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<br /> NO TEch ENTERPRiSES RECENED
<br /> 19 December 2002 D E C 2 3 2002
<br /> To: Ms. Margaret Lagorio, Supervisor ENVIRONMENT HEALTH
<br /> Environmental Health Department PERMIT/SERVICES
<br /> San Joaquin Public Health Services
<br /> 304 East Weber Avenue--Third Floor
<br /> Stockton, CA 95202
<br /> From: Edward W. Finucane, PE, QEP, CSP, CIH
<br /> Subject: Standards for non-hazardous concentration levels of various chemicals found to be in pri-
<br /> vate septic tanks
<br /> Thank you for your help in this area. My principal expertise, as you may know, is focused in the area
<br /> of the concentrations of various chemicals in the ambient air;however, since I am a credentialed Envi-
<br /> ronmental Professional, I intend to learn more about the various standards that apply to groundwater, in
<br /> - general;-andto'tlie contents of septic tanks,n' particular. 'I'561ieve that ilie EPA gtound°and drinking
<br /> water web site URL you provided me will likely be very helpful in this quest;-I have already down-
<br /> loaded and printed out more than 100 pages from this site. I plan eventually to wade through all these
<br /> documents and hope, in the end, to discover the acceptable standard concentration levels of various
<br /> chemicals in septic tanks, and by extension even in the groundwater.
<br /> I attempted to call Elizabeth Janes of the EPA's Region 9 in San Francisco, and discovered that the
<br /> phone number you had provided was no longer in service—the operator claimed that it had not been a
<br /> working number for more than one year. Her current correct phone number is (415) 972-3537. Al-
<br /> though I have not yet been able to speak with her,I did leave her a long voice mail request, asking for
<br /> these same standards, etc.
<br /> My principal concerns in this area stem, in part, from a couple conversations I have had with Mike In-
<br /> furna. I will try to summarize the aspects of these conversations that continue to trouble me:
<br /> 1. Mr. Infurna informed me that the presence in a septic tank of any of the component chemicals that
<br /> make up vehicle gasoline (which he identified as an extremely hazardous material) clearly indicates
<br /> that gasoline has been illegally disposed of in a manner that resulted in these materials being in the
<br /> septic system. I suggested the possibility that gasoline might have reached the septic system be-
<br /> cause the home owners washed items of clothing onto which gasoline had been spilled. In my
<br /> judgment, this type of process is far more likely to have occurred,than one in which someone inten-
<br /> tionally poured gasoline into a toilet, or a sink, or a tub. Mr. Infurna informed me that'if a person
<br /> were to have clothing on which there had been a gasoline spill, that the only acceptable procedure for
<br /> handling this situation would be for that individual to notify the local Fire Department, asking them
<br /> to pick up the co3itaminated item(s) rind-see,to its(their)proper disposal-as-a serious health hazard. I
<br /> would guess that clothing manufacturers would love to see such a mandate. Mr. Infurna informed
<br /> me that, under no circumstances, could such clothing be washed or treated in any manner that might
<br /> cause the gasoline that had spilled on it to be transported into a septic system. I consider his view-
<br /> point on this matter to be EXTREME to the point of absolute absurdity. '
<br /> 2. Mr. Infurna and I discussed the presence of 96 pgA of acetone (clearly not a component of gasoline)
<br /> in the Miller's septic system. I can think of many possible innocent procedures under which ace-
<br /> tone might get into a septic system; however, my point here is not the fact that this material was
<br /> found in this septic tank. My focus relates to the acetone concentration in the septic tank. As you
<br /> know, 96 pg/1 is, in effect, a mass based concentration of 96 ppb(mass). The established OSHA 8-
<br /> hour Time Weighted Average Permissible Exposure Limit Standard [PEL(TWA)] for acetone in the
<br /> ambient air is 1,000.ppm(vol), which under Normal Temperature and Pressure [25° C, I atmosphere
<br /> barometric pressure] would be approximately 2,037 ppm(mass), or 2,037,000 ppb(mass). These
<br /> data mean, in effect, that acetone is a fairly non-toxic chemical. An individual can work for 8-hours
<br /> each day in an atmosphere where the acetone concentration is 2,037,000 ppb(mass) and experience
<br /> absolutely no harmful physiological effects. Acetone's IDLH of 21,000 ppm(vol), or roughly 2%,
<br /> is slightly greater than its lower explosive limit(LEL). In addition, acetone is a byproduct of normal
<br /> Telephone: Address:
<br /> (20 9) 473-1113 l=ax: (209) 473-1114 FbotOffice 13ox7a35
<br /> (8 00) 2 21-959 5 http://www.hi-tech-ent.com Stockton,GA 95267-0835
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