MassDEP Issues Guidance On Performing Response Actions During COVID-19

Just a straightforward informational post. MassDEP has issued a concise, helpful, guidance on performing response actions during COVID-19. Here are the highlights:

• All release notifications are still required within MCP deadlines.
• MassDEP is still taking oral notice of Immediate Response Actions and issuing oral approvals. It is still reviewing written IRA plans. If MassDEP does not respond to a within plan 21 days, then the plan is deemed approved.
• Other routine submittals should be made to the extent practical. If they cannot be made, a notice of delay should be filed. MassDEP will exercise enforcement discretion with regard to delayed routine submittals.
• Active remedial systems should be operated unless they cannot be monitored to ensure that the discharge from the system would be safe. If not, the PRP may consided temporary suspension of operations, unless that would in itself present an imminent hazard.