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New West Petroleum • - 5 - • 26 November 2012 <br /> 6437 Banner Street <br /> Lodi, San Joaquin County <br /> Public Participation <br /> Public participation was conducted from 23 October 2011 to 23 November 2011 with no <br /> adverse comments received by this agency. SJCEHD is in agreement with the closure. <br /> Low Risk Closure Policy (LTCP) Review <br /> The Site qualifies for a low risk closure under the State Water Resources Control Board <br /> Low Risk Closure Policy, based on the following rationale: <br /> Groundwater Specific Criteria 1.5. The regulatory agency determines, based on an <br /> analysis of site specific conditions, that the site under current and reasonably <br /> anticipated near-term future scenarios, the contaminant plume poses a low threat to <br /> human health and safety and to the environment and water quality objectives will be <br /> achieved within a reasonable time frame. <br /> See above Table 1 and Sensitive Receptors section. <br /> Petroleum Vapor Intrusion to Indoor Air. Exemption - Active Commercial Petroleum <br /> Facility. <br /> Soil vapor samples were collected between the USTs and an adjacent fast food <br /> restaurant. The November 2007 Human Health Risk Assessment reviewed the soil <br /> vapor and monitoring data, and concluded risks from soil, soil vapor, and groundwater <br /> as a contributor to vapor migration into nearby buildings was insignificant. <br /> Direct Contact and Outdoor Air Exposure. Exemption — The upper 10 feet of soil is free <br /> of petroleum contamination. 3.2 A site specific risk assessment demonstrates the <br /> maximum concentrations of petroleum constituents in soil will have no significant risk of <br /> adversely affecting human health (i.e., `passes'). <br /> The Regional Board staff closure recommendation was also made by review of the site <br /> specific data and professional judgment prior to implementation of the LTCP. <br /> Summary and Recommendations <br /> The RPs have complied with all of the requirements in the Regional Board CAO <br /> R5-2007-0709, staff letters and directives, and the Low Threat Closure Policy, and have <br /> adequately assessed and remediated MTBE- impacted groundwater associated with the <br /> Site release. As evidenced by declining concentrations in groundwater, the residual <br /> contamination beneath the subject site will continue to attenuate in place, poses a <br /> minimal risk to municipal supply well CSA-31-2, and will not pose a threat to human <br /> health and/or the environment. Based on the minimal residual contamination in <br /> groundwater, lack of threats from soil or soil vapor intrusion, declining groundwater <br />