Summary of FY 2013 NOAFs Concerning Downgradient Property Status Submissions The annual review of MassDEP Notices of Audit Findings (NOAFs) conducted by the LSPA's Loss Prevention Committee included a review of audit findings for five sites with Downgradient Property Status (DPS) submissions. The following is a summary of our review. Only one of the five DPS submissions was deemed adequate by MassDEP. At that site the contamination was discovered during a Phase I Environmental Site Assessment, and the property owner submitted the DPS Opinion two days after filing the Release Notification Form. The property owner identified a known upgradient MCP site as the likely source. The other four DPS submissions examined each resulted in MassDEP's issuance of a Notice of Noncompliance with the NOAF. Three of the four also terminated the DPS; the fourth required either a termination of the DPS or a revised DPS Opinion. All of these NOAFs concluded that there was insufficient information provided in the DPS submission to support the conclusion that the source of oil or hazardous materials was located on an upgradient property and had migrated in or on groundwater. The practice tips from review of the DPS submissions are as follows:
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