http://www.environmentcalifornia.org/reports/clean-water/clean-water-program-reports http://www.environmentcalifornia.org/reports/clean-water/clean-water-program-reports/leaking-enforcement-analyzing-the-effectiveness-of-the-1999-clean-water-enforcement-and-pollution-prevention-act http://www.environmentcalifornia.org/reports/clean-water/clean-water-program-reports/leaking-enforcement-analyzing-the-effectiveness-of-the-1999-clean-water-enforcement-and-pollution-prevention-act Sun, 11 Nov 2007 18:02:25 -0600 http://www.environmentcalifornia.org/reports/clean-water/clean-water-program-reports/new-spike-in-perchlorate-pollution-threatens-rialto-drinking-water-wells  New pollution tests reveal a new perchlorate ‘pulse’ that threatens to spread to Rialto drinking water wells. Perchlorate is the major ingredient in solid rocket fuel. According to scientific reviews conducted by U.S. Environmental Protection Agency and several state agencies, at low concentrations in drinking water the toxin can lead to Attention Deficit Disorder, learning disabilities and decreased IQ in children. As a result of inadequate industrial storage and disposal practices, perchlorate pollutes the drinking water supplies of millions across the country. The City of Rialto is at the epicenter of this contamination crisis. Perchlorate pollution in local water wells was first detected in 1997 and has to date resulted in the closure of numerous local drinking water wells and incurred the city residents millions to cover the cost of stop-gap cleanup measures.Between 1957 and 1963, Goodrich Corporation (then known as B.F. Goodrich) owned and operated a rocket fuel manufacturing and processing facility in Rialto, a small working-class city located an hour east of Los Angeles. During its tenure, the company produced rocket fuel for the Loki, Sidewinder, ASP I and ASP II missiles. According to depositions given by former employees, thousands of pounds of waste rocket fuel from the manufacturing process were disposed of in a large unlined pit behind the Goodrich facility.1 Federal and state officials believe that the Goodrich facility and disposal pit into which thousands of pounds of the chemical were dumped are a source of the perchlorate pollution that has decimated the Rialto’s water supply. Rialto’s perchlorate pollution problem may soon worsen.New mandated pollution tests conducted by Goodrich Corporation and submitted to state water officials in July 2006 reveal an alarming spike in contamination that threatens to send a new pulse of toxic perchlorate pollution into Rialto drinking water wells. Levels of perchlorate pollution in well PW-2, located close to the historic Goodrich perchlorate disposal pit spiked sharply in 2006 – from an April 2005 concentration of 53 µg/L to an April 2006 concentration of 10,000 µg/L. The increased threat highlights the urgent need for Goodrich Corporation and other parties responsible for perchlorate pollution in the Rialto area to immediately halt the spread of contamination throughout the region, provide replacement water for wells they have polluted and institute a long term cleanup plan for the community.   http://www.environmentcalifornia.org/reports/clean-water/clean-water-program-reports/new-spike-in-perchlorate-pollution-threatens-rialto-drinking-water-wells Sun, 11 Nov 2007 18:02:25 -0600 http://www.environmentcalifornia.org/reports/clean-water/clean-water-program-reports/reviving-the-san-joaquin http://www.environmentcalifornia.org/reports/clean-water/clean-water-program-reports/reviving-the-san-joaquin Sun, 11 Nov 2007 18:02:25 -0600 http://www.environmentcalifornia.org/reports/clean-water/clean-water-program-reports/three-strikes-and-you-profit-a-calpirg-study-of-clean-water-enforcement-in-california  As the new home of CALPIRG's environmental work, Environment California http://www.environmentcalifornia.org/reports/clean-water/clean-water-program-reports/three-strikes-and-you-profit-a-calpirg-study-of-clean-water-enforcement-in-california Sun, 11 Nov 2007 18:02:25 -0600 http://www.environmentcalifornia.org/reports/clean-water/clean-water-program-reports/the-case-for-cleanup-of-rialto39s-drinking-water-supplies  Perchlorate, the major ingredient in rocket fuel, pollutes the drinking water supplies of Rialto - a small working class, mostly minority community nestled beneath the San Bernardino Mountains.  Although officials discovered the contamination nearly ten years ago, comprehensive cleanup has not yet begun.  As the delay continues, the pollution spreads; resdients pay increased water rates to fund cleanup and legal action; and officials worry about future water shortages in the drought-prone region.  While local leaders have shut down or placed stop-gap treatment on wells polluted above California health warnings, out of date detection methods mean many residents may continue to drink pollution considered unsafe in other states. In proposing order 2005-0053, the Santa Ana Regional Water Board aims to take the single largest step to-date toward cleaning up the perchlorate pollution that plagues the Rialto-Colton region.  In more than 10,000 pages of submissions and exhibits, the dischargers named in the draft order present a  host of legal and technical claims that argue against its adoption.  This policy brief, however, rebuts the overarching notion presented in the submissions that the core issue before the State Water Board in these proceedings is technical or legal in nature.  In fact, we strongly believe that the core issue before the board is to answer a single fundamental policy question - Should California require that polluters who dump dangerous chemicals into drinking water clean up their mess? Environment California and CCAEJ firmly believe that the public interest answer to this question is a resounding yes.  Any other answer would be contrary to the California Water Code, which states that "The principles, guidelines and objectives [adopted by the State Water Resources Control Board] shall be consistent with the state goal of providing a decent home and suitable living environment for every Californian." (CWC Section 13142)Furthermore, we believe that the submissions of Goodrich, Emhart and Pyro Spectaculars are in large part based upon a series of depositions, discovery demands, procedural objections and legal maneuvers that have significantly hampered the ability of the public process to adequately address this question.  As such, we urge the Board to give the answer to the fundamental policy question highlighted above the weight it deserves, even amidst the tens of thousands of pages of legal and technical arguments presented by the dischargers named in the proposed order.  In addition, we urge the Board to ensure that the remediation requirements contained in a final draft order reflect its overriding public policy mandate to ensure that polluters that dump dangerous chemicals into drinking water are required to clean up their mess.   http://www.environmentcalifornia.org/reports/clean-water/clean-water-program-reports/the-case-for-cleanup-of-rialto39s-drinking-water-supplies Sun, 11 Nov 2007 18:02:25 -0600 http://www.environmentcalifornia.org/reports/clean-water/clean-water-program-reports/a-cleanup-order-that-will-restore-rialto39s-drinking-water-supplies-to-health  Environment California and CCAEJ respectfully request that the State Board Hearing Officer recommend that the State Board affirm an amended Cleanup and Abatement Order No. R8-2005-0053 as described in this policy brief. By including the remediation requirements in the proposed Order, staff members of the Santa Ana Regional Water Quality Control Board make significant progress toward the ultimate remediation of perchlorate in the Rialto-Colton groundwater basin.  In affirming an amended Order, the State Water Board will assume a much-needed leadership role in addressing a pressing water quality problem in California. The 'Community Groups' support many of the remediation provisions of Draft Order 2005-0053.  After nearly ten years after the first discovery of perchlorate contamination in the Rialto Colton sub-basin, we believe the Order takes the largest step to date toward cleanup and abatement of perchlorate contamination in the groundwater basin. This said, in order to fully restore the waters of the sub-basin to health, maintain consistency with the 'State Water Resources Control Board Statement of Policy with Respect to Maintaining High Quality Waters in California,' and ultimately clean up and abate perchlorate contamination, the 'Community Groups' respectfully request a series of amendments and additions to Draft Order 2005-0053 that will:1) Fulfull statutory intent to require dischargers to provide replacement water supplies for all wells impacted by contamination, not simply wells with perchlorate detection levels above the California Public Health Goal;2) Explicitly mandate that cleanup will occur to a background level of water quality;3) Outline a clear, automatic process for enforcement, should a failure to meet all cleanup requirements, including applicable deadlines, occur;4) Require the deposit of funds reimbursed for past cleanup costs to impacted public water purveyors in a 'Community Perchlorate Reimbursement' account dedicated to reimbursement of residents.As described below, we believe all elements of the 'Community Groups' request are fully supported by statute and State Water Resources Control Board and Regional Water Quality Control Board precedent. Summary of Policy Arguments1) It is in the public interest to issue a cleanup and abatement order that will ensure long term and immediate cleanup measures to restore the groundwater of the Rialto-Colton subbasin to health;2) Statutory authority and regulatory precedent exist for key remediation requirements included in Draft Order 2005-0053;3) The addition of provisions to Draft Order 2005-0053 that ensure cleanqup is required to background levels, the provision of replacement water for all impacted wells, the deposit of funds reimbursed to impacted public water supplies in an account dedicated to reimbursement of residents and strict enforcement provisions will significantly strengthen the proposed Order and ensure comprehensive cleanup and abatement of perchlorate discharge in the Rialto-Colton groundwater basin.   http://www.environmentcalifornia.org/reports/clean-water/clean-water-program-reports/a-cleanup-order-that-will-restore-rialto39s-drinking-water-supplies-to-health Sun, 11 Nov 2007 18:02:25 -0600 http://www.environmentcalifornia.org/reports/clean-water/clean-water-program-reports/the-politics-of-rocket-fuel-pollution   For decades, tobacco companies have ignored evidence and distorted science in order to mislead the public and decision-makers, despite clear evidence that tobacco smoking is hazardous to public health. Now companies facing government action over rocket fuel pollution are deploying similar tactics. The main ingredient in solid rocket fuel— perchlorate—pollutes drinking water sources in more than 20 states. Tests also reveal perchlorate in grocery store food supplies and in breast milk from women across the country. A 2005 study by researchers at Texas Tech University suggests that breastfed babies ingest levels of perchlorate that exceed the ‘safe dose’ recently established by the National Academy of Science—putting children at risk for development damage. California state agencies have discovered perchlorate in more than 400 water sources since 1997, including the Colorado River and hundreds of municipal wells. In 1992 the U.S. Environmental Protection Agency (EPA) took the first steps toward requiring cleanup of perchlorate from drinking water. In response, a group of manufacturers and users of rocket fuel joined to form the Perchlorate Study Group (PSG), with the stated intention of helping EPA by providing scientific information. However, documents from the internal files of participants in the PSG reveal that, much like the tobacco industry, these companies paid millions of dollars to fund misleading research and millions more to influence the scientific and public debate. Environment California Research & Policy Center investigated the activities of the PSG, using recently uncovered sources of information—including files and testimony obtained in the course of litigation. For the first time, these documents provide an inside look at the money spent and strategies employed by the industry in the ongoing debate over how to address rocket fuel pollution.  The Perchlorate Study Group campaigns for weak regulation of rocket fuel spills. Publicly, the PSG describes itself as unbiased, with a mission of working “cooperatively with the U.S. Environmental Protection Agency to increase scientific and medical understanding of perchlorate’s risk to human health.” However, according to an internal Aerojet presentation, the PSG was founded to “provide EPA with a scientific based argument to justify a higher RfD and thus a more reasonable remediation standard.” RfD is a scientific term meaning ‘safe dose’ and is the foundation of cleanup regulations. A “more reasonable remediation standard” would have the effect of limiting the manufacturers’ financial liability for existing and future spills while also providing support for defense against lawsuits. The Perchlorate Study Group hired a public relations firm, which then downplayed concerns about rocket fuel spills. This same firm once performed a similar service for tobacco giant Philip Morris. The PSG supports an organization called the Council on Water Quality, including a prominent spokesperson (former California EPA director James Strock). The Council has consistently and publicly downplayed concerns about rocket fuel exposure. Deeper investigation reveals that: The Council on Water Quality is actually a project of the public relations firm APCO Worldwide; <!--[if !supportLists]--> In 2004, the PSG paid APCO $770,000 to run this effort (See “Perchlorate Study Group Budget, 2004” on page 4); and <!--[if !supportLists]-->On behalf of Philip Morris, APCO has used similar front groups to challenge the use of science in policy-making and make it harder for citizens to sue corporations. The Perchlorate Study Group funded scientific research that was then used to argue that rocket fuel exposure was not a big concern. <!--[if !supportLists]-->New analysis by Environment California Research & Policy Center shows that the PSG or its members funded more than half of all studies directly addressing the health effects of perchlorate exposure that were published between 1996 and January 2005 when the National Academy of Sciences issued a report on perchlorate. Independent sources like the National Institutes of Health funded less than 10 percent of the research. <!--[if !supportLists]--> In some cases, PSG research appears to have deliberately employed an experimental approach that was inappropriate for the task. <!--[if !supportLists]-->The Council on Water Quality concludes that perchlorate is not a health threat at low levels using only PSG-funded research. The Council Website omits concerns raised by independent scientists who believe that perchlorate in drinking water at even a few parts per billion, or ppb, could constitute a significant health threat.The Perchlorate Study Group worked to influence the conclusions of a National Academy of Sciences panel charged with evaluating perchlorate for the U.S. government. The PSG paid a consultant to present PSG-funded research at meetings of the American Thyroid Association, where members of the National Academy of Sciences (NAS) panel were present and while the panel was active.Dr. Steven Lamm, the director of a firm called Consultants in Epidemiology and Occupational Health, requested $25,000 from the PSG to attend the American Thyroid Association annual meeting in 2004. He justified this request by noting that National Academy panelists would be in attendance. He wrote: “The session is chaired and hosted by a member of the NAS committee and this will probably be the last opportunity before the finalization of the NAS report for a PSG presentation to be observed by the many NAS panel members who are part of that panel.”While acting as a consultant for the PSG, Dr. Lamm became a member of the Public Health Committee at the American Thyroid Society. During his tenure, the Thyroid Society issued two formal statements favorable to industry.An email exchange between members of the PSG indicates that industry-funded research was intended to influence the panel to deliver a weak recommendation. Rocket Fuel Cleanup Standards Should Be Based on Independent Science State and federal regulatory decisions affecting rocket fuel spills will directly dictate what the corporate members of the PSG will have to pay to clean up rocket fuel spills. As a result, the PSG has a clear motivation to corrupt the regulatory process. Actors with a clear financial stake in decisions that could affect the health of millions of people across California and the U.S. should not be allowed to influence the regulatory process. Rocket fuel manufacturers should not play any role in crafting scientific standards meant to protect public health against the effects of their products. California’s public health goal (and other state and federal regulatory standards for perchlorate) should reflect the findings of independent science, not bought-and-paid-for science. We all have the right to clean water and food free of rocket fuel contamination.    http://www.environmentcalifornia.org/reports/clean-water/clean-water-program-reports/the-politics-of-rocket-fuel-pollution Sun, 11 Nov 2007 18:02:25 -0600 http://www.environmentcalifornia.org/reports/clean-water/clean-water-program-reports/a-clean-water-future-for-california-how-californias-water-boards-can-clean-up-nine-of-the-states-biggest-polluted-rivers-lakes-and-bays  To restore nine of the largest polluted waterways in the state to health, legally mandated cleanup plans drafted by California’s water boards must be strengthened. To put the state on a path to a clean water future, the plans should stop new pollution from entering the waterways, clean up existing contamination, ensure flows sufficient to maintain healthy water quality and restore essential habitat. California’s waterways are at a crossroads. On our current path lies a future filled with great bays too polluted to swim in much of the year, signature rivers emptied of salmon, and vital drinking water sources polluted by pesticides and other chemical pollutants. This future, however, is not inevitable. Under a 1997 U.S. EPA policy and several court orders, California’s water boards are required to establish cleanup plans called Total Maximum Daily Loads, or TMDLs to clean up the state’s most polluted waterways in the next decade. Through a series of straightforward measures in these legally mandated plans, the water boards have the potential to make Santa Monica Bay safe for swimming throughout the year, return salmon to the San Joaquin and protect the clarity of Lake Tahoe.While current state and federal law provide the authority needed to adopt strong clean-up plans, many plans that have already been drafted do not fully use this authority to ensure that nine of the largest polluted waterways in the state will be cleaned up. Without a change in direction, cleanup plans for the waterways profiled in this report may simply codify the status quo and miss the historic opportunity to clean up many of California’s largest polluted bays, rivers and lakes. California’s State Water Board and Regional Water Boards should shift course. To fulfill their legal mandate, cleanup plans they draft should include a series of straightforward measures that• Require dramatic reductions in new pollution such as agricultural and stormwater runoff reaching our largest waterways • Establish a renewed California Superfund program to clean up existing toxic contamination, which is paid for by polluting industries• Compel dam operators to allow river flows sufficient to maintain healthy waterways and• Increase funding for habitat restoration With the adoption of such measures in cleanup plans, California’s water boards can put the state on a path to a clean water future. The Bays: Santa Monica Bay, Humboldt Bay and San Francisco Bay California’s great bays collect large amounts of contamination such as grease, trash and toxic pesticides from inland areas and highly developed coastal cities. The destruction of local habitat exacerbates this problem by weakening nature’s ability to filter out the pollution before it reaches the bays. Wastewater treatment plants also discharge a range of toxic constituents which, while less in volume than the pollution contained in urban runoff, can be highly concentrated. Air pollution is also a significant source of contamination in the waterways. A consequence of this contamination is mercury and Polychlorinated biphenyl (PCB) pollution that coats bay floors in many areas and builds up in marine life, threatening the health of subsistence fishermen. Cleanup plans for Santa Monica Bay contain several strong requirements to limit trash entering the waterway, redirect stormwater to treatment plants and reduce toxic chemical pollution. Plans to clean up PCBs and dioxin pollution, however, have yet to be established for Humboldt Bay and a proposed cleanup plan for mercury in San Francisco Bay was recently rejected by the State Water Board as insufficient to address the pollution. To bring California’s largest bays back to health, California’s water boards should ensure that cleanup plans: Stop New Pollution: Cleanup plans should require the full enforcement of existing clean water laws and commit to specific inspection schedules and other measures that will ensure mandated pollution reductions are met. Plans should also require that stormwater polluters adhere to the same strong pollution reduction standards as other sources of pollution. Such an effort would include strong permits that contain numeric limits for stormwater pollution. Cleanup plans should also require that wastewater treatment plants reduce the pollution they discharge into the bays to the maximum extent possible. The North Coast Regional Water Board should also recognize Humboldt Bay as seriously polluted with the extremely toxic chemical dioxin and pursue the polluters responsible to immediately clean up sources of contamination. Clean Up Existing Pollution: To ensure cleanup of toxic mercury and PCB ‘hot spots’ in the bays, cleanup plans should establish a renewed California Superfund program, paid for by polluting industries. Regional water boards should also pursue polluters directly responsible for legacy PCB pollution in the bays for cleanup funds. Restore Habitat: Where feasible, cleanup plans should require restoration of coastal and watershed habitat for creeks, estuary and streams that naturally filter water entering the bays and shelter wildlife. Specifically, cleanup plans should support local restoration efforts around San Francisco and Humboldt Bay and recommend genuine stewardship of the Ballona Wetlands and threatened lagoons that line Santa Monica Bay. The Rivers: The Sacramento, San Joaquin and Klamath New pollution continues to enter three of the largest polluted rivers in the state.Agricultural operations leak farm waste that can contain pesticides, salt, toxic metals and nutrients into the waterways. Urban runoff also carries numerous pollutants into the rivers and legacy mercury pollution leaked into the San Joaquin and Sacramento rivers from old mine sites threatens the health of local communities and river ecosystems. Low flows from dams and water diversions in the Klamath River and San Joaquin River have devastated local fish populations and degraded water quality. The destruction of wetlands and forests that lined the waterways removed important buffer zones that can filter out pollution before it reaches river waters. Despite their degraded state, a cleanup plan for the Klamath River has yet to be drafted and existing cleanup plans for the Sacramento and San Joaquin Rivers do not require dramatic reductions in agricultural pollution, a comprehensive plan to clean up toxic contamination, safeguards against increased use of more dangerous pesticides or ensure water flows necessary to protect water quality. To return these rivers to health, California’s water boards should ensure that cleanup plans: Stop New Pollution: Cleanup plans should require dramatic reductions in the amount of agricultural pollution entering the Klamath, San Joaquin and Sacramento rivers. Officials can do this by issuing strong clean water permits that require significant and measurable reductions in agricultural pollution, overall reductions in pesticide use and agricultural water conservation measures that reduce the amount of irrigation water released into the waters. In addition, the state should order mining operations in the Klamath River that degrade water quality to immediately cease operation. Clean Up Existing Pollution: Cleanup plans should establish a renewed California Superfund Program, paid for by polluters, which will clean up pollution from mines. Until contamination is fully addressed, plans should also establish aggressive risk reduction programs to protect the health of surrounding communities from exposure to toxic pollution. Ensure Sufficient Flows: Cleanup plans should require that dams on the Sacramento, San Joaquin and Klamath are operated in a manner that ensures the water quality of the river downstream is healthy enough to sustain vibrant fish populations and larger ecosystems. Specifically, plans should withdraw water rights and withhold Clean Water Act certification for dams that degrade downstream water quality. In addition, the Central Valley Regional Water Board should establish limits on salt pollution for the entirety of the San Joaquin River and require increases in water releases from Friant Dam to meet these limits. Restore Habitat: Cleanup plans should require, where feasible, funding for the establishment of protective vegetative buffer zones along the waterways that will further protect them from further pollution. The Lakes: Clear Lake, Eagle Lake, and Lake Tahoe Despite strong measures to curtail urban runoff into Lake Tahoe, a lack of development around Eagle Lake and a cleanup plan for mercury pollution in Clear Lake, three of the largest polluted lakes in California face several remaining challenges on the road back to health. New pollution continues to enter Lake Tahoe and Clear Lake. Nitrogen and phosphorous deposited by urban runoff and air pollution fuel the growth of algae that chokes off oxygen and clouds Lake Tahoe. Fine particles of dirt pollution, called sediment, are carried into the lakes by runoff and erosion of streams and further threaten its clarity. The pollution of the lakes is exacerbated by the destruction of local wetlands that can filter out pollution. Eagle Lake and Clear Lake also face a set of unique challenges: Non-native Eastern brook trout interferes with the ability of native Eagle Lake rainbow trout to reproduce naturally. Mercury pollution from an inactive mine on its banks seriously impairs Clear Lake.Despite the seriousness of the issues facing the lakes profile din this report, cleanup plans for Lake Tahoe and Eagle Lake have yet to be drafted and the cleanup plan for mercury pollution in Clear Lake does not guarantee ongoing funding for continued cleanup efforts. To bring these lakes back to health, cleanup plans should: Stop New Pollution: Cleanup plans should restrict development that contributes to the runoff of nitrogen, phosphorous and fine particle pollution and strengthen runoff controls on existing development. In addition, working with state and local air quality officials, the plans should limit air pollution that deposits nitrogen contamination into Lake Tahoe. Finally, cleanup plans should stop new pollution entering the waterways from septic tanks. Clean Up Existing Pollution: Cleanup plans should establish a renewed California Superfund program, paid for by polluters, which will ensure funding for cleanup of pollution caused by old mine sites. Restore Habitat: Where feasible, cleanup plans should require the restoration of wetlands habitat and the establishment of buffer zones along lakeshores and lake tributaries that will revive ecosystems, filter pollution and prevent the erosion of streams into the lakes. The Lahontan Regional Water Board should also list Eagle Lake as seriously polluted with non-native fish species and take steps to control nonnative fish species that hinder the natural life-cycles of native fish populations.     http://www.environmentcalifornia.org/reports/clean-water/clean-water-program-reports/a-clean-water-future-for-california-how-californias-water-boards-can-clean-up-nine-of-the-states-biggest-polluted-rivers-lakes-and-bays Sun, 11 Nov 2007 18:02:25 -0600 http://www.environmentcalifornia.org/reports/clean-water/clean-water-program-reports/petition-to-amend-public-health-goal-for-perchlorate-in-drinking-water We write on behalf of the Environmental Working Group, NRDC (Natural Resources Defense Council), Environment California, Clean Water Action, the Center for Community Action and Environmental Justice, the Center for Public Environmental Oversight, Physicians for Social Responsibility - Los Angeles, the Environmental Justice Coalition for Water, and Latino Issues Forum, as well as our organizations' more than one million members and activists, to petition your Office to immediately intitiate a review of the public health goal (PHG) for perchlorate and to amend that PHG in light of new scientific data.Two factors justify urgent review of the perchlorate Public Health Goal at this time, in advance of the March 2009 statutory deadline.  First, recent studies, including one published in October 2006 by the federal Centers for Disease Control and Prevention (CDC), demonstrate that exposure to perchlorate in drinking water at concentrations below 6 parts per billion poses "a significant risk to health," including to "subgroups that comprise a meaningful protion of the general pollution." The CDC study, for example, documented anti-thyroid effects in a large population of women exposed to perchlorate at concentrations far lower than levels previously shown to have such effects.  These rsulting, significant risks are of particular concern in light of emerging data that shows that the "additive effect of exposure to 'perchlorate' in food' is higher than previously understood.  Taking some of this new information into account, the Massachusetts Department of Environmental Protection (MADEP) in June 2006 finalized a maximum contaminant level (MCL) and cleanup standard of 2 parts per billion.  The subsequent publication of the CDC study justifies promulgation of an even more protective PHG. Second, the Department of Health Services is presently engaged in a rulemaking to establish California's MCL for perchlorate in drinking water.  The California Safe Drinking Water Act not only permits, but requires, the Department to promulgate an MCL below 6 parts per billion if the lower MCL is both 'feasible' and necessary to 'avoid known or anticipated adverse effects on public health with an adequate margine of safety."  However, the Department's establishment of an MCL below the PHG may cause confusion among some members of the public or even generate oposition among interests that do not support the more protective, scientifically basaed MCL.  For these reasons, DHS may be reluctant to establish an MCL lower than the PHG, notwithstanding the new sicenc and the nondiscretionary standards of the Health and Safety Code. We appreciate your consideration of this petition and look forward to a prompt response.  A more detailed analysis follows and we request that the enclosed the referenced studies and date, as well as these comments, be included in the administrative record.  Please do not hesitate to contact us should you have any questions.   http://www.environmentcalifornia.org/reports/clean-water/clean-water-program-reports/petition-to-amend-public-health-goal-for-perchlorate-in-drinking-water Sun, 11 Nov 2007 18:02:25 -0600 http://www.environmentcalifornia.org/reports/clean-water/clean-water-program-reports/troubled-waters-an-analysis-of-2005-clean-water-act-compliance   http://www.environmentcalifornia.org/reports/clean-water/clean-water-program-reports/troubled-waters-an-analysis-of-2005-clean-water-act-compliance Sun, 11 Nov 2007 18:02:25 -0600 http://www.environmentcalifornia.org/reports/clean-water/clean-water-program-reports/down-the-drain-six-case-studies-of-groundwater-contamination-that-are-wasting-california39s-water http://www.environmentcalifornia.org/reports/clean-water/clean-water-program-reports/down-the-drain-six-case-studies-of-groundwater-contamination-that-are-wasting-california39s-water Sun, 11 Nov 2007 18:02:25 -0600 http://www.environmentcalifornia.org/reports/clean-water/clean-water-program-reports/perchlorate-and-children39s-health-the-case-for-a-strong-cleanup-standard-for-rocket-fuel-in-drinking-water  In order to protect expecting http://www.environmentcalifornia.org/reports/clean-water/clean-water-program-reports/perchlorate-and-children39s-health-the-case-for-a-strong-cleanup-standard-for-rocket-fuel-in-drinking-water Sun, 11 Nov 2007 18:02:25 -0600