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[Fwd: f w: CW4)7NC and GW std for PFOA--0.5 ppb not what we are ca...
Subject: [Fwd: Fw: CWFNC and GW std for PFOA--0.5 ppb not what we are calling for]
From: Liz Cannon <[e-mail]>
Date: Fri, 15 Dec 2006 08:46:44 -0500
To: "Matthews, Dexter" <[e-mail]>, "Brower, Connie"
<[e-mail]>, "Goldhaber, Susan" <[e-mail]>
FYI
- Original Message--------
Subject:Fw: CWFNC and GW std for PFOA--0.5 ppb not what we are calling for
Date:Thu, 14 Dec 2006 17:49:31 -0500 (EST)
From:LARRY STANLEY <LARRY. STANLEYczncmail.net>
Reply-To:LARRY STANLEY <LARRY.STANLEY &ncmail.net>
To:elizabeth.cannon(cr�ncmail.net, cathy.akroydPncmail.net
----Original Message ----
From: [e-mail]
Date: Dec 14, 2006 17:03
To:, &quot;Dexter.Matthews&quot;, , &quot;Larry Stanley&quot;
Subj: CWFNC and GW std for PFOA--0.5 ppb not what we are calling for
All,
Just for clarification, I did not tell Mr. Fuquay that CWFNC wanted
a GW standard of 0.5 ppb for C8, and I have contact him to ask that he correct
this and state that we will do it by letter to the editor if necessary.
I've "pasted in" the relevant paragraph from my 12-11 email to him at the
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[Fwd: Fw: CWFNC and GW std for PFOA--0.5 ppb not what we are ca...
bottom of this message.
The focus of my comments was the fact that this action was taken as an interim
standard, short circuiting the work of the SAB, without any final consultation
with DHHS staff, that the resulting standard was four times weaker than the
"action level" being used in WV, and would take much of the Fayetteville
Works site out of requirements for monitoring or other regulatory action
under DWM's RCRA program.
With a reasonable public process and scientific review, we believe that a
protective standard would, in fact, be significantly lower than 0.5 ppb
and that the limit of detection for PFOA had been an appropriate regulatory
level until those processes were complete. Dr. Williams and I had both conveyed
to DWQ staff that the division should wait and not issue an interim standard.
DWQ was under no obligation to provide an interim GW standard to DuPont.
If the public had tried to petition for a stronger interim limit, one can
only imagine how glacially that would have moved through DWQ processes.
By the way, if the line in Mr. Fuquay's article, about Micheal Johnson hoping
that DuPont won't have to monitor any wells with levels "less than zero,"
is the result of a direct quote from Mr. Johnson, I don't think I need to
say what that would reflect about the level of scientific knowledge in DuPont's
environmental team. Let's hope he didn't really say that.
Following is the relevant paragraph from the email I sent to Mr. Fuquay on
Monday afternoon:
"Last Thursday, the NC Div. of Water Quality approved an IMAC (interim
standard) of 2.0 ppb C8 (PFOA), which is four times weaker than the
action level recently set under the settlement agreement for WV drinking
water, and probably hundreds of times weaker than the use of realistic safety
factors would call for. Further, the NC interim limit was set without any
public notice, without allowing the state's Science Advisory Board to complete
its ongoing review, and without seeking input from staff in the Dept. of
Health and Human Services, a very dangerous precedent that threatens the
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health basis of NC water protection standards."
Elizabeth W. Cannon
Chief, Hazardous Waste Section
Division of Waste Management
N.C. Department of Environment and Natural Resources
401 Oberlin Road, Ste. 150
1646 Mail Service Center
Raleigh, NC 27699-1646
919-508-8534
[e-mail]
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