Comment
Under the Proposal Details, in Part B. 1. the document states that "The QP has confirmed and documented evidence from the Phase One ESA that the site restrictions in A, do not apply to the RSC property"
This should be revised to state that
"The QP has confirmed and documented evidence from the Phase One ESA that the site restrictions in A, do apply to the RSC property"
In Part B. 3. If VOCs were not identified as a COC in the Phase One ESA, then no testing for VOCs would normally occur. I would revise this to read
"Confirmed through sampling and analyses that the concentrations of VOCs in soil, if identified as a COC in the Phase One and Two ESA, and subsequently tested, met applicable SCS."
OR alternatively, introduce mandatory soils VOCs testing as a condition of not testing groundwater on sites where there is no soil and under key conditions.
Submitted December 12, 2019 9:58 AM
Comment on
Amendment to the Record of Site Condition (Brownfields) Regulation related to the Requirement to Sample Ground Water
ERO number
019-0987
Comment ID
38003
Commenting on behalf of
Comment status