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.