Waste Site Cleanup Advisory Committee Meeting Agenda Waste Site Cleanup Advisory Committee Meeting Agenda April 25, 2013, MassDEP, One Winter Street Boston.

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Presentation transcript:

Waste Site Cleanup Advisory Committee Meeting Agenda Waste Site Cleanup Advisory Committee Meeting Agenda April 25, 2013, MassDEP, One Winter Street Boston 9:30 amGeneral updates - Assistant Commissioner Ben Ericson 10:00Forms/guidance to be updated to support MCP amendments- Liz Callahan/Paul Locke 10:15 Gardening BMPs & outreach/implementation - Paul 10:30 Consideration of new approaches to define & evaluate short-term risk/Imminent Hazards under the MCP (Note: longer term discussion; not part of the current amendments) - Paul 11:00 Source control scenarios & proposed provisions - Liz 11:30 Adjourn 1

Amendment Implementation Amendment Implementation – Guidance & Form Updates Timeframes – by effective date, close to effective date, can wait 2

Guidance Revision Priorities LNAPL amendments – revisions to the VPH/EPH guidance (2002) or separate document  LNAPL Workgroup Interim Final Vapor Intrusion Guidance (2011) Draft AUL Guidance (2010) - finalize; incorporating earlier public comment and changes to reflect amendments New Q&As to assist in implementation of amendments 3

Other Guidance Updates Retire NRS Guidance Manual Lower priority - Update references/terminology in other guidance, old Q&As, fact sheets and technical updates 4

Forms/Database... 5

Permanent Solutions With Conditions But No AUL For Potential Gardening Exposures

Issue #1: What Are the Recommended BMPs?

Other People’s Information We don’t have to… don’t want to… reinvent the wheel or BMPs… just Google® it

Issue #2: What Is DEP’s Enforcement Angle?

As Proposed, the MCP would REQUIRE that the Permanent Solution Statement contain RECOMMENDATIONS for the use of Gardening BMPs under certain conditions. The relevant question is: “Does the PSS contain the appropriate BMP recommendations?

DEP’s Goal is to educate & inform & minimize potential exposures where the direct contact risks are already demonstrated to pose NSR, and the incremental exposure – even without BMPs – is thought to be minimal but difficult to quantify. Question for Public Comment: Would the proposal do this?

Source Elimination/Control Source elimination or control is an existing requirement ( (5)) 18

Why Change It? Other proposed amendments – Permanent Sol’n with Active Pathway Elimination Systems and elimination of the LNAPL UCL - remove requirements that now define the endpoint for cleanup Providing more specificity re: adequate source control intended to ensure that the source is stable, prevent occurrence of new/unforeseen exposures after Permanent Sol’n and minimize the time period for existing impacts 19

Some MCP Context Difference between source elimination/control for sudden releases versus historical sites Other MCP requirements: – expedite source elimination and control activities and 72-hour notifications trigger Immediate Response Actions, SRM & CEP require response –aim at ensuring adequate temporal/spatial characterization of site conditions and risk, e.g., nature and extent, CSM, risk characterization, representativeness 20

Source Elimination/Control Provide basic definition of “Source of OHM Contamination” – refers to the original OHM release location and/or contaminated media from which OHM can migrate Source of OHM Contamination shall be eliminated, if feasible If not feasible, then Source must be controlled; performance standards for “Source Control” are specified

Proposed Definition Source of OHM Contamination means a point of discharge of OHM into environmental media and/or OHM within environmental media, that is migrating or likely to migrate in a dissolved or vapor state or as a separate phase liquid. Sources of OHM may include, without limitation: 1. leaking storage tanks, vessels, drums and other containers; 2. dry wells or wastewater disposal systems that are not in compliance with regulations governing discharges from those systems; 3. contaminated fill, soil and sediment; 4. sludges and waste deposits; and 5. Nonaqueous Phase Liquids.

Source Control Performance Standards Absence of Non-Stable NAPL Removal of LNAPL to extent feasible (using LCSM principles) OHM plumes in any media not expanding Absence of DNAPL constituent concentrations greater than 1% of their solubility limit

Scenario #1

OVERBURDEN GROUNDWATER BEDROCK TANK #1

OVERBURDEN GROUNDWATER BEDROCK LEAK TANK #1

OVERBURDEN GROUNDWATER BEDROCK LEAK TANK #1

OVERBURDEN GROUNDWATER BEDROCK TANK #1

OVERBURDEN GROUNDWATER BEDROCK Tank removed Soil removed #1

OVERBURDEN GROUNDWATER BEDROCK Tank removed Soil removed #1

OVERBURDEN GROUNDWATER BEDROCK Tank removed Soil removed #1

Scenario #2

OVERBURDEN GROUNDWATER BEDROCK TANK #2

OVERBURDEN GROUNDWATER BEDROCK LEAK TANK #2

OVERBURDEN GROUNDWATER BEDROCK LEAK TANK #2

OVERBURDEN GROUNDWATER BEDROCK TANK #2

OVERBURDEN GROUNDWATER BEDROCK TANK #2

OVERBURDEN GROUNDWATER BEDROCK #2 Tank removed Soil removed

OVERBURDEN GROUNDWATER BEDROCK #2 Tank removed Soil removed Public Water SSDS

Scenario #3

OVERBURDEN GROUNDWATER BEDROCK TANK #3

OVERBURDEN GROUNDWATER BEDROCK LEAK TANK #3

OVERBURDEN GROUNDWATER BEDROCK TANK #3

OVERBURDEN GROUNDWATER BEDROCK #3 Tank removed Soil removed

OVERBURDEN GROUNDWATER BEDROCK #3 Tank removed Soil removed

OVERBURDEN GROUNDWATER BEDROCK #3 Tank removed Soil removed

OVERBURDEN GROUNDWATER BEDROCK #3 Tank removed Soil removed Public Water SSDS

OVERBURDEN GROUNDWATER BEDROCK #3 Tank removed Soil removed Public Water SSDS

BEDROCK #3 Tank removed Soil removed Public Water SSDS

BEDROCK #3 Tank removed Soil removed Public Water SSDS