MCP Regulatory Reform Project Complete

The Regulatory Reform revisions to the Massachusetts Contingency Plan are effective June 20, 2014 (with some provisions in effect as of April 25, 2014).

This concludes BWSC “Reg Reform” project, although the program is committed to continually evaluating and improving the regulations, policy and guidance as appropriate.  Please check the MassDEP Waste Site Cleanup web page for any new projects or initiatives.


NRS/Tier Classification/Permit “Strawman” Proposal

A CONCEPTUAL overview of possible changes to the NRS, Tier Classification and Permits, based on the discussions to date. Please keep in mind that this is for discussion purposes ONLY and does not represent a final regulatory proposal. This material will be discussed at the March 22, 2012 Waste Site Cleanup Advisory Committee meeting.

Permits/TC/NRS Discussion Summary

A summary of the February 8, 2012 discussion about revisions to the Permits, Tier Classification and Numerical Ranking System sections of the MCP is now available. These are notes from the discussion and not MassDEP’s interpretation. For those who participated in the conversation, please read the notes and comment on anything we may have missed or misinterpreted. For those who missed the meeting, this is a great chance to add your voice to the discussion! Either way, please use the comment block below so that the wider community can benefit from your thoughts & observations.

MS Word version: February 8 2012 TC Discussion

Adobe PDF version: February 8 2012 TC discussion

Questions to Ponder for Permits/TC/NRS

Looking ahead to the meeting Wednesday (February 8, 2012) on eliminating/modifying/improving the MCP Permits, Tier Classification and Numerical Ranking System sections, here are a few leading questions for you to ponder…

  1. In your experience, are Tier 1 sites treated the same or differently as Tier 2 sites? (By MassDEP? LSPs, PRPs, the Public?)
  2.  Should MassDEP maintain Tier 1 Classifications (Tier 1A, Tier 1B,and Tier 1C)? Why or why not?
  3. What has been your experience with MCP permit approvals?  Are they mostly/all presumptive or do you receive additional permit conditions? Are those additional conditions relevant, useful, and thoughtful, etc…?
  4. Should MassDEP maintain a Tier I Permit?
  5. What aspects/requirements/safeguards from Permits are useful and should be maintained (if any) in some form?
  6. What are your views on streamlining or eliminating the Numerical Ranking System?  What aspects of the NRS are useful and should be maintained (if any)?
  7. What information would be beneficial to include/exclude from the existing transmittal forms (including NRS scoresheet)?
  8. Does the NRS provide benefits to the public, LSPs or PRPs, such as useful information on the complexity/range of sites?  If so, how is that information useful?
  9. There are different extension periods for Tier I versus Tier II.  Should they be consistent?  1 to 2 years?  How would a permit-less system work for extensions?
  10. MassDEP has the statutory authority/obligation/need to implement fees to cover operating costs. How can/should fees should be restructured for sites beyond year 1 if the current permits & tiers are modified/eliminated?
  11. Please provide any thoughts on specific regulatory changes, modification of transmittal forms and/or updates to data tracking/management to improve efficiency, improve the information submitted to DEP, improve the quality of the work, etc.  THINK BIG
  12. And what about Special Projects?
Questions for us? Please comment here on the MCP Reg Reform Blog!