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GeoInsighter Spring
1999 Newsletter
Substantial
Release Migration - An Update
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The Massachusetts Department of Environmental Protection (MADEP) recently circulated proposed revisions to the Massachusetts Contingency Plan (MCP) for public comment. Included in the proposed revisions were changes to the definition of Substantial Release Migration (SRM) and a 72-hour release notification requirement. The revision to the SRM definition was included in the current MCP proposed revisions package because the recently enacted Massachusetts Brownfields Act provides a statutory definition for the phrase "Conditions of Substantial Release Migration" and provides that "this section shall be further defined in regulations promulgated by the Department."
The proposed SRM definition reads: "SRM means a release of oil and/or hazardous material(s) that is likely to be transported through environmental media where the mechanism, rate or extent of transport has resulted in or, if not promptly addressed, has the potential to result in (a) health damage, safety hazards or environmental harm; or (b) a substantial increase in the extent or magnitude of the release, the degree or complexity of future response actions, or the amount of response costs."
The proposed revisions to the notification section of the MCP includes a 72-hour reporting requirement if conditions of SRM are identified at a disposal site. This revision was also proposed to address requirements established by the Brownfields Act. However, MADEP did not revise the list of conditions that constitute SRM, including (in abbreviated form):
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discharges of separate-phase product (OHM) to surface water and/or subsurface structures;
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releases that, if not promptly addressed, could result in significant impacts to ground water;
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ground water impacts that are or could migrate more than 200 feet per year;
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ground water impacts that are or could impact a water supply well within one year;
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ground water impacts that are or could be detected in a surface water body or wetland within one year; and
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ground water impacts that are or could produce vapors within schools or homes within one year.
The inclusion of SRM within the 72-hour notification criteria will require that Immediate Response Actions (IRA) be performed at all SRM sites. Four of the SRM reportable conditions require an evaluation of the potential rate of ground water flow across a disposal site and an evaluation of the likely fate and transport characteristics of the constituents of concern present. Therefore, the ability to fully evaluate possible SRM conditions will depend upon collecting representative hydrogeologic information and a good understanding of the magnitude and extent of ground water impacts. However, site conditions that could produce a condition of SRM often require a more detailed evaluation than is typically performed during initial site characterization activities. Additional monitoring wells may be necessary to better define ground water flow; slug tests may be required to better estimate the rate of ground water flow; additional chemical analyses may be required to characterize the behavior of dissolved-phase constituents in ground water; and ground water modeling and soil gas surveys may be necessary to evaluate and predict how far ground water impacts may migrate in a year.
The MADEP indicated that SRM is a component of the MCP that MADEP in general feels has not been fully addressed by the Licensed Site Professional (LSP) and regulated community. The proposed revisions are likely to focus new attention upon SRM and, because the rate of movement through environmental media is not an exact science, result in considerable discussion between LSPs and the regulated community regarding possible notification requirements.
Michael J. Webster
mjwebster@geoinc.com
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