6-10-16 master site remediation urban soils

7/26/2019 6-10-16 MASTER Site Remediation Urban Soils

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Environmental Business Council of New England

Energy Environment Economy

EBC Site Remediation and Redevelopment

Program: Update on Soil Re-Use in

Massachusetts for Large Reclamation

Projects (Interim Policy #COMM-15-01)



Jonathan D. Kitchen

Chair, EBC Site Remediation &

Redevelopment Committee

Senior Project Manager, Civil &

Environmental Consultants, Inc.



Welcome



Edward Van Doren

Program Co-Chair & Moderator

Principal Environmental Engineer,

CDM Smith



Introduction



David G. Austin

Program Co-Chair & Moderator

Technical Leader, AECOM



Introduction



Paul Locke

Assistant CommissionerBureau of Waste Site Cleanup

Massachusetts Department of

Environmental Protection



Where Have All The Soils Gone?

10 Months After Comm-15-01



Where Have All the Soils Gone?10 Months After Comm-15-01

Paul W. Locke

MassDEP Bureau of Waste Site Cleanup

One Winter Street, Boston, MA 02108www.Mass.Gov/dep

[email protected]



10 Months of Talkin’ Soil



MassDEP’s Basic Message

Presentations to…

• EBC

• LSPA

• BWSC Advisory Committee

• MHOA

• Meetings with proponents &

local officials



???



Observations

• The “Screaming” has stopped

• Overall Comm 15-01 seems to work well

• We’re still learning & clarifying some issues



•

What are appropriate site-specific differencesin ACO/SMP versus changing ground rules for

everyone?

•

What is appropriate level and form ofmunicipal & public input?

• What is de minimis ?

•

How to best coordinate resolution of cross-program issues



What’s Up for the Next 10 Months

(10 years)?

• Let’s look back several years first…



OLD FLOWCHART – USED FOR REMINISCING PURPOSES ONLY



Hazardous Waste, Solid Waste or Highly Contaminated Soil

NOT Suitable for Re-Use – Treat/Dispose this Stuff

Addressed by Similar Soils Policy OR is Similar to Similar Soils

Addressed OR Could be Addressed by COMM-15-01



What’s Up for the Next 10 Months

(10 Years)?

• We now have TOOLs to manage the soil

•

EVALUATION: – Are these tools enough?

– Is there compliance with ACOs/SMPs

–

Are regulations & permits needed? – Is there sufficient capacity



Carl Shapiro

President

Avidar Environmental Consulting &

Engineering LLC



The “Early” MA Interim Soil

Re-Use Policy - Some LSP

Observations and Insights



‘Clean’ Soil Management inMassachusetts

– An LSP’s Insights

Perspectives on Managing ‘Non - MCP’Soil in MA

from Source Propertyto RCS-1 Facility

Avidar Environmental, June 2016



Carl Shapiro, [email protected]

A vidar Environmental

Consulting & Engineering LLC400 Franklin Street, Suite 304

Braintree, MA 02184(bus) 781-848-1114 * (mob) 781-726-2518

www.avidarco.com


http://www.avidarco.com/




Program

I. MA Uncontaminated Soils Regulatory Framework Interim Soils Policy 2016

II. MA Soils Re-Use Facility Permitting

III. RCS-1 Facility Soil Acceptance Process Levels of Constituents No. of Soil Tests per Soil Volume Standard Operating Procedures

IV. Waterville Farms

New RCS-1 Facility Being Permitted Planned Use for Hydroponic Greenhouses

V. Closing Comments – Challenges and Opportunities for Regulators, Facility Operators, Soil Generators



MA Soils Framework - Overview

Anti-Degradation Regulation – MCP

>> Crisis – Shortage of Air Space for Non-

Contaminated Soils >> Similar Soils Policy

Interim Policy for Re-Use of Soils at Large

Reclamation Sites Future: Final Policy for Re-Use of Soils ….




Mystique of Soil Management in

Massachusetts Crisis of finding ‘air space’ for soils from new

construction underway

Quarries, sand & gravel pits – ‘hole-in-the-ground’ Environmental restoration of exploited properties

Evolution of the Interim Policy, waiting for themissing side of flow chart … for clean soils




Mystique of Soil Management in

Massachusetts (cont’d)

Essential Soil Disposal Business Unit -

$0.25 Elephant in Room … Is soil ‘contaminated’

Elevated background levels of constituents




RCS-1 Facility – State Permitting

Soil Re-Use Management Plan Soil Acceptance Criteria: Testing Frequency,

Levels of Constituents

Administrative Consent Order with Penalty Vehicle to Document Changes to Plan

Independent Third Party LSP Oversight




Local Approvals

Town Approval – Town Manager, Board ofSelectmen, Town Departments

Earth Permits, if applicable to town

“No clear process in place to providedocument, and towns vary”

Manage noise, traffic, air/dust

Public Communication and Transparency:newspaper, letters, discussions




Interim Soils Policy – Re: Local Approval

MassDEP will review documentation submitted by project proponents to demonstratethat the appropriate local officials are aware of the project and have been affordedthe opportunity for meaningful input. Examples of such documentation may include:

a copy of any local permit or other approval specific to the use of large volumes of fillmaterial that may be required (municipal approval of an up-to-date reclamation plan for thereceiving location, and/or or a municipal permit under an “earth filling” ordinance, and/orany other approval required by a municipality for activities that involve the transportationofsoil onto the receiving site);

a summary of the steps taken to solicit meaningful input from those local officials, copies ofcomments received, and a description of the ways in which these comments have been (orwill be) addressed.

MassDEP will not finalize an Administrative Consent Order on the proposed quarry,gravel pit or sand pit reclamation project unless and until all comments from suchlocal officials on project impacts related to noise, dust, odor and/or trucks have beenappropriately addressed by the project proponent.



Soil Acceptance Approval Into

RCS-1 Facilities

Working with Other LSPs Acceptable Levels of Chemical Constituents – approved

as part of SRMP

Metals: MCP-14 vs. RCRA-5 for landfills VOCs: Rule of thumb developed as 10% SVOC/PAHs: Some can be restrictive

Rate of Analyses – 1 sample per … Arsenic in Worcester County Soils near MCP disposal site on property

LSP Opinion Letter




Waterville Farms – Planned RCS-1

Facility, Middleborough MA Environmental Restoration of 42-Acre Site

Est. 1Million yards of sand & gravel removed

Hydroponic Greenhouses – nutrient-fed vegetables

Higher Education and R&D – agriculture, energy

Social Responsibility – working with public schools andfamilies

DEP Issued WF Project Draft Administrative Consent Order(ACO)

Working with Town for ANRAD – wetlands delineation – noimpact anticipated

Modification of existing earth permitAvidar Environmental, June 2016



Challenges –

Clean Soils Management

Early Stages of Policy – will need to continue tobe exercised

Local Approval – new more intense introspection

for towns Budget for soil laboratory analyses




Opportunities

Provision of Air Space for Excess Soils

Environmental Site Restoration and Return toPurposeful Use

New LSP opportunities: for RCS-1 facility; ThirdParty LSP oversight

Projects like Waterville Farms to provide lens of

future opportunities, through leadership inbusiness. Avidar Environmental, June 2016



Working to understand – and achieve – our clients’

environmental goals in industry and government

Avidar Environmental

Consulting & Engineering LLCwww.avidarco.com

Carl Shapiro, LSP

[email protected] (cel) 781-726-2518


mailto:[email protected]

mailto:[email protected]




Dan Walsh

Senior Project Manager / EnvironmentalEngineer

W. L. French Excavating Corporation



Operation of Two Soil Reuse

Facilities Under MassDEP

Interim Policy



Operation ofTwo Soil Reuse Facilities

Under MADEP ACOs

St. Mary Cemetery Expansion Project, Tewksbury, MA

and

Dudley Reclamation Project, Dudley, MA



• Procedures to obtain ACO – May 2015 LSPA MeetingPresentation

•

Mass DEP Interim Policy Comm-15-01

• Local Regulations – Wetlands, Land Ordinances

• USEPA SWPPP

• Soil and Fill Management Plan



St Mary Cemetery Expansion

• 450,000 cubic yards total

•

implemented prior to Comm-15-001

• approximately 2 years remaining

• Close proximity to Boston



Dudley Reclamation Project

• ACO in 2016

•

Over 2 million cubic yard capacity

• Estimated 15 years of operation

• 2 distinct areas – RCS-1 and RCS-2 sections

• 3 load day from Boston



• Submittal Requirement

• Acceptance Criteria based on MassDEP Similar Soils

Policy

• WL French provides Transportation and Disposal

• Pricing readily available and quoted on job-specificbasis



Contact InformationFor W.L. French Excavating Corp.

www.wlfrench.com 978-663-2623 Main Office

Fill Management Plans, submittal forms etc. on website

Bill French, Jr. President

Lisa French Kelly, Principal

Jarrett Everton, Project Manager

Chris Paulino, Project Manager

Dan Walsh, Project Manager

Call for information, quotes, or to set up Projects.

P l Di i

http://www.wlfrench.com/

http://www.wlfrench.com/



Panel Discussion

Moderators: Edward Van Doren and David Austin

• Paul Locke, MassDEP

• Carl Shapiro, Avidar Environmental Consulting &

Engineering LLC• Dan Walsh, W. L. French Excavating Corporation

• Kevin Francis Gervais, Lighthouse

Environmental Management LLC








Program: Update on Soil Re-Use in

Massachusetts for Large Reclamation

Projects (Interim Policy #COMM-15-01)

6-10-16 master site remediation urban soils

Documents