LSPA Comments on 2009 Indoor Air Workgroup Progress


Carl Shapiro, LSPA President, and Wesley E. Stimpson, LSPA Executive Director, provided a comment letter to MassDEP on the progress of the Indoor Air Workgroup on June 17, 2009.  Attached is a PDF copy of the comments:  Letter_to_MassDEP_on_Indoor_Air_Workgroup.

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One Response

  1. Dear Mr. Shapiro and Mr. Stimpson:

    Thank you very much for your letter of June 17, 2009 on behalf of the Licensed Site Professional Association (LSPA), regarding LSPA comments relating to MassDEP’s development of Indoor Air Guidance. I agree with many of the main points of your letter, and can assure you that as we continue to work toward our goal of identifying up-to-date, health-protective assessment and remediation practices and methodologies for vapor intrusion cases, and articulate MassDEP’s regulatory interpretations, we will take your issues and concerns into consideration. We intend this guidance to help the regulated community, including your constituents, understand how to meet regulatory requirements and reduce some of the uncertainty inherent in this complex exposure pathway.

    I would like to encourage you and other LSPA members to continue to participate in the guidance development process, either in person at workgroup meetings, or via written comment. The workgroup now stands at over sixty Licensed Site Professionals (LSPs), environmental attorneys, laboratory managers, risk assessors, engineers, geologists and MassDEP staff. Seventeen workgroup and sub-group meetings have been held since December, giving everyone multiple opportunities to discuss their opinions on the topics to be covered by the guidance document. Additional meetings will be scheduled beginning in September and continuing through the fall.

    For those who are unable to attend all those meetings, input can also be given via the indoor air “Blog”, on which we will continue to post draft sections of the documents as they are prepared, or to a separate Vapor Intrusion e-mail account (in the process of being created) for those who do not wish to post comments on the blog. A consolidated, updated draft was posted to the blog on July 7, 2009. Members of the LSPA are strongly encouraged to submit comments and concerns directly to MassDEP by one of these means.

    On a separate but related note, I would like to thank LSPA for conducting its recent independent review of 89 Notices of Audit Findings on indoor air cases, and also personally thank Wes Stimpson for his even-handed presentation of the results of that review at LSPA meetings in May and June. I was encouraged to hear that LSPA found that MassDEP had consistently used sound engineering, scientific and regulatory principles in our review of submittals relative to vapor intrusion issues, and that LSPA felt that we had not been overly prescriptive in directing the manner in which investigation and mitigation actions should be conducted. It seems to me that this positive result should go a long way towards reassuring you and your membership that the guidance we are developing will also be reasonable.

    MassDEP will continue to work in an open format with LSPs and other program stakeholders, and we will strive to provide specific information and data to support our positions. I am confident that our efforts will result in a guidance document that is clear, consistent with practices recommended by other regulatory entities, and protective of human health.

    Thank you for your interest in this important and challenging issue. MassDEP looks forward to working with you and all members of the LSPA in finalizing this guidance document. If you have any questions, or would like to discuss this with me further, please call me at 617-556-1121.

    Sincerely,

    Janine Commerford
    Assistant Commissioner
    Bureau of Waste Site Cleanup

    Download a PDF version of MassDEP response letter.

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