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- � � �FARR ASSOCIATES <br /> = Environmental Engineering and Geohydrology <br /> OO OCT 23 P9 00 <br /> October 16, 2000 <br /> via facsimile and U.S. Mail <br /> Mark Adams, Trustee <br /> Lincoln Center Environmental Remediation Trust <br /> Point Environmental <br /> 137 Park Place <br /> Richmond, CA 94801 <br /> Subject: LPL Review of LFR's Revised Draft Health Risk Assessment, Lincoln Center, <br /> Stockton, California <br /> Dear Mr. Adams: <br /> On behalf of Lincoln Properties, Ltd. ("LPL"), Farr Associates submits the following comments <br /> on Levine-Fricke-Recon's ("LFR's") Revised Draft Health Risk Assessment (Draft HRA), dated <br /> August 30, 2000. LPL appreciates the opportunity to review this document and provide the <br /> following comments for your consideration. In summary, LPL believes the estimated health risks <br /> associated with vapor inhalation presented in the Draft HRA are inaccurate due to shortcomings <br /> in the vapor-transport and indoor-air modeling analysis presented in Appendix A. Because LFR <br /> has disregarded LPL's previous comments over the past 16 months on the interim deliverables <br /> leading up to the Draft HRA, LPL believes it is important to re-state several important comments <br /> here for the record. LPL's re-stated comments, along with additional comments are presented <br /> below. <br /> General Comments <br /> I. The repeated references to the "150 micrograms per liter of PCE in soil vapor" as meeting <br /> cleanup goal(s) for the Site (e.g., pages viii, 1, and 29) need to be removed from the HRA. <br /> The purpose of an HRA is not to establish cleanup goals, and LPL believes much more <br /> work needs to be completed, separately from the HRA effort, to develop a defensible set <br /> of cleanup goals for the Site. The"150 micrograms per liter of PCE in soil vapor" number <br /> is irrelevant in the Lincoln Center case, considering that LFR represents it to be a soil- <br /> vapor concentration relevant in cases where commercial/industrial land-use restrictions <br /> apply. Residential cleanup standards are applicable to the remediation of Lincoln Center <br /> due to the lack of restricted land use and the potential for future residential development <br /> on all or part(s) of the current property. Finally, the 150 micrograms per liter PCE <br /> concentration is not accompanied by a required description and justification of the analysis <br /> method, and/or supporting calculations. <br /> Juhn6m cklyFile,\I,PL1l etters\letH11600HR.A.wpd <br /> 6016 Princeton Reach Way • Granite Bay, California 95746 Tel. (916)781-9327 • Fax(916) 781-9357 <br />