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Tracie Billington, P.E. <br /> August 5, 1991 <br /> *age 2 <br /> Section 4 . 0. Exposure Assessment: The Environmental Fate <br /> and Transport section should be part of this section. A table <br /> summarizing complete exposure pathways also should be included. <br /> See exhibit 6-8 of RAGS manual (1989) . In addition, a summary of <br /> exposure concentrations should be included. See exhibit 6-10, <br /> RAGS manual (1989) for tabulating all the chemicals of concern. <br /> Exclusion of any contaminant and exposure pathway(s) should b <br /> justified. <br /> Section 4 .3 . 3 . Exposure Pathway Analysis: Exposure to <br /> contaminants via consumption of agricultural products is "not <br /> expected to contribute significantly to the potential risks <br /> because of the volatile nature of the contaminants identified at <br /> the site" . It is unclear whether this reasoning applies to <br /> potential for plant uptake. <br /> Table 4-4 : A footnote explaining the derived values would <br /> be very useful. <br /> Section 4 . 7 .2 . Dermal Contact: The elimination of this <br /> pathway is not a reasonable assumption. A quantitative <br /> evaluation should be carried out to assess its significance. <br /> Default assumptions should be included. <br /> Section 5. 0. Risk Characterization: It would be helpful in <br /> evaluating risk by presenting tabulated data separately for <br /> current and future land use as baseline risk assessment <br /> components. <br /> Table 5-1 does not contain the cancer potency factors for <br /> the inhalation route, although this route of exposure was <br /> considered in the exposure assessment. The default assumption <br /> should also be included. <br /> Table 5-2 through 5-7: Are the risks under current or <br /> future land use? What are units of mean and maximum <br /> concentration? Cancer risk and hazard indices should be <br /> presented as shown in exhibits 8-2 and 8-3 of the RAGS manual <br /> (1989) . <br /> Recommendations/Comments <br /> The major flaw in this document is that the RAGS guidelines <br /> for format and content were only followed partially. Information <br /> and data need to be presented in a manner to facilitate review <br /> and evaluate risk. References and footnotes should be included <br /> where appropriate. <br />