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2900 - Site Mitigation Program
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PR0508450
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SITE INFORMATION AND CORRESPONDENCE
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Last modified
5/29/2019 11:58:23 AM
Creation date
5/29/2019 11:10:41 AM
Metadata
Fields
Template:
EHD - Public
ProgramCode
2900 - Site Mitigation Program
File Section
SITE INFORMATION AND CORRESPONDENCE
RECORD_ID
PR0508450
PE
2960
FACILITY_ID
FA0008087
FACILITY_NAME
DDJC-TRACY
STREET_NUMBER
25700
STREET_NAME
CHRISMAN
STREET_TYPE
RD
City
TRACY
Zip
95376
APN
25207002
CURRENT_STATUS
01
SITE_LOCATION
25700 CHRISMAN RD
P_LOCATION
99
P_DISTRICT
005
QC Status
Approved
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EHD - Public
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Subtask B: Exposure Assessment and <br /> Subtask D: Risk Characterization <br /> The choice of exposure scenarios in Subtask B of the revised risk <br /> assessment should be a "most likely" or average scenario and RME <br /> which incorporates upper 95% confidence limit for the mean data <br /> and RME exposure parameters (from Region 9 guidance) . Use of the <br /> worst-case scenario in risk assessment should be reserved for <br /> instances in which the RME cannot be calculated. <br /> Subtask C: Dose-Response Assessment <br /> No rationale is provided for the development of toxicological <br /> profiles for a maximum of eight chemicals. As stated earlier, <br /> little detail is provided in the present comments and the <br /> baseline risk assessment for the selection of chemicals of <br /> concern. The selection of a maximum of eight chemicals seems <br /> premature at this point. <br /> Subtask D: Risk Characterization <br /> Summing noncarcinogenic hazard quotients across pathways for each <br /> and/or all chemicals involves a number of limitations (see pages <br /> 8-14 in RAGS for a more detailed description) . Most importantly, <br /> summing noncarcinogenic hazard quotients should be applied to <br /> compounds that induce the same effect by the same mechanism of <br /> action otherwise there exists the potential to overestimate <br /> adverse health effects. <br /> GENERAL COMMENTS <br /> General Comment 1 <br /> The fact that most of the area is paved does not eliminate all <br /> contact with volatile solvents because the pavement may retard <br /> the volatilization of these solvents and may be a source for <br /> future exposure. Future development of cracks in the pavement <br /> may cause a localized release of volatile solvents and may be of <br /> concern to those present in the area. <br /> 7. General Comment 4 <br /> An indication of methods to be used to evaluate future plume <br /> development would be helpful (modeling, field sampling) . <br /> SPECIFIC COMMENTS <br /> Specific Comment 2 <br /> EPA suggests the use of "chemicals of concern" instead of <br /> "indicator chemicals. " Also, see earlier comment on "Hazard <br /> II-2 <br />
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