CDM Report Deficiencies
The following are the contents of the slide shown briefly at the end of the PIP meeting. It lists a portion of the technical deficiencies of the RAO as submitted by the consultant (``technical deficiencies'' is the formal way of saying ``reasons why the approach taken is not legally sufficient'').
LEGAL REQUIREMENTS ESTABLISHED BY THE MASSACHUSETTS CONTINGENCY PLAN THAT WERE NOT MET BY THE AUGUST 2001 RESPONSE ACTION OUTCOMEThe law requires that the full extent of contamination, both vertical and horizontal, be delineated in all media 310 CMR 40.0835 and 40.0904
The law requires that the Tail Race and Mill River be sampled and characterized because of their proximity to areas of contamination. 310 CMR 40.0904
The law requires that the potential impact to wetlands be fully characterized via a process called a Method 3 risk characterization. 310 CMR 40.0942 and 40.0990
The law requires that contaminated soil be placed entirely on a base of impermeable material, and that it not be stockpiled in an environmentally sensitive area 310 CMR 40.0036
The law requires that cleanup efforts continue until the applicable standards have been met 310 CMR 40.1003
The law forbids the implementation of an AUL (aka deed restriction) in lieu of meeting applicable standards. 310 CMR 40.1012(4)
10/24/2001
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