LSPA Advocacy Opportunities

Advocacy is a key component of the LSPA’s Mission. The LSPA consistently works to represent the best interests of its members with MassDEP, the LSP Board, the Massachusetts Legislature, other government agencies, and the media.

Provided below are the current advocacy opportunities in which the LSPA is involved. Contact Wendy Rundle, LSPA Executive Director at lspa.wendy@gmail.com to learn more. We encourage you to participate with us.

LSPA Seeks Comments from Members on MassDEP's Draft Vapor Intrusion Guidance

MassDEP's draft guidance document on vapor intrusion has been published here. 

The LSPA Regulations Committee is assembling comments. Please forward your comments, questions or concerns on this guidance document to
vidraftguidance@lspa.org.

We cannot guarantee that your comments will be included in the LSPA document so, as always, we urge you to also submit your comments directly to MassDEP. Written comments on this document should be submitted to Gerard.Martin@state.ma.us by February 2, 2015.

We hope to hear from you.

LSPA to Comment on MassDEP Guidance on Revised MCP

Draft guidance documents are out for public comment or are coming soon:

• Comments on draft AUL guidance are due September 22, 2014, read more detail: http://www.mass.gov/eea/docs/dep/cleanup/laws/14-300prdr.pdf  
• The LNAPL guidance document has been posted on the MassDEP website here; http://www.mass.gov/eea/docs/dep/cleanup/laws/lnapldr.pdf  there is no deadline for public comment posted at this time. 
• A Vapor Intrusion (VI) guidance document is expected to be released shortly. 

MassDEP will stagger comment deadlines for AUL, VI, and LNAPL Guidance documents, with VI and LNAPL comments due late summer/early fall.  

The LSPA will submit comments on each. To get involved, contact the LSPA Regulations Committee Co-Chairs, Matt Young (myoung@cumberlandgulf.com) and Dave Leone (davide.leone@gza.com).  

MassDEP Soliciting Input on Management of "Gap Soil"

MassDEP expects to release a guidance document on management of non-remediation waste from 21E sites at some point this summer. “Gap Soil” is defined as soil containing analytes above detection but not remediation waste. MassDEP feels that this segment of soil is being over regulated (sent for recycling/landfill). The goal would be to allow for more reuse options by providing regulatory certainty while maintaining proper management through LSP oversight, appropriate characterization, and some form of MassDEP approval (presumptive or explicit).  

MassDEP is looking to receive examples of Soil Management Plans to assist in the guidance preparation, please send to Paul Locke at paul.locke@state.ma.us as soon as possible. This could be part of the 2014 regulatory reform trailer package.

MassDEP Soliciting Suggestions for Regulatory Reform Trailer Package

MassDEP is preparing for a regulatory reform trailer package anticipated to be released in Fall 2014. Please send comments on errors, omissions, clarification, or potential improvements to Liz Callahan (Acting Director Div. of Policy and Program Development, MassDEP Bureau of Waste Site Cleanup) at elizabeth.j.callahan@state.ma.us.

MassDEP has identified a few specific items anticipated to be in the trailer, including:

• Errors and technical publication issues;
• PCE update;
• Hierarchy of establishing toxicity values;
• Reconsidering approach for Imminent Hazard in cases of carcinogenic chemicals;
• Changes in resident/occupant notification protocols for assessment only IH/CEPs; and
• Permanent Solutions with Conditions for GW-2 exceedances that would otherwise have required an AUL.
  

MassDEP Soliciting Information and Experiences with Implementation of Newly Revised MCP

You can also send your comments on implementation of the revised regulations and guidance to Liz Callahan at elizabeth.j.callahan@state.ma.us.