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Analysis of this sample indicated concentrations of toluene at 22 mg/Kg and TPH at 8200 mg/Kg were present.. Upon discovering the concentration of TPH in the soil sample, additional soil sampling was conducted. A hand auger was uti- lized to collect two soil samples from depths 71 and 120 beneath the tank bottom which was 121 below grade. These activities are described in the December 9, 1987 letter to the San Joaquin Local Health District from Precision industries, a copy of which is presented in Appendix A. Analysis of the soil samples revealed only 0.016 mg/Kg of TPH for the south boring (coded 19S) . Based on these soil sample 11 results, Laura Scudders requested authorization to remove soils to a depth of twenty feet below grade and stockpile the removed soils on-site. Verbal permission to proceed' was granted by the San Joaquin Local Health Department. c tion of the soils from beneath the previous location of Fa T Mas completed on December 23, 1987, Upon removal of the a tional soils, two excavation bottom soil samples and three stockpile soil samples were collected by Precision Industries. These sampling activities were observed by personnel from the San Joaquin Local Health Department. During the sample collection effort, the inspector made a note that odors were emitted by the southern most excavation bottom soil sample (coded 1 South) . Note was also made that the stockpiled excavated soils were emitting odors. All of the soil sample, were analyzed by Trace Analytical Labora- tory. Both excavation bottom soil samples contained no detect- able amounts of either TPH or BTX&E compounds. Thestockpiled soil _ samples, however, contained .significant levels of TPH, ranging from 150 mg/Kg to 1,200 mg/Kg. Upon receipt of the analytical results, Laura Scudders requested permission to backfill the tank removal area. Verbal permission was granted by the San Joaquin Local Health Department. In early 1988, the tank area was backfilled and covered with an asphalt surface. The backfill soil source was not documented. The stockpiled soils (approximately 100 cubic yards) were moved to t..4 the southwest corner of the facility and secured with plastic. These stockpiled soils 6 AUL, os�� 2.2 Tank T3 Tank T3 was a 12,000 gallon diesel storage tank located directly adjacent to the west side of tank T2. This tank had been integ- rity tested in 1987 and had tested tight. The decision to remove this tank was based on an effort to reduce Laura Scudders__ environmental-liabilities--for-the-forthcoming sale off -the proper- -�