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I Reported a Spill to MassDEP – Now What?

March 16th, 2014 by Rick Cote, P.E., LSP

After a spill has been reported, preliminary response actions must be initiated. The type of response action will depend on the reporting condition (e.g., 2-hour, 72-hour and 120-day), and may consist of initial site investigation activities, an Immediate Response Action (IRA) or a Release Abatement Measure (RAM).

  1. Initial site investigation activities are used to assess and guide the appropriate response actions for a site. The results can be used to support a Response Action Outcome (RAO) for the site, which means no further remedial action is required, or it may indicate the need for further investigation and remedial action.

  2. IRAs are implemented where timely actions are required to assess, eliminate, abate or mitigate adverse release conditions. They must be implemented where a 2-hour or 72-hour notification was made, or at sites where a condition of substantial release migration has been identified. An IRA plan must be prepared and submitted, outlining the proposed remedial actions to be taken at the site. An IRA plan or IRA Completion Statement (if the release is remediated) must be submitted to MassDEP within 60 days of notification of a release or condition of substantial release migration. All written IRA plans must be approved by MassDEP. Approval is presumed if MassDEP does not issue a written approval or denial of the plan within 21 days of receipt.

  3. RAMs are implemented to remediate limited or localized releases, and/or to mitigate the impacts of larger releases until such time as more comprehensive remedial actions can be implemented at the disposal site.

These preliminary response actions will lay the foundation for future response and remedial actions. Generally, if a RAO cannot be filed within one year of notifying, comprehensive response actions must be initiated, beginning with the filing of a Phase I – Initial Site Investigation Report and Tier Classification due one year from notification. This process must begin even if IRA and RAM activities are ongoing.

For more information about CEI’s Hazardous Waste Remediation and Assessment Services please contact Rick Cote, P.E., LSP directly at 800.725.2550 or rcote@ceiengineers.com or Rebecca Balke, P.E. at rbalke@ceiengineers.com.

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