1. Anthropogenic Background Historic Fill WSCAC March 2015
Patricia Donahue, MassDEP, Northeast Regional Office

2. Presentation Summary Purpose/Background Definitions
Historic Fill Criteria
Cases/Examples
Assessment expectations
Closure Documentation

3. Initial Report Review Is the site history adequate?
Are there industrial/mfg sources of OHM?
Comingled OHM?
How is the Historic Fill documented? Assumptions? Boring logs, TPs, town records, USGS topo map?
Is the sampling adequate?
Is groundwater eligible?

4. Permanent Solution w/Conditions no AUL
From 4/20/14 to 3/3/15
58 total statewide PS w/conditions no AUL
17 submitted for Anthropogenic Background

5. Background & Historic Fill
PERMANENT SOLUTION NO CONDITIONS
Background
Natural Background
Historic Fill
Anthropogenic Background
Atmospheric Deposition
Exempt from 21E/MCP
Public Water Supply
Petroleum Residuals
PERMANENT SOLUTION WITH CONDITIONS NO AUL

6. Background – includes both Natural & Anthropogenic Background
Anthro. Background is OHM from….
Atmospheric deposition of emissions which are ubiquitous and consistently present
Attributable to Historic Fill
Exempt from 21E and/or MCP reporting
Public water supply
Petroleum residues from motor vehicle use

7. What is Historic Fill?

8. Historic Fill means Fill Material based upon weight of evidence and consistent with CSM
Emplaced before January 1, 1983
May contain, but is not primarily, construction & demolition debris, reworked soil, dredge spoils, coal, coal ash, wood ash, solid waste
Was contaminated by metals, hydrocarbons, PAHs prior to emplacement at levels consistent with the pervasive use prior to 1983

9. Historic Fill (cont.) Does not contain OHM from site operations
Does not contain and is not a HazMat (other than Oil, Waste Oil)
Does not contain chemical or manufacturing waste, metal or ore processing waste, residues, slag or tailings
Does not contain material disposed in a muni solid waste dump, burn dump, landfill, waste lagoon et al.

10. Historic Fill?

12. Observations from PSC reviews
Pre-1983 emplacement of Fill – most OK
Percentage of debris – most did not address
Not a HW, dump, lagoon, etc. - yes
Eligible COCs – yes, some high metals concentrations, metals in gw
Consistent with pervasive use - ?
Fill boundary delineated – most did not
Conditions - gardening

13. Historic Fill – Weight of Evidence
Filling documentation, field observations
Site history to rule out on-site source of OHM
Predominately soil (>50%)
Concentrations consistent with pervasive use

14. Case Examples
Site history weak in some cases and did not provide adequate documentation of no on-site source
Groundwater at a gasoline station contaminated with metals (As, Pb)
Fill material with elevated (>S-3) EPH
Few data points analyzed

15. Assessment – Lines of Evidence
Thorough Site History to document fill and rule out on-site sources of OHM
Level of effort commensurate with levels of OHM and site history, i.e. higher levels of OHM, greater level of assessment and explanation
Data compilation & comparison (Table 1, literature sources), to show consistent with pervasive use
Fill delineation on a map

16. Input Data sets that are representative of:
Typical application of pesticide use
Lead paint in soil
Leaded gasoline, stations and roadways
Concentration guidelines to identify expected/more typical ranges
Forensic Analysis – pros and cons

17. Next Steps Finalize Internal comments
Review by LSPA Technical Practice Group
Broader review in April (April 16 WSCAC meeting)

18. patricia.donahue@state.ma.us 978-694-3364
Contact Info