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Vapor Instrusion Update
You probably read our article on Vapor Intrusion in last week's newsletter. At that time, GEC reported that the MADEP was planning to release their comments and a final version of the policy in September. GEC learned today that the meeting has been rescheduled for the end of October. We will update you about MADEP's comments at that time. |
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MCP Audit Update
The laws covering audits of waste sites and properties with Activity and Use Limitations (AUL) recently changed. Under the Brownfields Act and Chapter 21E, the MADEP was required to annually conduct audits of at least 20% of the waste sites and all of the properties with AULs. In July 2011, as part of the "Outside Sections" of the state budget, the laws were amended and now state that only a "statistically significant number" of these disposal sites need to be audited. No longer must every site with an AUL be audited within a couple years. This appears to be a result of budget cuts and an attempt to stretch the MADEP's budget to other areas of the agency. Although the likelihood of being audited by the MADEP may be reduced, it is important to remember that the auditing program remains. You need to ensure that you are managing and maintaining your property in accordance with the terms of the AUL conditions in place at your property and that you continue to remain in compliance with the regulations.
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