This year, we're again focusing on Remedy Operation Status submittals. However, this time, instead of reviewing the Phase II at home, and the Phase III, IV and V in class, we're providing a selection of the reports we have in our files (yes, there are more!) and asking you to approach this as if you were a DEP auditor, with a couple of hours to briefly review the case before making some determinations about the effectiveness of the remedy.
Included in the documents uploaded for the "homework" are several (partial) reports from our files for the case:
- Phase II Comprehensive Site Assessment file size 3MB
- Phase III Remedial Action Alternative selection
- Acme Site Plan
- Immediate Response Action Completion Statement and Phase IV Comprehensive Response Action file size 1MB ; and
- The Remedy Operation Status reports file size 3MB that led to the findings you will receive later.
Let us be clear that we don't expect all LSPs will review all of these documents in the "hour's" worth of "credit" time for doing the homework. That being said, we leave it up to you to play auditor, and decide:
- Is the ROS a sufficient "stand alone" document that helps you to determine whether or not the remedy is working?
- If so, what can you determine about the remedy (i.e., working/not working)?
- If not, what additional information will you likely review to make decisions about the ROS?
- If you are unsure whether the ROS is "working" or not, what is "missing" or "unclear"?
- If you can't review all the documents, what documents will you review?
- Are there things you would add to the ROS report without recreating all previous documents?
SUGGESTION: Some LSPs may want to focus their review on ONE document for purposes of the in-class discussion. If you choose to do this, you will then become the "expert" on that portion of the file.
As with last year, each LSP must present the written portion of the homework at registration before the class. The LSP Board has said no partial credit may be given for the class.
The discussion in class will focus on the documents/discussions between DEP and the LSP/PRP that were generated during the audit of this ROS.
It should also be noted that the homework documents will NOT be redistributed in class so you should bring whatever documents you need from the homework. There are no additional maps or site plans.
Remember, the purpose of this training is to foster better understanding of what is involved in a MassDEP audit. Please do not hesitate to contact Lisa.Alexander@state.ma.us or Susan.Fessenden@state.ma.us if you have any additional questions regarding the reading or written "assignment".