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r 1 Memo From the Desk of RON ROWE To: Steve Sasson , Date: 9-16-96 Subject: Safeway Site, 1111 Navy Drive, TRC Comments Response to Site Contact Regarding Closure Deficiencies In accordance with Corrective Action Regulations the site assessment phase and Corrective Action Plan are incomplete. A mass volume calculation is warranted at this and all sites where residual contamination is proposed to be left in place which poses acceptable risk to ground and surface water use, human or ecological receptors (general health and safety). To complete the closure request the RP must propose a Corrective Action Plan(CAP)with alternatives,their costs and technological feasibility, ' this may include natural attenuation, presented for the record. This CAP must also satisfy the conditions of plume definition and stability with accurate and representative data. If work performed in the past has effectively defined and remediated the site reducing or eliminating risk to an acceptable level, no further site data acquisition should be required, it becomes necessary at this stage only to re-evaluate and compile data on paper providing a sound closure document. In the event the data obtained previously is not comprehensive or defensible additional data from the site may be required. If the RP can provide information indicating that contaminant distribution on this property is the result of a third party action, past or present, have this documented appropriately in order to address that entity with regard to Corrective Action. In summary, soil and groundwater definition including residual mass is required, plume stability must be evident, a risk assessment within the CAP or closure request is advised, and evidence that additional and reasonable work at this site will not significantly further reduce risk is necessary to bring final closure to this site.