DTSC responded to our comment letter. DTSC_response_ENU_28NOV2018. As usual, we have disagreements with many of their comments. However, we think it is important that the letter states, “DTSC acknowledges that this remedy has not reached the offsite RAPs sent in the RAP. We are not there yet.” On this we agree.
Escondido Neighbors United encourages everyone to attend the DTSC Public Workshop on Chatham Wednesday, December 12, 2018 from 4:00 p.m. to 8 p.m., located at: California Center for the Arts Escondido (Theater Lobby) 340 N. Escondido Blvd., Escondido
ENU will, again, be raising concerns about the failure to monitor all of the required wells, the lack of action on the toe of the plume, and other issues we have raised before.
Further, per this new letter, which states “Before site certification, a final allowable level will be established [for 1,4-dioxane] to ensure that an appropriate risk-based health protectiveness level is achieved.” (DTSC at 5) We will want to know how that will be done.
Again, we will ask for more appropriate posting of the worst part of the creek and more action to address the releases into the creek.
Last, it states that, “DTSC has not found a ‘silver bullet’ that would have allowed us to reach the RAOs by today”. (DTSC at 2) To this comment we want to reassure that we are not so unsophisticated to think that a highly complex situation such as this would respond to a simplistic, single action ‘silver bullet’. It will take many actions. Further, we do not see the finding of these strategies, as DTSC’s job. It is the job of the PRPs to propose additional actions needed to get us to the RAOs to be reviewed by DTSC. We will be asking what new and innovative technologies they have proposed to address our site. It is incumbent on them to bring options to the regulatory agencies as they are ‘potentially’ responsible.
But, it is incumbent on all parties to estimate when, if ever, this will be remediated. We have waited long enough.
The post about our original letter is here.