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LSPA Submits Comments to MassDEP on 2019 Proposed MCP Amendments

by: Kristi Lefebvre
Category: News
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Jul
22

On Friday, July 19, 2019, at the end of MassDEP's public comment period, the LSPA submitted our comments on the 2019 Proposed MCP Amendments. Our cover letter summarized three key topics of concern: PFAS, Risk Characterization, and Transition Provisions. A separate document included 15 pages of comments.  

As usual, the LSPA process started with a call to members to submit their comments to the LSPA Regulations Committee.  Then committee co-chairs Joe Roman (GEI) and Dan LaFrance (Fuss & O'Neill) assembled a team of "champions" to review, develop, and vet comments.  Many thanks and kudos to that group for an awesome job pulling together a solid draft set of comments.

These comments were reviewed by the LSPA Board and finally by Michele Paul (City of New Bedford), the LSPA's new President. 

We encourage you to share any additional thoughts and comments with the LSPA at [email protected].  


LSPA Soliciting Issues for MassDEP's

by: Kristi Lefebvre
Category: News
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Aug
16
MassDEP Bureau of Waste Site Cleanup is developing a "trailer package" to the 2014 MCP amendments; this package is intended to be a combination of new items that have become apparent since the previous MCP update, items held over from the previous regulatory reform discussion, and corrections to issues that have arisen under the new regulations. 
 
If you have items you'd like considered for MassDEP's trailer package, please reach out to us with an explanation of the issue and what you think needs refining. 
 
The LSPA Regulations Committee will be preparing a submittal for the LSPA Board to review and then submit to MassDEP. This document will comment on topics that MassDEP plans to present for inclusion in the trailer package as well as propose additional topics that the LSPA believes MassDEP should include. 
 
Comments should be sent to us by Wednesday, August 31.  
 
We appreciate your input.
David E. Leone, LSP, Senior Project Manager, GZA, [email protected]
David Foss, LSP, Principal Hydrogeologist, Wilcox & Barton, [email protected]
 
LSPA Regulations Committee Co-Chairs
 

2014 MCP Regulatory Changes: Characterizing and Closing Out NAPL Sites

by: April Veilleux
Category: News
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Jan
08

By: Wesley E. Stimpson, Technical Practices Committee

The recent revisions to the MCP, most of which became effective June 20, 2014, substantially change how sites with NAPL are characterized and moved through the MCP process.  In addition to some new terminology, MassDEP has embraced the fundamental scientific principles describing the behavior of fluid flow in porous media necessary to assess NAPL in subsurface strata.  PRPs are now asked to provide multiple lines of evidence to support any endpoint conclusions, and MassDEP will be looking for more data than has historically been provided in support of closing out this type of disposal sites.  The NAPL Upper Concentration Limit of 0.5 inches no longer needs to be met, and in fact is no longer available to be used as a component for obtaining an endpoint. 

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Overview of 2014 MCP 2014 Regulatory Changes: Characterizing and Closing Out NAPL Sites

by: Kristi Lefebvre
Category: News
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Jan
01

Overview of 2014 MCP 2014 Regulatory Changes: Characterizing and Closing Out NAPL Sites 

The LSPA has prepared an overview as part of a series of topic discussions and resourc  MCP 2014 Regulatory Changes es pertaining to the 2014 MCP changes; this first in the series provides a discussion of key aspects of  the investigation and closure of NAPL sites. Read more.