SITE INFORMATION AND CORRESPONDENCE

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Wlrsox;SONslNl,GoonnzcH&Rosarr Ms. Linda Turkatte, REHS , May 26, 1993 Page 4 . ti 1 Color Spot has performed adequate soil and groundwater investigation at the site as required by Agency guidelines. According to Agency guidelines, adequate soil and.groundwater investigation has been preformed at the site and,this case should be closed. Pursuant to the LUFT Field Manual (March 1989), tank sites fall into three categories. (1) cases in.which there.is no evidence of significant soil contamination or any; groundwater pollution (Category 1), (2) uses in which there is known soil contamination `= (Category 2), and (3) cases of known dr suspected g � groundwater pollution, or.areas with' shallow groundwater (Category 3). In Girder to determine a site's category, the Guidelines: suggest that the inspector.should follow the decision three set forth as Figure II (copy` attached). This case clearly fails into Category 1. As stated above, there was no evidence-6f odor, free product or holes in the tank upon_removal, and the miner spillage observed.had n6t migrated beyond the excavation. , y For Category 1 sites, the guidelines indicate that soil samples should be taken and { groundwater evaluated as set forth on Figure 11-2, attached. The guidelines prow de,that if, BTEX and TPH are found in concentrations below acceptable levels and other resources are i not at risk, the soil may be left in place. In this case, 1100 ppm of TPH was initially " detected in the sample taken;from the first two feet of soil. This soil was removed, and confirmatory samples indicated that non-detectable concentrations of TPH remained in the , excavation. Only trace amounts of toluene, ethyl benzene and xylene were detected.(see Table 2, attached). Pursuant to the LUFT guidelines, the.remaining soil is clean enough acid the vertical extent of contamination has been defined and removed: Therefore, ease closure should be granted. 3' given these findings. further groundwater investigation is not required 'by�pplicable law and policy. i Given these results and the fact that it is not technically feasible to install monitoring wells on the property, Color Spot believes that additional groundwater investigation is impracticable and unreasonable. Color Spot has attempted to install monitoring wells at the: x site as requested by the Health Department, but efforts have been futile. All four wells which SG&D attempted to put in were dry,.and groundwater was not encountered. 'SG&D r has-advisedthat it is not technically feasible to install the wells. Therefore, it unreasonable for the Health Department:to request them. Clearly, the-purpose of this request is not to investigate the site for evidence of impact ft* Color Spot's tank, but to allow the Health Department to monitor an area-wide benzene U tWO MVMCWOLORSPnTURM17.L`FR(SP2), F