December 15, 2011
Dave McBride Washington State Department of Health Office of Environmental Health, Safety & Toxicology PO Box 47846 – Olympia, WA – 98504-7846
Marc Stifelman Toxicologist U.S. Environmental Protection Agency, Region 10 Office of Environmental Assessment, Risk Evaluation Unit 1200 Sixth Avenue, Suite 900 – Mail Stop: OEA-095 Seattle, WA – 98101-3140
Re: ASTHO Funding Opportunity for Northport Project / Air Monitoring Concerns
Dear David & Marc,
I realize that the EPA is currently in the process of conducting the Human Health Risk Assessment of recreational use of the Upper Columbia River/Lake Roosevelt Areas. Although I am thrilled that a more comprehensive study is finally being done regarding the possible health issues associated to the elevated levels of toxins discovered in decades of the different studies done by the EPA, Ecology, DOH and the USGS, (just to name a few).
However, I am still disappointed in the fact that the Human Health Risk Assessment is still only focusing on possible health risks to recreational users. I do think this is an extremely important issue, especially since the areas major source of income is tourism and recreational use of the beautiful area, and being able to ensure visitors that they are safe, if their exposure is limited to 35 days of the year, is very beneficial and important. My concern lies in the health and safety of the 350+ residents of Northport, and the other small communities and tribes along the Upper Columbia River who are exposed 365 days of the year, and are exposed to areas found, in past studies, to have higher levels of toxins than the areas studied in the EPA’s 1993 RI/FS and Teck’s current RI/FS (the 15 beaches, river sediments, boat launches and campgrounds, the 3 found to be the worst contaminated being located in Northport).
My biggest concern is to see that, (per the current version of the HHRA work plan), there is no future plans to do further air monitoring in or around Northport. This shocked me as all four phases of air monitoring Ecology completed in and around Northport from 1992-1997 showed levels of arsenic and cadmium to be extremely elevated and higher than all recommended safety levels for both acute and chronic exposure.
The results of elevated toxins of concerns found in phase 3 were actually reduced by 73 -87%, (based on information Teck provided Ecology on what they anticipated the levels would be once the installation of the new Kivcet smelter was completed, in 2 years).
Based on these inaccurate levels Ecology not only approved the revised permit Teck requested, but published those false numbers in their report which gave them no reason to recommend to the DOH and EPA a need, or even a raise a red flag to these Agencies, the need for another health assessment that desperately needed to be done in the area. The phase 4 air monitoring was then planned specifically to ensure the reduction of the actual elevated toxin levels Ecology used in the phase 3 air monitoring report were correct, once the Kivcet smelter had been installed and in use, as Teck had promised they would be.
Phase 4 showed that arsenic and cadmium levels continued to exceed safety recommendations, as a matter of fact the levels had not changed at all. The Phase 3, as well as Phase 4, air monitoring reports indicated that long term air monitoring would have to be conducted by Teck, with monthly, (eventually reduced to quarterly), reports of the monitors collected data to be forwarded to Ecology for review. There was never any follow up on any air monitoring done after Ecology completed Phase 4 air monitoring and published the report. Northport no longer even has an air monitor.
The closest US air monitor is in Colville, 35 miles away. When I contacted Ecology recently about the location of Teck’s air monitors, and the possibility of getting copies of the quarterly reports they had received from Teck since 1997, I was told they had no data and they were not even sure if Teck had any air monitors in the area. This astounded me.
Obviously they had not been monitoring the quarterly air monitoring reports Teck was to provide them as indicated in both phase 3 and phase 4 of their air monitoring reports, which means no one had been monitoring the possible danger Northport residents were in.
What confuses me the most is Ecology did not think it necessary to have their own air monitors in, or even near, Northport – which their testing had proved the extremely elevated levels of arsenic and cadmium in the air.
Finally, with the recent surfacing of many health clusters in the community, along with the current RI/FS being done by Teck (based on the agreement reached between the EPA and Teck in 1996), as well as the current HHRA being conducted by the EPA, how is it that none of the involved State agencies discovered the fact that there had been no follow up to the promised air monitoring to the Northport community, and the fact that, based on the levels of arsenic and cadmium recorded in the 4 air monitoring reports done between 1992-1998, that monitors needed to be installed immediately, if not for the safety of the residents then at the very least to do an accurate HHRA?
Instead the HHRA states that no further air monitoring is necessary in the Northport area, based on the data they have from the previous 4 air monitoring studies done by Ecology. If the HHRA is going to base their decision on the data from those 4 air monitoring reports, then (based on Health Risk Assessment Guidelines) the EPA should have began an in-depth HHRA of the Northport community, meaning the 350+ residents who had been, and continue to be, chronically exposed to high levels of arsenic and cadmium via inhalation AND multiple other routes of exposure – not to mention their exposure was not limited to arsenic and cadmium alone, but to several other heavy metal toxins.
I was hoping that possibly the local Health Agency would be willing to submit Northport for the ASTHO funding project (see background below, and report attached).
The Background for the ASTHO/CDC/NCEH/HCDI Project:
“The Association of State and Territorial Health Officials (ASTHO), in conjunction with the Centers for Disease Control and Prevention/ National Center for Environmental Health/Healthy Community Design Initiative (CDC/NCEH/HCDI) will fund and support up to two (2) state or territorial health agencies (STHAs) to do at least one of the following: 1) conduct one Health Impact Assessment (HIA), or 2) conduct one HIA training. The primary purpose of this RFP is to build capacity for conducting HIA among STHAs through a hands-on, project-oriented approach. HIA targets can originate from a variety of sectors, but those with an environmental health focus will be given preference (i.e. transportation, land use, housing, parks, agriculture, or energy).”
To read the full report see attached, or go to: http://www.astho.org/Display/AssetDisplay.aspx?id=6578
The funding could be used to either install air monitors, and/or assist in conducting or financing research for The Northport Project plan (see attached). The Northport Project plan would not only benefit the community by providing early detection of possible health diseases and illnesses, as well as proper management of the illnesses, but would also provide much needed data in a long term study of health impacts triggered or caused by chronic exposure to multiple toxins, via multiple routes – resulting in providing the research and information needed to ensure that the safety levels of chronic exposure to specific toxins are accurate, and if they are not the data will assist in correct levels to be implemented, which will save thousands of lives throughout the Country.
I look forward to your response.