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Summary of Response During Public Comment

A group of unnamed concerned residents, an employee and nearby resident, and the manager of environmental affairs for Sola each submitted a letter during the public comment period that ran from July 9, 1992 to August 7, 1992.

  1. The concerned residents expressed a concern about the release of acetone to air and its health effects that could result from exposure to acetone.

    The release of acetone to air as reported in the Toxic Chemical Release Inventory is a result of normal operating procedures at the plant and not due to the existence of acetone leaking into the subsurface soil. The health effects that were cited in the letter have been documented to occur as a result exposure to acetone in the workplace. However, these levels in the workplace occurred at much higher concentrations than would be expected to occur from the release of acetone by Sola. It is unlikely that the acetone levels reports to be released to the air by Sola would result in similar health effects.

  2. The concerned residents questioned whether anyone had drunk the water from the city well before it was discovered to be contaminated.

    The contamination occurred between 1978 and 1985 (the period of time during which Sola was using the underground storage tanks), thus the groundwater contamination is unlikely to have spread from the Sola property to the Station 5 city well to any great extent before 1986. Sola began monitoring the well in 1986. Although Sola did detect low levels of some VOCs in the water from the city well between 1986 and 1988, these levels were below health-based comparison values. Additionally, the water from this well is diluted with other well water before it is delivered to the consumer.

  3. The concerned residents also questioned whether there might be an association between the high incidence of sudden infant death syndrome (SIDS) in that area and the site.

    In 1983, CDHS did investigate a proposed cluster of SIDS cases in Sonoma County, the county in which Sola is located. CDHS concluded that there was no cluster. CDHS found that the cases were not distributed in any certain pattern. There was no clustering of cases around Petaluma as compared to the rest of the county which suggests that no relationship existed between the supposed SIDS cluster with any potential exposure from groundwater. There was no clustering around the southeastern sector of Petaluma as compared to the rest of the county which suggests no relationship of the SIDS clustering with any potential air exposure from the Sola site.

    The causes of SIDS is still unknown, but to date no environmental factors have been shown to be responsible.

  4. The concerned residents wanted to know the implications of a recent documentary that was shown on television suggesting a relationship between autism in children and their parents and grandparents having lived near a sunglass manufacturing facility in Massachusetts.

    CDHS contacted the Massachusetts Department of Health to inquire about the television story that was referred to in the question. At this point their investigation is in the early stages of verifying that the reports are in fact of autistic cases. Besides the sunglass manufacturing facility the Massachusetts Department of Health is also investigating a number of plastics manufacturers in the same area.

    A scientific literature search by the Massachusetts Department of Health indicates that the majority of autistic cases are thought to be genetically related. They could not find any reports of autistic cases due to environmental or drug exposure.

  5. An employee who also lives approximately 500 yards from the Sola plant wrote "your report seems carefully prepared, and I am confident that no health risks are posed to either employees or nearby residents, provided your recommendations are followed".
  6. Sola concurs with the conclusion of the public health assessment that the Sola site presents no apparent public health hazard to either the nearby community or on-site workers.
  7. Sola offered some comments on the potential pathway of migration of VOCs from on-site groundwater into the Sola facility:
    1. the portion of the Sola facility where the majority of worker-related manufacturing activities are performed is maintained under a positive-pressure atmosphere, effectively serving to retard the potential migration of VOCs into the Sola facility.
    2. gaseous diffusion of VOCs to a depth of approximately 10 feet is highly unlikely because homogenous clay makeup of the subsurface soil is highly saturated with water, leaving very little interconnected air-filled pore space for gaseous transport to take place.
    3. soil borings and soil-gas data from the shallow soil around the Sola facility are as clean as ambient air, supporting the fact that there is little gaseous diffusion of VOCs occurring.

As stated in the public health assessment, while this pathway may be occurring, it is at a level below health concern. However, given the current extended drought period California is experiencing, it is questionable whether the first 10 feet of any soil is still saturated with water.

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