The LSPA received the following email yesterday afternoon from MassDEP BWSC. Among other things, it highlights a fact sheet with guidance outlining expectations related to MCP requirements and site work during the COVID-19 State of Emergency, including discussion of meeting response action deadlines for routine submittals. MassDEP recommends that should work be delayed by postponed field work, reduced staffing, or other interruptions, parties should notify MassDEP of the compliance delay in writing, include the deadline(s) that will be missed, and any measures, if applicable, taken to secure the disposal site during the period of work stoppage. The written notice of delay should be submitted to MassDEP through eDEP using transmittal form BWSC121: Notification of Delay. 

MassDEP BWSC also notes that it intends to exercise enforcement discretion for failure to meet deadlines for routine submittals during this State of Emergency. 
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MassDEP has published a Fact Sheet on the continuity of waste site cleanup activities during the COVID-19 State of Emergency.  

I expect we will discuss the new Fact Sheet and other matters during this week's BWSC Office Hours on Thursday morning. (DETAILS: https://www.mass.gov/service-details/bwsc-office-hours-video-calls)

As always, questions can be directed to [email protected] prior to the Thursday call.
 
I hope you are all safe & well.

  • Paul Locke