more on off-post sampling

[Marsden and June Chen <doobage@localnet.com>]

In the early days of Superfund, the regulators used to stick to the
requirement that the remedial investigation should
identify the areal and vertical extent of the contamination., because
Superfund defines the source as the extent of the
contamination. Very slowly with all of the Line of Compliance language
in RCRA , the unrelenting whining of the
PRP's and the half-baked jobs that the USEPA and most of the States are
inclined to follow and accept, we now find
that the program requires sampling in a short space beyond the suspected
source of contamination. Therefore, after the
source is identified, an agreement will be reached that downgradient
sampling should include only a couple or three
ground water wells (limiting comments to GW), - the argument being that
Superfund investigation is an iterative
process, and after the first phase of investigation and contaminants are
defined, another set of wells will be constructed
and so on. Iterative, my foot! 

That is the situation you now face and it requires a strong Division
Director or better, some real civic activists or
sympathetic or seeking-the-vote politician to beat this back.