Re: [CPEO-MEF] GOCO Facility

[doobage@localnet.com]

Dear FM

Without the details of the new tenant's situation I would like to offer the 
following:
1) Assumptions - the new tenant has leased the property. Sounds as if the 
GOCO folks, aside from the EBS, have not informed the new tenant of
location of contamination; the EBS probably has not provided that
information; under the Finding of Suitability to Lease (FOSL), the GOCO
folks should have some type of institutional control which would warn the
new tenant of possible contaminated
areas. The new tenant is proposing a sampling program, only to satisfy
himself/herself, and is under no order on consent with the environmental
regulators. The remainder of the GOCO property is under a Superfund
investigation.

2) If the tenant is just curious of the location(s) of contaminants, he/she 
should be free to sample and analyze in whatever manner comes to mind.
After all, this work is to be done using his/her resources. Ex. - A trowel
could be used to obtain a soil sample and just by smelling the off-gas, one
could determine that a petroleum spill had occurred; or assuming that
toluene was spilled, a Draeger tube could be pushed into the loosened soil
and the color scheme would provide gross values of the off-gas; or with
enough money a soil sample could be sent to an off-site laboratory with a
request for analysis - such an analysis could be any ol' method that
springs into the chemist's mind, as long as the method is accurate and precise.

3) Because the remainder of the property is under a CERCLA investigation,
the Army's contractor is required to follow the CERCLA protocols laid down
by the USEPA. In arriving at these protocols, USEPA chose certain sampling
and analytical methods, chain of custody (borrowed from our legal
brethrens), holding times for samples, redundancy of laboratory
instrumentation, instrumentation
calibration techniques and frequency, tons of paper work to mention some of
the hoops to be jumped through. I think the chief reasons were to ensure
court-acceptable data and uniformity in the Superfund program. But this
does not mean that other sampling and analytical methods, not specifically
required by the CERCLA protocols, are no good - they can be and are as good.

4) So, if the new tenant foresees the time when he/she will "hold
discussions" with the deep pockets or GOCO folks, it would be to his/her
advantage to go the full CERCLA methodology. If it merely curiousity, other
inexpensive methods are out there - just check with a good lab.


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