Preliminary Response Actions-Part I
The Massachusetts Contingency Plan (310 CMR 40.0000) “the MCP” allows three main types of preliminary response actions at disposal sites. These are Limited Removal Actions, Immediate Response Actions and Release Abatement Measures. The regulations related to Limited Removal Actions are described below.
Limited Removal Actions (“LRA”) are described in section 40.0318 of the MCP. LRA’s are restricted to the removal of contaminated soil. While performing a LRA contaminated soil can be removed from a site under certain conditions without notification or reporting to the MA DEP, or direct oversight by the MA DEP.
LRAs can be conducted for soil that would be a “120 Day Notification” release if the volume of contaminated soil is less than 100 cubic yards for oil or waste oil contamination, or 20 cubic yards for contamination by other hazardous materials.
LRAs cannot be conducted for releases requiring “2 Hour” or “72 Hour” notification, or after the MA DEP has been notified of a release.
All excavation activities related to the LRA must be conducted within 120 days of obtaining knowledge of the release, and all contaminated soil generated must be managed in accordance with the remediation waste management procedures detailed in section 40.0030 of the MCP. Management of remediation waste typically requires transportation using a Uniform Hazardous Waste Manifest, or a MA DEP Bill of Lading form signed by a Licensed Site Professional, and recycling or disposal at a permitted facility.
Look for future engineering blogs about MCP Preliminary Response Actions, Immediate Response Actions, Release Abatement Measures, and other topics. Please contact Triumvirate’s Engineering group for more information, we have Licensed Site Professionals and Environmental Engineers ready to answer your questions.