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Parmar Texaco December 2014 521 North Cherokee Lane, Lodi Claim No: 8790 Rationale for Closure under the Policy • General Criteria: The case meets all eight Policy general criteria. • Groundwater Specific Criteria: The case does not meet Policy criteria because the contaminant plume that exceeds water quality objectives is not defined. • Vapor Intrusion to Indoor Air: The case meets Policy Criterion 2b. Although no document titled "Risk Assessment"was found in the files reviewed, a professional assessment of site- specific risk from exposure through the vapor intrusion pathway was performed by Fund staff. The assessment found that there is no significant risk of petroleum vapors adversely affecting human health. The Site is paved and accidental exposure to site soils is prevented. In addition, the onsite building is an active automotive repair facility with multiple rollup doors that would prevent the accumulation of soil vapors in the building. In addition, as an active automotive repair facility, there would adequate air exchange provided by the building's ventilation system required to control vehicle exhaust generated during automotive repair • Direct Contact and Outdoor Air Exposure: This case meets Policy Criterion 3b. Although no document titled "Risk Assessment"was found in the files reviewed, a professional assessment of site-specific risk from potential exposure to residual soil contamination was completed by Fund staff. The results of the assessment found that maximum concentrations of petroleum constituents remaining in soil will have no significant risk of adversely affecting human health. The Site is paved and accidental exposure to site soils is prevented. Therefore, the pathway is incomplete. Any construction crew performing subsurface work will, per the requirements of Title 8 of the California Code of Regulations, be prepared to deal appropriately with environmental hazards anticipated or encountered in their normal daily work. The presence of residual contamination should be taken into account when issuing and executing excavation or building or other permits at the Site, including but not limited to the inclusion of a Competent Person in the work crew. The local building permitting agency has been informed of the existence of this environmental case. Objections to Closure and Responses According to the Path to Closure page in GeoTracker, finalized on July 8, 2014, the County objects to UST case closure because: • Inadequate conceptual site model because the groundwater plume is not defined. RESPONSE: We concur the extent of the plume is not defined. • Secondary source remains. RESPONSE: Secondary source as defined by the Policy was removed by excavation and active remediation. • The case does not meet Policy vapor criteria. RESPONSE: The case meets Policy Criterion 2b. • The case does not meet Policy direct contact criteria. RESPONSE: This case meets Policy Criterion 3b. Recommendation The Fund recommends that the County direct the responsible party to define the extent of contamination southwest(downgradient) of the Site. Kirk Llarson, P.G. Date Robert I rornmer, C.H.G. Date Engineering Geologist Senior Engineering Geologist Technical Review Unit Chief, Technical Review Unit (916) 341-5663 (916) 341-5684 Page 2 of 2