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Diesel Impacted Soil Removal Report May 2010 California Army National Guard Armory Lodi, CA 6.0 CONCLUSIONS AND RECOMMENDATIONS Based on the scope of removal actions employed at the site and the results for soil samples collected prior to and following excavation and restoration activities, OTIE presents the following conclusions regarding site conditions: • Removal actions at the site were completed in substantial accordance with the strategy defined in the CVRWQCB-approved Workplan, and resulted in the effective excavation and removal of approximately 14 tons of diesel fuel-impacted soil; • Although one confirmation soil sample exceeded the defined default cleanup threshold concentration of 100 mg/kg for TPH-D, comparison of the reported concentration(140 mg/kg)to the potentially applicable ESL for a commercial/industrial site in the Central Valley,where first groundwater is greater than 55 feet bgs, leads to the reasonable conclusion that the remaining soil is not a potential threat to groundwater; • The close proximity of the confirmation floor sample that exceeded the defined default cleanup threshold to the other floor sample that was below the threshold by a factor of nearly 50 and the four other sidewall samples that were below the threshold by factors of 20 to 50 suggests that the single exceedance does not represent overall soil conditions following removal actions; and • Soil removal and site restoration actions at the site were effective in meeting project objectives and in accordance with the SJCEHD September 30,2009 Notice to Abate Immediately, and support a finding of NFA. Pursuant to these conclusions,we respectfully recommend the site be given final closure and request a final NFA letter be provided to the CA ARNG by either the CVRWQCB as the lead regulatory agency or by the SJCEHD as the local oversight authority.