Laserfiche WebLink
Paragraph Response <br /> this criteria to our plant site, where the <br /> majority of surface soils are well below <br /> the 100 ppm chlorophenol level and the <br /> public is prohibited access, the public <br /> health should be protected. We have <br /> repeatedly asked DHS to provide us data <br /> or reasons that support the concern that <br /> an immediate threat is highly possible, <br /> so we can take this data into account in <br /> preparing our workplan scope and schedule. <br /> We have vet to receive any such informa- <br /> tion. <br /> Regarding Offsite Air Monitoring <br /> 2 We understand that air-borne exposure is <br /> a sensitive public concern but all anal- <br /> ysis performed to date indicate that <br /> offsite air-borne exposure is not of <br /> immediate importance. The PHERA con- <br /> clusions that support this position <br /> include: <br /> o Existing extensive NIOSH, USDA, and <br /> EPA studies of air-borne contaminates <br /> at wood preserving plants are below <br /> health hazard levels. <br /> o Offsite exposure levels using EPA' s <br /> Guideline on Air Quality Models and <br /> Industrial Source Complex Model were <br /> determined for worst case conditions. <br /> The evaluation showed exposure would <br /> be below OSHA permissible exposure <br /> limit (PEL) standards. In the absence <br /> of some compelling reason for sampling <br /> and analysis, we believe the DHS re- <br /> quest is unjustified. <br /> o McCormick and Baxter' s onsite monitoring <br /> for arsenic, the constituent of most <br /> concern, showed levels below health <br /> hazard levels and were consistent with <br /> literature values and the modeling <br /> analysis. If onsite levels are below <br /> health hazard levels, the same will be <br /> true for offsite levels. Again without <br /> specific compelling reasons from the <br /> DHS, we find this request for such <br /> sampling unreasonable. <br />