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Message From oto, Sent: 11/21/2017 3:16:10 PM To ‘ely Albert /ozExchangeLabsfou=txchonge Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=08576e43795 149e5a3196697 26dd044c-Kelly, Albe} Subject: EPA policy regarding TCE remediation ‘Attachments: ACC letter re TCE remediation policy pdf; OLEM Response pal; ACC follow-up letter on TCE. pdf; EPA to test for toxic vapors in some homes.pdf Kell — Ihave attached a short description of the issue we discussed related to remediation of trichloroethylene (TCE) contamination, Per your request, | have also included prior correspondence on the issue. As indicated, we would like to set up a meeting to review this issue with you. Happy Thanksgiving, Stove Stephen P. Risotto I HECCEHEHLHEEEELEEEEHLEEE-be+ This message may contain confidential information and is intended only for the individual named. If you are not the named addressee do not disseminate, distribute or copy this email, Please notify the sender immediately by email if you have received this email by mistake and delete this email from your system. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost, destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of this message which arise asa result of email transmission. American Chemistry Council, 700 — 2nd Street NE, Washington, DC 20002, wovwamericanchemistry.com Sierra Club v. EPA 18cv3472 NDCA. Tier 2 ED_002061_00115928-00001 America in Chemistry Counci June 28, 2017 Mr. Patrick Davis Deputy Assistant Administrator Office of Land and Emergency Management Mail Code 5101T US Environmental Protection Agency 1200 Pennsylvania Avenue, NW ‘Washington, DC 20460 Re: OLEM Policy Concerning Short-Term Exposure to Trichloroethylene in Indoor Air Dear Mr. Davis: ‘Thank you again for meeting with us to discuss our concerns with EPA's approach to addressing, indoor air exposure to trichioroethylene (TCE) from vapor intrusion at contamination sites. As we is defined in the enclosed 2014 memo from the Office of Superfund Remediation and Technology Innovation (OSRT!) which interpreted scientific data on non-cancer ({.e., developmental) effects to establish a national policy for accelerated response at remediation sites. The results on which the policy relies have not been reproduced in better conducted studies. We are aware of no Agency precedent, moreover, for OSTRI's application of a chronic inhalation reference concentration to short- term exposure, Implementation of the 2014 policy memo has resulted in a significant increase in remediation costs and caused confusion among state and regional officials and the general public. Implementation of the policy has been inconsistent among EPA Regions, moreover, and at least one state (Indiana) has taken the position that the OSTRI policy is “not scientifically supportable.” ‘As we discussed, the ongoing risk evaluation for TCE by EPA's Office of Chemical Safety and Pollution Prevention (OCSPP) under the Lautenberg Chemical Safety Act provides an opportunity for your office to review and, as appropriate, update its policy on TCE remediation. This evaluation will be enhanced by the availability of data from new research that the industry expects to complete by the end of this year. Consequently, we respectfully request that OLEM suspend the implementation of the 2014 OSTRI memo, and related memos issued by EPA Regional Offices, * until OCSPP's risk evaluation of TCE is complete. Until that time, OLEM can enforce the existing remediation values for TCE based on chronic risk exposures (of non-developmental risk endpoints) to ensure public health protection. Once the risk evaluation of TCE is complete, your office can assess the impact of its conclusions on OSTRI policy. * ACC is aware of memos issued by Region 7 on November 2, 2016, by Region $ on June 30, 2014 and July, 2014, and by Region 10 on December 13, 2012. americanchemistry.com! 700 Second St., NE | Washington, OC 20002 | mmm Sierra Club v. EPA 18cv3472 NDCA. Tier 2 ED_002061_00115929-00001 Mr, Patrick Davis June 28, 2017 Page 2 Thank you again for considering our request. Please feel free to contact me af Ex8 br at stisotto@americanchemistry.com if you have questions or if you would like to discuss our request further. Sincerely, Stove Risotto ‘Stephen P. Risotto Senior Director Enclosure americanchemistry.com* 700 Second St., NE | Washington, OC 20002 | _|/ Yp Sierra Club v. EPA 18cv3472 NDCA. Tier 2 ED_002061_00115929-00002