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expected to continue to decrease. The site meets the criteria of the Low-Threat Closure <br />Policy (Attachment 3). <br />Extent defined <br />A soil investigation conducted in March 2011 found that TPH-d was detected in all soil <br />borings between 9 and 12 feet bgs, with maximum concentrations in GP-15 at 14,000 <br />mg/kg (Figure 2), in a report dated 30 March 2011. The installation of upgradient <br />monitoring well MW-4, soil borings and grab groundwater samples collected in October <br />2015 showed the groundwater plume does not extend off-site. Analytical results are <br />presented in AGE’s Remediation Well Installation & Additional Site Assessment Report <br />dated 29 December 2015 <br />Threat to Groundwater <br />Soil and groundwater sampling showed that contamination was limited to a depth of 20 <br />feet below ground surface (bgs), and existing dissolved TPHd concentration in the water <br />table aquifer is defined and decreasing. Groundwater usage on site is prohibited by the <br />City of Lathrop and regional groundwater use is pumped from the Deep Zone aquifer at <br />depths of 151 -218 feed bgs. Therefore, groundwater is not likely to be further degraded <br />by residual TPH in near surface soils. <br />Threat to Human Health <br />In the most recent sampling event, no constituents were found in any of the monitoring <br />wells. Soil and groundwater sampling conducted in 2015 showed the extent of <br />contamination is limited to the spill area and has not migrated off site. Groundwater is <br />not used for any purpose on site, therefore no threat to human health is expected from <br />groundwater use. <br />Residual impact on site is comprised of weathered diesel fuel and the potential level of <br />volatility is expected to be insufficient to present hazards from soil vapor. Shallow soil <br />samples collected in October 2015 show BTEX compounds are below residential <br />criteria levels established in the LTCP. Planned development of the property will cover <br />the area containing the residual TPH-d with warehouses and asphaltic parking lots. <br />Data suggests the site meets Scenario 3 of the Petroleum Vapor Intrusion to Indoor Air <br />criteria established in the Low-Threat Closure Policy (LTCP). <br />Considering these circumstances, there does not appear to be a significant threat to <br />human health. <br />30 Day Public Comment Period <br />No comments were received during the 30 day comment period from 06 March 2020 – <br />06 April 2020. <br />Conclusion <br />The site meets the requirements of the Low-Threat Closure Policy for Underground <br />Tanks. Based on the elimination of LNAPL from the groundwater table, the reduced