The LSPA presented the following compliance tip at the September Membership Meeting at the Newton Marriott in Newton, MA on September 25, 2018.  

Compliance Tip of the Month
 

The LSPA’s review of recent Notices of Audit Findings indicates that a common violation of sites in Remedy Operation Status (ROS) is the failure to fulfill reporting obligations. 

To maintain compliance with the MCP ROS requirements, Phase V Status and Remedial Monitoring Reports must be submitted on a semi-annual basis (310 CMR 40.0893(2)(g)).  Failure to report could result in the termination of ROS (310 CMR 40.0893(6)).  Where ROS has been terminated, the PRP has two years from the date of termination to achieve a Permanent or Temporary Solution.  Response actions after the ROS termination cannot be conducted without a valid Tier Classification or Tier Classification Extension (310 CMR 40.0893(6)(e)).

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