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(2) Upgradient reported that the release had been stopped and the source(s)of hydrocarbons <br /> in the vadose zone had been removed or permanently contained. The UST and dispenser <br /> had been removed, and the residual hydrocarbons were restricted to the silt bed that <br /> underlies the site to'a depth of more than 25 feet. Silt beds typically have fairly low <br /> permeability, and diesel has limited mobility in soil. Hence,the contaminants were <br /> effectively contained. <br /> (3) Upgradient explained under item 2 above, that it was unlikely that groundwater had been <br /> or will ever become impacted because the soil at the site is generally silty and there is at <br /> least a 15-foot buffer zone of clean soil between the estimated high groundwater level and <br /> the residual soil petroleum hydrocarbon mass. <br /> (4) Upgradient also concluded that no significant tisk to human health and safety existed or is <br /> anticipated to exist. A sensitive receptor survey was conducted and the nearest potential <br /> receptor was identified as ST&E's own well,which is approximately 300 feet from the <br /> UST location. The ST&E locomotive shop parcel is several acres in size, and is <br /> surrounded on all sides by even larger industrial properties and the ST&E.freight yard. <br /> The area is not zoned for residential use. Upgradient concluded that the risk of public <br /> exposure is very low.Upgradient therefore concluded that the residual diesel <br /> contamination within the UST excavation posed no significant threat to public health. <br /> Upgradient(1999)recommended site closure but that request was denied jointly by the <br /> California Regional Water Quality Control Board(RWQCB) and PHSEHD. Upgradient <br /> subsequently submitted a fate and transport model for hydrocarbon contamination to PHSEHD <br /> in 2001 in an attempt to justify closure. The results of this transport model suggested that <br /> impact to groundwater at depths of 40 to 45 feet bgs might likely occur within several years of <br /> the release(1980's). The data contained in the report actually suggested a groundwater problem <br /> likely existed. However,the Upgradient document concluded that actual field conditions were <br /> not coincident to modeled conditions. <br /> Main5DWnvironmenWA15T61Workplan\Workplan)1192007,wpd 10 <br /> I�F <br />