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1 (2) the installation of three monitoring wells at the site, <br /> 2 (3) the submission of quarterly status reports for the <br /> 3 foreseeable future, and (4) the quarterly monitoring of the <br /> 4 domestic wells on site 'for Sag-oline contamination until no <br /> 5 contamination was detected for four consecutive quarters. <br /> 6 (Exhibit A-1. ) <br /> 7 In August 1993, Petitioner met with the Health Department <br /> 8 staff in an effort to reach some agreement with respect to the <br /> 9 Site. In addition, Petitioner retained Levine Fricke to peer <br /> 10 review the tank closure data and render an opinion as to the <br /> 11 adequacy of the tank closure. Based on the results of the August <br /> 12 1993 meeting and the fact that Levine Fricke concurred with <br /> 13 SG&D's recommendations for case closure, on September 9, 1993 <br /> 14 Petitioner finally decided that it had no alternative, but to <br /> 15 file this appeal seeking rescission of the Order and closure of <br /> 16 this case. To accommodate this appeal, the Health Department has <br /> 17 extended the date by which Color Spot must submit a work plan to <br /> 18 December 6, 1993. <br /> 19 MEMORANDUM OF POINTS AND AUTHORITIES <br /> 20 The issue on this appeal is whether Petitioner can be <br /> 21 required to undertake extensive and costly groundwater <br /> 22 investigation and monitoring in connection with removal of the <br /> 23 UST, when two well-respected environmental consulting firms both <br /> 24 agree, based on extensive soil and groundwater sampling, that <br /> 25 (1) the lateral and vertical extent of soil contamination <br /> 26 associated with the UST has been defined, (2) such soil <br /> 27 contamination has been adequately removed, (3) the low levels of <br /> 28 contamination detected in a few groundwater samples at the site <br /> -4- H\VMC\COLORSPT\APPEAL.PL4(5P2) <br />