SITE INFORMATION AND CORRESPONDENCE

Home Browse Search

y Ms. Barbara Coler _2_ 16 October 1996 1,4-dioxane is present as a stabilizer in certain chlorinated solvent formulations and so is often present in situations where an RP may argue whether indeed a "release" has occurred. Thirdly, although DTSC is aware of this Board's concern with dioxane (per 31 March 1995 memo to Duncan Austin from Barbara Renzi regarding Aerojet), the memo was issued without any apparent discussion or concurrence from supporting agencies which have a direct interest in its application. Since the memo is contrary to Board policies to protect water quality, Board staff find themselves "speaking with a different voice" and giving conflicting direction to RPs. We would prefer to work with DTSC to develop a consistent statewide position which satisfies the interests of both agencies. Fourthly, although your expertise and capabilities are well regarded, the bases for your instructions in the memo, which you state are the two memos from your Office of Scientific Affairs and your risk management experience, are not fully convincing. Although the 5 July 1996 OSA memo states that the "prior analysis [the 31 March 1995 memo] stands as written," the former does appear to cast a cloud on the latter and raises some confusion even to the careful reader. Moreover, whether intended or not, your request for the 5 July 1996 "supplemental analysis" implies to some extent a type of"forum shopping" to obtain the "correct" answer. It is not clear why DTSC, independently of OEHHA, would evaluate current State and Federal regulatory standards and relevant toxicologic literature and come to different conclusions as to what levels would be sufficient to protect public health. Finally, although one's experience is certainly important and helpful when professional judgment must be exercised, it can be somewhat of a slender reed upon which to base statewide policy. Oftentimes other experts' experience may be quite contrary, yet equally valid. We are concerned that your directive alters the standard procedure for evaluating and responding to chemicals affecting water quality. Rather than presume that remediating dioxane is too costly, or presume that it is not present if there has been "no release," we believe that remedial (treatment) alternatives and costs should be evaluated as they would be for any other constituent of concern . Attached are two Regional Board staff memoranda which provide further information. At several sites, such as Aerojet, Southern Pacific Transportation Company's Sacramento Yard (SP) and McClellan, dioxane has been found in the groundwater. At other sites, such as industrial and federal facilities, additional sampling has been requested where there is a reasonable likelihood that dioxane is present,. Board staff are concerned that the DTSC memo will hinder requiring full investigation and, where necessary, cleanup of groundwater. Such is already the case with the SP project where dioxane was found. SP is relying on the DTSC directive as a Cal/EPA position, and r?�.♦ Regc/ed Paper Our mission is to preserve and enhance the gualtry of California}water resource,and ��7 ensure their proper allocation and efficient use for the benefit of presera and fuave generatioms.