Update:AUL Guidance Revisions

October 23, 2014

Peggy ShawWorkgroup Chair

1

Process for Finalizing Guidance

• Public Review Draft released June 2014

• External meeting July

• Expecting additional comments

• Additional meeting date(s)-TBD

2

Consistency with other Policies

• VI and LNAPL

• Section 1.5 states that barriers must in place prior to AUL implementation

• Section 2.6 – subsection describing indoor air as a medium?

3

Voluntary AULs vs. Non-AULs

• Section 1.6

• Voluntary AULs allowed pursuant to 310 CMR 40.1012(3)

• Non-AULs are other recorded documents not regulated by MCP

4

Sketch Plan to Delineate Multiple Barriers

• Section 4.3.6• Previous policy required a survey plan when

individual barrier restrictions are different• Current draft allows delineation on the sketch

plan, but must be accurate and provide adequate detail

• Related comment: clarify when NEW survey plans are required

5

Form 1075 Issues

• Permanent Solution/Temporary Solution language and ROS

• Language in parenthesis (e.g., Exhibit C)

• Exhibit E: Signatory Authority

6

Sequence of Signatures on AUL

• 310 CMR 40.1074(2)(m) and Form 1075

• Must owner’s signature precede LSP’s signature?

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