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that addressed issues of particular importance to the RI/FS are briefly reiterated, <br />and in some cases expanded upon, below. Page references to the Supplementary Soil <br />Investigation Plan are provided in parentheses. <br />16. SHAD states that the groundwater pathway has been qualitatively identified as <br />representing the most significant risk to human health, and contends that direct <br />exposure to contaminated soil and inhalation of dust (from contaminants already <br />identified) do not represent significant human health or environmental risks (pg. 3-2, <br />paragraph 1). The plan cites a study that was then in preparation to support this <br />claim, but the cited report was not referenced in the list of references. What is the <br />basis for the conclusion? <br />17. Regarding the significance of the risk from exposure to soils, it is not possible to <br />evaluate the health risks from exposure to soils that have not been adequately <br />characterized. Since one of the purposes of the supplemental soil investigation is to <br />characterize those soils, it appears that SHAD is making a circular argument in <br />recommending that future characterization of soil contamination should be restricted <br />to compounds already identified in soils, or to those identified in another medium <br />(groundwater). The sampling plan should target compounds that are known to have <br />been used, stored, or disposed of at a particular site. <br />18. SHAD contends that all of the contaminants at certain sites (the fire -training area is <br />the only example provided) were introduced into the environment in the same manner <br />and therefore would be expected to have the same spatial distributions (pg. 3-2, <br />paragraph 2). <br />We agree that all information available to SHAD should be used if it may help <br />narrow the search for contaminant compounds and may provide clues as to their <br />distribution at specific potential source areas. But field verification of assumptions <br />about the types and distributions of compounds is still required. Compounds with low <br />attenuations in soil, such as TCE and other solvents can be expected to reach <br />groundwater long before compounds that are of greater concern in terms of health <br />risk such as dioxins, PCBs, chlorinated phenols, pesticides, polycyclic aromatic <br />hydrocarbons (PAHs), heavy metals and many others expected to be present in some <br />areas of the depot. (See preceding comment.) <br />8 <br />