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r+ <br /> Department of Toxic Substances Control y: .. <br /> j <br /> Alar:C.Lloyd,Ph.D. <br /> 1515 Tolihpuse Road Arnold schwarzenegger <br /> Agency Secretary Clovis, California 93611 Governor <br /> CaVEPA <br /> 'i <br /> ;j <br /> Jelly 1 , 2005 <br /> Mr. Steve Johnson, Operations Manager <br /> American Moulding and Millwork Company <br /> 2801 West Lane <br /> Stockton, California 95204 f <br /> d <br /> SUPPLEMENTAL SITE ASSESSMENT AND COMPREHENSIVE RISK ASSESSMENT <br /> WORK PLAN; AMERICAN MOULDING AND MILLWORK COMPANY, 2801 NORTH <br /> WEST LANE, STOCKTON, CALIFORNIA <br /> Dear Mr. Johnson: `�jE <br /> The California Environmental Protection Agency, Department of Toxic Substances <br /> Control (DISC) has reviewed the subject workplan"dated April 21, 2005(Workplan) <br /> prepared by MACTEC Engineering and Consulting`, Inc (MACTEC). The DTSC Fresno <br /> Responsible Party Unit (FRPU) requested that DTSC Human and Ecological Risk <br /> Division (HERD) conduct a detailed review of the submitted Workplan to determine if <br /> the proposed scope of work would provide appropriate data for the comprehensive risk <br /> assessment (RA). The HERD review memorandum, dated June 16, 2005 is enclosed <br /> with this letter. <br /> Ei <br /> J. <br /> f <br /> Within the review memorandum provided byEHERD, Dr. Yugal Luthra has presented <br /> several issues to be addressed. Such issues include the recommendation that a "Nw <br /> Further Action" determination for specific areas is not appropriate for the RA and that <br /> chernicals of concern within these areas still need to be included within the cumulative <br /> risk. HERD recommends that previous and supplemental investigation data should be <br /> submitted for evaluation of their adequacy. HERD comments from Dr. Luthra also <br /> presented two issues for the FRPWProject Geologist and DTSC Industrial <br /> Hygiene/Safety Section (IHSS). These issues are discussed below. <br /> �I <br /> 't• Section 5.4.1.4 of the Work pfan indicates that "typical" background <br /> concentrations for metals will be provided "as known to the DTSC." DTSC does <br /> not currently maintain a database of"background concentrations" for comparison <br /> purposes. Therefore, a minimum of four offsite locations must be sampled at the <br /> surface (0 to 6 inches) to determine background or ambient levels of heavy <br /> metals in the area. The samples must be collected near the site, preferably one <br /> from each of the four sides. The soil type of the offsite samples should be the :' <br /> same as the site samples, and if possible, the offsite samples should be <br /> TM 1.'.?5 <br /> P.n:ed;Dn Recyued 'aper <br /> +.3 <br /> Ni w <br />