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9:30    General Program Updates & 2014 Program Plan – Ben Ericson, Assistant Commissioner - PowerPoint PPT Presentation

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WSCAC Agenda January 23, 2014 (times are approximate). 9:30    General Program Updates & 2014 Program Plan – Ben Ericson, Assistant Commissioner 9:50     TCE sites – Current Case Experience – Steve Johnson, Millie Garcia-Serrano 10:20     MCP Amendments  - Liz Callahan & Paul Locke

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WSCAC AgendaJanuary 23, 2014 (times are approximate)

  • 9:30    General Program Updates & 2014 Program Plan – Ben Ericson, Assistant Commissioner

  • 9:50     TCE sites – Current Case Experience – Steve Johnson, Millie Garcia-Serrano

  • 10:20     MCP Amendments  - Liz Callahan & Paul Locke

        Summary of final amendments; MCP-related fee amendments; implementation (guidance, forms & training)

  • 11:15  PCE – update to the ShortForms – Sandra Baird, ORS

  • 11:30    Soil Management – Status and check-in on “Similar Soils” policy  - Paul Locke 

  •  11:45    Adjourn

Mcp amendments
MCP Amendments

  • Schedule

  • Related Amendments

    • Fee amendments public hearing draft is being prepared; aiming for same effective date

    • MCP trailer package (separate from fee package)

  • Most Significant Changes since the public hearing draft

  • Implementation

Proposed mcp related fee amendments
Proposed MCP-Related Fee Amendments

  • New Tier I fee

  • New AUL fee (for initial AUL, not amendments or Terminations)

  • Expanded Reduced Fees for Homeowners (RAM, Phase V, Post-Temp. Soln, AUL)

Mcp trailer package
MCP Trailer Package

  • Toxicity value hierarchy

  • PCE standard changes

  • Other

  • Timing

Tier classification
Tier Classification

  • Replacing NRS with 4 criteria, as proposed

    • RCGW-1 in a GW-1 area

    • IH

    • IRA ongoing to address CEP

    • IRA with remedial actions ongoing

  • Grandfathering current Tier IIs where IRAs to address CEPs or IRAs with remedial actions are underway prior to effective date of amendments

  • Changes to Phase deadlines, as proposed (Phase II due 3 years from TC;Phase II Scope of Work becomes Conceptual Ph II SOW

Conditions of srm for vapor intrusion
Conditions of SRM for Vapor Intrusion

  • Proposed more specific SRM triggers that reflected VI guidance on when to look for vapor intrusion

  • Final amendments incorporate triggers with modifications

  • eliminated proposed trigger of GW within 100’ structure with OHM concentrations greater than 10 times GW-2

  • eliminated proposed trigger “one or more VOCs exist in groundwater within 30’ of” structure with sump, earthen floor, fieldstone or concrete block foundation

  • revised other criteria to be more specific, based on comments, to narrow applicability

Conditions of srm for vapor intrusion1
Conditions of SRM for Vapor Intrusion

Final amendments – SRM VI triggers

  • 1. soil or soil gas with VOCs within 6’ (horiz.) and 10’ (vert.) at concentrations likely to discharge vapors into structure;

  • VOCs in GW > GW-2 within 30’ of structure, and the average annual GW depth is 15’ or less;

  • volatile LNAPL in well, excavation, or subsurface depression within 30’ of structure at thickness ≥ 1/8”; or

  • 4. evidence of vapor migration along preferential pathways at a location likely to result in the discharge of vapors into the structure.

Active exposure pathway mitigation measure as part of a permanent soln with conditions
Active Exposure Pathway Mitigation Measureas part of a Permanent Soln with Conditions

  • AUL only; no permit

  • Requirements now at 40.1025 (Subpart J)

  • Remote telemetry required; affected parties in buildings must be notified if shutdown extends beyond 30 days

  • Would apply to both SSD systems (vapor intrusion) and point of entry/point of use systems on private drinking water supplies

  • Added provisions specific to AEPMMs as part of ROS and Temporary Solutions (no AUL, but would require remote telemetry)

Lnapl napl

  • LNAPL Conceptual Site Model – folded into CSM definition

  • Proposed changes to the 72 hour and 120 NAPL notification thresholds not made

  • Permanent Solution requirements

    • Absence of Non-Stable NAPL

    • NAPL removal to the extent feasible (clarified, does not necessarily mean attempts to remove NAPL)

    • AUL required for NAPL with Microscale Mobility (added definition of NAPL with Microscale Mobility)

Source performance standards for perm temp solns
Source & Performance Standards for Perm. & Temp. Solns

  • Clarified definition of Source of OHM

    • Emphasis on area proximate to original release; addressed concern that dissolved/vapor phase could be viewed as a source

  • Reworked Performance Standards

    • Source Elimination or Control

    • Migration Control

    • NAPL

    • Removed 1 % Solubility Limit (DNAPL) as Perm Soln criterion


  • Eliminated AUL Opinion; site information related to the need for the AUL now to be attached as an exhibit

  • Within 30 days of recording or registering a deed conveying title for a property subject to a Notice of Activity and Use Limitation, a copy of such deed must be sent to MassDEP by either the grantor or grantee

  • For Active Exposure Pathway Mitigation Measures, standardized AUL conditions

  • Proposed text changes to 40.0019 and 40.0020 not included in final amendments

Permanent solutions
Permanent Solutions

  • With Conditions

    • AUL

    • No AUL

      • Anthropogenic Background

      • Gardening Best Management Practices (Gardening BMPs definition added)

      • Under roadways, rail rights-of-way

      • Above GW-2 in areas with no current/planned occupied blgs

  • With No Conditions

  • Background historic fill
    Background & Historic Fill


    Natural Background

    Historic Fill (definition clarified, including adding “Fill” definition)

    Anthropogenic Background


    Anthro. Backgrnd  Perm. Soln. with Conditions, No AUL

    Numeric standards
    Numeric Standards

    • Vanadium S-1 400 mg/kg (proposed 30 mg/kg)

    • Pb S-1 200 mg/kg (proposed bifurcated standard 200|300 mg/kg)

    Other provisions
    Other Provisions

    • Use of Modeling

    • Temporary Soln Transition Provisions

    • Remedial Additives Near Sensitive Receptors

      • Added requirement for prior approval for additives with 100’ of school, daycare or residence

      • In final amendments, changed from prior written approval to 30 day presumptive approval with option to request oral approval

    Guidance to support mcp amendments
    Guidance to Support MCP Amendments


    • Vapor Intrusion…coming soon, survey of VI guidance users

    • AUL

    • MCP Q&As - revising existing Q&As and developing new Q&As to address likely questions related to amendments

    • Posting BMP guidance links