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Reporting Releases Under the MCP – 120-Day Notification

March 7th, 2014 by Rick Cote, P.E., LSP

The Massachusetts Contingency Plan (MCP) is MassDEP’s regulatory framework for reporting and cleaning up oil and hazardous waste sites in the Commonwealth. In previous posts I’ve outlined the 2-hour and 72-hour notification criteria. The 120-day notification also has a set of criteria but provides some additional latitude above and beyond that of the other notification requirements. MassDEP must be notified within 120-days if the release meets any of the following criteria:

  1. The release is indicated by hazardous materials in soil or groundwater in an amount exceeding the reportable concentration.
  2. The release consists of two or more cubic yards of soil contaminated with oil at a concentration greater than the reportable concentration.
  3. The release is indicated by the presence of oil in the groundwater in excess of the reportable concentration.
  4. The release is indicated by the presence of subsurface NAPL more than 1/8 inch thick but less than ½ inch thick.

Unlike the 2-hour and 72-hour notifications, certain releases under the 120-day notification requirements may be cleaned up under a Limited Removal Action (LRA) within the 120-day time frame. In these cases, notification is not required and remedial work can be performed outside of the MCP process. Stay tuned for my upcoming posts on LRAs and avoiding the need to enter the MCP system.

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 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.