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�.f <br /> Comment on pg. 1, para. 4. <br /> This statement is erroneous. To date, the Department of Health Services (DHS) has not <br /> received a border zone request for the SPR property. Further review of the health risk <br /> assessment cannot proceed without this letter. <br /> Response to comment on Section 1, pg. 1, para. 4: <br /> A border zone determination request for APN 195-060-02, -03, -08, and -09 was sent <br /> to Mr. Allen Wolfenden, Chief, Technical Services Unit, from Mr. John T. Verner, <br /> owner of Verner Construction Company prior to April 6, 1989 (see Attachment 3). <br /> As indicated in "Response to comment on Section 1, pg. 1, para. 3:," above, the <br /> Segura Trucking Company site is not considered a hazardous site subject to border <br /> zone determination for the SPR property and subject HRA. <br /> Comment on Section 2.4 <br /> All toxic compounds likely to be contained in the disposal area should be identified and <br /> discussed. The possibility of migration of other fuel components via ground water should <br /> also be addressed. While monitoring soil gas for benzene is planned, Kleinfelder should be <br /> made aware that further sampling and analyses may be necessary, should the data so <br /> indicate. Kleinfelder should closely monitor the progress of the San Joaquin Local Health <br /> District's site assessment, and should inform DHS of the outcome of this assessment in a <br /> timely manner. <br /> Response to comment on Section 2.4: <br /> As indicated in 'Response to comment on Section 1, pg. 1, para. 3:," above, the <br /> Segura Trucking Company site is not considered a hazardous waste site subject to <br /> border zone determination for the SPR property. We will provide copies of our <br /> correspondences to both DHS and SJLHD. We assume we will also receive copies <br /> from both agencies to complete our file. <br /> Comment on Section 5.3 <br /> For a compound with no published DHS Toxic Substances Control Division Applied <br /> Action Level, U.S. Environmental Protection Agency (EPA) health-based criteria should <br /> be employed. Use of the EPA IRIS (Integrated Risk Information System) data base is <br /> recommended. "Target Concentrations" should only be derived when neither DHS nor <br /> U.S. EPA health-based criteria are available. <br /> Response to comment on Section 53: <br /> As requested, use of EPA IRIS (Integrated Risk Information System) data base will <br /> be employed for compounds with no DHS Toxic Substance Control Division <br /> Applied Action Level. Target concentrations will only be derived when neither <br /> DHS nor EPA health-based criteria are available. <br /> Comment on Section 5.4.3 <br /> Potential exposures attributed to the North Balloon Air Stripper should be estimated. <br /> KLELNFELDER 9795 Business Nark Drive, Suite C, Sacramento, CA 95827 (91i,) 36G1-'�l <br />