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Reporting Releases Under the MCP: 72-Hour Notification

January 30th, 2014 by Rick Cote, P.E., LSP


I previously outlined the criteria and thresholds for when MassDEP must be notified within 2-hours of a spill or threat of a spill per the MCP. The other reporting criteria include a 72-hour and 120-day notification timeframe depending on the type and severity of the release or threat of release.

With few exceptions, MassDEP must be notified within 72-hours of obtaining knowledge of a release of oil and/or hazardous material(s) that meets one or more of the following criteria:

  1. A release that is indicated by the presence of a subsurface non-aqueous phase liquid (NAPL) more than ½ inch thick.
  2. A release that is indicated by a headspace reading of organic vapors of more than 100 parts per million (ppm) in samples taken more than two feet below the surface in connection with a storage tank removal or closure.
  3. A release indicated by contaminated groundwater with total volatile organic compound (VOC) levels or more than 5 milligrams per liter (mg/L) within 30 feet of a school or occupied residential structure, and where the groundwater table is less than 15 feet below ground surface.
  4. A release that is indicated by contaminated groundwater exceeding reportable levels:
  • Within the Zone I of a public water supply well; or
  • Within 500 feet of a private water supply well.

Additionally, MassDEP must be notified within 72-hours of knowledge of a threat of release from an underground storage tank (UST), where testing indicates there is a substantial likelihood of a leak equal to or greater than 0.05 gallons per hour in:

  • a single UST;
  • the inner wall of a double walled UST; or
  • the outer wall of a double walled UST.

MassDEP will assign a release tracking number (RTN) to the site, under which subsequent response actions will be tracked and submitted. Response actions for a 72-hour reporting condition typically begin with an Immediate Response Action (IRA). Stay tuned to my future blogs about the 120-day reporting condition and the different options available to proceed through the MCP process and work towards site cleanup.

For more information about CEI’s spill assessment and hazardous waste remediation services please contact Rick Cote, P.E., LSP directly at 800.725.2550×302 or rcote@ceiengineers.com or Rebecca Balke, P.E. at rbalke@ceiengineers.com.  

Visit us at www.ceiengineers.com

Posted in the categories Hazardous Waste Remediation, MCP.