The following LSPA compliance tip was introduced at the February 2026 Membership Meeting, which was held via Zoom on Teusday, February 11, 2026, from 3:45-5:30 PM.

Compliance Tip  
Per the MCP (at 310 CMR 40.1074(2)(a)5.), where an Active Exposure Pathway Mitigation Measure (AEPMM) is subject to the Obligations and Conditions and other provisions of a Notice of Activity and Use Limitation (NAUL), the sketch plan attached as an exhibit to the NAUL must show the location of the AEPMM. Furthermore, MassDEP has indicated in Notices of Noncompliance that if a sub-slab depressurization system is the AEPMM, a sketch should be provided that shows the locations of suction points, underground piping/manifold piping, and sub-slab soil vapor sampling points, if they are relevant to maintaining the condition of No Significant Risk and meeting the Obligations and Conditions of the NAUL. More than one sketch, such as a sketch of the entire NAUL area and a sketch of the area with the AEPMM, may be necessary to address issues of scale if these details are included. 

MassDEP’s Bureau of Waste Site Cleanup (BWSC) held its quarterly Advisory Committee meeting on November 20, 2025. The full agenda and recording are available on MassDEP’s website. Key takeaways for LSPA members are summarized below.

1. Administrative Updates:

The following LSPA compliance tip was introduced at the November 2025 Membership Meeting, which was held via Zoom on Tuesday, November 18, 2025, from 3:45 PM - 5:00 PM.

Compliance Tip  
Remedy Operation Status (ROS) applies only when an active remedial system, mitigation measure, and/or remedial monitoring program is operating/being conducted to achieve a Permanent Solution (310 CMR 40.0893). In the case of a remedial system, once system operation ceases, continued monitoring of site conditions must occur under Phase V unless (1) the monitoring is being conducted pursuant to 310 CMR 40.0893(6)(d) or (2) the monitoring meets the definition of an Active Remedial Monitoring Program. Limited monitoring to document natural attenuation of residual contamination cannot be performed under ROS.

MassDEP has revised WSC-CAM-X A, Quality Control Requirements and Performance Standards for the Analysis of Per- and Polyfluoroalkyl Substances (PFAS) by Liquid Chromatography/Dual Mass Spectrometry (LC-MS/MS) in Support of Response Actions under the MCP, now posted at https://www.mass.gov/info-details/compendium-of-analytical-methods-cam#pfas-methods.

For aqueous samples with elevated levels of total suspended solids, Section 1.6 of the CAM Protocol was updated to clarify that the solvent rinse should be performed with the typical solvent used for the extraction of solid materials (e.g., methanolic ammonium hydroxide).

The LSPA received the following email from MassDEP Bureau of Waste Site Cleanup on Thursday, October 23, 2025: 

MassDEP has posted the Public Comment Draft of Interim Policy Regarding the Re-Use of Soil at Disposal Sites Regulated under the Massachusetts Contingency Plan (COMM-25) dated Oct 24, 2025 under “DRAFT Policies” at https://www.mass.gov/lists/policies-guidance-technical-support-for-site-cleanup#draft-policies- .

The following LSPA compliance tip was introduced at the September 2025 Membership Meeting, which was held in-person at the DoubleTree Hotel in Westborough, MA on Wednesday, September 17, 2025, from 5:30 - 8:00 PM.

LSPA Practice Tip of the Month
It is important LSPs check the correct boxes when submitting MCP documents. MassDEP has noted two examples where LSPs frequently check incorrect boxes: (1) When a Permanent or Temporary Solution Statement (PSS or TSS) has been retracted for any reason (pursuant to a Notice of Noncompliance or other), a new PSS or TSS is required and so, LSPs should not indicate they are submitting a revised PSS or TSS when they submit the new PSS or TSS; and (2) When putting a site into Remedy Operation Status (ROS), LSPs need to check box #17 when they submit their ROS Opinion, otherwise the MassDEP database will not reflect that the site has transitioned to ROS. If you have questions about BWSC forms, contact [email protected].

The LSPA received the following email from MassDEP Bureau of Waste Site Cleanup on September 9, 2025: 

Two new Public Comment Draft documents have been posted for your review at https://www.mass.gov/lists/policies-guidance-technical-support-for-site-cleanup#draft-policies-:      

The LSPA received the following email from MassDEP Bureau of Waste Site Cleanup on September 4, 2025: 

The newest installment of the Risk Characterization Guidance, Chapters 14 and 17, has been posted to the MassDEP MCP Amendments webpage.  The review/comment period for these chapters is 90 days, until December 5, 2025.

The LSPA received the following email from MassDEP Bureau of Waste Site Cleanup on August 13, 2025: 

MassDEP’s Technical Assistance Grant (TAG) Program

The LSPA received the following email from MassDEP Bureau of Waste Site Cleanup on August 11, 2025: 

The final installment of the 2024 MCP Amendments Q&A has been posted as of August 11, 2025.

Dear LSPA Member,

As the voice of LSPs and environmental practitioners across Massachusetts, the LSPA is actively advocating to strengthen our profession and advance sound environmental policies. Below is a summary of what we’ve been working on recently:

The LSPA received the following email from MassDEP Bureau of Waste Site Cleanup on June 30, 2025: 

MassDEP has published a number of new Compendium of Analytical Methods (CAM) protocols and materials at https://www.mass.gov/info-details/compendium-of-analytical-methods-cam.

The following LSPA compliance tip was introduced at the June 2025 Membership Meeting, which was held via Zoom on Wednesday, June 11, 2025, from 3:45 PM - 5:00 PM.

Compliance Tip  
When OHM from an upgradient source migrates onto a disposal site being addressed for other releases, and regardless of whether DPS has been established, that OHM must be included when evaluating risk and/or otherwise seeking to achieve a Permanent Solution for the disposal site. OHM from an upgradient source is not considered “background” and, for example, cannot be excluded as a contaminant of concern.

The MassDEP Bureau of Waste Site Cleanup (BWSC) has released its revised Policy for “Off-Gas Treatment of Point-Source Remedial Air Emissions” (formerly Policy #WSC-94-150), with a public comment period ending on June 30, 2025.

This Policy concerns air emissions that occur as a result of air stripping of contaminated groundwater, vacuum extraction of soil gases, or any other remedial activity conducted pursuant to MGL Chapter 21E that creates a point-source discharge of contaminants to air. The intent of this Policy is to articulate when off-gas treatment of point-source remedial air emissions may not be necessary to protect human health, safety, public welfare, and the environment.

MassDEP Brownfields Roundtables

The LSPA received the following email from MassDEP on Monday, May 5, 2025.

The LSP Association requests your nominations for our 2025 "Contribution to the Practice" Awards. If you know of a deserving candidate and wish to nominate the person and/or organization, please complete this form. The deadline for nominations is Friday, August 8, 2025. The awards are presented annually in the fall at an LSPA event.

Nominations are solicited in the following categories:

The LSPA received the following email from MassDEP on Wednesday, April 23, 2025.

MassDEP has posted the Final GUIDANCE ON IMPLEMENTING ACTIVITY AND USE LIMITATIONS, Policy #WSC 25-300, April 23, 2025, available at: https://www.mass.gov/lists/policies-guidance-technical-support-for-site-cleanup. 

The Massachusetts Department of Environmental Protection (MassDEP) Bureau of Waste Site Cleanup is holding an online informational meeting about upcoming Technical Assistance Grants (TAGs) funding. TAGs are available to community and municipal groups to enhance public participation in assessment and cleanup activities at oil or hazardous material disposal sites. TAGs may be used to obtain expert advice and technical assistance and to promote community education for qualifying projects.  The informational meeting will include a presentation on the purpose of the TAG program, grant eligibility requirements, and the grant application process and timelines.

The online informational meeting will take place on Wednesday, April 16, 2025 at 4:00 PM via Zoom. You may access the meeting via MassDEP’s TAG webpage at this link:  https://www.mass.gov/info-details/technical-assistance-grants-waste-site-cleanup

On March 19, 2025, Annual Certification letters were sent by MassDEP’s Bureau of Waste Site Cleanup to property owners where an Active Exposure Pathway Mitigation Measure (AEPMM) is required to maintain a Permanent Solution with Conditions under the Massachusetts Contingency Plan (MCP). The MCP requires that the current property owner submit an annual certification concerning the operation and maintenance of the AEPMM upon receipt of a form sent by MassDEP (310 CMR 40.1025(8)).

In addition to the annual certification, MassDEP is requesting that the property owner conduct a shutdown and restart test (310 CMR 40.1025(9)) to demonstrate the remote telemetry for the system is operating correctly. In total, seventy-four (74) letters were sent to property owners. Letters were also emailed when MassDEP had an email on file for the property owner. The deadline for returning the Annual Certification form is May 5, 2025. Annual Certification letters sent by MassDEP are publicly available on the Energy & Environmental Affairs Data Portal.  As MassDEP receives completed forms from property owners those letters will be added to the Data Portal as well. 

The following LSPA practice tip was introduced at the March 2025 Membership Meeting, which was held via Zoom on March 20, 2025.

Practice Tip of the Month
Spring is a good time to document the condition of monitoring wells, especially after a busy snowplow season. Well covers that are damaged over the winter may no longer meet the requirements of 310 CMR 40.0028, which specifies: