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Department of Toxic Substances Control <br /> M <br /> Edwin F. Lowry, Director <br /> 10151 Croydon Way, Suite 3 <br /> Winston H. Hickox Sacramento, California 95827-2106 Gray Davis <br /> Agency Secretary Governor <br /> California Environmental <br /> Protection Agency <br /> April 12, 2001 <br /> Mr. Steve Pinkerton, Director <br /> Housing and Redevelopment <br /> City of Stockton <br /> 305 N. EI Dorado Street, Suite 200 <br /> Stockton, California 95202 <br /> NORTH SHORE PROPERTY, CITY OF STOCKTON: ADDENDUM TO THE <br /> REVISED FEASIBILITY COMMENTS <br /> Dear Mr. Pinkerton: <br /> Below are our comments on the Treadwell & Rollo Addendum to the Revised <br /> Feasibility Study (FS) dated February 28, 2001,. and the Treadwell & Rollo letter dated <br /> March 29, 2001: <br /> Using Preliminary Remedial Goals (PRG) as Remedial Action Objectives (RAOs) may <br /> be acceptable, but are not intended as stand-alone decision-making tools or to be <br /> used as a substitute for performing risk assessment. PRGs have limitations in their <br /> use since they do not consider all exposure pathways, including groundwater, and do <br /> not evaluate the potential additive effects of risk. For this reason, using PRGs as <br /> cleanup numbers may underestimate the risk by not considering multiple pathways <br /> with multiple contaminants. Conversely, PRG cleanup numbers may be lower than <br /> would be developed with a site-specific risk assessment. <br /> DTSC reviewed and approved the risk assessment for this Site and would have <br /> expected that RAOs were based on these site-specific risk calculations. DTSC <br /> provided assistance in determining a cleanup number for arsenic based on <br /> background numbers and these values have been incorporated into the FS. DTSC is <br /> willing to accept the proposed lead value of 750 ppm for industrial setting provided this <br /> is a maximum value for residual contamination. <br /> DTSC accepts the RAOs for PAHs proposed in Table 1 of the Treadwell & Rollo letter <br /> dated March 29, 2001. <br /> The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption. <br /> For a list of simple ways you can reduce demand and cut your energy costs.see our Web-site at www.disc.ca.gov. <br /> © Printed on Recycled Paper <br />