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TECHNICAL RESPONSES <br /> Response to Comments--July 27 Letter from J. Allen <br /> Paragraph Response <br /> 2 The major focus of the preliminary PHERA, <br /> which was submitted in December 1987 , <br /> and approved by the DHS and CVRWQCB, was <br /> to identify those areas of most public <br /> health concern in order to focus the <br /> scope and schedule of the work and pro- <br /> vide interim remedial measures if <br /> necessary. The most important need <br /> identified was to obtain additional <br /> hydrogeologic information necessary to <br /> complete assessment of the groundwater. <br /> Exposure of the public to offsite air- <br /> borne contaminants was carefully anal- <br /> yzed and was determined not to present a <br /> health hazard. The Preliminary Site <br /> Assessment for Dioxins, which was sub- <br /> mitted in October 1987 , focused on the <br /> dioxins issue. The preliminary assess- <br /> ment indicated dioxins would not present <br /> a health hazard. The DHS insinuation <br /> that dioxins and offsite air-borne ex- <br /> posure is of immediate importance has not <br /> been shown. <br /> Regarding Dioxins <br /> 2 The Preliminary Site Assessment for Dio- <br /> xins, October 1987 , concluded that <br /> dioxins are not expected to be a problem <br /> and M&B ' s plant site. Based on this <br /> assessment we feel the proposed schedule <br /> to begin sampling in April 1989 (with a <br /> report, including related PHERA, sched- <br /> uled to be completed four months later) <br /> addresses this issue in a manner con- <br /> sistent with the importance of the issue. <br /> Findings from the Preliminary Site As- <br /> sessment for Dioxins that support this <br /> approach include: <br /> o Dioxins are a trace contaminant in <br /> pentachlorophenol and will be found <br /> at proportionate levels where <br /> pentachlorophenol is found. In the <br /> process area and old oily waste pond <br /> area where pentachlorophenol is <br />