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LSPA Introduces December 2022 Compliance Tip of the Month

The following LSPA practice tip was presented at the December 2022 Membership Meeting, which was held virtually through the Zoom webinar platform, on December 14, 2022.  

Compliance Tip of the Month: 
Consistent with 310 CMR 40.1003(7), if all other MCP closure requirements are met, a site with NAPL may be closed with a Permanent Solution With Conditions (PSWC) following complete evaluation of the nature and extent of the NAPL, including demonstration of the following consistent with Policy #WSC-16-450:

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September 2021 Newsletter

LSPA's September 2021 Member Newsletter has been published! Table of Contents is listed below. Please log in to your account and visit Member Materials to view the full newsletter.

In this Issue....

Lessons Learned from FY'19 Nature & Extent-Related NONs

All thirteen of the FY'19 audit findings pertaining to Nature and Extent (N&E) reviewed by the LSPA's Loss Prevention Committee (LPC) resulted in Notices of Noncompliance (NONs) issued to Responsible Parties. Permanent Solutions or Response Action Outcomes were invalidated by MassDEP in two cases.  The NONs related to ten Permanent Solution Statements/Response Action Outcomes, one Permanent Solution with Conditions, one Temporary Solution, and one Phase IV submittal. 

MassDEP referenced deficiencies in the following areas:
  • Application of Conceptual Site Models (CSM),
  • Definition of disposal site boundaries,
  • Incomplete data sets and scope of investigation, and
  • Insufficient information to support risk evaluations. 
For more details, read the article by Jim Begley, LSP of MT Environmental Restoration and an LSPA Loss Prevention Committee member.