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Paragraph Response present at high concentrations in the soils and therefore the potential for dioxins are the greatest, dioxin levels were calculated to be at very low levels and the most toxic dioxins were estimated to be below detection. o Most of the site, including the perimeter area adjacent to roadways , has very low or nondetectable pentachlorophenol levels and, therefore, dioxin levels will be insignificant. o A fence around the site perimeter and plant security prevent trespassing at the site. o McCormick and Baxter is protecting the public health by preventing public access to a site where the dioxins are believed to be below health risk levels. 2 Our proposed Work Plan scope will provide the necessary data to determine if dio- xins are or are not a issue at our site. This scope is a practical first step to- wards resolving this issue. We disagree with the DHS ' s continued insinuation that dioxins present a immediate threat to public health at our site. In our opin- ion, data and existing literature support our conclusion that dioxins do not pose a health threat. Comparing our site to the DHS recommended guidelines for a similar wood treating plant in California, with a much greater potential for dioxins due to a penta- chlorophenol fire, the levels of dioxins at our site should be below health risk levels. In the Preliminary Incident Re- port on the Koppers-Oroville Fire, November 9 , 1987 by Kenneth W. Kizer, Director, Department of Health Services , contained the protocol to guide action for soil contamination which included "Below 100 ppm of chlorophenols. . . Do not require mandatory dioxin testing. " This health action level is based on a residential exposure setting. Comparing