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Jerry the Page 2 <br /> Fsbruery 2,2005 <br /> HERD has participated-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, DISC/HERD is coricemed'with the lack of progress towards the completion of an <br /> acceptable HRA, See SPECIPIC COMMENTS below for further details. <br /> 2. The area evaluated In the NRA encompassed the Dena 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 locatlons in text,tables, maps, <br /> and appendices. <br /> 4. HERD has prepared the following lisf of ADDITIONAL DOCUMENTATIONIDATA <br /> NEEDED to continue progress towards an acceptable HRA and the accompanying <br /> Tables of data gaps with recommended sampling locations,specified separately for <br /> both-the apartment area and undeveloped area, and anafyttoal methodologies. <br /> HERD's rationale for repeating active soil gats sampling and analyses at the <br /> following.locations Is based on non-detection (ND)with high detection limb <br /> (superscnpted a)andforto confirm previous hits(superscripted b)at locations SV- <br /> 16D, SV-4 , SV-711,SV-8b, SV-1011,SV-11°h,SV-13b, SV-14�b,SV-151,and SV-176. . <br /> 5. To confanue progress-towards-an acceptable HRA HERD recommends., <br /> a. Fill all soil gas data gaps prior to operation of an'SVE system,lncluding,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 (ADCs),to expedite risk ; <br /> evaluations in the apartments'area. One AOC being the Dt to Mew Apartments <br /> (the apartments'area)and the second AOC being the undeveloped area. <br /> c. Provide the below listed ADDITIONAL DOCUMENTATIONIDATA NEEDED. <br /> d. Collect supplemental data to address all data gaps consistent Wdh a DTSC <br /> approved sampling and analyses work plan(for the apartments'area use"Work <br /> Plan for Collection of Data for Human Health Risk Assessment for the L&M <br /> Operable Unit"dated September 11,2003 by Earth Tech with modifications <br /> identified in this memo and attached tables),- <br /> e. <br /> ables),e. Subrnh the complete data sets as well as The data sets propose flbr use in the <br /> HRA for eadh AOC In elacb 1c:format to ensure site characterization is adequate <br /> 'for 11RA 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 /> 28,20011 memoranda using the DTSCIHERD approved HRA data set, <br /> - OS02021Ldoe• - - , <br />