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:
- Non-stable NAPL is not present under current site conditions and will not be present in the foreseeable future; and
- NAPL with Micro-scale Mobility has been removed to the extent feasible.
An Activity and Use Limitation is required to support the PSWC at sites where NAPL with Micro-scale Mobility is still present after the removal efforts specified above.
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