SITE INFORMATION AND CORRESPONDENCE_FILE 1

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n ivaiye 11:33 UST CLEANUP FUND j 912094640138 r. N].910 907 George Lockwood State Water Resources Control Board January 26, 1996 Page 6 0 On May 4, 1495, Mr. Infuma and Ms. Hinson sent a letter to Mr. Langston with some critical comments regarding the work done by WHF. The issues raises] in that letter were disputed by Mr. Fox, but the LOA's letter of May 4, 1495 does state that: "In order to ensure there are no delays in your proposed site work (over-excavation)..." These documents set the record straight. The LOA, specifically Michael Infurna and Diane Hinson,approved in writing not once but several times the Remedial Excavation Work Plan and Executive Summary submitted to them by WHF. Their efforts to deny these facts are simply, transparently, ineffective. Their motivation for doing so is unfathomable. The LOA's approval of the Remedial Excavation Work Plan should put an end to the discussion,but your Payment Summary also raises the issue of whether there was a feasibility study to determine whether or not excavation was a proper remedial action. The IAA was satisfied that excavation was proper. Preliminarily on this is ue,it would seem that you are predisposed to believe that excavation was not appropriate and that in situ remediation would somehow be more cost effective tluui or achieve similar results to, excavation. Michael Notmoyle of Notmoyle & Newman spoke with you several weeks ago, and he reports that you expressed an opinion that the Langston site would be "ji]deal for vapor extraction." If you have information not known to the Langston'consultant on this issue, you are urged to share it. Given the fact that there was groundwater contamination and a secondary source of groundwater contamination (a level of primarily silty/clay soil)at approximately 16 feet below grade,this opnnon,if property attributed, is remarkable. Predispositions aside,attached hereto as Exhibit 'D" is a narrative from► William Fox which explains the rationale for excavation and the reasons why vapor extraction was not an option. As to your inquiry regarding a feasibility study, there was no feasibility study prior to excavation because the work dote at the Langston property was characterized as "interim" by the LOA. Further,herring logs,soil types, and other known conditions at the site caused the experts involved, including LOA overseers, to dismiss in situ remediation as a cost effective, viable alternative. The result of in situ remediation would have been speculative at best. Not studies were neither justified nor cost effective. However,now that the sours„has been removed and reliable data is available,such a study can be effectively performed- The experts are hopeful that due to the success of the interim excavation work and water treatment, they may be able to justify closing the site with no further remediation work.