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CALIFORNIA REGIONATER QUALITY CONTROL BOARDCal/EPA , �- CENTRAL VALLEY REGION Sacramento, Ro mento, Road, Suite 0 Sacramento, CA 95827-3098 FAX(916)255 3015 Phone AX 0 P�� Pete wilscn.Gove nnr 17 December 1997 Max M. Howie, Jr. Chief, Program Evaluation, Records, and Information Services Branch Division of Health Assessment and Consultation ATSDR Mailstop E-56 1600 Clifton Road, NE Atlanta, GA 30333 Sharpe Army Depot, Lathrop, San Joaquin County, California: Public Health Assessment Thank you for this second opportunity to comment on the Public Health Assessment for Sharpe Army Depot. We previously provided comments on the Draft version of ATSDR's evaluation and discussed our concerns with Emilio Gonzalez by phone in November of this year. We have reviewed the revised report and attached is a memorandum with our detailed comments addressing which portions of the Health Assessment still do not adequately address our concerns. The Public Health Assessment Report concludes that, in ATSDR's estimation, no public health hazards exist at or in the vicinity of the Sharpe Depot. We do not concur or support this position. The State of California calculates risk to human health based on one-in-a-million cancer risk values as the point of departure. We believe this Cal/EPA process should be conducted and have precedence over the ATSDR's risk protocol to evaluate risk to human health at facilities in the State of California. The volatile organic chemicals (VOCs); trichloroethylene (TCE), tetrachloroethylene (PCE), and 1,2 dichloroethane (1,2-DCA) detected in wells downgradient of the Sharpe facility exceed the one-in-a- million cancer risk. The Public Health Assessment should acknowledge the risks to human health from drinking this water. Furthermore, ATSDR recommends that Sharpe provide an alternative water source only if the maximum contaminant level (MCL) is exceeded. The State's position is that an alternative water supply is required when the source water fails to meet all the water quality objectives. In this case the one-in-a- million cancer risk objective is much more stringent than MCL. As stated above the water exceeds the one-in-a-million cancer risk level. MCLS are not purely health-based limits because they were set equal to laboratory analytical quantitation limits that were achievable at the time each MCL for these constituents was established. In recent decisions regarding an off-site VOC plume from Mather Air Force Base, the Board has reaffirmed the position that replacement water supply must be provided when the level of carcinogenic chemicals are detected and confirmed at or above the one-in-a-million cancer risk level. The Board staff wrote to the Sharpe facility in November 1996 requesting that an alternative drinking water supply be provided to the users of wells that have been impaired north and east of the facility, along Roth Road. The Public Health Assessment should extend the recommendation to provide alternative drinking water to groundwater users in the vicinity of the Sharpe facility. Recycled Paper Our mission is to preserve and enhance the quality of California's water resources,and ensure their proper allocation and efficient use for the benefit of present andfuture generations.