Document 3eQJaEGvMzagMpNO8K927vRjx

t DATE: UNITED STATES ENVIRONMENTAL PROTECTION A REGION V OCT 1 81983 s u b j e c t : Draft Dioxin Strategy ----- As Transmitted October 12, 1983 Valdas V. Adamkus FR0M: Regional Administrator T0. Steven Schatzow, Director Office of Water Regulations and Standards In response to your October 12, 1983 note, I offer the following brief comments on the subject document with the request that they be read together with the more extensive comments that we provided on September 12, 1983, 1. Need to Reconsider the Emphasis on 2, 3 , 7, 8 - TCDD - My previous memo indicated our concerns with the strong emphasis on 2, 3, 7, 8 - TCDD based in large part on our experience in Midland where a more complete data set and e xp lic it concerns about other isomers and chemicals dic tate a more extensive analytical program. Other sites where dioxin is found w ill lik e ly demand the same sort of attention. Ultimately, I expect we w ill spend more time and money by taking a more narrow approach in the beginning. 2. Need to.augment the Midland Program - The continuation of the 2, 3, 7, 8 - TCDD emphasis nationally places the Midland effort in a class of one, making it more d iffic u lt to draw comparisons between site s and ra isin g concerns among residents that the city is being unfairly singled out. It would be more useful to Midland area residents and generally more effective in the long run fo r the Agency to do extensive chemistry at a broader number of site s now. The matter could be handled in the strategy by providing more f le x ib ilit y in the design of site studies through changes in language in places lik e Part 1, page 2 and Part 2, items 39, 40 and 49. It should be stated (suggested language attached) that several studies with more extensive chemistry are to be conducted at Midland and several other site s to be selected. 3. Need to Improve the Long Term Efficiency of the Effort - While more extensive chemistry at a limited number of site s would a ssist our efforts at Midland, th is alone w ill not be sufficient to realize the potential efficiencies and cost savings. A program is needed that w ill optimize the chemistry for each sampling program, not only for dioxin, but for the many other chemicals for which EPA has regulatory responsibility. Some thoughts for improving the overall efficiency of the program are as follows: Suggested Language Changes - In Part 1, page 2 replace the sentence beginning on line 20 with; "The 2, 3, 7, 8 - TCDD investigation w ill be augmented by analyses for other dioxin isomers and other chemicals at Midland, Michigan, and a limited number of other site s to be selected." - In Part 2, item 26, delete the word "lim ited" on the 2nd line.. - In Part 2, item 39, the last sentence should read: "Followup in vestigations at contaminated site s may require so il analyses at the ppt detection lim it and for other isomers and chemicals, depending on the circumstances of contamination and potential for human exposure." - In Part 2, item 40, add the sentence: "Analyses of other isomers and chemicals w ill be performed, when necessary, at a number of sites as a control for investigation of Tier 1, 2 and 3 site s." - Replace Part 2, item 49 with; - "Analyses of other chemicals, in addition to 2, 3, 7, 8 - TCDD, may be necessary at certain sites. While the National Dioxin Strategy p rin cip ally focuses on Dioxins, analyses for other chemicals of concern on a site -sp e c ific basis are appropriate and can be completed to make cost-effective use of fie ld and laboratory resources. In some cases, depending upon the types of chemical manufacturing f a c ilit ie s and combustion sources present at a site , it may be appropriate to analyze for other dioxin isomers, dibenzofurans and other related toxic chemical such as PCBs, chlorinated phenols, and chlorinated benzenes." - In Part 2, item 47, add the sentence: "Higher p rio rity may be given to some tie r 7 samples i f needed as controls for studies of tie r 1 and 2 s it e s ." 2- - a. Build additional f le x ib ilit y into the strategy to allow regions to design additional chemical analyses into their site investigations and to lower detection lim its as may be ju stifie d on a site -b y-site basis.. b. Take notice of the extensive amounts of dioxin data already being generated by States and other e n titie s. Such data should be u tilize d in establishing further fish sampling networks making regional reports on site s, and should be well known to the Dioxin Sample Control Center. 4. Need to get the Dioxin Strategy out on the street - The national strategy is a subject of intense interest among the States, for members of the public in general, and for the citizens of Midland in particular. We much appreciate the yeoman efforts you and your sta ff are making on the document and strongly urge it s early publication. - , Please refer to the attachment and our September 12, 1983 memorandum for additional specific comments. Thank you once again for the' opportunity for review. I f you have questions on these further comments, please contact Dave Stringham at FTS 8/886-7579 or Jon Barney at 8/886-6109. cc: A. Aim B. Hedeman fi. Lucero M. Cook H. Wiser D. Clay D. Dewling M. Kay A. McBride M. Slimak \ W 6S