This will be formally referred to as the Limited Phase II ESAs. These ESA's were prepared for the properties to be acquired by the Agency for the proposed Commons Park. An ESA was completed on each of the eighth sites (34, 35, 36, 37, 44, 45, 46, and 49).
During the Phase II process it was realized that there was not sufficient grant funds to complete standard Phase II assessment for petroleum product, hence the reference to "Limited". Essentially, enough subsurface investigation was conducted to determine whether or not the sites were contaminated with petroleum product, but not enough subsurface investigation to delineate the extent of the petroleum products, or to develop a meaningful mitigation plan. However, the completion of a thorough evaluation of reliable cleanup strategies based primarily on technical relevance, property redevelopment initiatives, and cost was not possible due to the limited analytical data. To proceed with a Limited Phase II ESA it was necessary to obtain approval from EPA. On May 17, 2008 the EPA approved the modified Quality Assurance Project Plan (QAPP). The QAPP provides a baseline for planning and implementation of Phase II ESAs and evaluation activities.
In addition to having to modify the QAPP it was also necessary that the consultant update the Property-specific Sampling and Analysis Plan (PSAP). The PSAP detailed the proposed sample locations, analytical program and rational for sampling. EPA provided comments to the Revision 0 PSAP on December 14, 2007. The consultant submitted an updated PSAP, Revision 1 for the property on April 1, 2008 and the EPA approved the PSAP on May 12, 2008.
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