Dear LSPA Member,

As the voice of LSPs and environmental practitioners across Massachusetts, the LSPA is actively advocating to strengthen our profession and advance sound environmental policies. Below is a summary of what we’ve been working on recently:

The LSPA received the following email from MassDEP Bureau of Waste Site Cleanup on June 30, 2025: 

MassDEP has published a number of new Compendium of Analytical Methods (CAM) protocols and materials at https://www.mass.gov/info-details/compendium-of-analytical-methods-cam.

The following LSPA compliance tip was introduced at the June 2025 Membership Meeting, which was held via Zoom on Wednesday, June 11, 2025, from 3:45 PM - 5:00 PM.

Compliance Tip  
When OHM from an upgradient source migrates onto a disposal site being addressed for other releases, and regardless of whether DPS has been established, that OHM must be included when evaluating risk and/or otherwise seeking to achieve a Permanent Solution for the disposal site. OHM from an upgradient source is not considered “background” and, for example, cannot be excluded as a contaminant of concern.

The MassDEP Bureau of Waste Site Cleanup (BWSC) has released its revised Policy for “Off-Gas Treatment of Point-Source Remedial Air Emissions” (formerly Policy #WSC-94-150), with a public comment period ending on June 30, 2025.

This Policy concerns air emissions that occur as a result of air stripping of contaminated groundwater, vacuum extraction of soil gases, or any other remedial activity conducted pursuant to MGL Chapter 21E that creates a point-source discharge of contaminants to air. The intent of this Policy is to articulate when off-gas treatment of point-source remedial air emissions may not be necessary to protect human health, safety, public welfare, and the environment.

MassDEP Brownfields Roundtables

The LSPA received the following email from MassDEP on Monday, May 5, 2025.

The LSP Association requests your nominations for our 2025 "Contribution to the Practice" Awards. If you know of a deserving candidate and wish to nominate the person and/or organization, please complete this form. The deadline for nominations is Friday, August 8, 2025. The awards are presented annually in the fall at an LSPA event.

Nominations are solicited in the following categories:

The LSPA received the following email from MassDEP on Wednesday, April 23, 2025.

MassDEP has posted the Final GUIDANCE ON IMPLEMENTING ACTIVITY AND USE LIMITATIONS, Policy #WSC 25-300, April 23, 2025, available at: https://www.mass.gov/lists/policies-guidance-technical-support-for-site-cleanup. 

The Massachusetts Department of Environmental Protection (MassDEP) Bureau of Waste Site Cleanup is holding an online informational meeting about upcoming Technical Assistance Grants (TAGs) funding. TAGs are available to community and municipal groups to enhance public participation in assessment and cleanup activities at oil or hazardous material disposal sites. TAGs may be used to obtain expert advice and technical assistance and to promote community education for qualifying projects.  The informational meeting will include a presentation on the purpose of the TAG program, grant eligibility requirements, and the grant application process and timelines.

The online informational meeting will take place on Wednesday, April 16, 2025 at 4:00 PM via Zoom. You may access the meeting via MassDEP’s TAG webpage at this link:  https://www.mass.gov/info-details/technical-assistance-grants-waste-site-cleanup

On March 19, 2025, Annual Certification letters were sent by MassDEP’s Bureau of Waste Site Cleanup to property owners where an Active Exposure Pathway Mitigation Measure (AEPMM) is required to maintain a Permanent Solution with Conditions under the Massachusetts Contingency Plan (MCP). The MCP requires that the current property owner submit an annual certification concerning the operation and maintenance of the AEPMM upon receipt of a form sent by MassDEP (310 CMR 40.1025(8)).

In addition to the annual certification, MassDEP is requesting that the property owner conduct a shutdown and restart test (310 CMR 40.1025(9)) to demonstrate the remote telemetry for the system is operating correctly. In total, seventy-four (74) letters were sent to property owners. Letters were also emailed when MassDEP had an email on file for the property owner. The deadline for returning the Annual Certification form is May 5, 2025. Annual Certification letters sent by MassDEP are publicly available on the Energy & Environmental Affairs Data Portal.  As MassDEP receives completed forms from property owners those letters will be added to the Data Portal as well. 

The following LSPA practice tip was introduced at the March 2025 Membership Meeting, which was held via Zoom on March 20, 2025.

Practice Tip of the Month
Spring is a good time to document the condition of monitoring wells, especially after a busy snowplow season. Well covers that are damaged over the winter may no longer meet the requirements of 310 CMR 40.0028, which specifies:

The MCP-mandated March 1, 2025 deadline is fast approaching.

Pursuant to 310 CMR 40.0560(7)(i)(4.)(b), a Periodic Review of the Temporary Solution and Tier Classification Extension shall be submitted within one year of March 1, 2024 for disposal sites where Active O&M is not occurring and the following apply: (i) a Temporary Solution Statement for a disposal site was submitted to the Department prior to March 1, 2024; (ii) the Tier Classification had expired prior to March 1, 2024, and (iii) Status Reports and, as applicable, the Periodic Review of the Temporary Solution had not been submitted at the frequency specified pursuant to 310 CMR 40.0898 and 310 CMR 40.1050(4) prior to March 1, 2024.

The following LSPA practice tip was introduced at the February 2025 Membership Meeting, which was held via Zoom on February 12, 2025.

Practice Tip of the Month
When an MCP submittal form is required, you should download the form directly from the MassDEP website. That way you will have the most current version of the form rather than a possibly outdated version saved to your desktop or laptop.

2024 flew by while the LSPA advocated for the waste site cleanup practice and supported practitioners throughout the Commonwealth. We are always eager to review and assess our annual accomplishments and this year is no different. We can’t say “thank you” enough to LSPA members, committees, workgroup leaders, and committee chairs who make this association successful. We also applaud our annual and event sponsors who underwrite our work; we appreciate your confidence in our ability to carry out our mission. Below are some 2024 highlights.  

The following LSPA compliance tip was introduced at the December 2024 Membership Meeting, which was held via Zoom on December 18, 2024.

Compliance Tip of the Month
While the MCP requires an assessment of “reasonably foreseeable future changes in site conditions” related to climate change, it does not indicate a specific assessment timeframe. 

BWSC Advisory Committee Meeting Highlights

MassDEP’s Bureau of Waste Site Cleanup (BWSC) Advisory Committee meeting was held on November 21, 2024. The meeting agenda, meeting slides, and a YouTube meeting video are all available here. The LSPA’s key takeaways are below.

• AUL Guidance is “nearing the finish line” and expected to be final by early 2025. MassDEP is continuing to review and incorporate comments received, and ensuring consistency with other documents – e.g., Risk Characterization guidance. Contact Margaret Shaw at [email protected] with questions.
• Soils Reuse Update: The COMM-24 Soils Policy is currently under review by MassDEP senior staff. This policy would allow reuse of contaminated soils at other 21E sites at levels greater than currently allowed by COMM-15. There will be a public review of the draft policy before it is finalized. At this time, major acceptance requirements include but are not limited to: must result in achievement of a Permanent Solution, must include a public involvement process, and at least 250,000 cubic yards of soil must be moved.  
• The PFAS Q&A is under review by senior staff and expected to be released in early 2025.  For PFAS questions, contact John Ziegler, LSP, at [email protected].
• The Western Regional Office has a new Deputy Regional Director (DRD): Tamara Cardona-Marek, Ph.D. She replaces Catherine Skiba who was the most recent Acting DRD.

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

On September 10, 2024, the LSPA sent our comments to MassDEP’s Bureau of Waste Site Cleanup (BWSC) as part of its public comment period on Risk Characterization Guidance, Chapters 6-10, Public Review Draft.

The LSPA adhered to our typical process for collecting and submitting comments on draft documents:

The MassDEP, Bureau of Waste Site Cleanup is currently accepting applications for its FY25-26 Technical Assistance Grants (TAGs) funding opportunity. This grant opportunity provides $200,000 in funding, with up to $20,000 per award to support community and municipal groups in fostering public participation in decisions related to assessment and cleanup activities at oil or hazardous material disposal sites. Recipients of TAGs may use funds to access expert advice and technical assistance, and to facilitate community education for qualifying projects.

The application submission deadline is 5pm on September 6, 2024.

The Massachusetts Department of Environmental Protection (MassDEP) has issued the newest installment of and opened a public comment period on its Risk Characterization Guidance; this draft guidance covers Chapters 6-10 of the longer document. All pertinent information has been posted to MassDEP’s MCP Amendments web page.

With this email, the LSPA’s Regulations and Technical Practices Committees are soliciting comments on this latest document; the LSPA will be providing comments to MassDEP by close of business on September 12, 2024. 

The Massachusetts Department of Environmental Protection (MassDEP) announced that the application for the FY2025-26 Technical Assistance Grant (TAG) is now available. This grant opportunity provides $200,000 in funding, with up to $20,000 per community or municipal applicant group selected for an award, to enhance public involvement and promote a better understanding of the cleanup of contaminated sites in their communities. 

The application deadline is Friday, September 6, 2024.