[CPEO-MEF] GOCO Facility

[fmolloy@techlawinc.com]

I'm working on a government-owned contractor operated (GOCO) facility in
which there has recently been a change in tenants.  Contamination at the
facility is being investigated under CERCLA.  The new tenant is proposing to
obtain samples following an Environmental Baseline Survey (EBS) to get a
handle on exactly where the problem areas are located.  Since contamination
at the facility is being under CERCLA, does the new tenant have to follow
the same procedures that the Army's contractor has to follow to obtain
samples, e.g., submission/approval of work plans/sampling plans, validation
of data, etc.?  In other words, does the new tenant have to follow the
CERCLA process?

Any enlightenment on the subject would be appreciated.

Thanks,

Fred Molloy
TechLaw, Inc.
6901 West 63rd Street, Suite 407
Overland Park, Kansas 66202
(913) 236-0006
fmolloy@TechlawInc.com


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