3/1/2000

Julie Roth
Technical Advisor, DSCSOC
Via email

Julie,

Following up on yesterday's LEHR RPM meeting, as I mentioned at the meeting and have discussed repeatedly over the past three years, the inadequate monitoring of mercury in stormwater runoff from LEHR that was discussed is equally applicable to chlordane. Thus far, DOE and UCD have not used analytical methods for chlordane with sufficient sensitivity to determine whether chlordane in the stormwater runoff from the LEHR site exceeds US EPA water quality criteria.

Further, we do not know if the fish in Putah Creek contain excessive chlordane compared to US EPA Region 9 guidelines. I would be surprised if they do not contain excessive chlordane, since chlordane is a widespread contaminant as a result of its use in many areas for termite and other pest control. This situation has caused many waterbodies to have excessive chlordane in fish tissue. There is still need for the RPMs to require that UCD and DOE develop, for approval by the RPMs, a study that would determine whether fish in Putah Creek contain excessive chlordane. If they do, then the stormwater runoff from LEHR needs to be monitored with sufficiently sensitive analytical procedures to determine if the previous use of chlordane at LEHR is contributing to the excessive chlordane in Putah Creek fish.

Since other pesticides were used at LEHR, the suite of chlorinated hydrocarbon pesticides, PCBs and dioxins should be determined in Putah Creek fish. This time, the sampling and analytical procedures should be more appropriately selected and used than has occurred in the previous ATSDR US EPA studies.

I suggest that you forward this to the RPMs, requesting that the chlordane and other chlorinated hydrocarbons that were used at LEHR or could be at LEHR, such as PCBs and dioxins, are properly evaluated with respect to their threat to the beneficial uses of Putah Creek.

If there are questions on these comments, please contact me.

Fred