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MassDEP refines Subpart I Q&A to clarify ‘‘visible’’ coal-tar deposits and exposure-point calculations
Summary
MassDEP staff said outreach with the LSPA and National Grid prompted revisions to the Subpart I Q&A to clarify when coal-tar deposits trigger MCP requirements and how legacy data should be used in exposure-point concentration determinations.
Unidentified Speaker 1, a MassDEP program staff member, said the agency is revising the draft Subpart I Q&A after meetings with the LSPA and National Grid in July to clarify when coal-tar deposits meet MCP reporting and remediation thresholds.
The revisions, staff said, focus on two issues: defining a "visible coal tar waste deposit" and clarifying how to calculate exposure-point concentrations. "The intent is that is that the DEP's focus is not the fringe impacts that can otherwise be characterized with soil sampling, but the main concern is significant waste deposits," Unidentified Speaker 1 said, adding that small flecks of coal tar interspersed in soil may be analyzed as soil rather than treated as bulk coal-tar waste.
Staff described analytical challenges when material is composed predominantly of coal tar. "As most people are aware that if it's pure coal tar or heavily coal tar, composed of coal tar, it does mess up lab equipment and it's hard to analyze directly," Unidentified Speaker 1 said. For heavily coal-tar material, MassDEP noted it may accept literature values for contamination concentrations where direct analysis is impractical.
On the exposure-point issue, staff discussed how older, judgmental data can be integrated into exposure-point concentration determinations and how those determinations should consider the feasibility of remediating coal tar at the site. "It's based on the OHM that's known to be present for the feasibility of remediating the coal tar," Unidentified Speaker 1 said.
Staff also told participants that in situ stabilization has been used with deputy regional director (DRD) approval and is an acceptable remediation approach in some circumstances. They noted that if coal-tar material exists as a liquid under ambient conditions it could be characterized under the MCP NAPL provisions, but that in most cases coal tar is solid or semi-solid.
MassDEP staff said they were compiling meeting notes and rewriting the Q&A to share with DRDs "in the next few days or few weeks" with the goal of posting the revised Q&A before the next office hours.
The session did not include any vote or formal decision; staff framed the work as an administrative revision informed by stakeholder outreach and internal review.
