Maurice Hamel

Maurice Hamel
Environmental Analyst
Bureau of Water Protection and Land
Reuse - Remediation Division
CTDEEP

Connecticut Department of
Energy and Environmental Protection

MANAGING POLLUTED SOILS:
On-Site
Off-Site
September 7, 2012
Maurice Hamel, Environmental Analyst, Remediation Division,
Bureau of Water Protection and Land Reuse
EBC CT Chapter
Connecticut Department of Energy and Environmental Protection

CURRENT HANDLING REQUIREMENTS
Polluted soil
meeting criteria
can stay on-site
without restriction
Soil contaminated in
excess of criteria can
stay on-site with
restrictions
or
Be disposed of as
solid waste
Beneficial reuse onsite
or off-site

EXCESS CONSTRUCTION-RELATED SOIL
DEEP approved plan for reuse
Off-site reuse of soil
• Soil must meet criteria for receiving site
• Soil in which the concentration of any
substance exceeds the GA PMC cannot be
placed over soil and ground water not
already affected by a release at the
receiving site

INFORMATION NECESSARY FOR
APPROVAL TO REUSE POLLUTED SOIL
• COCs and concentrations
• Basic characterization info - CSM
• Volume of materials proposed for reuse
• Receiving Site
– GW class
– Potable wells
– Existing levels of contamination at receiving site
– Land use
– Acknowledgment from property owner

PROCESS TO REQUEST APPROVAL TO
REUSE POLLUTED SOIL
Approval Request Form
• http://www.ct.gov/dep/cwp/view.asp?a=2715&q=420686&depNav_GID=1626
• Reuse of Polluted Soil
22a-133k-2(h)(3)

EXAMPLES OF CURRENT ISSUES
Municipal Sewer Project
• Incomplete characterization
• No Soil Management Plan
Brownfield in Southington
• Incomplete characterization

URBAN SOILS WORK GROUP
• Guidance document in early 2013
• Provide certainty and flexibility
• Make outcomes and cost predictable
• Minimize need for off-site management
• Streamline characterization and remediation
process
• Streamline DEEP approval process of EC
• Maintain protectiveness and consistency with
RSRs

URBAN SOILS WORKING DEFINITION
Urban Soil includes material deposited on a
parcel that contains a mixture of one or more
of the following: soil, coal ash, coal fragments,
wood ash, asphalt paving fragments, clinkers,
brick, concrete, glass, ceramics, metal
fragments and incidental amounts of other
construction and land-clearing debris

URBAN SOILS RECOMMENDATIONS
• The goal is to exempt from PMC
under RSRs 22a-133k-2(f) (coal ash exception)
if soil characteristics meet eligibility guidelines:
– Table of typical COC thresholds for PAHs & Metals
• Other releases are characterized as hot spots and
remediated to RSRs
• Presumed remedy is to render inaccessible with
standardized ECs to allow soils to remain on-site

URBAN SOILS CHARACTERIZATION
• Different Data Quality Objectives
• Basic understanding of lateral and vertical limits
– Minimize investigation
• Less sampling
• Similar to Targeting Brownfield Remedy
• Multiple lines of evidence
– Site History
– COCs
– Visual
– Minimal groundwater impacts

URBAN SOILS ON-SITE MANAGEMENT
Standardized designs for
streamlined approval
Lawn / Landscaped areas /
Stone and pavers / Paved
surfaces
Maintenance, monitoring and
inspection plan
Financial surety
Application forms with EC
templates
Similar approach would be
appropriate for use at sites
not in a remedial program
Long-term goals to allow to be
self-implementing with “deed
restriction”

Questions?
Maurice Hamel, Environmental Analyst
Remediation Division
Bureau of Water Protection and Land Reuse
maurice.hamel@ct.gov
860-424-3787
Connecticut Department of Energy and Environmental Protection