2015 CPEO Brownfields List Archive

From: Lenny Siegel <lsiegel@cpeo.org>
Date: Thu, 12 Nov 2015 19:31:19 -0800 (PST)
Reply: cpeo-brownfields
Subject: [CPEO-BIF] "Updates on the Site Cleanup Program in Massachusetts: TCE, LNAPL and More"
 
Updates on the Site Cleanup Program in Massachusetts: TCE, LNAPL and More

By:Jeanine L.G. Grachuk
National Law Review
November 12, 2015

The Massachusetts Department of Environmental Protection (“MassDEP”) has been updating its policy and guidance to address improvements in scientific understanding as well as its experience in addressing 
site contaminants.  As we previously reported, significant changes to the Massachusetts site cleanup regulations, known locally as the Massachusetts Contingency Plan (“MCP”), became effective June 20, 2014.  These changes substantially revised numeric standards and closure requirements and modified the assessment and remediation of sites with vapor intrusion, historic fill, and light nonaqueous phase liquid (“LNAPL”).  Today, we provide an update on recent activities.

TCE Sites

Trichloroethylene or TCE is a volatile organic compound that at some sites seeps from soil or groundwater into the air of overlying buildings.  This is referred to as vapor intrusion.  The 2014 changes to the MCP made the site closure standard more strict for sites with TCE in groundwater to address concerns regarding vapor intrusion.  In addition, the MCP amendments substantially changed the approach to vapor intrusion sites placing greater emphasis on indoor air testing, among other things.  Guidance regarding these changes is still being drafted by MassDEP. 

But what of the sites with TCE in groundwater that were closed prior to the recent changes to the MCP?  MassDEP discussed this question at the October 22, 2015 Waste Site Cleanup Advisory Committee meeting.  MassDEP indicated that a fairly large number of sites (at least 700) have been closed out under previous versions of the MCP that allowed site closure under a less strict standard.  Further, MassDEP indicated that some of these sites may pose an “imminent hazard” because the existing science on the toxicology of TCE indicates that TCE can cause harm to a fetus in utero over a fairly short time frame and at low concentrations in indoor air.

…

For the entire article, see
http://www.natlawreview.com/article/updates-site-cleanup-program-massachusetts-tce-lnapl-and-more

--

Lenny Siegel
Executive Director, Center for Public Environmental Oversight
a project of the Pacific Studies Center
278-A Hope Street
Mountain View, CA 94041
Voice: 650-961-8918 or 650-969-1545
Fax: 650-961-8918
LSiegel@cpeo.org
http://www.cpeo.org

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