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20 . Page 4-18 Section 4 . 6.7 , Bullet 4 <br /> The ARARs for all chemicals of potential concern for soil , <br /> groundwater, and air will need to be submitted for <br /> regulatory review along with an evaluation of the "risk at <br /> AKAR" prior to any sampling. <br /> 21. Page 4-18 Section 4 . 6.7 , Bullet 5 <br /> Explain how a "negligible contribution to total risk" will <br /> be determined. <br /> 22 . Page 4-18 , Section 4.6.7 <br /> The criteria for selecting chemicals of concern slightly <br /> differ from those discussed at meetings on OU #1. Some of <br /> these criteria are inappropriate or inadequately justified. <br /> For example, all Class A carcinogens should be selected as <br /> chemicals of concern. <br /> 23. Page 4-27 Section 4 .7.4. 1, Paragraph 4 <br /> The reasonable maximum exposure (RME) concentration <br /> according to RAGS should be either the upper 95% confidence <br /> limit on the arithmetic mean or the maximum concentration <br /> value, whichever is smaller. <br /> 24 . Page 4-28 Section 4.7 .4 .2 , Bullet 1 <br /> There is no conclusive evidence that Well 7 is not <br /> contaminated. The draft BRA for OU #1 provides data that, r 7 <br /> indicates Well 7 , is contaminated with arsenic and mercury. S <br /> 25. Page 4-29 Section 4.7 . 4 . 5 , Paragraph 4 <br /> What models will be used to predict environmental fate and <br /> transport? These models should be submitted to EPA for <br /> approval prior to their use. <br /> 26. Page 4-30 Section 4.8. 1, Paragraph 3 <br /> Provide intake equations and initial exposure parameters. <br /> 27 . Page 4-31 Section 4.9. 1. Paragraph 1 <br /> What is the California toxicity guidance? Please provide <br /> references. <br /> 28. Page 4-33 Section 4 . 10 - 6. Sentence 1 <br /> The BRA makes no decisions regarding acceptable risks or <br /> risks that warrant remedial actions. Instead the BRA should <br /> II-5 <br />