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Harding Lawson Associates <br /> December 22, 1998 <br /> 4034405 <br /> Margaret Lagorio, Supervising REHS <br /> San Joaquin County Public Health Services <br /> Environmental Health Division <br /> ' Page 5 <br /> Decontamination of Drilling and Sampling Equipment <br /> Drilling equipment was steam cleaned prior to use Groundwater sampling equipment and soil sampling <br /> egmpment were washed in a residue-fiee detergent (such as Alconox, Liquinox, TSP, etc ) and rinsed in <br /> tap water and deionized water prior to each use <br /> 1 Waste Disposal <br /> All drill cuttings and decontamination water generated during drilling activities was retained on Site in <br /> clean, Department of'I ransportation-approved, 55-gallon steel drums, which were sealed and then labeled <br /> with the boring number and accumulation date Upon receipt of the analytical results, disposition of the <br /> cuttings and decontamination water was performed in accordance with local, state, and federal <br /> environmental and transportation laws <br /> Assessment of Risk to Human Health and Safety <br /> To evaluate whether impacted soils at the Site pose a risk to human health and safety, a Risk Based <br /> Corrective Action(RBCA) process was utilized The RBCA process is not a formal risk assessment per se, <br /> but rather, a consistent decision-making process for the assessment and response to a petroleum release <br /> based on the protection of human health and the environment The RBCA assessment was performed <br /> consistent with the American Society for Testing and Materials (ASTM) guidance document ASTM E <br /> 1739-95 entitled Standard Guide for Risk-Based Corrective Action Applied at Petroleum Release Sites <br /> (ASTM), 1995) Terminology in the following discussion is consistent with definitions presented in <br /> ASTM 1? 1739-95 (ASTM, 1995) Once it has been determined that theie is no immediate threat to health <br /> and safety, the first step in the RBCA piocess is the identification of chemicals of concern (CDCs) and <br /> reasonable potential exposure scenarios (RPES) fol the Site These RPESs are characterized in teims of <br /> primary and/or secondary sources, transport mechanisms, exposure pathways, and potential receptors <br /> ' An example of an RPES is the ingestion of impacted surficial soils by staff of the Newark Sierra plant <br /> A Tier 1 RBCA evaluation is performed by comparing the maximum concentrations of COCl with the risk- <br /> based screening level (RBSLs) associated with each RPES identified A Tier 1 RBSL is a generic (non-site <br /> specific), and therefore conservative value, calculated from reasonable maximum exposure intake <br /> assumptions (RME), toxicological parameters, and non-site specific physical parameters for site-media as <br /> recommended by the United States Environmental Protections Agency (USEPA) An RBSL is associated <br /> i with a given level of risk (generally for carcinogens this is a range of one-in-ten thousand to one-in-one <br /> million and for non-carcinogens a hazard quotientl of one or unity), the acceptable level of risk adopted <br /> for this assessment is a conservative one-in-one million for carcinogens and a hazard quotient of one for <br /> 1 non-carcinogens If the maximum concentrations of COCs exceed the RBSLs associated with any of the <br /> RPES identified for the Site, then the Site can be remediated to below the exceeded RBSL or a Tier 2 <br /> analysis can be performed In a Tier 2 analysis, concentrations of COCs are compared with site specific <br /> target levels (SSTLs) which are calculated with the same fate and transport equations by substituting site- <br /> specific intake assumptions and site media physical parameters for the generic default parameters If the <br /> maximum concentrations of COCs are less than relevant RBSLs (and the user is confident that the <br /> 1 o€a COC(s)over a specified time period to a reference dose for that COC(s)derived <br /> • 1 Hazard quotients-the ratio of the loves o€exposure O P <br /> for a srrrvlar exposure period in equation form this represented as Hazard quotient= average intake Inig1 kg day)(reference dose <br /> [uiWkg-day](ASTM,1995) <br /> 'fir <br />