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A S S 0 C f A T E S I N C <br /> 6.0 EVALUATION OF LOW RISK CRITERIA <br /> 661 Low Risk Groundwater Case Evaluation <br /> Using the criteria listed in CRWQCB's No Further Action (NFA) requirements, as outlined by <br /> CRWQCB (Appendix B of the Tri-Regional Recommendations), conditions at the subject site <br /> i� were evaluated to determine if NFA as a "low risk, Groundwater Case" is appropriate for this <br /> site. <br /> i� Criterion 1: Contaminants remaining in the vadose zone must not reverse or threaten <br /> to reverse the mass reduction rate of groundwater pollutants. <br /> Over the course of the investigation, aquifer levels have been measured at depths of z <br /> approximately 22 to 26 feet. One soil sample collected in 1998 contained a detectable <br /> concentration of ethyl benzene at 0.3 mg/kg. The same soil sample also contained TPHg rte, <br /> and TPHd at concentrations of 300 mg/kg and 2,100 mg/kg, respectively. The soil Id <br /> samples collected during the overexcavation of the former tank pit contained low <br /> concentrations of benzene and xylenes and detectable concentrations of TPHg, TPHd, and <br /> TPHss. The estimated mass of BTEX remaining in soil is approximately 4.6 pounds. <br /> Concentrations of BTEX constituents in groundwater well MW3 have generally been <br /> decreasing and only benzene has ever detected above its respective maximum <br /> contaminant level in December 1999. Concentrations of TPHss, TPHd, and TPHg in <br /> groundwater well MW3 have generally been decreasing over time. TPHg has never been <br /> ' detected in wells MW1, MW2, and MW4. TPHd and TPHss have not been detected in <br /> wells MWi or MW2 since March 1999 and have never been detected in well MW4. <br /> Therefore, the likelihood of contaminants in the vadose zone reversing or threatening to <br /> ' reverse the mass reduction rate of groundwater pollutants is very low. <br /> Criterion 2: Separate phase product has been removed to the extent practicable. <br /> ' Free product has never been detected at this site. <br /> ' Criterion 3: No existing water supply wells, deeper aquifers, surface waters, or other <br /> receptors are threatened by pollutants remaining in the aquifer. <br /> ' Well MW1, located 33 feet in the generally downgradient direction, had one detectable <br /> concentration of TPHd at 68 ug/L in December 1998 and detectable concentrations of <br /> TPHd and TPHss at 52 and 95 ug/L, respectively in March 1999. No other constituents <br /> have been detected in this well. TPHd was detected once in well MW2, located <br /> crossgradient from the former UST, at 77 ug/L in March 1999. The closest water supply <br /> well is located approximately 1,200 feet downgradient from the site and the well is not <br /> active. The nearest surface water is located approximately 2,300 feet from the site. For <br /> w:\172951reportsklosure.doc 7 <br />