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Mr. Gurjinder Singh Sohal #3 February 28 , 2019 - Page 4 and 0 . 065 mg/kg , respectively in only sample SEPE-4 . Benzene also had an estimated (J flag ) value of 0 . 0018 mg/kg , which is less than the reporting level (RL) but greater than the method detection limit ( MDL) in sample SEPE4 . MTBE , TBA , DIPS , ETBE , TAME , EDB , 1 , 2 -DCA , ethanol , and naphthalene were not detected in any of the samples . Total lead was detected in all of the samples at concentrations ranging from 5 to 25 mg/kg , which are less than the California Code of Regulations (CCR) Title 22 total threshold limit concentration (TTLC ) and are consistent with the concentration of total lead in the near surface soils in the Stockton area (see Table 1 - Summary of Soil Sample Analytical Results and Attachment 3 for the Laboratory Report) . The State Water Resources Control Board ' s ( SWRCB ' s) Low Threat UST Case Closure Policy ( Policy) for commercial and industrial use properties specifies maximum benzene concentrations of 8 . 2 and 12 mg/kg for the intervals from surface to 5 fbg and 5 to 10 fbg , respectively ; maximum ethylbenzene concentrations of 89 and 134 mg/kg for the intervals from surface to 5 fbg and 5 to 10 fbg , respectively , and maximum naphthalene concentrations of 45 and 45 mg/kg for the intervals from surface to 5 fbg and 5 to 10 fbg , respectively . Therefore , the concentrations of benzene , ethylbenzene , and naphthalene at the site are less than the limits specified in the Policy. CONCLUSIONS AND RECOMMENDATIONS Based upon the laboratory results of the soil samples collected during the dispenser and piping upgrades , gasoline hydrocarbons were detected at trace concentrations in only one of the samples and the concentrations of benzene , ethylbenzene , and naphthalene are less than the limits specified in the SWRCB 's Policy . Therefore , MP.% recommends that the SJCEHD issue an NFA determination in association with the upgrades to the MPD and piping . This report has been prepared for the exclusive use of Mr. Gurjinder Singh as it pertains to the soil sampling conducted during the dispenser and piping upgrades at Sohal #3 located at 2494 East Fremont Street , Stockton , California . The services performed by M" were conducted in a manner consistent with the level of care and skill ordinarily exercised by members of its profession currently practicing under similar conditions in the State of California . No other warranty is expressed or implied .