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Jerry dile <br /> June 5, 2000 <br /> Page 2 <br /> COMMENTS <br /> 1. Section 2.3 (Selection of Chemicals of Concern) <br /> HERD requests that any elimination of chemicals of concern for the purposes of <br /> quantitative risk assessment be approved by HERD and the SMP prior to the <br /> submission of a formal risk assessment. This approval need not be conducted in <br /> so formal a manner so as to require a formal report, and may be conducted in <br /> any forum (conference call, e-mail, etc.) acceptable to SMP. <br /> 2. Section 3.2 (Toxicity Assessment), Page 13, 14 <br /> The primary source of cancer slope factors and noncancer reference doses for <br /> this exercise should be obtained from the Cal-EPA Office of Environmental <br /> Health Hazard Assessment Toxicity Criteria Database at the web address: <br /> http://www.oehha.ca.gov/risk/chemicalDBfndex.asp <br /> Please use this prior to use of the other listed information sources. Please note <br /> that the reference source for the U.S. EPA Health Effects Assessment Summary <br /> Tables ("EPA 1997b") is missing from the work plan. No action is suggested, as <br /> the EPA has stopped publishing this document and the other cited sources <br /> (OEHHA, IRIS, NCEA) should suffice. <br /> Also, please note that (last paragraph on page 14) Cal-EPA has both a unit risk <br /> factor for lead as a carcinogen and a lead hazard assessment model <br /> (Leadspread 7; found at http://www.cwo.com/herdl). The latter is recommended <br /> for evaluation of lead health impact at these properties. <br /> 3. Section 5.2 (Remedial Goals) <br /> HERD recommends that any media-specific screening values not be termed 'remedial <br /> goals" only to allow more flexibility for the project manager to achieve the desired level <br /> of risk where multiple chemicals are present since there is no unique solution to the <br /> equation Chemical A concentration + Chemical B concentration + Chemical C <br /> concentration = Risk D. The methodology used to calculate these remains unchanged. <br /> Other than the concerns listed above, the work plan is satisfactory, and need not be <br /> revised if this memorandum accompanies the document in the administrative record <br /> and is considered an amendment to the work plan itself. <br /> If you have any questions, please feel free to contact me at (916) 327-2517. <br />