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Sete of'Californio • • Department of Health Services <br /> Memorandum <br /> To James L. Tjosvold Date: July 2 , 1990 <br /> Senior Waste Management Engineer <br /> Region 1 <br /> From <br /> Toxic Substances Control Program <br /> 10151 Croydon Way <br /> 855-7895 <br /> Subject : SOIL AND HEALTH RISK ASSESSMENT WORKPLAN - BECK DEVELOPMENT <br /> PROPERTY, TRACY <br /> I have reviewed the subject document. My comments are listed <br /> below with references to the Workplan section and page numbers. <br /> These comments also reflect suggestions and recommendations made <br /> by Dr. Yugal Luthra, Staff Toxicologist, in conversations with <br /> me. <br /> Since the Workplan conforms in general to the appropriate <br /> guidance documents, I recommend that we approve it, providing <br /> that our comments are adequately addressed in the risk <br /> assessment. <br /> My comments are: <br /> Section Pane Comment <br /> 3 . 2 .3 6 The statement that all of the PAH compounds <br /> detected in the deeper onsite soils are <br /> "suspected human noncarcinogens" implies that <br /> no carcinogenic PAH compounds exist in the <br /> soils. Such a statement is misleading in <br /> that such PAH species may be present at <br /> levels below the detection levels for the <br /> analytical method employed. <br /> In lieu of conducting another round of <br /> sampling and analysis using a more sensitive <br /> method, the EPA guidances (Workplan <br /> references U.S. EPA 1989a; 1986) allow the <br /> assumption of the presence of these <br /> substances at one-half of the method <br /> detection limits. The health effects of <br />