SITE INFORMATION AND CORRESPONDENCE_1985-1997

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Mr. Theodore I. Wittmayer, Attorney at Law January 2", 1993 Stone Brothers and Associates Page 3 Adequacy of the Phase V Work Plan As demonstrated by the EHD's response to the Phase V work plan, the original plan did not propose an adequate soil and groundwater investigation on the site. In particular, the work plan did not address the presence of high TPH concentrations in boring B-9 and their possible impact on groundwater. As most of these issues have been addressed in the amendment to the work plan, WESTON's review will focus on the amendment. Adequacy of the Amendment to the Phase V Work Plan The work plan amendment issues may be divided into facility abandonment issues, soil investigation issues and groundwater investigation issues. Each of these is addressed below. 1. Facility Abandonment The facility abandonment issue consists of the need to properly abandon certain facilities or structures associated with , lre operation of the former gas station which are still present on the site. In WESTON's opinion, the presence of the product piping and the subsurface concrete slab on the site could create a futureenvironmental liability for Stone Brothers. As a result of the EHD's letter~,/Ward has agreed to remove the product piping and stated that it is in the process of selecting a contractor to conduct the work. Stone Brothers s ould be assured by Ward that the product piping will be completely removed and disposed in a manner which frees Stone Brothers of future liability. The EAI work plan amendment states that "in as much as the concrete slab is not a hazardous waste, Montgomery Ward does not intend to remove the slab." This statement appears to be premature because to the best of WESTON's knowledge, the concrete slab has never been sampled or tested for presence of hydrocarbons. If there was a release from the former UST situated above the slab, it is likely that the slab could be impacted by hydrocarbons and therefore potentially hazardous. WESTON recommends that the concrete cuttings from the boring through the slab be field screened with the air monitoring device to determine whether the slab has been impacted by hydrocarbons. If field screening indicates hydrocarbon presence, the concrete cuttings should be analyzed for TPH-G. If soil beneath the slab is found to contain hydrocarbons, it should be assumed that the slab has been impacted by hydrocarbons and the slab should be removed and disposed in a proper/manner. Regardless of the findings of analyses in or beneath the slab, it is WESTON's opiffion that the slab should be removed in order limit Stone Brother's future liability for the presence of a structure which is so closely associated with the operation of a former UST. STKCIR MWrrM"1."