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Mr. Jim Levy <br /> June 14, 2006 <br /> Page 3 <br /> affected by the high bias. It is unwise to dismiss this high bias as not significant <br /> without sufficient documentation and/or study to support these claims. <br /> 8. Page 22, Section 5.2 Analytical Results. Reference is made to Preliminary <br /> Remediation Goal (PRGs) and California Human Health Screening Level <br /> (CHHSLs) that are health-risk based concentrations. As stated in the Disclaimer <br /> of the Use of California Human Health, Screening Levels in Evaluation of <br /> Contaminated Properties the document and the Human Health Screening Levels <br /> presented are not to serve as 1) a stand alone decision making tool; 2) a <br /> substitute for guidance for the preparation of a baseline human health risk <br /> assessment; 3) to be used to determine if a waste is hazardous; 4) a rule for <br /> determining if a release must be reported; 5) to set final cleanup or action levels <br /> to be applied at contaminated sites; or 6) to guarantee that oversight will <br /> determine that project is adequately studied or agree with conclusions of the site <br /> investigation and risk assessment report. Additionally, the results should also be <br /> compared to site-specific background concentration for each contaminant. <br /> Although the individual constituents found at the site indicate lower risk level, a <br /> baseline Human Health Risk Assessment which takes into account all <br /> contaminants would still be required as part of the investigation. <br /> 9. Page 22, Section 5.3 OU 1, and Figure 5. Please clarify the location for the <br /> following borings: OU1 AOI 3-S1, OW A013-S3, OW AOI-S5, and OW A013- <br /> S10. The text is inconsistent with the locations shown on figures 3 through 5. <br /> 10.Figures. Figures 2 through 9 outline the parking lot in the commercial area as <br /> part of OU4. This area has not been identified in previous documents; therefore, <br /> no historical data has been presented. If this area is part of OU 4, additional site <br /> characterization will need to be conducted to evaluate if this area has been <br /> impacted by past activities. <br /> 11 .Appendix A. The boring logs are not clear with regard to the column identified as <br /> "Type & No". Please clarify what these mean. In addition, the logs should show <br /> the depth where samples were collected and where ground water was <br /> encountered. <br /> 12.Appendix A. There are some discrepancies (i.e., see Boring OU1-AO12-S3, neat <br /> cement to 12 feet and total depth of boring only 4 ft. bgs) in some of the boring <br /> logs that need to be addressed. <br />