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Jeff Van Slooten <br /> Page 3 <br /> November 29 , 1989 <br /> area. The concentration of contaminants found at the <br /> McCormick and Baxter site could contribute to <br /> contamination of the slough and the aquatic life <br /> therein. The slough does represent an "unique" habitat <br /> in that aquatic species found there attract local <br /> residents for fishing. <br /> In the evaluation of on-site workers ' exposure, the use <br /> of Occupational Safety and Health Administration (OSHA) <br /> Permissible Exposure Limit (PEL) levels may be <br /> appropriate. However, off-site workers and residents <br /> must be evaluated using health based criteria (such as <br /> Environmental Protection Agency (EPA) Cancer Potency <br /> Factors or DHS Applied Action Levels, (AALs) ) . The <br /> trespass scenario and the possible future residential <br /> use scenario must also use health based criteria. <br /> Another possible exposure scenario that is not <br /> addressed is the casual visitor or worker at the site, <br /> e.g. delivery truck drivers. If the air modeling <br /> results presented in Table B-2 are correct, off-site <br /> workers are at risk to exposures that pose more than a <br /> 10-6 cancer risk from both arsenic and PCP. <br /> Current residents must be included in the potentially <br /> exposed populations. What about the nearby school? <br /> Are students exposed to dust from vehicular traffic <br /> exiting the site? <br /> References must be supplied for the assumptions used to <br /> calculate worker' s exposure. Forty years, not 30, is <br /> usually used to estimate the work time exposure and 10 <br /> m3/day is an underestimate =or workers involved in even <br /> light labor. <br /> 5 . Apparent errors in some of tables and the textual <br /> discussion of these tables makes it difficult to <br /> independently evaluate the conclusions drawn in the <br /> report. For example, ._In Figure C-1 of Volume 3 , a <br /> graph of PCP discharge 'to Stockton Regional Wastewater <br /> Control Facility (SRWCF) is presented. According to <br /> the legends, the numbers are in thousand of pounds. In <br /> 1988 , only half a year is shown on the graph. Does <br /> that mean that 6, 600 , 000 pounds were released in the <br /> entire year of 1988 or is the 3 , 300, 000 pounds for the <br /> entire year? The text, page C-7 , states that the <br /> current discharge rate is 3 , 300 pounds per year. <br /> Another example is found in the PHA, page 3-3 and Table <br /> 3-8 , where PCP concentration in storm water is listed <br /> as 7 , 915. 7 mg/ml in the tale but the text discusses a <br />