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L E A R WTt, A EALTh <br /> G R O U P, I N3C. <br /> Environmenn r , ' 05 <br /> Mr. Michael Infurna October 29, 1996 <br /> San Joaquin County PHS/EHD <br /> P. O. Box 388 <br /> Stockton, CA 95201-0388 <br /> Re: Togo's Property/MBP Site, Lodi <br /> Dear Mr. Infurna, <br /> Thank you for your phone call last week informing me of the TRC's decision <br /> regarding the Togo's request for closure. I agree that closure based on overall threat <br /> of the UST-related contaminants to health and the environment is appropriate. <br /> As we briefly discussed, you will soon receive a workplan describing proposed <br /> methods to investigate the source and the upgradient/cross-gradient extent of <br /> hydrocarbon contamination on the MBP property. The workplan will also establish <br /> a basis for not further assessing the subsurface south of Lodi Avenue, as this appears <br /> to have been sufficiently addressed by others (as evidenced by the TRC decision <br /> yesterday). As you are aware, groundwater beneath the current Togo's property has <br /> been shown to likely have been impacted by releases from the former service <br /> stations at that site, as well as possibly from releases associated with other sources. It <br /> will probably not be possible to distinguish one release from another beneath the <br /> Togo's property. As such, the PHS/EHD overall risk approach should continue to be <br /> applied to this area, in lieu of further assessment. <br /> An approach to longer term management of the MBP site will be contemplated <br /> following receipt of results of the next phase of site characterization. As we <br /> discussed, if levels of contamination are found to be comparable to those evidenced <br /> at the Togo's site, a request for similar consideration will likely be prepared. These <br /> discussions will include a summary of plans for the site regarding actions that may <br /> be taken in association with 1998 UST compliance requirements. <br /> 520 Third Street,Suite 104 ♦ Oakland,California 94607 + Telephone 510-893-5160 • Fax 510-893-5947 <br />