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• • Page 2 of 5 good answers to these questions and a favorable status of current gw concentrations (data) helps. Show a trending downward of the COCs and you definately put your site in contention for NFA consideration. A fully characterized site is a MUST (lateral and vertical soil and ground water delineation). A conceptual understanding of the plumes only supports consideration and eases evaluations. If this all sounds favorable, address the potential for soil vapor to migrate and you're done if it passes the ESI-s. if not, there are some other ways to gently 'get around them'....again, soil vapor sampling is NOT required if the potential for intrusion is adequately 'addressed..... Future slte usage has allowed some sites (still active gas stations, auto repair, petroleum usage, etc) to get a NFA leaving much more soil and vapor in place unremediated. This site, based on the new owner usage, may qualify. The more yuk you plan on leaving in, the more 'addressing' your big PG, Ph.D.'s, CEGs, and CHGs have to do. so YES, there could be a way to get the site closed with out doing the remediation. For this site it may be a stretch, but Ray and Tamorah are smart cookies. IF there's a way, they should find it. That's why you have hired geo-GUNS---- to eval sites and convince regulators. so what to do? the biggest helpful thing I see for you to do is to get the Geoprobes in. Get the soil data (not necessarily in report format) correlated, add some cross- sections, iso-cons, some maps and get ti to me. we'll get back to you ASAP. Throw in some discussion of residual mass, potential migration of vapors to the public or leaching to gw, ESLs, land use, aquifer risk, data history, trends, time estimates and Water Quality Objectives. If you plan on NFA consideration, these concerns will eventually have to be addressed. Think maybe putting in a few soil vapor probes NOW while you're out there. could help with 'addressing' later on and save another mobe. The financial/political winds lately are changing. Big pushes to get UST sites CLOSED. what used to make you drill more 5 years ago would make you do it today, assuming the data is current. We're not allowed to DIRECT the RP until the site is 'reviewed'...just what constitutes a 'review', no one knows yet. you wanna do work, we're told to approve if at all possible. you want closure, address residual....estimate when it'll be clean on it's own... last estimate of 50 years was acceptable for one site... go figure.? so go ahead and work yourselves right out of a job/company.....close em all.......... I just do what I'm told. From: Jenny Weese [maNto:JennyW@gtienv.com] 5/71/�fl(19