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r <br />Page 1 of 1 <br />V �! <br />Nuel Henderson [EH] <br />From: <br />Nuel Henderson [EH] <br />sent: <br />Tuesday, November 02, 2010 3:38 PM <br />To: <br />'Kirk Larson' <br />Cc: <br />Vicki McCartney [EH] <br />Subject: Five -Year Review Recommendations for 2651 Airport Way Claim Number 2429 <br />Kirk, <br />Thanks for giving me an opportunity to comment on this site after the initial 45 -day comment period. <br />The EHD had reviewed this site for closure consideration in January of this year, and found there are some good <br />reasons to be favorably disposed to site closure; specifically: <br />Sorbed and dissolved plumes appear to be adequately delineated; <br />Dissolved concentrations in outboard wells appear to be declining; <br />Much of the surrounding area is in industrial use; and <br />Modeling predicts limited plume migration and eventual reduction to background levels. <br />The EHD also identified potential issues not favoring immediate site closure: <br />Very high TPHg concentrations in several core area wells do not exhibit significant, sustained declining trends of <br />the last three years and only minimal decline over the last ten years; <br />Benzene concentrations in PZ -1 have remained high for the last ten years; <br />There are several residential lots nearby, one residential structure within 500 feet of the former UST site; and <br />There are twodomesticwells within 600 feet of the former UST area. <br />The EHD has recently approved a pilot test to evaluate insitu chemical oxidation using modified Fenton's <br />Reagent. <br />In view of the persistent high dissolved TPHg and benzene concentrations in the core area, the presence of <br />domestic wells within 600 feet of the former LST. area, and the very long time frame estimated to be required for <br />natural attenuation to reduce the contaminate concentrations to background levels, the EHD believes it would be <br />prudent to attempt some mass reduction in the core area to accelerate the overall rate of return to background <br />conditions. <br />The EHD believes that the CLIF recommendation of April 2008 is still valid. <br />Nuel Henderson <br />8/16/2011 <br />