As you are aware, a group that is broadly representative of the many constituencies interested in the STAR program have been meeting for many months in an effort to identify and develop consensus on adjustments in the language of the STAR program regulations that will clarify the intent of the regulations and make technical modifications that will provide greater clarity or flexibility without sacrificing protection of the public health and welfare. I have served on that group as the representative from KRC.
On many points, consensus has been reached regarding the version of 5.21 that is before you for consideration. In one important area, however, consensus was not reached, and from KRC?s vantagepoint, the proposal before you remains very problematic as a matter of public health and public policy.
In existing Section 2.9, an adjustment factor was adopted in that increased the Environmental Acceptability goals by a factor of 4.2 for cancer risks for industrial properties. KRC objected to this factor in the initial package as discounting the protection of the health of workers in an industrial workplace, since unlike the transient exposure on roadways that supported the adjustment factor for public roadways, workers within and outside of structures in the workplace face exposure for a longer duration on a more frequent schedule, and typically reside in the community, thus accumulating exposures at concentrations that exceed the benchmarks set for the general public.
In the proposed revisions to Section 2.9, that factor has been increased to 10, resulting in an additional erosion of protection of the industrial workforce and sanctioning lifetime exposure of those workers to elevated levels of carcinogens significantly higher than the threshold EA goals adopted for the general population.
KRC requests that as you review the proposed regulation and public comments, the adjustment factor increase for industrial properties is rejected as being underprotective of the industrial workforce in our community.
Thank you for your consideration of these concerns.