The following LSPA compliance tip was introduced at the November 2024 Membership Meeting, which was held via Zoom on November 19, 2024.

Compliance Tip of the Month

According to MassDEP's 2024 MCP Amendments Q&A, the term “visible coal tar waste deposits” is not intended to include sporadic occurrences of limited coal tar wastes that are entirely interspersed in and comprise a small part of the soil matrix. These limited coal tar wastes, if they meet the characteristics listed in the Q&A document, “can be (must be) adequately characterized through analysis of representative soil samples.”  These occurrences of limited coal tar wastes may be considered to be part of soil and not a “visible coal tar waste deposit,” and can be evaluated as soil in a Risk Characterization.

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