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Changes Coming to Telemetry Registration Process in the Massachusetts Contingency Plan (MCP)

Changes Coming to Telemetry Registration Process in the Massachusetts Contingency Plan (MCP)

Sub slab depressurization systems (SSD Systems or SSDSs) in Massachusetts require telemetry systems to communicate with system owners and the Massachusetts Department of Environmental Protection (MassDEP). This requirement is relatively new (2014) and MassDEP has been working cooperatively with the Licensed Site Professional Association (LSPA) to ensure that the regulations are effective, workable, and compliant. Cooperstown Environmental LLC is helping to lead the way in developing these new rules.

Last fall, Isaac Anderson of Cooperstown Environmental LLC, working through the LSPA Technical Practices Committee and in conjunction with MassDEP, created and distributed a survey to LSPs. The purpose of the survey was to find out how environmental practitioners are implementing the newly promulgated telemetry requirements since the requirements were incorporated into the Massachusetts Contingency Plan (MCP) regulations. MassDEP has used the findings of this survey, in part to refine the telemetry device registration process.

EFFECTIVE FEBRUARY 1, 2016, based on the survey results, MassDEP has implemented a revised registration process. The new process adds steps to confirm that new telemetry devices, at the time of registration, are able to meet necessary the communication requirements. The new rules require that:

  1. the devices communicate by either text message or email (new voicemail systems will not be accepted);
  2. the devices be capable of providing notifications upon shutdown and upon restart; and
  3. the notifications be made in a format and sequence that MassDEP can retrieve (formatting/sequencing specifications are provided on MassDEP’s the webpage).

As part of the new registration process, MassDEP now requires that the registrant conduct a system shutdown and restart test to demonstrate that the device notifications are occurring properly. MassDEP will notify the registrant by email, on the day of the test or next business day, as to whether the test was successful, and if all is well, the registration will be considered complete.

For those devices registered prior to February 1, 2016 (54 systems at 36 sites at last count), MassDEP has been contacting the operators of those systems to confirm their proper operation. In cases where devices are not meeting the communication requirements, including providing both shutdown and restart notifications, MassDEP is working with those operators to bring the systems into compliance. Note MassDEP will “grandfather” voicemail devices registered before February 1st provided they can meet all of the other device communication requirements.

For more information on this topic, please contact Isaac Anderson (isaac@cooperstownenv.com). The text of an article on this topic, which was originally published in the LSPA’s February newsletter, can be read here, after logging in to your LSPA member account.

To learn more about the telemetry device registration process, see MassDEP’s telemetry registration webpage:  http://www.mass.gov/eea/agencies/massdep/cleanup/regulations/remote-telemetry-information.html

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