[Edited/updated July 1, 2013.]
There was a Waste Site Cleanup Advisory Committee meeting on Thursday, June 27th from 9:30 am to noon at MassDEP’s Boston Office, One Winter Street, 2nd floor conference rooms A & B.
The first part of the meeting provided general program updates.
We then held a discussion on the public comment received on the Active Pathway Elimination Measure proposal (the proposed changes that provide for a Permanent Solution with Conditions where a sub-slab depressurization system is operated as to prevent vapor intrusion impacts to a building as part of a permanent solution). This portion of the meeting was intended to assist MassDEP in developing the final amendments for this closure option through more focused discussion of the different procedural and technical requirements proposed in the public hearing draft.
AUDIO CAN BE HEARD ON ARCHIVE.ORG:
9:30 am Welcome and General Program Updates
10:00 Topic Specific Discussion of Proposed Amendments related to
Active Exposure Pathway Elimination Measures
as a Permanent Solution with Conditions
Below is a list of discussion topics to be covered:
- While all systems must achieve No Significant Risk, not all systems completely eliminate the pathway. Should we refer to these as “mitigation” rather than “elimination” measures?
- Regulatory vehicle to be used to implement the Active Exposure Pathway Elimination Measure as a Permanent Solution with Conditions
- Permit with AUL, Permit only, AUL only, AUL only with a standardized AUL conditions for operating/maintaining system
- Appropriate threshold conditions/requirements for filing this Permanent Solution with Conditions with an Active Pathway Elimination Measure
- Current proposal (310 CMR 40.0701(4)) does not allow AEPEM as part of a Permanent Solution with Conditions if shutdown for 60 days would constitute an IH condition
- Remote telemetry requirement and related notices to property owners, MassDEP and building occupants
- Appropriate approach to provide parties with notice, deal with multi-unit building notices and avoid alarming building occupants unnecessarily in the case of insignificant events
- Annual certification that system is still running
- Financial assurance requirements
- Costs to be covered
- What forms can it take?
- Discontinuing system operation – requirements/documentation to demonstrate system is no longer necessary
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