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I <br /> Guardino — Crawford Company February 2015 <br /> 517 West Fremont Street, Stockton <br /> Claim No : 14349 <br /> hydrocarbon constituents are limited and stable, and concentrations are decreasing . Corrective <br /> actions have been implemented and additional corrective actions are not necessary. Any <br /> remaining petroleum hydrocarbon constituents do not pose a significant risk to human health, <br /> safety or the environment. <br /> Rationale for Closure under the Policy <br /> • General Criteria : The case meets all eight Policy general criteria. <br /> • Groundwater Specific Criteria: The case meets Policy Criterion 1 by Class 1 . The contaminant <br /> plume that exceeds water quality objectives is less than 100 feet in length. There is no free <br /> product. The nearest water supply well or surface water body is greater than 250 feet from the <br /> defined plume boundary. <br /> • Vapor Intrusion to Indoor Air: The case meets Policy Criterion 2a by Scenario 3a . The <br /> maximum benzene concentration in groundwater is less than 100 micrograms per liter (pg/L). <br /> The minimum depth to groundwater is greater than 5 feet, overlain by soil containing less than <br /> 100 milligrams per kilogram (mg/kg) of TPH. <br /> • Direct Contact and Outdoor Air Exposure: The case meets Policy Criterion 3a. Maximum <br /> concentrations in soil are less than those in Policy Table 1 for Commercial/Industrial use, and <br /> the concentration limits for a Utility Worker are not exceeded. There are no soil sample results <br /> in the case record for naphthalene. However, the relative concentration of naphthalene in soil <br /> can be conservatively estimated using the published relative concentrations of naphthalene <br /> and benzene in gasoline. Taken from Potter and Simmons (1998) , gasoline mixtures contain <br /> approximately 2 percent benzene and 0. 25 percent naphthalene. Therefore, benzene can be <br /> used as a surrogate for naphthalene concentrations with a safety factor of eight. Benzene <br /> concentrations from the Site are below the naphthalene thresholds in Policy Table 1 . <br /> Therefore, the estimated naphthalene concentrations meet the thresholds in Table 1 and the <br /> Policy criteria for direct contact by a factor of eight. It is highly unlikely that naphthalene <br /> concentrations in the soil , if any, exceed the threshold . <br /> Objections to Closure and Responses <br /> According to the LTCP Checklist in GeoTracker, finalized on April 30, 2014, the County objects to <br /> UST case closure because: <br /> • Secondary source has not been removed to the extent practicable because SVE and IAS <br /> systems have been installed but no report of operation yet received . <br /> RESPONSE: The results of SVE and IAS operations are now available, and have <br /> demonstrated the remediation has been effective in reducing the benzene plume. <br /> • The case does not meet Policy groundwater criteria . <br /> RESPONSE: The case now meets Policy Criterion 1 by Class 1 . <br /> • The case does not meet Policy vapor criteria. <br /> RESPONSE : The case now meets Policy Criterion 2a by Scenario 3a . <br /> Determination <br /> The Fund Manager has notified the tank owners or operators and reviewed the case history of their <br /> tank case . The Fund Manager determines that closure of the tank case is appropriate based upon <br /> that review. The Fund Manager has prepared this review summary report summarizing the <br /> reasons for this determination, provided the Review Summary Report to the applicable Regional <br /> Water Board and Local Oversight Agency Program, as appropriate, with an opportunity for <br /> comment on the Review Summary Report, <br /> Page 2 of 3 <br />