• 2.   a level of exposure that poses No Significant Risk; and• (f)   Following submittal of a Temporary Solution Statement or Remedy Operation Status, the Active Exposure Pathway Mitigation Measure shall be consistently operated and

maintained at a level of effectiveness that ensures a level of No Significant Risk is maintained for the Receptors of concern and in accordance with the provisions of 310 CMR 40.1026.

•  (4)   In the event of any suspension or failure of an Active Exposure Pathway Mitigation Measure implemented as part of a Temporary Solution or Remedy Operation Status, the owner of the property where the Active Exposure Pathway Mitigation Measure is located shall undertake immediate steps to return the Active Exposure Pathway Mitigation Measure to full operating condition.  If such suspension or failure of the system lasts 30 consecutive days, the owner of the property where such Measure is located shall notify both the Department and any non-transient occupants of the building protected by such Measure who may have experienced exposure to oil and/or hazardous material as the result of the system suspension or failure on the 30th day from the start of the suspension or failure period.  This notice shall document the reason for the suspension or failure of the Active Exposure Pathway Mitigation Measure, any efforts made or steps to be taken to resume operation of such Measure, and the expected timeframe for resuming operation of such Measure.

AEPMM Regulations; Takeaway PointsPermanent Solution/Temporary Solution/ROS ALL Require:• AEPMM that is designed and demonstrated to eliminate exposure to OHM to the extent feasible• Must ensure condition of No Significant Risk is achieved and maintained• Demonstration of effectiveness based on representative EPCs collected DURING normal AEPMM

operation and to account for season and temporal variations.• PSS, TSS or OMM Plan must provide the operating regimen • Operating regimen must document the parameters for operating the AEPMM to include:

• Methods and frequency for monitoring to ensure that AEPMM is operating consistently with stated parameters• Documentation of the longest duration of a shutdown that would be consistent with:

• A level of exposure that does NOT pose an IH• A level of exposure that poses No Significant Risk

• MUST EMPLOY REMOTE MONITORING that will notify the owner and operator of the building immediately upon failure of the system (such as power loss, mechanical failure or other significant disruption of the effectiveness)

• After submitting PSS, TSS OR OMM Plan the AEPMM must be operated consistently with said submittal

• In the event of a failure the property owner must take immediate steps to repair the system to full operating condition; if the failure lasts greater than 30 days, the owner must notify (in writing; no specific form per Q.27 of new MCP Q&A) the department and all non-transient occupants of the building of the failure.

• Notification shall document the reason for the failure, efforts being made to correct the problem, and expected timeframe for repair.

Takeaway Points, ContinuedPermanent Solution cannot be achieved if suspension or failure lasting more than 60 days would result in an IH, and ALSO Requires:• AUL to be recorded on the property deed and state that the AEPMM

must be operated and maintained per the PSS• Obligations and Conditions (standard language in Form 1075)

• Owner of the property certifies that financial resources have been made available for immediate repair and/or replacement of AEPMM if it experiences failure

• Annual Certification to Department to include• Property owner is aware of obligation to operate and maintain AEPMM• Property owner is aware the Department may upon reasonable notice

inspect the AEPMM to ensure compliance• Property owner certifies financial resources are available for repairs• Property owner certifies AEPMM is operating pursuant to 40.1025

New MCP Question and Answers

25. Q:   If I have a subslab depressurization system (SSDS) that is part of remedial actions at a site with Remedy Operation Status (ROS) or a Temporary Solution, do I have to retrofit that system with remote monitoring technology (a.k.a. remote telemetry) under the regulations at 310 CMR 40.1026 that became effective June 20, 2014?  A:  Yes. If the SSDS is required to meet the conditions for ROS or Temporary Solution, which in both cases require the maintenance of a condition of No Significant Risk for current site use and activities, and is being operated as an Active Exposure Pathway Mitigation Measure, persons doing the work would be expected to retrofit the SSDS with telemetry consistent with the requirements at 310 CMR 40.1026. These requirements include providing notice to affected individuals if the system shuts down.  MassDEP recognizes that retrofitting the system may not happen immediately (i.e., by June 20, 2014), but we would expect parties to make those changes within six months of the effective date.

Telemetry Standards for an Existing SSDS used as an AEPMM at TS or ROS Sites

1. Define Operating Parameters of the SSDS as an AEPMM if not previously done (include IH and NSR determinations)

2. Modify the TSS or Phase IV OMM with AEPMM operating regimen3. Retrofit the SSDS with Telemetry hardware*4. Program Telemetry for reporting to appropriate persons in the

appropriate format5. Register Device with Bureau of Waste Site Cleanup

*Check the BWSC registration form BEFORE installing the system

Remote Telemetry Information for Active Exposure Pathway Mitigation MeasuresActive Exposure Pathway Mitigation Measures (AEPMM) that are part of a Permanent Solution, Temporary Solution or Remedy Operation Status require the use of remote monitoring technology to provide immediate notification to both MassDEP and the owner and operator of the building protected by the AEPMM upon failure of the AEPMM, as the result of loss of power, mechanical failure or other significant disruption of the effectiveness of the system (pursuant to 310 CMR 40.1025(3)(d) and 40.1026(3)(d), respectively).Notification must also be provided upon restart of the system.Notifications to MassDEP of AEPMM shutdowns and restarts are to be made either by email, text messaging or telephone message: Email:        AEPMM.BWSC@state.ma.usText:          AEPMM.BWSC@state.ma.usPhone:     (617) 292-5972 Initial Device RegistrationAt the time of installation a new AEPMM system, you must contact MassDEP at AEPMM.BWSC@state.ma.us  and provide the following information for each AEPMM installed: RTN:  ______________                               Device Number: ________   (01, 02, etc)Device Installation Date:  ________________________Device Type(s) Monitored: (Pump, fan, etc): ___________________________________Description of the Notification Events (shutdown, restart, etc…the system is programmed to report:__________________________________________    AEPMM Location (Building Name, floor & room): _______________________________Address:  ______________________________________________________________Town, State, Zip:  ________________________________________________________     Contact Name:  _________________________________________________________Contact Organization:_____________________________________________________Contact Email: __________________________________________________________Contact Telephone: _______________________________________________________ Changes to this information should be sent by email to AEPMM.BWSC@state.ma.us. Event NotificationThe following information shall be emailed, texted or called in to the department by the remote telemetry system whenever when an AEPMM experiences a notification event (at a minimum, at any system shutdown or restart).  

1. Site RTN:   _-_______2. Device Number: ________   (01, 02, etc)3. Event Description (Start, Shutdown, etc): _______________4. Event Date:      YYYY/MM/DD5. Event Time:  HH:MM  (24 hour format)

For example, a text message notification of a shutdown at 7:25 PM of June 20, 2015 would look like:“1-0012345”,”01”,”shutdown”,”20150620”,”19:25”The Activity Description informs the Department of system failures and restarts. Systems may also be designed to send notifications for other triggers, such as a loss of pressure, reduction in air flow, or scheduled maintenance. MassDEP will accept notifications that exceed the minimum requirements of 310 CMR 40.1025(3)(d).

BWSC Registration FORMhttp://www.mass.gov/eea/agencies/massdep/cleanup/regulations/remote-telemetry-information.html

Interim Final Vapor Intrusion GuidanceWSC#-11-435

• 3.5.1 Performance Standards • 3.5.2 Demonstration of Effectiveness for Active Mitigation Systems • 3.5.2.1 Confirmation of Pressure Field of Active Mitigation Systems• 3.5.2.2 Indoor Air Quality Monitoring of Active Mitigation Systems • 3.5.2.3 Maintenance and Monitoring of Active Mitigation Systems

PUBLIC DRAFT NOW AVAILABLE, WSC#-14-435

Guidance for Operation of an SSDS as an AEPMM

• Demonstration of adequate sub-slab negative pressure field • -0.015 inwc in moderate weather

• Measurement & documentation of SSDS operational parameters• Confirmation of pressure field at observation locations• In-line manometer readings

• Indoor air testing with SSDS operating to demonstrate a condition of NSR has been achieved

• Operation, Maintenance and Monitoring Plan• What needs to be measured• Frequency• (see VI guidance)

• Annual system checks to consist of • Fan operation• negative pressure field below slab is maintained

Guidance Key Points for Operation of an SSDS as an AEPMM

But What Does the Telemetry Unit Have to Do?

AT A MINIMUM, Monitor the AEPMM to make sure that:1. There is power to the system, 2. that the system is mechanically functional, 3. and that it is operating without significant disruption of

effectiveness AND IF THOSE CONDITIONS AREN’T MET:4. Notify MassDEP and Owner/Operator of the building of the

power loss, mechanical failure or other significant disruption of system effectiveness

5. Provide notification upon restart of the system

How Do We Do That?

case study

Drycleaner with PCE release

Web-based Telemetry

• Choosing web based; most places have internet access

• Choosing components and considering cost:

• power monitoring• digital vs analog sensors• switched sensors vs signal processing• hard wired vs wireless and signal boosting

• Supplying power to the sensors• Do the signal transducers require their own DC power

supply? (voltage vs current-based)• Backup battery

• Web-based Processing Unit• Modem/router (UPS)• signal boosters

• Expansion• ability to install multiple sensors

Web-based Telemetry-Programming Features

• Individual sensing zones; allows for incorporation of multiple systems on a single reporting device;

• Identifying and defining alarm conditions; • Data-logging option to determine normal

operating conditions • In-line valves to modify negative pressure field

during observation hole testing• Scheduled shutdowns• Escalation levels• Message Formatting

• Text• Email• Return to normal

Potential Problems and Solutions

• Hardware - know what you are getting, then check what you have • NO vs NC switches• workaround with flexible programming options

• Reporting format- follow DEP example• Power outages-

• battery for telemetry• battery backup for router• be sure to power your wifi boosters also

• Weatherproofing and tamper-protection of outdoor units• Internet Service and Routers stay on• Who provides internet service- property owner/tenant? • DPS

• Internet/phone service installation costs• Annual service provider fees• Cost/benefit – capitol vs hassle (cellular)

AEPMM SHUTDOWN

Per 40.1025 (Permanent Solution)Operation of AEPMM can be terminated if a revised PSS is provided stating the measure is no longer needed to maintain the permanent solution.

• Demonstration based on the Risk Characterization that evaluates and documents exposure to receptors in absence of AEPMM and that accounts for temporal variability and still supports condition of NSR without operation of AEPMM (see VI Guidance for recommended procedures)

Not included in 40.1026 (Temporary Solution or ROS), but:Operation of AEPMM at ROS disposal site can be terminated in accordance with conditions set forth in 40.0893(6)(d).

• (d) Notwithstanding 310 CMR 40.0893(6)(c), any person who intends to discontinue operation of the remedial system, program or Active Exposure Pathway Mitigation Measure on which the Remedy Operation Status is based in order to assess whether the remedial goals have been achieved and conditions remain stable over time may maintain Remedy Operation Status provided that he or she:

• notifies the Department of the system shut down for the purpose of such evaluation and the plans for monitoring site conditions in the next required Status Report following system shut down;

• continues to submit Status Reports at the frequency required in 310 CMR 40.0892; and• notifies the Department if operation of the system is resumed in the next required Status Report following

resumed operation;• (see VI guidance for recommended procedures)