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W10ON. SSONSINI.GOODRICH_& RosAn <br /> y <br /> Id Ms. Linda Turkatte, RENS <br /> I, May 26 1993 <br /> 4 Page 3 <br /> requested that quarterly status reports be submitted to the Health Department and that the <br /> domestic wells on site be monitored quarterly for gasoline contamination. a <br /> As discussed below, Color Spot submits that the vertical extent of the contamination <br />} lias been defined and all contaminated sail removed, as indicated in the January 1990 report. <br /> Further, monitoring wells are not required at the site under applicable guidelines, and are <br /> i technically infeasible to install. <br /> I DISCUSSION <br /> y Color Spat believes that it;should not be required to conduct any further groundwater <br /> k <br /> investigation at the site for the following reasons: <br /> 11. There is no evidence that Color Spat's tank caused the benzene contamination de=d <br /> Y. <br />' in the eroundwater surrounding ;the site. <br /> A i <br /> There is absolutely no evidence that Color Spot's underground storage tank caused the <br /> b enzene contamination that has been detected in the groundwater near the site. First, the r <br /> l <br /> field observations from thel tank removal indicate that the tank did not leak. SG&D reported <br /> that the tan[ appeared intact and structurally sound upon removal, Neither SG&D nor the; <br /> inspector noted such defects:in the tank as hales, rusting or pitting. Neither the inspector nor <br /> SG&D repotted evidence.of a release such as the presence of free product in�the excavation. <br /> ' <br /> In fact. all that those`present noted was a minor amount of sail contamination which <br /> subsequent field work confirmed was limited to the excavation. SG&D concluded that this <br /> contammad.on was likely the result of overspill from filing the tank. Therefore the tank was <br /> not leaking when removed. <br /> Second, subsequent soil. and groundwater testing has confirmed that the.benzene <br /> contamination in the off-site wells could not .halve possibly been caused by Color Spot's tank: <br /> I The tank was used to store:diesel.fuel, which does not contain benzene. Test results taken'. <br /> from existingwater wells on two separate occasions have indicated that benzene is present <br /> but that diesel is not. <br /> Finarllys: the groundwater at the site is over 90 feet below ground surface and there are <br /> stratum composed of clay material layer between the surface and the aquifer: A gtab <br /> groundwater sample.taken at 92 .feet was non-detect for hydrocarbons. 'herefore, the data <br /> clearly indicates that-Color Spot's tank did not contaminate the groundwater, <br /> t <br /> r <br /> r <br /> i <br /> H uiOME\VMMCOLORSMTURKOSI7.LTR(SP2) <br /> C .a <br /> p <br />