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James L. Tjosvold Page 2 July 2, 1990 these substances must then be evaluated at the assumed concentrations. 7 The current standard for individual air inhalation is 23 cubic meters of air per day, not 20 as stated. 8 Table 1, applied action levels (DHS 1989) lists a soil applied action level (AAL) of 100 mg/kg for phenanthrene, but does not list AALs for other PAH compounds. The 100 mg/kg soil AAL is cumulative for all noncarcinogenic PAHs. Also note that other noncarcinogenic PAHs may be present which are not listed in Table 1. (See first comment. It also applies to the noncarcinogenic PAHs. ) Since the Department has not published soil AALs for carcinogenic PAHs, Table 2 must be expanded to include the appropriate cancer potency factors for these compounds. 3 . 2 . 4 9 For ingestion of soil, the current guidance states that ingestion rates should reflect infant, child, and adult age segments (See U.S. EPA 1989a) rather than assume a 150 mg/day lifetime average rate. 10 For dermal absorption of soil compounds, use the current guidance provided in U.S. EPA 1989a instead of the 450 mg/day value derived from the state document cited. The ingestion of ground water cannot be dismissed as a potential exposure route at this point. Simply stating that the developer does not intend the ground water to be utilized and that no contamination has been detected to date in wells installed by Kleinfelder does not obviate the need for evaluating potential future impacts. This issue must be addressed in the risk assessment. If ground water is deemed to be an insignificant exposure route, the risk assessment must justify such a determination. it The scenario put forth on top of Page 11, involving the construction of a swimming pool