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ARCADES BBL Mr. Brian Taylor <br /> July 27,2007 <br /> For example, prediction of indoor air vapor concentrations for buildings is an area of <br /> uncertainty. However, the air exposure models incorporated into GW-SCREEN are <br /> based on equations recommended by Cal-EPA DTSC and USEPA which provide a <br /> very conservative overestimate of indoor air concentrations for most cases, which in <br /> turn will result in an overestimate of risks. The degree to which this may impact the <br /> estimated risks and hazards was not quantified. <br /> The degradability of volatile petroleum hydrocarbons in groundwater was not <br /> considered in this evaluation, though a significant decline in concentrations over the <br /> 25 year exposure duration is likely, suggesting that that risk and hazard estimates <br /> presented herein have been overestimated. Use of petroleum hydrocarbon <br /> groundwater data to evaluate potential onsite indoor air exposures, without <br /> considering natural attenuation mechanisms known to affect petroleum <br /> hydrocarbons, is likely to overestimate risks and hazards for onsite workers. <br /> However, the degree to which this may impact risk and hazard estimates cannot be <br /> quantitatively determined. <br /> Although detected in groundwater monitoring wells beneath the footprint of the office <br /> building, neither TBA or TAME were selected as COPCs. Inhalation toxicity criteria <br /> for these oxygenates have not been established by either Cal-EPA or USEPA, and <br /> thus it is uncertain that exposures to these chemicals in indoor air vapor may pose <br /> adverse health effects. Regardless, both Cal-EPA OEHHA(1999)and the American <br /> Petroleum Institute(API, 2005)have derived oral toxicity criteria for TBA. Cal-EPA <br /> OEHHA has derived an oral cancer slope factor(CSF)of 3 x 10-3(mg/kg-day)"' and <br /> API has derived an oral reference dose (RfD)of 0.22 mglkg-day.Assuming route-to- <br /> route extrapolation of the OEHHA-derived oral CSF results in an estimated excess <br /> cancer risk of 7 x 10-9,while use of the API-derived oral RfD results in a hazard index <br /> of 3 x 10-6.These levels would not significantly affect the overall estimated excess <br /> cancer risk and hazard index presented in this evaluation. <br /> The RWQCB also raised concerns associated with the potential inhalation hazard <br /> posed by the office shower.The shower located within the office building is expected <br /> to only be used for emergency dousing if a worker is sprayed by petroleum product. <br /> The emergency shower is supplied by WSW-1. Since the only COPCs detected in <br /> WSW-1 are xylenes, and they were detected at very low concentrations, exposure <br /> associated with emergency showering is likely to be negligible as compared to the <br /> vapor intrusion pathway. <br /> Finally, this evaluation was based on use of the maximum detected groundwater <br /> COPC concentrations as a source beneath the onsite office building.Typically,the <br /> 95 percent upper confidence limits of the mean groundwater concentrations of the <br /> COPCs are also evaluated, because they are likely to be more representative <br /> Page: <br /> c:mxnnomniro+ni roa��oo iwinaGs�.iur .mo 5/7 <br />