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' Jerry Life ' December 10, 2003 Page 7 from any other potential or actual sources of release on the Surland Homes property ' were not evaluated. HERD disagrees with the conclusion that no further action is required. Soil and ' groundwater data demonstrate impacts by petroleum contamination; however the data are not sufficient to draw conclusions regarding potential human health risks. Accordingly, HERD does not agree with the results of the screening level human health risk evaluation that estimated a total hazard index of 0.03 and a total risk of 1 x 10-6, with risk from groundwater exposures estimated at 1 x 10-6. HERD requests information regarding the depths of the OVP and APL, whether the ' - pipelines have been removed,and the source of the backfill. Furthermore,HERD requests amendment of maps to depict the locations, or former locations, of the OVP and APL pipelines. HERD recommends additional soil and groundwater sampling and ' analysis for metals, since no data exist. HERD advises analyses of unfiltered groundwater samples for PAHs, and BTEX, in addition to metals. HERD also advises analyses of soil samples from both visually impacted soil and shallower soils for PAHs, BTEX, and metals. HERD suggests this additional sampling from soil depths appropriate for residential receptors. HERD recognizes that residences are currently located in the Surland Homes area of ' petroleum impact. HERD is available to discuss options for location of soil and groundwater sample collection, after receipt of information requested above on pipeline locations. It may be possible to collect data from immediately adjacent to the Surland ' Homes property in the Southern Pacific Railroad right-of-way and/or West Side Irrigation District right-of-way. ' HERD recommends soil and groundwater samples from 3 borings in the railroad right- of-way and West Side Irrigation District areas from immediately adjacent to the Surland Homes property with analyses for TPH, metals, PAHs and BTEX from unfiltered groundwater and soil from 0, 2, 5, and 10 ft bgs, as well as depths at which the soil is ' the most visually impacted and the interface of visually impacted/no visual impact. BTEX analyses need not be applied to soil from 0 ft bgs. t Subsequent to establishing a data set sufficient for a screening human health risk evaluation, HERD recommends preparation and submission of a revised Human Health Screening Evaluation document consistent with the comments herein. HERD proposes ' inclusion of a cover letter stating how each of the comments herein has been addressed. Any changes In the document that are not made in response to the reviewer's comments should be identified and the reason for the changes clearly specified. ' Please contact me at (916) 255-6633 if you have any questions. 1 1