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Massachusetts Waste Site Cleanup Program _________________________________

Massachusetts Waste Site Cleanup Program _________________________________. Privatized program since 1993 Direct oversight of only the highest priority sites Reliance on LSPs Implement an audit program. Common Violations Cited Relative to Site Characterization ________________________________.

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Massachusetts Waste Site Cleanup Program _________________________________

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  1. Massachusetts Waste Site Cleanup Program_________________________________ • Privatized program since 1993 • Direct oversight of only the highest priority sites • Reliance on LSPs • Implement an audit program

  2. Common Violations Cited Relative to Site Characterization________________________________ • Failure to define horizontal and vertical extent of contamination • Scope and level of effort of site characterization not commensurate with complexity of disposal site • Failure to develop a Phase II SOW or adequate SOW • Failure to identify all existing or potential migration pathways • Failure to identify exposure point concentrations • Failure to identify receptors, site activities and site uses

  3. Common Violations Cited Relative to Site Characterization; cont’d_________________________________ • Failure to collect, develop, evaluate, and discuss the finding and conclusions of the Phase II CSA • Failure to identify human receptors • Failure to identify environmental receptors • Failure to conduct a Stage II Environmental Screening when indicated

  4. Message From LSPA to Members: Summary of Frequently Cited Violations_________________________________ • Insufficient testing of soil and gw to delineate the nature and extent of site boundaries, both within source areas and down gradient • Failure to cross property lines to determine the extent of contamination • Insufficient frequency of testing rounds to assess gw quality fluctuations

  5. Message From LSPA to Members: Summary of Frequently Cited Violations_________________________________ • Inadequate evaluation of the migration to air/indoor air pathway (e.g. lack of soil gas or air testing) • Failure to clearly define and identify exposure points, to clearly calculate EPCs • Inadequate or unclear maps (clear and accurate delineation of the site boundaries)

  6. Discussions with DEP Staff: Primary Issues of Concern_________________________________ • Inadequate characterization of nature and extent of contamination • Inadequate determination of horizontal and vertical extent of contamination in soil and gw • Reluctance by PRPs to allow LSPs to track contamination off-site • Inadequate characterization of LNAPL sites

  7. Discussions with DEP Staff: Primary Issues of Concern; cont’d_________________________________ • Indoor air impacts not being evaluated sufficiently (site specific info not being developed or used) • Impacts to private wells not being evaluated • Contaminant fate and transport not being evaluated sufficiently

  8. Efforts to Help Improve the Quality of Site Characterization_________________________________ • Conceptual Site Model Training • DEP/LSP Case Study Discussion Sessions • Highlighting frequent problems through LSPA • Exploring other mechanisms for outreach

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