Upcoming Sampling-focused Meeting

Greetings!

Looking ahead to the upcoming Reclamation Soil meeting on soil characterization (including sampling), I wanted to let you know that the “What’s Happening Elsewhere?” page on the blog (https://reclamationsoil.wordpress.com/other-states/) has been updated with a number of links to articles, policies and regulations relevant to our discussions.

While I’m not assigning homework,  I hope you are able to attend next Tuesday’s meeting with a common understanding of the issues.

Last week, I stressed that MassDEP’s goal is that all stakeholders will have a level of confidence that the soil arriving at a Reclamation Soil Project  is a known quantity, that what we think is in the truck is in the truck.  If you believe you KNOW (well enough) what’s in the soil (if anything), then it is easy (relatively) to determine whether the soil is appropriate for a particular project (does it meet the applicable standards?).

Some of the comments we have heard include:

  • Knowledge of the soil’s point of origin plays a role
    (what were the previous land uses? How deep was the excavation? Is it a known or suspected 21E site?)
  • Prior in situ characterization plays a role
    (Were there test pits? Borings? Who did them? Why? Was there previous analytical data? Field screening?)
  • The “soil type” plays a role
    (Is it “contaminated soil”? “historic fill”? “clean fill”?  “natural material”? and what do these terms mean?)
  • The end use of the soil is important
    (will the soil be close to the surface?  Will there be utilities through it or buildings directly on it? Near water supplies, surface water or wetlands? Will someone grow food in it?)
  • The “chain-of-custody” is important
    (Is the correct stockpile loaded in the truck? Who’s providing oversight? How is it all documented?  Who takes responsibility? Who’s accountable?)
  • Cost is not an insignificant factor
    (Knowledge and confidence come at a price.  Oversight and redundancy is expensive. Unexpected results and changes to soil management plans lead to delays.)

All of this comes provides the context for the ultimate question:  “How does the stockpile get sampled before it is loaded on the truck?”  (i.e., what’s the frequency of sampling, and what are we sampling for?)

This if why next Tuesday’s discussion must be more nuanced than a simple X-samples-per-Y-cubic-yards debate.  DEP’s objective is to establish a process that provides sufficient knowledge, appropriate oversight and clear accountability so that all stakeholders have confidence that the process is working and the appropriate soil is being used for the Reclamation Project.

So I encourage you to visit the www.ReclamatioSoil.org blog and read about existing programs that are addressing similar issues related to soil reuse.  More importantly, I ask for your help in identifying additional material that will help us all fit the pieces together into a protective & workable process to characterize Reclamation Soil  Please use the comment box at the bottom of the “What’s Happening Elsewhere?” page (https://reclamationsoil.wordpress.com/other-states/) to make your suggestions or email them to me at Paul.Locke@state.ma.us.

I look forward to seeing you at 9:30 AM on Tuesday, October 28, 2014 in the MassDEP Boston Office (One Winter Street, Boston, MA 02108, 2nd floor conference rooms).**  Please use the blog or email any questions you may have before the meeting.

  • Paul Locke

** We advise taking public transportation to the Downtown Crossing Station on the Orange and Red MBTA subway lines.  Both North Station and South Station are short walks away if you take Commuter Rail.  Several Hubway bicycle stations are within a couple blocks of the office.

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5 Responses to Upcoming Sampling-focused Meeting

  1. massdepwsc says:

    [A stakeholder emailed the following comment (with attachment) as a response to the post about the sampling-focused meeting]

    Paul I am attaching a document (Dartmouth Testing.pdf) off the Dartmouth BOH site that is relevant to the discussion. I think it fits into the testing meeting as well as the local approval part. This is what we run into at local public meetings when I pitch a site to a community, this document is the first time I have seen any thing in writing on University letterhead.

    Dust particulate is an issue on these projects, during low humidity and just a little wind receiving sites get extreme dust conditions. The trucks are driving over the soil being placed and it grinds the soil into a fine powder.

    I have not experienced any issues with dust coming out of a loaded truck on the road. I owned 115 dump trucks on the big dig that ran 24/7 they all had standard canvass covers and seemed fine. Weekend dust is an issue at sites with receptors.

    There should be a requirement for head space on load out for transport, in 18 years I have seen a lot of volatile’s shimmering off the loaded trucks in the sun. Even though some soil management plans require this it is not being done, based on rejecting these loads wondering who loaded that truck?

    We have intercepted truckers using copies of MSR’s and BOL’s trying to sneak in a “phantom” load, we require a truck list the day before shipment and if the truck is not on the list they don’t get in.

    Confirmatory testing does not work (as we discussed in CERO) if something fails testing prior material from same site becomes suspect in the public’s eyes.

    That’s all for now….

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    • massdepwsc says:

      [MassDEP is aware of the document attached to the comment above and had provided the following response to the Dartmouth BOH.]

      Ms. Henderson,

      I first heard about the report from the Boston University School of Public Health regarding the Comm-97 Policy on the use of contaminated soil at landfills when I attended the Town’s public meeting on March 17th. When I had the opportunity to read the report, I believed it mis-characterized and overstated the actual and potential risk to residents from the importation of Comm-97 material as a component to cap the landfill. I asked the risk assessment and policy experts in the Boston Offices of the Bureau of Waste Prevention and the Bureau of Waste Site Clean-Up to review the report, and I have incorporated their comments into the attached letter.

      I took the step of requesting a review of the report because it was apparent to me that a significant source of the apprehension the residents expressed at the meeting was founded on the report’s mistaken or imprecise conclusions. I understand that this letter will not eliminate all of the residents’ sincere concerns. But I do hope it will lend to the publics’ understanding of why MassDEP concluded that it better served the long term public health of Dartmouth to cap the landfill and eliminate it as an on-going source of ground and surface water contamination.

      I would appreciate it if you could arrange for this e-mail and the attached letter (Dartmouth Bd Health-MassDEPResponsetoBUreport.pdf) to be circulated to the Board of Selectmen and others you deem appropriate.

      Thank You

      Phil Weinberg
      Regional Director
      MassDEP-Southeast Regional Office

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  2. massdepwsc says:

    [A participant emailed the following note/attachment to MassDEP]

    Paul:

    Attached is a Sampling Procedural Doc from ITRC that Martha Zirbel forwarded to me which addresses the soil sampling representativeness issues you note below. It’s quite long but useful.
    I’m sure MassDEP is aware of this, perhaps it should be referenced or considered in some part in developing this section of the Interim Policy.

    ITRC Incremental Sampling Guidance: https://reclamationsoil.files.wordpress.com/2014/10/itrc-incremental-sampling-method.pdf

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  3. massdepwsc says:

    [A participant asked via email…]

    Hi Paul. Do you have a copy of the st Mary cemetery Tewksbury fill management plan?

    Like

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