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Pre-Design Investigation Workplan <br /> Former Manufactured Gas Plant—Lodi, California <br /> soil excavation will not likely reduce benzene and naphthalene concentrations in soil to levels that do <br /> not exhibit nuisance odors to the neighboring properties. <br /> 2.5.7 Removal Action Workplan <br /> Based on the results of the RI combined with data from other Site investigations, soil beneath the <br /> Site has been found to contain MGP residues from MGP operations between 1913 and 1928. <br /> Following characterization of the Site, a Draft Final RAW including a Human Health Risk <br /> Assessment (HHRA) and streamlined feasibility study was prepared to identify and evaluate remedial <br /> alternatives, recommend a proposed remedy, and present an implementation plan for the <br /> recommended proposed remedy (Stantec, 2011b). The selected remedy presented in the Draft Final <br /> RAW includes excavation and off-site disposal of impacted soil located on-site, off-site in South <br /> Sacramento Street,and off-site to the south in the Lodi Iron Works property. <br /> TERRA PACIFIC GROUP Page 8 April 4, 2012 <br />