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... _,._ ...- .. ..... lei VU IIV IJ <br /> . Jerry Lile Page 2 <br /> February 2,2D05 <br /> HERD has partidpated•in numerous meetings and teleconferences, reviewed numerous <br /> documents,and provided written or oral comments on issues related to preparing an <br /> acceptable health risk assessment(HRA). <br /> GENERAL COMMENTS <br /> 1, DTSClHERD is coricerned'with the lack of progress towards the completion of an <br /> acceptable HRA. See SPECIFIC COMMENTS below for further details. <br /> 2. The area evaluated In the NRA encompassed the Delta Gateway Apartments and <br /> the remaining northeastern portion of the L&M OU that Is currently undeveloped <br /> Including to the midline of the former Harrison Street. <br /> 3. Please ensure consistent Identification of all sample locations in text,tables, maps, <br /> and appendices. <br /> 4. HERD has prepared the following Iisf of ADDITIONAL DOCUMENTATIONIDATA <br /> NEEDED to continue progress towards an acceptable HRA and the accompanying <br /> Tables of date gaps with recommended sampling locations,specified separateiyfor <br /> both-the apartment area and undeveloped area, and analytical methodologies. <br /> HERD'&rationale for repeating active soil gas sampling and analyses at the <br /> following.locations is based on non-detection (ND)with high detection Ilmka <br /> (supersenipted a)andforto confirm previous hits(superscripted b)at locations SV- <br /> 1a" SV-40, SV-7b,SV-8b,SV-10b,SVAJD° 5V-Ie,SV-14a° SV-15b,and sV-17°. <br /> • 5. To continue <br /> progress-towards-an acceptable HRA HERD recommends: <br /> a. Fill all soil gas data gaps prior to operation of an'SVE system,induding'not only <br /> soll'gas sampling and analyses but also collection of soil geotechnical data <br /> needed for predictive Indoor air modeling, <br /> b. Address the L&M OU as two areas of concern(AOCs),to expedite risk <br /> evaluations In the apartments'area. One A00 being the Deb View Apartments <br /> (the apartments'area)and the second AOC being the undeve"area. <br /> c. Provide the below listed ADDITIONAL DOCUMENTATION/DATA NEEDED. <br /> d. Collect supplemental data to address all date gaps oonsistenrwith a DTSC <br /> approved sampling and analyses work plan(for the apartments'area use"Work <br /> Plan for Collection of10ats for Human Health Risk Assassment for the L&M <br /> Operable Untr dated September 11,2003 by Earth Tech with modifications <br /> Identified in this memo and attached tables); <br /> e. Submit the complate data sets as well as the data sets propssed.for use in the <br /> .HRA for eadh AOC In electronic format to ensure site characterization Is adequate <br /> 'for tiRA purposes <br /> f. Prepare a separate revised HRA using a hot spot approacti for each AOC, <br /> consistent with comments provided In HERD's September 9,2004 and September, <br /> 2812004 memorands using the DTSC/HERD approved NRA data set. . <br /> • 0502621LdoC• <br />