May
20
All thirteen of the FY'19 audit findings pertaining to Nature and Extent (N&E) reviewed by the LSPA's Loss Prevention Committee (LPC) resulted in Notices of Noncompliance (NONs) issued to Responsible Parties. Permanent Solutions or Response Action Outcomes were invalidated by MassDEP in two cases. The NONs related to ten Permanent Solution Statements/Response Action Outcomes, one Permanent Solution with Conditions, one Temporary Solution, and one Phase IV submittal.
MassDEP referenced deficiencies in the following areas:
- Application of Conceptual Site Models (CSM),
- Definition of disposal site boundaries,
- Incomplete data sets and scope of investigation, and
- Insufficient information to support risk evaluations.
For more details, read the article by Jim Begley, LSP of MT Environmental Restoration and an LSPA Loss Prevention Committee member.
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