MCP

April 6, 2017
The LSPA presented the following monthly compliance tip at the April Membership Meeting at Bridgewater State University on April 6, 2017. 

How does one apply Reportable Concentrations and Method 1 Standards when they are equal to the site Oil and Hazardous Materials (OHM) concentrations?


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March 16, 2017
The LSPA presented the following monthly compliance tip on March 16, 2017. 

“Greener Cleanup evaluations” or considerations are not only called out in the MCP under Phase III (Detailed Evaluation Criteria for selecting a comprehensive remedy at 310 CMR 40.0858[4][c]), but also under Response Action Performance Standard (RAPS) at 310 CMR 40.0191(3)(e). 
 
Therefore, Greener Cleanup practices should be considered in all MCP Phases, except during time critical responses (e.g., “2-hour” and “72-hour” reportable conditions). MassDEP provides assistance in the Greener Cleanups Guidance, WSC #14 – 150 (October 2014).

Click here to view all published compliance tips. This document is also posted in the Members Only section of the website under Technical Resources.

LSPA Comments on MassDEP's DRAFT Fact Sheet Guidance on Sampling and Analysis for PFAS at Disposal Sites Regulated under the Massachusetts Contingency Plan.
As the presence of Per- and Polyfluoroalkyl Substances (together, PFAS) become more commonly identified and sampled at MCP sites, LSPs and other practitioners need guidance on sampling protocols, analytical methods, and reporting limits. MassDEP's draft guidance begins to address these issues. LSPA comments are embedded in the draft fact sheet.  

As mentioned at the MassDEP Waste Site Cleanup Advisory Committee meeting last month, there will be a meeting on Wednesday, November 16, 2016 to discuss possible revisions to the Massachusetts Contingency Plan provisions concerning Imminent Hazards.

The meeting will be begin at 9:30 am and will be located in Conference Room C on the 2nd floor of MassDEP’s 1 Winter Street, Boston office.  (The duration of the meeting will depend upon the depth and breadth of the discussion. The room is reserved until 12:00 pm.) Please click here for directions.  

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MassDEP Bureau of Waste Site Cleanup is developing a "trailer package" to the 2014 MCP amendments; this package is intended to be a combination of new items that have become apparent since the previous MCP update, items held over from the previous regulatory reform discussion, and corrections to issues that have arisen under the new regulations. 
 
If you have items you'd like considered for MassDEP's trailer package, please reach out to us with an explanation of the issue and what you think needs refining. 
 
The LSPA Regulations Committee will be preparing a submittal for the LSPA Board to review and then submit to MassDEP. This document will comment on topics that MassDEP plans to present for inclusion in the trailer package as well as propose additional topics that the LSPA believes MassDEP should include. 
 
Comments should be sent to us by Wednesday, August 31.  
 
We appreciate your input.
David E. Leone, LSP, Senior Project Manager, GZA, davide.leone@gza.com
David Foss, LSP, Principal Hydrogeologist, Wilcox & Barton, dfoss@wilcoxandbarton.com
 
LSPA Regulations Committee Co-Chairs
 

LSPA Comments on MassDEP's Second Public Review Draft LNAPL Guidance 

The LSPA submitted comments on December 18, 2015 to MassDEP on its Second Public Review Draft of Light Nonaqueous Phase Liquids (LNAPL) and the MCP: Guidance for Site Assessment and Closure, Policy #WSC‐14‐450. Read our cover letter and comments

LSPA Files Amicus Brief with MA Supreme Judicial Court  

On September 30, 2015, the LSPA filed an Amicus Curiae (“Friend of the Court”) brief with the Commonwealth of Massachusetts Supreme Judicial Court in the case of Peterborough Oil Company, LLC v. Department of Environmental Protection.  The case is on appeal from Worcester County Superior Court.   

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Overview of 2014 MCP 2014 Regulatory Changes: Characterizing and Closing Out NAPL Sites 

The LSPA has prepared an overview as part of a series of topic discussions and resourc  MCP 2014 Regulatory Changes es pertaining to the 2014 MCP changes; this first in the series provides a discussion of key aspects of  the investigation and closure of NAPL sites. Read more.

By: Matt Young, Senior Project Manager Environmental Affairs, Cumberland Gulf Group of Companies  and Dave Leone, LSP, Senior Project Manager, GZA GeoEnvironmental, Inc.

LSPA Regulations Committee members were in attendance at the July 31, 2014 MassDEP Bureau of Waste Site Cleanup pre-comment meeting on the public review draft Activity and Use Limitation (AUL) Guidance. The meeting was an informative and productive start to the draft guidance review process. The meeting was moderated by Liz Callahan, Acting Director Div. of Policy and Program Development, and included a presentation by Peggy Shaw, Esq.,

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Provisions of the Amended MCP are Fully in Effect

The 2014 MCP is fully in effect.  While most provisions took effect on June 20, 2014, there were certain regulations that became effective on April 25, 2014.  The "unofficial" version of the MCP is available on the DEP website, along with new MCP Questions and Answers.

Request for Information on EPH Results

by: The LSPA Technical Practices Committee

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