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December 22, 1998 Harding Lawson Associates <br /> 4034405 <br /> Margaret Lagorio, Supervising RENS <br /> San Joaquin County Public Health Services <br /> Environmental Health Division <br /> Page 10 <br /> sample from SB-1 did not contain detectable TPHd or BTEX, the presence of 1 8 mg/l of TPHd in the <br /> Hydropunch sample collected from the screened-interval depth of 21 5 to 24 feet bgs is somewhat <br /> enigmatic In addition, the Hydropunch sample was collected from boring SB-1 in which impacted soils <br /> were exposed in the borehole from near the ground surface to depths of at least 15 feet bgs After <br /> encountering groundwater in the 20 foot sample from boring S13-1, static water level rose to approximately <br /> 16 feet bgs Because solid-flight augers were used, the augers were pulled to pound the 20-foot soil <br /> sample and then the Hydropunch sample Pulling the augers is likely to have resulted in impacted soils <br /> falling into the boring and contaminating the groundwater in the borehole The potential exists for down- <br /> hole contamination of the Hydropunch sample by contaminated bore hole water derived from shallower <br /> depths These conditions suggest that the results are suspect and do not in fact reflect formational waters <br /> This is corroborated by the soluble analyses which indicated that impacted soils (maximum detected <br /> concentrations) do not contain detectable concentrations of soluble TPHd, TPHmo, or BTEX <br />' Another objective of the investigation was to assess the feasibility of insitu passive bioremediation of <br /> impacted soils As discussed above, the results of feasibility studies indicate that a subpopulation of <br /> microorganism capable of degrading petroleum hydrocarbons is present in soils at the site and that this <br />' population is within the range acceptable for biological degradation of TPH as a viable remedial <br /> alternative <br /> One of the criteria for no further action on low risk sites is that the Site must not pose a significant risk to <br /> human health or safety (RWQCB, 1996) As discussed above a RBCA assessment of the Site consisting of <br /> a Tier 1 evaluation performed in accordance with ASTM-E 1739-95 (ASTM, 1995), indicates that the Site <br /> does not pose a significant risk to human health or safety <br /> CONCLUSIONS <br /> Based on the results of previous investigations, the data collected during this investigation, and the <br /> information discussed above, HLA makes the following conclusions <br /> • Potential leaks have been eliminated by closure activities which removed all former product, cleaned <br /> and backfilled the USTs/sump with concrete <br /> • The lateral extent of the impacted soil associated with the courtyard USTs/sump location has been <br /> determined <br /> • The vertical extent of impacted soil has been determined and does not extend to depths of 20 feet bgs <br /> at the source <br /> • The areal extent of impacted soil is less than 700 square feet <br />' • The Hydropunch groundwater data aie suspect and groundwater is not likely to be impacted based on <br /> the available data <br /> • The lack of detectable benzene in all soil samples collected to date and the lack of detectable PAHs in <br /> the soil with the maximum TPH concentrations indicates that the remaining impacted soils do not <br /> contain the CDCs associated with # six fuel that would typically pose a potential threat to health or <br /> safety <br /> • The soluble data from the courtyard samples and the additional soluble data from the six UST- <br /> removal samples indicate that the impacted soils remaining on site do not pose a threat to <br /> . groundwater quality <br /> • Z he RBCA assessment shows that the Site does not pose a threat to human health or safety <br /> 0 <br />