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• <br /> JM Equipment Company <br /> 1245 West Charter Way, Stockton <br /> Claim No: 12607 <br /> shallow groundwater is not currently being used as a source of drinking water, and it is highly <br /> unlikely that the affected shallow groundwater will be used as a source of drinking water in the <br /> foreseeable future. Other designated beneficial uses of the affected shallow groundwater are <br /> not threatened, and it is highly unlikely that they will be, considering these factors in the context <br /> of the site setting. <br /> Rationale for Closure under the Policy <br /> • General Criteria: The case meets all eight Policy general criteria. <br /> Groundwater Specific Criteria: The case does not meet Policy criteria because contaminant <br /> plume that exceeds water quality objectives is greater than 100 feet in length and the <br /> dissolved concentration of benzene is greater than 3,000 micrograms per liter(Ng/L). <br /> • Vapor Intrusion to Indoor Air: The case meets Policy Criterion 2b. Although no document <br /> titled 'Risk Assessment'was found in the files reviewed, a professional assessment of site- <br /> specific risk from exposure through the vapor intrusion pathway was performed by Fund <br /> staff.The assessment found that there is no significant risk of petroleum vapors adversely <br /> affecting human health. The onsite building is a covered equipment storage shed which has <br /> ample ventilation that would prevent the accumulation of soil vapors in the building. <br /> • Direct Contact and Outdoor Air Exposure: The case meets Policy Criterion 3a. Maximum <br /> concentrations in soil are less than those in Policy Table 1 for Commercial/Industrial use, <br /> and the concentration limits for a Utility Worker are not exceeded. There are no soil sample <br /> results in the case record for naphthalene. However, the relative concentration of <br /> naphthalene in soil can be conservatively estimated using the published relative <br /> concentrations of naphthalene and benzene in gasoline. Taken from Potter and Simmons <br /> (1998), gasoline mixtures contain approximately 2 percent benzene and 0.25 percent <br /> naphthalene. Therefore, benzene can be used as a surrogate for naphthalene <br /> concentrations with a safety factor of eight. Benzene concentrations from the Site are below <br /> the naphthalene thresholds in Policy Table 1. Therefore, the estimated naphthalene <br /> concentrations meet the thresholds in Table 1 and the Policy criteria for direct contact by a <br /> factor of eight. It is highly unlikely that naphthalene concentrations in the soil, if any, exceed <br /> the threshold. <br /> Objections to Closure and Responses <br /> According to the Path to Closure page in GeoTracker, finalized on June 4, 2015, the County <br /> staff objects to UST case closure because: <br /> • Secondary source remains. <br /> RESPONSE: Secondary source as defined by the Policy was removed by excavation and <br /> active remediation. <br /> • The case does not meet Policy groundwater criteria. <br /> RESPONSE: We concur; the case does not meet Policy criteria because contaminant <br /> plume that exceeds water quality objectives is greater than 100 feet in length and the <br /> dissolved concentration of benzene is greater than 3,000 Ng/L. <br /> • The case does not meet Policy vapor criteria. <br /> RESPONSE: The case meets Policy Criterion 2b. Although no document titled 'Risk <br /> Assessment'was found in the files reviewed, a professional assessment of site-specific risk <br /> from exposure through the vapor intrusion pathway was performed by Fund staff. The <br /> assessment found that there is no significant risk of petroleum vapors adversely affecting <br /> human health. The onsite building is a covered equipment storage shed which has ample <br /> ventilation that would prevent the accumulation of soil vapors in the building. <br /> Page 2 of 3 <br />