May 2019 LSPA Compliance Tip
The LSPA presented the following compliance tip at the May Membership Meeting at the DoubleTree in Westborough, MA on May 16, 2019.
COMPLIANCE TIP OF THE MONTH
The LSPA presented the following compliance tip at the May Membership Meeting at the DoubleTree in Westborough, MA on May 16, 2019.
COMPLIANCE TIP OF THE MONTH
The LSPA presented the following compliance tip at the April Membership Meeting at the Holiday Inn in Taunton, MA on April 23, 2019.
COMPLIANCE TIP OF THE MONTH
MassDEP Response to CLF and Toxics Action PFAS Petition
In a January 28, 2019 email, Douglas E. Fine., Assistant Commissioner, Bureau of Water Resources, MassDEP wrote:
As you know, MassDEP received a “Petition for Rulemaking to Establish a Treatment Technique Drinking Water Standard for Per- and Polyfluoroalkyl Substances” on October 25, 2018 from the Conservation Law Foundation and Toxics Action Center. In accordance with regulatory requirements under 310 CMR 2.03 and 2.04, MassDEP held a public meeting on January 16, 2019 to consider the petition and to take comments on the petition. This opportunity allowed for representatives of the Conservation Law Foundation and the Toxics Action Center to present their views on the petition to 71 participants attending the meeting in person, and more than 80 watching via on-line stream. The public meeting also allowed for 21 stakeholders to formally offer their views. In addition, MassDEP received written comments from 45 different individuals and organizations. MassDEP greatly appreciates attention to this important matter from the petitioners, and the agency is very appreciative of the participation of all stakeholders through their written and oral comments, and attendance and viewing of the public meeting.
While we can't comment on the specifics of this Blackstone property, we can say that Licensed Site Professionals (LSPs), attorneys, the Massachusetts Department of Environmental Protection (MassDEP), and the LSP Association (LSPA) hear regularly from homeowners who are overwhelmed and desperate about how they will afford to clean up home heating oil releases on their properties to meet the requirements of the State’s environmental regulations. Home heating oil spills are emotional and difficult for all involved.
Many homeowners do not have the financial means to pay for costly cleanups, and MassDEP does not have the public funds to do this itself. The backing of homeowners' insurance companies is critical to make cleanups financially viable. The LSPA is working with state legislators to mandate that insurance companies provide coverage to homeowners using oil heat - just like they do for homeowners using electric, gas, and other energy sources, and just as most homeowners would expect when purchasing insurance.
The LSPA presented the following compliance tip at the January Membership Meeting at the Holiday Inn in Taunton, MA on January 16, 2019.
Compliance Tip of the Month
The LSPA kicked off its “school” year with a great event on September 25th sponsored by Regenesis.
We heard a high energy and far ranging talk by Jay Ash, MA Secretary of Housing and Economic Development. Secretary Ash covered topics including his time as Mayor of Chelsea, collaboration with several LSPA members with whom he has worked (all good experiences!), Governor Baker’s bipartisan administration, exciting economic development projects happening statewide, and why he is optimistic about the Massachusetts innovation economy. MassDEP Commissioner Marty Suuberg gave a broad reaching overview of the 25 year privatized program and generously acknowledged the important role of the LSPA in this work. He spoke about MassDEP priorities going forward, including the use of new technology to improve government transparency, emerging contaminants, climate change and resiliency, and brownfields development. Both speakers addressed the value of the work that LSPs and other practitioners do, and its importance to the economic and environmental health of the Commonwealth.
The LSPA presented the following compliance tip at the June Membership Meeting at the Holiday Inn in Taunton, MA on June 13, 2018.
Conducting Public Involvement at PIP Sites
From the Waste Site Cleanup perspective, the background information on the development of the guideline will also serve as background information for Waste Site Cleanup’s soon-to-be-proposed MCP Method 1 GW-1 Standard for PFAS.
MassDEP expects to keep us up-to-date throughout the summer on the status of the proposed MCP revisions and MassDEP’s approach to PFAS.
The LSPA presented the following compliance tip at the May Membership Meeting at the DoubleTree Hotel in Westborough, MA on May 17, 2018.
MassDEP recommends that at sites relying on a sub slab depressurization system (SSDS) to prevent exposure to contaminants of concern, annual checks be conducted of fan operation status and for potential differential pressure drops. These annual checks should be conducted as part of site maintenance and monitoring activities, and are recommended even after the installation of remote monitoring (telemetry).
MassDEP’s internship application period is open now through April 30. MassDEP is seeking a student (or team of 2 or more students) that would be interested in developing articles or mini-video documentaries about the history, decline and rebirth of some of the region’s brownfields (‘Brownfield Success Stories”). This internship will expose students to researching the history of disposal sites, learning about site cleanup assessment and technologies, and understanding Massachusetts cleanup process and regulations. (This position requires the type of due diligence research and report writing that would be required of a young environmental consultant).
This internship may be a good fit for liberal arts students with a background in history or communication/journalism, as well as students in environmental science or the earth sciences. The internship is unpaid, but the hours can be part-time and flexible.
The Massachusetts Department of Environmental Protection has updated its Method for the Determination of Volatile Petroleum Hydrocarbons by Gas Chromatography/Photoionization Detector/Flame Ionization Detector (VPH by GC/PID/FID) and the corresponding CAM protocol, WSC-CAM-IVA, Quality Control Requirements and Performance Standards for the Analysis of Volatile Petroleum Hydrocarbons (VPH) by Gas Chromatography/Photoionization Detector/Flame Ionization Detector in Support of Response Actions under the Massachusetts Contingency Plan. The updates include revised calibration requirements, changes to retention time windows for aliphatic hydrocarbons, required traps for the purge-and-trap process, new requirements for data deliverables, and a series of other minor revisions and clarifications. The revised method may be found here VPH Method by GC/PIC/FID. A complete list of the updates is provided in the preface of the revised method.
Laboratories that are currently performing VPH by GC/PID/FID must make the necessary adjustments to implement the changes to the method on or before June 1, 2018 to comply with the method requirements and certify that the method is being performed in conformance with the CAM protocol, found here WSC-CAM-IVA. If you have questions about the revised method or CAM protocol, you may contact MassDEP at [email protected].
LSPA’s Western Massachusetts Committee had a record-breaking number of attendees at its membership meeting on Monday, January 29.
We would like to thank our speakers of the evening: Mr. Jason Barroso, Waste Management, Inc.; Mr. Hugo DelRosso, US Ecology and Ms. Eva Tor, Bureau of Waste Site Cleanup, MassDEP’s Western Regional Office. The speakers addressed the topic of Waste Management Considerations for MCP Projects to an audience of 60+.