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Mr. Joel Weiss • • <br /> October 8, 1996 <br /> Page 4 <br /> SITE CLOSURE RATIONALE AND PROPOSED APPROACH <br /> Based on over five years of data from this site, several other historical crude oil release sites <br /> (e.g., WMR pipeline sites), and a thorough understanding of the crude oil weathering process <br /> including physical and chemical breakdown, CPL believes the best approach to closure of the <br /> Lyoth site is: <br /> • Completion of a health risk assessment(HRA)to assess potential human health concerns <br /> from in-situ weathered crude oil; <br /> • Potential additional soil and groundwater investigations to gather data required for the HRA; <br /> • Excavation of areas with obvious tar-like material seeps for nuisance avoidance; and <br /> • Implementation of a Soil Management Plan (SMP)which will provide a mechanism by which <br /> the current or future property owners may access CPL'S assistance during potential <br /> encounters with crude oil impacted soil. <br /> Once sufficient soil and groundwater data has been collected(i.e., recommendations in this <br /> letter),this approach will be reevaluated and formally proposed to the CVRWQCB in the Former <br /> Lyoth Loading Station Assessment and Closure Plan,to be submitted in accordance with the <br /> schedule presented in Table 2. <br /> Please review this letter and provide CPL comments at your earliest convenience. If you have <br /> any questions or concerns regarding this letter or CPL'S strategy for the Lyoth site,please contact <br /> Mr. Dan Lapporte at(510) 842-6718 or me at (510) 842-6877. <br /> ,Sincere , <br /> � dor <br /> Katie Ho <br /> Project Manager <br /> California Site Remediation <br /> Attachments: 2 <br /> cc: Mr. Ron Hoffman, Hoffman Brothers Harvesting Company <br /> Ms, Margaret Lagorio, R.E.H.S., San Joaquin County Public Health Services <br /> Mr. Dan Lapporte, CPL <br />