2004 CPEO Brownfields List Archive

From: Bob Hersh <bhersh@cpeo.org>
Date: 26 May 2004 13:51:48 -0000
Reply: cpeo-brownfields
Subject: RE: OSHA levels for TCE
 
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Reply submitted by Peter Strauss petestrauss1@comcast.net:

No matter how inadequate the OSHA value is, it is still appropriate to
use it as an ARAR, as it is a regulation.  As Bob has written, even
NIOSH has more stringent guidance.  The PRGs (preliminary remediation
goals) used in Mountain View are really not ARARs, although on several
occasions I have recommended (unsuccessfully) that they be used as such.

Peter Strauss

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