Comment
1) It is unclear how the QP will demonstrate that contaminants have not migrated from soil into groundwater at concentrations in exceedance of applicable standards.
2) The regulation does not appear to address contaminants that have migrated offsite.
3) It is unclear who is responsible for reviewing and ensuring compliance with the required documentation and considerations of the QP.
4) It is unclear who has the authority/responsibility to address adverse effects in the event groundwater is contaminated after the professional determination of the QP is made.
Submitted January 13, 2020 3:36 PM
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
40149
Commenting on behalf of
Comment status