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Project No. 014-13157 <br />Page No. 3 <br />APPLICABLE REGULATORY AGENCY REFERENCE <br />Krazan's evaluation of the results and findings associated with the sampling included referencing the <br />Interim Final 2007 (Revised December 2013) San Francisco Regional Water Quality Control Board's <br />(SFRWQCB) environmental screening levels (ESLs) referenced in the technical document titled, Screening <br />for Environmental Concerns at Sites with Contaminated Soil and Groundwater. <br />According to the RWQCB's 2013 documents, ESLs are considered to be conservative. Under most <br />circumstances and within limits described by the RWQCB, the presence of a chemical in soil, soil-vapor, <br />or groundwater at concentrations below the corresponding ESL can be assumed not to pose a significant, <br />long-term (chronic) threat to human health and the environment. Additional evaluation will generally be <br />necessary at sites where a chemical is present at concentrations above the corresponding ESL. Active <br />remediation may or may not be required, however, depending on site-specific conditions and <br />considerations. As stated by the RWQCB, the ESL document may be especially beneficial for use at sites <br />with limited impacts, where the preparation of a formal environmental assessment may not be warranted or <br />feasible due to time and cost constraints. It should be noted, ESLs are intended for use only at sites overseen <br />by the RWQCB. <br />For the purposes of evaluating specific COCs, Krazan also referred to the September 2009 and November <br />2009 (ethylbenzene only) technical documents prepared by the California Environmental Protection <br />Agency (Cal/EPA) titled Use of California Human Health Screening Levels in Evaluation of Contaminated <br />Properties. The California Human Health Screening Levels (CHHSLs) are concentrations of 54 hazardous <br />chemicals in soil, shallow soil gas, and indoor air that the Cal/EPA considers to be below thresholds of <br />concern for risks to human health. The CHHSLs were developed by the Office of Environmental Health <br />Hazard Assessment (OEHHA) on behalf of Cal/EPA, and are contained in a Cal/EPA report titled Human- <br />Exposure-Based Screening Numbers Developed to Aid Estimation of Cleanup Costs for Contaminated Soil. <br />The thresholds of concern used to develop the CHHSLs are an excess lifetime cancer risk of one-in-a- <br />million (104) and a hazard quotient of 1.0 for non-cancer health effects. The CHHSLs were developed <br />using standard exposure assumptions and chemical toxicity values published by the U.S. EPA and Cal/EPA. <br />CHHSLs can be used to screen sites for potential human health concerns where releases of hazardous <br />chemicals to soils have occurred. Under most circumstances, and within the limitations described in the <br />January 2009 documents, the presence of a chemical in soil, shallow soil vapor, and/or indoor air at <br />concentrations below the corresponding CHHSLs can be assumed to not pose a significant health risk to <br />people who may live (Residential CHHSLs) or work (Commercial/Industrial CHHSLs) at the site. It should <br />be noted, CHHSLs are not regulatory "cleanup standards" and regulatory agencies cannot be compelled to <br />use the CHHSLs as final cleanup standards for a contaminated property. <br />REPORT OF FINDINGS <br />The analytical results were not detected (ND) for TPH-d and TPH-mo for the six (6) confirmation <br />soil samples, EX-1 through EX-6 as shown on Table I. The laboratory analytical results are <br />provided in Appendix C. <br />The results of the compaction testing conducted on the backfill material are provided in Appendix <br />D. <br />The soil from the excavation was removed and transported to Forward Landfill of Manteca, <br />California. <br />KRAZAN & ASSOCIATES, INC. <br />With Offices Serving the Western United States <br />Phase II LSA - 014-13157 Excavation Report FINAL docx