News Asbestos Other Contaminants Regulations

IQHQ’s Required Environmental Process Filings, Summarized on March 1, 2021

At ASG’s request, Jennifer L Sweet, P.E., LSP (MA), Senior Associate and Program Manager at Haley & Aldrich, wrote this March 1, 2021 summary below of required environmental process filings for the IQHQ site. Thank you, Jen Sweet!

The Former WR Grace Disposal Site (RTN 3-0277) went through the comprehensive response action process under the Massachusetts Contingency Plan (MCP – 310 CMR 40.0000) in the past which resulted in regulatory closure in 2006 in the form of a Permanent Solution Statement with Conditions (Conditions being implementation of an Activity and Use Limitation (AUL)).

In accordance with the MCP (Massachusetts Contingency Plan), after the submittal of a Permanent Solution with Conditions in an area with an AUL (Activity and Use Limitation), response actions shall be conducted as a Release Abatement Measure (RAM).  The RAM will be limited to the portion of the Disposal Site where response actions are being proposed for redevelopment with purpose of managing contaminated media during construction.  Therefore, a RAM Plan will be prepared and submitted to MassDEP Bureau of Waste Site Cleanup prior to soil disturbing construction work.

Since the RAM Plan includes management of soils containing asbestos, a Non-Traditional Asbestos Abatement Work Plan (NTWP) (310 CMR 7.15) will also be prepared and submitted to MassDEP Bureau of Air and Waste.

The NTWP will be prepared by a Certified Asbestos Project Designer.  Additionally, as set forth as Obligations of the AUL, a Soil Management Plan, contractor Health and Safety Plan (HASP), and Airborne Asbestos, Dust, and Odor Management and Monitoring Plan will be prepared prior to construction.  These plans may be submitted as part of or as an attachment to the RAM Plan.

These plans will be provided in draft form for public review and comment in accordance with the Public Involvement Plan for the Site.