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Page 2 of 3 <br /> farther than benzene travels in groundwater on average, at gasoline release sites of all sizes as documented in <br /> the Technical Justification for Groundwater Plume Lengths, Indicator Constituents, Concentrations, and Buffer <br /> Distances (Separation Distances) to Receptors; State Water Resources Control Board; July 2011, <br /> http://www,waterboards.ca .gov/ust/policy/techoust07l211 . pdf top of page 2 . There is no evidence to suggest <br /> that potential historic releases from Tracey Country Market's small, gas tanks would come close to what is <br /> generally considered an "average" sized release as discussed in this document. <br /> Furthermore, the soil sample data we have at the Country Market site, which was collected in the immediate <br /> vicinity and directly below the UST's shows no evidence of a release capable of reaching groundwater ( reported <br /> at 78 feet , 1974 DWR well install report), let alone migrate down gradient another 300 feet. The soil samples <br /> collected beneath the LISTS were non-detect and as we discussed in October, the highest concentrations of BTEX <br /> compounds detected at the site in the samples located adjacent to the tanks, are already below concentrations <br /> that would warrant further risk evaluation . In addition, the on-site domestic well that Antea Group already <br /> sampled is active, is the closed potential receptor to the potential release point, and can reasonably be expected <br /> to draw in residual hydrocarbon concentrations in groundwater, if they were present. That sample was also <br /> non-detect. <br /> Therefore, based on this additional information and further evaluation, Antea Group reiterates our <br /> recommendation and request that this case be closed with no further action . <br /> Sincerely, <br /> Andrew M . Lojo, P.G . 6034. <br /> Links to reports documenting regional GW flow direction to the north or northwest. <br /> "Based on groundwater elevations collected during December 2001, the groundwater appears to be flowing to <br /> the northwest with a gradient of approximately 0.001 foot per foot (ft/ft) ." <br /> RAP for Pyrolytic Oil- and Metals-Affected Soil Tracy Tire Fire Site <br /> September 18, 2003 <br /> http ://www.envirostor.dtsc.ca .gov/regulators/deliverable documents/5660034000/Tracy%20Tire%20Fire% <br /> 20RAP%209 18 2003 . pdf <br /> "Based on depth to water measurements recorded during ground sampling events from 2003 through 2006, <br /> groundwater within the upper waterbearing unit generally flows toward the north-northwest with a calculated <br /> gradient ranging between approximately 0.001 to 0.002 feet per foot (ft/ft) ." <br /> Letter of Transmittal from LFR Environmental Management and Consulting Engineering <br /> November 10, 2006 <br /> http://www.envirostor.dtsc.ca .gov/regulators/deliverable documents/4871686637/combined-rpt-RA summ- <br /> Nov06-revfinal-09025. pdf <br /> "Based on file reviews of surrounding properties, groundwater flows northward in this area"; DTW reported at <br /> 75' bgs <br /> Soil and Groundwater Investigation ReportTAOC Tracy Gravel Pits <br /> October 2006 <br /> http ://geotracl<er.waterboards.ca .gov/esi/uploads/geo repo rt/3204346656/SL0607723732 . PDF <br /> Andrew Lojo P.G. 1 Senior Consultant I USA <br /> 12/18/2014 <br />