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1 From June 1999 through June 2000, ENSR operated a sod vapor extraction (SVE) system at the • site Initially, ENSR extracted from VW-1D, VW-1S, VW-2S, VW-3, and VW-4 After several ' months of operation, air sparging was initiated in MWA According to ENSR, the remediation system removed over 7,000 pounds of gasoline hydrocarbons from the subsurface In July 2000, ENSR decommissioned the system and removed the equipment from the site ' On November 28 2000 Ramage Environmental published Environmental Site Investigation Report documenting the results of a sensitive receptor survey and the drilling of confirmation soil borings According to available records, three property parcels within 2,000-feet of the site had operating water wells These properties included the San Joaquin Catholic Cemetery (site), St Joseph's ' Hospital, and a residential dwelling at 1821 North Hunter Street To confirm the effectiveness of remediation efforts, soil samples were collected every 10 feet to a total depth of 100 feet directly beneath the former USTs The soil sample results indicated that except for 560 milligrams per kilogram (mg/kg) of Total Petroleum Hydrocarbons (TPH)-as- gasoline in soil at a depth of approximately 10 feet below ground surface (bgs), the vadose zone soil was remediated by the SVE system To delineate the vertical extent of impacted groundwater, discrete groundwater samples were collected with a cone penetration test (CPT) rig at 75, 90, and 125 feet bgs from soil borings 1 located approximately 20 feet northeast (downgradient) of the former USTs The discrete groundwater sample results indicated that the vertical extent of impacted groundwater was mostly delineated Concentrations of MTBE declined significantly with depth and were absent in ' the 125-foot groundwater-bearing interval Only 1,2-dichloroethane (1,2-DCA) was detected in the 125-foot groundwater sample, at a low concentration of 0 5 micrograms per liter (µg/l) ' On May 2, 2002, Ramage Environmental published Report, Additional Site Investigation, which documented the drilling of CPT borings for discrete groundwater sampling at six additional ' locations, and the installation of a two-well monitoring well cluster (MW-8A and MW-8B) The results of the project indicated that the extent of MTBE was defined and limited to the ' groundwater table northeast (downgradient) of the former UST Only low concentrations (0 5 to 1 2 µg11) of 1,2-DCA were detected in the 110 to 125 foot groundwater-bearing interval south and west of the former UST 4