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�i Color Spot, Inc. SGD March 19, 1991 (M88168F) 3 standards (DWS) at that time. Trace concentrations of benzene were found in all four wells which were sampled. A PHS-EHD letter dated January 17, 1990, required Color Spot, Inc. to conduct a ground water investigation at the site. SGD responded to this requirement in a letter-report entitled, Response Reply to the San Joaquin Countv Public Health Services Environmental Health Division letter dated January 17 1990, dated April 4, 1990. SGD concluded that Color Spot, Inc. should not be required to implement a ground water investigation and that PHS-EHD should investigate other possible sources of the benzene concentration found in the surrounding water wells. Because PHS-EHD could not be convinced of this recommendation, Color Spot, Inc. elected to have SGD conduct a supplemental site assessment in the vicinity of the former UST. This supplemental site assessment was conducted with the approval of PHS-EHD during the week of October 8, 1990. Results of the assessment are documented in the SGD report entitled, Supplemental Site Assessment Color Spot Inc_. Facility. 5400 East Harney Lane Lodi California, dated November 1990. Benzene concentrations were not detected in any of the soil samples nor the ground water sample collected from within the hollow stem auger. FINDINGS RESULTANT FINDINGS OF ENVIRONMENTAL SERVICES The UST has been properly removed and abandoned at the site in the presence of a PHS-EHD inspector, and in compliance with all PHS-EHD requirements. Following the collection of soil samples from the resultant excavation, the PHS- EHD inspector refused permission for additional soils excavation to remove contaminated soils. The inspector stated that PHS-EHD would require the submittal of a remedial action plan for review and approval prior to the implementation of additional site work. To facilitate the development of an adequate remedial action plan, SGD conducted a soil vapor survey in the vicinity of the former UST. The results of the soil vapor survey indicated that soil contamination existed within the shallow subsurface (0 to 6 feet below the ground surface) of the UST excavation and did not appear to have migrated laterally outside of the UST excavation, and appeared to be limited to the southwest corner of the excavation. SGD recommended that because the extent of the soil contamination appeared to be limited, the remaining contaminated soil be excavated and then remediated with the contaminated soil generated during the removal of the UST by