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Jeff Van Slooten <br /> Page 5 <br /> November 29 , 1989 <br /> 9 . In the RAP, it is stated that there will be an <br /> increased discharge of ground water to the SRWCF. Is <br /> there any indication that the discharge will contain <br /> any chemicals of concern above the aquatic AAL levels? <br /> Will the sludge be analyzed for increased levels of <br /> contaminants? <br /> III. Specific Comments - These minor points must be addressed <br /> before the Public Health Assessment is finalized. <br /> RAP, page 2-2 . In the first paragraph "les toxic zone" <br /> should be "less toxic zinc" . <br /> RAP, page 2-3 . Remedial goals are mentioned, but could not <br /> be located in this document. Again, this document must be <br /> able to "stand alone" . <br /> RAP, page 4-2 . Background levels for PCP and polycyclic <br /> aromatic hydrocarbons (PAH) in soil are stated to be less <br /> than the detection limit of 10 ug/kg. However, values <br /> presented in Tables 3-1 through 3-4 of Volume 2 show widely <br /> divergent values for the detection limits. <br /> PHA, page 2-1. Lead and cadmium must be addressed as <br /> contaminants in both soil and water since there was a former <br /> battery recycling facility at the site. In the RAP, page <br /> 5-3 , it is stated that both lead and cadmium levels exceed <br /> the water quality standards. These levels must be <br /> cruantified and included in the risk assessment. <br /> PHA, page 3-2 . Background levels for metals should not be <br /> determined on site but from an uncontaminated nearby area. <br /> The values listed for background levels on page 3-2 of <br /> Volume 2 have all increased from the values given in the <br /> Preliminary PHA dated January 18 . 1989 . The rationale for <br /> these changes should be presented. <br /> PHA, Tables 3-1 through 3-4 , Some of the values for soil <br /> sampling do not have superscripts to indicate the depth of <br /> the sample. In this same series of tables, the average <br /> concentration is sometimes presented as a value below the <br /> detection limit. <br /> PHA, page 3-4 . Setting non-detects in ground water to an <br /> arbitrary value of zero underestimates the concentration and <br /> therefore the risk. See attached Toxicology and Risk <br /> Assessment Unit Scientific Guidance Memo 89-2 . <br />