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OEMORANDUM Cal/EPA CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD v, CENTRAL VALLEY REGION Pete Wilson,Governor3443 Routier Road,Suite A,Sacramento,CA 95827-3098 (916)255-3000 • CALNET 8-494-3000 • FAX(916)255-3015 TO: Cori L. Condon FROM: Jon B. Marshack,D.Env. Associate Engineering Geologist Senior Environmental Specialist Federal Facilities Unit Environmental/Technical Support DATE: 15 December 1997 SIGNATURE: SUBJECT: PUBLIC REVIEW DRAFT PUBLIC HEALTH ASSESSMENT FOR DDRW SHARPE ARMY DEPOT—VOCs IN WELLS Request. The volatile organic chemicals (VOCs)trichloroethylene(TCE),tetrachloroethylene (perchloroethylene or PCE), and 1,2-dichloroethane (1,2-DCA)have been detected in on-site wells and/or in private domestic wells located north and northwest of the subject site. The Agency for Toxic Substances and Disease Registry (ATSDR) evaluated the health significance of the exposure to these contaminants in drinking water as part of their"Public Health Assessment." At your request, I reviewed and commented on the water quality aspects of the 2 July 1997 draft document prepared by ATSDR. Numerous concerns were noted in my 29 August 1997 memorandum to you,which was provided to ATSDR and discussed with representatives of that agency in a 12 November 1997 telephone conference. ATSDR has prepared a revised"public review draft" of the report. You asked that I determine whether concerns raised regarding the earlier draft have been adequately addressed in this revised document. Response: In the public review draft document,ATSDR reiterates their conclusions that"Sharpe poses no apparent public health hazard' [p. 1,¶ 11,that"past, current, or future use of the on-site drinking water by on-site residents and on-site workers or personnel is not likely to result in adverse health effects [p. 10,¶ 51 and that"use of water from [off-site] private wells does not pose a public health hazard" [p. 13,¶31. The report also states that"Sharpe will continue to monitor VOCs in private wells ... and will take action(e.g.,provide alternative water souFees) if the contaminant levels consistently exceed the MCLS." As stated in my comments on the earlier draft report,ATSDR's conclusions are inconsistent with Regional Board's position regarding pollution of groundwater that is or is likely to be beneficially used and where 10-6 lifetime cancer risk levels have been exceeded. In addition, it is also incongruous that the report continues to state that no apparent health hazards exist for users of domestic wells in which California drinking water standards, and in some cases federal drinking water standards, are exceeded. At the same time,however,the report calls for provision of alternative water supplies for such users, which contradicts ATSDR's own conclusions regarding health risk. Errors and omissions noted in my earlier comment memorandum have been partially,but not satisfactorily, addressed in the revised report. 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 and future generations.