Mass MCP

Massachusetts Contingency Plan

MCP

Licensed Site Professional

LSP

Limited Removal Actions

LRA

Immediate Response Action

IRA

Release Abatement Measure

RAM

Remedy Operation Status

ROS

Downgradient Property Status

DPS

Initial Site Investigation

ISI

Non Aqueous Phase Liquid

NAPL

Activity and Use Limitations

AUL

Massachusetts Oil and Hazardous Material Release Prevention and Response Act

What is the act that created Mass General 21E?

lender liability protections

keeps fiduciaries and lenders from being deemed an “Owner or Operator”, with provisions

310 CMR 40.0000

Law number of MCP

2 hours

Within how much time should MassDEP be notified of a release under a LRA?

72 hours

Within how much time should MassDEP be notified of a release under an IRA?

120 days

Within how much time should MassDEP be notified of a release under a RAM?

5 phases and ROS

How many phases are in the MCP?

Permanent Solution/Phase I/ DPS

What happens 1 year after initial notification under MCP?

Phase II

What happens 3 years after initial notification under MCP?

Phase III/IV

What happens 4 years after initial notification under MCP?

Permanent Solution/ Temporary Solution/ROS/Tier Class Extension

What happens 5 years after initial notification under MCP?

no significant risk, sources OHM controlled, plumes in vadose controlled, threats of release eliminated, NAPL addressed, OHM concentration reduced, sites with no OHM released

What justifies a permanent solution with no conditions?

no significant risk relying upon limitations to activity if it needs AUL or doesn’t have AUL, sources OHM controlled, plumes in vadose controlled, threats of release eliminated, NAPL addressed, OHM concentration reduced, sites with no OHM released

What justifies a permanent solution with conditions?

Means a level of control of each identified substance of concern at a site or in the surrounding environment such that no such substance of concern shall present a significant risk of harm to health, safety, public welfare or the environment during any foreseeable period of time

no significant risk

Means a level of control of each identified substance of concern at a site or in the surrounding environment such that no such substance of concern shall present a Substantial Hazard to health, safety, public welfare, or the environment.

no significant hazard

no substantial hazard, all sources of OHM controlled, control of plumes in vadose, NAPL addressed, response actions for PS not possible

What justifies a temporary solution?

5 years

How many years does MassDEP have to complete an audit?

Having an AUL

What requires sites to have an audit?

310 CMR 40.0956

What law defines a substantial hazard

310 CMR 40.1003

What law defines OHM control, plumes control, and NAPL control?