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i 4 WIPI:S(IR SO'NSINL GOODRICH & RosATI <br /> r - <br /> Ms. Linda Turkatte, REHS <br /> May 26, 1993 <br /> Page 4 <br /> tr <br /> 2. Color Snot has pgrformed adeQuate ;oil and groundwater investigation at the site as <br /> required by Agency guidelines. <br /> { a <br /> t <br /> According to Agency guidelines, adequate sail and groundwater investigation has been <br /> preformed at the site and this case should be closed; <br /> Pursuant to the LUFT Field Manual (March 1989), tank sites fail into three <br /> 1 categories: (1) cases in which there is no evidence of significant soil contamination or any <br /> groundwater pollution (Category 1), (2) cases in which there is known soil contamination <br /> (Category 2), and (3) cases of known lor suspected groundwater pollution, or areas with <br /> shallow groundwater (Category 3). to order to determine a site's category, the Guidelines <br /> suggest that the inspector should follow the decision three set forth as Figure Ii (copy <br /> 4 attached) This case clearly falls into Category 1. As stated above, there was no evidence of <br /> odor, free product or holes in the tank.upon removal. and the mincer spillage observed had <br /> not migrated beyond the excavation. <br /> For Category I sites; the;guidelines indicate that soil samples should be taken land <br /> groundwater evaluated as set forth on Figure 11-2, attached. The guidelines:provide thatif <br /> TEX and TPH are found in concentrations below acceptable levels.and other resources.Ve <br /> not at risk, the soil may be left in place. In this case, 1100 ppm of TPH was initially <br /> } `detected in the sample.taken from the first two feet of sail. This soil was removed, and. .; <br /> confirmatory samples..indicated that non-detectable concentrations of TPH remained in the <br /> excavation. Only trace amounts of toluene, ethyl benzene and xylene were detected (see <br /> Table 2 attached). Pursuant to the LUFT guidelines, the remaining soil is divan enough and <br /> the vertical extent of;contmininap has been defined and removed. Therefore, ca closure <br /> should be grantd <br /> S: <br /> } 1 Given these findings further groundwater investigation is not rerg heti by appli ole <br /> law and pvlicv:. <br /> -Given these results and the fact that it is not technically:f to install monit0h <br /> wells on the property, Color Spot believes that additional groundwater investigation is <br /> impracticable and unreasonable. Color Spot has attempted to install.,monitoring wells at the. <br /> site as requested by the Health 13epartment, but efforts have been futile. All four.wells. <br /> �. which SG&D.atte pted to put in:were dry, and groundwater was not encountered:: SO&D. <br /> . <br /> has auivised that it is not technically feasible to install the wells.. Therefore, it is unreasonable <br /> €or the Health.Department to request diem. <br /> i dearly, the purpose of thig request is not to investigate the site for evidence of impact <br /> ' firt m Color Spot's tanks but to allow.the Health Department to monitor an area wide benzene <br /> fi <br /> x <br />