Now viewing articles in the category MCP.

  • 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

  • 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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