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 ________________________________ 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

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

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

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)

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

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

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