Response to Mather Early Transfer

[WJASmith <WJASmith@aol.com>]

I have grave concerns about any transfer for a groundwater pump
and treat system for chlorinated organics. The National
Resources Council has concluded that only under very limited
circumstances are those systems effective at removing the
source. Mainly, the systems function to contain the source and
must be kept operating indefinitely.

The National Resources Council has also concluded that sites
clean up almost as fast (e.g. decades to centuries) without pump
and treat as with it. Therefore they recommend that pump and
treat only be used when containment is necessary. As noted next,
I also recommend a miniature version of pump and treat when more
reliable characterization of the extent and distribution of
contaminants is required.

The best way to characterize subsurface contaminantion is with a
pump and treat system. After two years of operation,
understanding of the distribution of subsurface contamination
will be much better than can ever be had with static sampling.
Pump and treat systems will reveal the presence of small pockets
of pure contaminated fluid that are easily missed with random or
grid sampling on 40 foot by 40 foot by 40 foot 3-dimensional
grids.

I suggest that those who are willing to risk complicating future
remedial action by allowing early transfer of property, at least
consider allowing the transfer to occur only after the remedial
system has operated long enough, generally two or more years for
pump and treat systems, to show that the system is effective.
Even so, I'm more comfortable with long-term leases of 50 or
more years that with outright transfer.

Lenny Siegel
Director, SFSU CAREER/PRO (and Pacific Studies Center)
c/o PSC, 222B View St., Mountain View, CA 94041
Voice: 650/961-8918 or 650/969-1545
Fax: 650/968-1126
lsiegel@cpeo.org