Emergency Spill Response Management
CSE provides assessment and oversight for contractors responding to leaks, spills, and releases of oil and hazardous materials (OHM). These could include anything from an oil, hazmat or diesel fuel spill, to a chemical fire or natural disaster. Typical situations requiring emergency response include roadway releases, surface spills, pipeline leaks, and storage tank (AST/UST) ruptures. We maintain relationships with several emergency response dispatching companies such as Cura Emergency Services and Emergency Response & Training Solutions (ERTS). Additionally, CSE has several emergency response contractors ready to respond to a spill, while we maintain compliance with the MCP.
Pipeline / Storage Tank Releases
Contractor Oversight and Sampling
- Assessing the extent of the release and affected areas;
- Determining and delegating response actions;
- Performing field screening and environmental sampling;
- Selecting and submitting samples to be laboratory analyzed;
- Performing a risk characterization;
- Preparing the Permanent Solution closure report and associated documents to be submitted to the MassDEP.
All CSE personnel are 40-Hour Occupational Safety and Health Administration (OSHA) Hazardous Waste Operations and Emergency Response (HAZWOPER) certified. CSE completes a broad range of response actions required for both simple and complex OHM releases with a cost-effective and innovative approach to remediation in accordance with current and potential future site uses. A list of MassDEP recognized OHM can be found on our ‘Resources’ page.
Contaminate Nature and Extent Delineations
CSE has extensive experience with investigating and characterizing contamination of soils and groundwater. Our team has been involved in planning, field sampling and data analysis phases of contaminant investigations at hundreds of sites across the New England region for more than 25 years.
Characterizing the magnitude and extent of groundwater contamination is a challenging task due to the limited locations from which subsurface data can be collected, and to the dynamic nature of contaminant plumes as they migrate and degrade over time. A solid background in geology, soils, hydrology and chemistry, along with applicable regulations and laboratory analysis methods, is needed to successfully delineate contamination. Understanding the nature and extent of contamination is an essential step in determining how best to reduce further impacts and to identify appropriate cleanup approaches.
CSE applies the Conceptual Site Model (CSM) approach, which is a three dimensional picture of site conditions that illustrates contaminant distribution, release mechanisms, exposure pathways, migration routes and potential receptors. The purpose of the conceptual site model is to present an understanding of known and suspect environmental conditions as they currently exist for the Disposal Site. The CSM also provides a basis for evaluating the need for implementing additional remedial actions.
Imminent Hazard Evaluations
The focus of an Imminent Hazard Evaluation is to determine actual or likely exposures within the ground surface, drinking water, or indoor air to human and environmental receptors under current site conditions and the surrounding environment based upon the potential for carcinogenic health effects. Risk Characterizations for Imminent Hazard Evaluations are conducted separately for safety, human health, and the environment, depending on the type of condition that triggered the need for the evaluation. The toxicity information used to characterize risk include reference doses and reference concentrations; and carcinogenic slope factors and unit risk values.
Response to Notices by Regulatory Agencies
The Massachusetts Oil and Hazardous Materials Release, Prevention and Response Act (M.G.L. c.21E) and the Massachusetts Contingency Plan (the MCP), 310 CMR 40.0000, contain the requirements and timeframes for completing the cleanup of releases.
Many clients have reached out to CSE after receiving a MassDEP ‘Notice of Responsibility’ letter, indicating an urgent legal patter and that prompt action is necessary. CSE has help to decipher the legal and statutory liabilities, necessary response actions, and options available. If you have received one of these letters, please review the Massachusetts Contingency Plan (MCP) First Year Compliance Fact Sheet and contact CSE as soon as possible to review your case.
Determination of Regulatory Reporting Requirements
CSE can help to identify whether a release and/or threat of release of oil and hazardous material requires notification to the MassDEP. There are three (3) reportable release notification thresholds according to the MCP:
- 2-Hour Notification
- 72-Hour Notification
- 120-Day Notification
If you have experienced a release and/or threat of release of oil and hazardous materials to the environment, please contact CSE today to determine your regulatory reporting requirements.
Furthermore, a release indicated by the measurement of oil and/or hazardous material in soil and/or groundwater requires notification to the MassDEP if the measured concentration in any soil or groundwater sample is equal to or greater than the media and category-specific Reportable Concentrations in effect on the date of the sample analysis.