The LSPA presented the following compliance tip at the February Membership Meeting held at the Holiday Inn in Taunton, MA on February 13, 2018. 

A situation that meets one of the Conditions of Substantial Release Migration (CSRM) specified at 40.0006 is not a CSRM and therefore not reportable, unless there is another, separate reportable condition at the site (see 40.0313(4)).  
This issue arises frequently with the detection of VOCs in indoor air.  
If indoor VOC concentrations are not an Imminent Hazard and there is no other reportable condition such as VOCs > RCs in groundwater or soil, the presence of VOCs in indoor air is not a CSRM and is not reportable. 
Without a separate reportable condition, there is no guarantee that the source of the VOCs is at the site.  Nonetheless, in the absence of an obvious source, the LSP is wise to look further.    

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

A Safety Tip was also presented at the meeting. Please click here to view.