MassDEP’s Bureau of Waste Site Cleanup (BWSC) held its quarterly Advisory Committee meeting on November 20, 2025. The full agenda and recording are available on MassDEP’s website. Key takeaways for LSPA members are summarized below.

1. Administrative Updates:

• Ken Marra retired on November 21—the LSPA thanks him for his years of service.
• Brian Roden is now Acting Director of Policy and Development and will serve on the 21J Board along with John Ziegler.
• Derrick Bruce is the new WERO ER Section Chief.
• Ken Sanderson is now NERO ER Section Chief.
• Tony Kurpaska, CERO ER Section Chief, is retiring.

2. Policy and Guidance Updates:

• Open for Public Comment: Draft Interim Policy Regarding the Re-Use of Soil at Disposal Sites Regulated under the Massachusetts Contingency Plan (COMM-25) (comments due December 24).
• Guidance Coming Soon: Public Involvement Plans, AEPMM Operating Regimen, VPH/EPH.
• Under Internal Review: Master Q&A, UST Closure Manual, Vapor Intrusion, PFAS Q&A, PFAS Interim Sampling, PFAS CAM (Method 533).
• Guidance Still Needed/Requiring Updates: Monitored Natural Attenuation, Asbestos in Soil, Capping SOP, COMM-97/COMM-94, Historic Fill, and Coal Tar Characterization.

3. Draft COMM-25 Policy: COMM-25 is intended for large-scale soil reuse at MCP sites, where a Permanent Solution must be achieved and maintained. Lucas Rogers, Chief Bureau Counsel at BWSC presented on the Policy’s components and a presentation by Paul Locke, former BWSC Assistant Commissioner, was also shown (see the meeting materials).

• Key Components:
• Section I: Defines eligibility for COMM-25 ACOs at Soil Receiving Sites importing large quantities of pre-characterized soil from Donor Sites.
• Section II: Outlines the ACO request and issuance process.
• Section III: Sets minimum ACO terms and soil acceptance criteria (Appendix B).
• Section IV: Public involvement requirements, including enhanced obligations for EJ communities (Appendix C).
• Comparison to COMM-15:
• COMM-25 applies only at MCP sites, requires pre-characterization and transport sampling, written public notification, response to comments, and EJ-specific provisions.
• Notifications occur under 310 CMR 40.0317(13) (pre-PS) and 40.0317(17) (post-PS), with additional approvals under 40.0031(1).

4. LSP Board Updates

• The LSP Board is moving ahead with two LSP exams per year. Spring 2026 dates have been announced. Learn more here. 
• 309 CMR regulation amendments were approved by MassDEP Commissioner Heiple and are under review by EEA. Until the revised regulations are promulgated, LSPs must comply with current continuing education requirements.
• Updated LSP application forms are now available online with improved clarity and usability.

5. ORS Updates

• Age-Dependent Adjustment Factors (ADAFs): EPA’s 2005 ADAF framework accounts for the higher cancer susceptibility of children to mutagenic chemicals. MA incorporated ADAFs into the 2019 Method 1 revisions. ADAFs are built into the Shortform’s Residential Soil ELCR (“OtherMut C” tab). Any adjustments must be documented in the risk characterization narrative.
  • Default EPA factors:
  • Chemical-specific factors apply when sufficient data exist (e.g., TCE).
  • Chapters 1–10: External comments received.
  • Chapters 14 and 17: Out for comment.
  • Chapter 11 (Method 3): Under review by ORS Toxicology; includes appendices on dioxins/furans, adherence factors, and ADAF/MMOA application.
  • Chapters 15 and 16: Aquatic and Terrestrial Eco Risk under development, along with 12 technical appendices.

• Risk Characterization Guidance: This guidance is intended to update the 1995 guidance. MassDEP is planning to host at least two meetings with risk assessors to obtain feedback.

6. PFAS Updates

• 2025 Notifications: Twenty-one notifications to date, with most being 2-hour notifications. Most common sources include AFFF, septic/wastewater, and landfills. Sixty-four cases still have unknown sources.
• Site Status: Of ~200 PFAS sites, 20 have reached Permanent or Temporary Solution. The majority of sites are conducting Phase I/II assessments and, as far as remedies, MassDEP is seeing stable plume monitoring, permeable reactive barriers, and a smoldering technology that’s being piloted at Joint Base Cape Cod.
• Imminent Hazards: Ninety-eight POET systems installed; 27 transferred to owners. Radon adsorption on GAC is an emerging issue. MassDEP is addressing this on a case-by-case basis and installing aeration pretreatment where needed. MassDEP is hoping to issue additional guidance in the future.

MassDEP’s next BWSC Advisory Committee meeting will be held February 19, 2026.