We have a site with contaminated soils. A Phase II was conducted, but not per ASTM E1527-05 as required. We have an independent environmental consultant coordinating our remediation efforts with the state pollution control agency. We are enrolled in the state's Voluntary Investigation and Cleanup (VIC). We are pursuing three separate methods to 'deal with' the contaminants: (1) under-slab vapor remediation, (2) phytoremediation where existing asphalt layers are removed, and (3) keeping existing asphalt layers intact with intent to 'cap' the contaminated soils. All of these methods have been verbally understood by our state pollution control agency.

Assuming the state agrees with our proposal, will this overall plan be acceptable for SSc3? I've noticed others asking about 'partial' remediation. I'm concerned about our portion that will be kept in place with an asphalt 'lid' on it.

Are we okay without an ASTM E1527-05 Phase II if we have an environmental consultant describing the contaminated soils & plan?