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I 1994, with the CVR.VNQ .B A letter was"sent by D1.A describing the planned operation. ;Its . 12Cuss telephnned�\TO after the meeting and said that air purging was prcferrrcivunlis.s...-t�-e� water to be uscd� first tested for contaminants . At tine date of wri ; , ng this docurnent , the work had not yet been done. DISCUSSION OF PAST ACTIONS Although JTO took a number of actions, 50;110 without DHS prior approval and some without them being witnessed by registered personnel , the writer (DILA) believes that they made an honest effort to clean up the polluted soil at the !SC Winnery Site. This opinion is based on the documentation supplied herein and the willingness of JTO to do whatever is required to achieve per- mission to undertake a soil remediation program and ultimately to refill the pit and restore the surface. Also, in almost every case, they made an attempt to have their operations witnessed by the DHS and/or performed by a certified laboratory. SITE ASSESSMENT Based on the sampling and testing of soils, pit water, industrial wells water and monitoring wells water , inspection o:` the. spoil piles and the partially refilled excavation, it is bef"eved by the writers that all contaminated soil has been removed; however , . This is not an absolute, provable judgement at "this time, owing. to the partial refilling of the excavation. GTI , in their report of 5/25/1988, page 16, of Appendix A-7, stated that "Groundwater conversely has not been impacted accord- ing to the most recent laboratory results. The viscous nature of the hydrocarbons present within the underground storage tank have apparently impeded migration through the sandy soils underlying the site. " As an amplifiction of this statement, it appears that the viscos- ity and specific gravity of the first-leaked fuel were high, as compared to that leaked a1 a later time. Because of its high viscosity and high surface tension. migration probably stopped when the viscous oil reached the mater table, and perhaps formed a barrier to further penetration of later-- leaked fuels. At that point , leaked fuel migrated laterally, forming the tear-dropped shape described in the earlier quote from 3TC. All of the testing done subseq.:nt to the GTI evaluation has only affirmed their statement to the effect that groundwater has not been impacted: although the lateral extent of the contamination ._.._.__tn.._..the-..vados_e_.-z_one. was. 0.r.dbab1 `. reater than they anticipated. GTI made four recormnendtions in their cover letter for their re- port of 5/25/1988 . The first three refer to determining the extent .of contamination and removing contaminated soil . This has 13