Now viewing articles in the category Hazardous Waste Remediation.

  • The Use of LRA's to Avoid MCP Notification

    March 18th, 2015 by Rick Cote, P.E., LSP


    I introduced Limited Removal Actions (LRAs) as a potential option for avoiding notification in my “Reporting Releases under the MCP – 120-Day Notification” post. LRAs are allowed under certain circumstances where the release meets the 120-day notification criteria, and the total volume of soils for removal and treatment/disposal is less than:

    • 100 cubic yards of soil contaminated solely by a release of oil or waste oil; and

    • 20 cubic yards of soil contaminated by a release of hazardous material or a mixture of oil or waste oil and hazardous material.

    If these criteria are met then a LRA can be accomplished without oversight or reporting. However, it must be completed within 120 days of the discovery of the release and certain records must be kept.

    A LRA may NOT be used if:

    • The release or threat of release requires 2 or 72 hour notification; or

    • MassDEP has already been notified.

    A few more intricacies of an LRA – if greater volumes of contaminated soil are encountered during the LRA, MassDEP must be notified within the 120-day time frame and remedial actions must cease or approval sought to continue the removal actions as a Release Abatement Measure (RAM). Finally, records of the LRA must be kept for a minimum of 5-years and must include post-action oil and/or hazardous material concentrations and the volume and chemical characterization of excavated soils.

    For more information about CEI’s spill assessment and hazardous waste remediation services please contact Rick Cote, P.E., LSP directly at 800.725.2550x302 or rcote@ceiengineers.com or Rebecca Balke, P.E. at rbalke@ceiengineers.com.  

    Visit us at www.ceiengineers.com

  • Is Your SPCC Plan In Place for an Emergency?

    August 12th, 2014 by Eileen Pannetier


    Do you have a Spill Prevention, Control and Countermeasures (SPCC) Plan? If so, is it up to date with the best available information? If not, you could be subject to penalties and fines. The U.S. Environmental Protection Agency (US EPA) recently fined several facilities in New England anywhere from $3,000 to $10,000 for failing to have an adequate SPCC Plan in place. In some cases, these fines can exceed the cost to prepare the SPCC Plan itself, not to mention the headaches, legal fees and negative publicity.

    You are required to have an SPCC Plan if your facility stores either more than 1,320 gallons of oil in aboveground containers or more than 42,000 gallons in underground tanks and could potentially discharge oil into waters of the United States. Municipal facilities that are typically subject to these requirements include highway garages, transfer stations and recycling centers, where fueling, maintenance and/or waste oil collection are commonly performed. Plans generally outline where oil is stored, spill prevention practices, and response measures to implement in the event of a release. 

    A successful plan should be written so that information is easy to locate when needed the most - during an emergency. Unfortunately, that isn’t always the case and important emergency information often gets buried with the administrative requirements of the plan.

    CEI specializes in creating plans that are comprehensive but functional. Components may include a stand-alone “Action Plan”, focusing on facility inspections and spill response for use by workers in the facility and development of “Emergency Response Cards” or posters designed to hang on the wall near each oil storage location. Cards provide the most pertinent information for each storage area, including what is stored there, emergency response procedures and contacts, inspection and maintenance requirements, and a detailed map of the area showing the locations of oil containers and spill response equipment. These provide an invaluable quick reference in the event of an emergency, avoiding the need to locate and read through a lengthy written plan.

    For more information or examples of any of the materials referenced above, please contact Nick Cristofori, P.E. at 800.725.2550 x303, ncristofori@ceiengineers.com, or Rebecca Balke, P.E. at x308, rbalke@ceiengineers.com or visit www.ceiengineers.com for information on other services we offer.

  • What is a Downgradient Property Status?

    July 11th, 2014 by Rick Cote, P.E., LSP


    Downgradient Property Status is a provision in the Massachusetts Contingency Plan (MCP) for people whose property has been impacted by contamination from an upgradient or upstream property. In most of these situations, the property owner does not control the source of the contamination and therefore may not be able to meet the requirements of the MCP. A Downgradient Property Status submittal allows the property owner to submit information to MassDEP showing the source of contamination is coming from an offsite, upgradient source. Once the Downgradient Property Status becomes effective, the deadlines associated with Tier Classification and Comprehensive Response Actions and associated fees are suspended. This allows time for the property owner to communicate with the upgradient source owner, allow for site access, assess the contamination issues and move through the MCP remediation process.

    For more information about CEI’s site assessment and remediation services please contact Rick Cote, P.E., LSP directly at 800.725.2550x302 or rcote@ceiengineers.com or Rebecca Balke, P.E. at rbalke@ceiengineers.com.

  • ASTM Phase I vs. MCP Phase I

    March 28th, 2014 by Stephanie Hanson


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  • Reporting Releases Under the MCP: 72-Hour Notification

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


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  • MCP and the 2-Hour Notification Process

    December 12th, 2013 by Rick Cote, P.E., LSP


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  • Massachusetts Contingency Plan – Remediation 101

    November 19th, 2013 by Rick Cote, P.E., LSP


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