Responses to my initial e-mail to DOH & Ecology re: Northport Air Monitoring, etc.

  • RE: ASTHO/CDC/NCEH/HCDI Funding for Health Assessment and/or Training‏ for Northport, WA residents & past Air Monitoring Concerns

    Below is: 1) my e-mail to
    2) David McBride’s (DOH) response to
    3) my initial e-mail
________________________________________________________________

#1

To : David McBride DOH, Marc Stifelman,
From: Jamie Paparich
December 27, 2011
Hi David –
I appreciate your response and willingness to address all of my concerns. I have a few questions to your responses below.Paragraph 2(Please note bold sentences):You have mischaracterized the air monitoring results from Ecology collected from 1992-97. The Ecology report from August 1999 titled Northport, Washington Air Quality Study: Phase IV Final Report states that the 24-hour average levels of arsenic and cadmium at all three sites were generally at, or below, the detection limits of 0.01 ug/m3. Quarterly lead averages were below the health based standards. Toxicological analysis of the Phase IV lead data indicate that there should not be any adverse health effects resulting from this level of exposure”. With regards to arsenic and cadmium, the Phase IV Health Risk Assessment statesthat both arsenic and cadmium exceed the risk-based concentrations in actual ambient measurements. However, it should be noted that the majority of the data are reported as being at or below the detection limit and have been rounded up from the detection-limit-qualified values reported by the laboratory. In reporting the average, and especially in calculating the 95th percentile, such qualified data tends to skew numbers upward. As a result, the ambient values reported for arsenic and cadmium may be artificially high and may not represent the true risk estimates.” While the detection limits were high, characterizing the levels of arsenic and cadmium as extremely elevated is incorrect. They were below detection limits. Had they been reported at zero or one half the detection limit, the averages and 95th percentiles would be much lower. The report goes on to state that“none of the actual ambient measurements exceeded risk based concentrations.
My Questions:
  1. I might be misunderstanding you, or the quotes you used from the actual study, but don’t the above underlined statements contradict each other?
  2. If the arsenic and cadmium levels were below the monitors detection limit of 0.01ug/m3, how could the Department of Ecology possibly state in their study; ” both arsenic and cadmium exceed the risk-based concentrations in actual ambient measurements” then go on to say; “none of the actual ambient measurements exceeded risk based concentrations.” ?
  3. How could they state two completely opposite findings in one report?
  4. If the detection limits of the monitor were 0.01ug/m3, how could they accurately state anything about the risk based concentration values found in the ambient measurements? Risk based concentrations are below the detection limits stated to be 0.01ug/m3, the risk based concentrations for arsenic are .0023 ug/m3 and .0056 ug/m3 for cadmium.
Paragraph 3
You state; My understanding from reading Ecology’s report is that Ecology concluded that air monitoring was no longer necessary.
However, as stated on page 5 of the Northport, Washington Air Quality Study: Phase IV Final Report; Cominco, Ltd. is required under the terms of the approved air permit modification application to continue monitoring for particulate and metals at the sheep creek site for a period of one year following the attainment of steady-state production with its new lead smelting process. This production level had been attaed by January 1, 1999, and monitoring will continue at least through December 31, 1999. A summary report will be due to BC Environment no later than December 31, 2000. Data generated at the Sheep Creek site during this period will be provided to Ecology on a monthly basis for subsequent analysis and modeling.”
My Question:
5. What were the results of this year long study? What did the monthly data reports provided to Ecology by Cominco show? How was this data used in subsequent analysis and modeling?
As stated in the Northport, Washington Air Quality Study; Phase III and in the Northport, Washington Air Quality Study: Phase IV Final Report, (page 5, under Ecology Modeling of the Northport Area); “Ecology will also continue its efforts to fine-tune the MM5, CALMET and CALPUFF air quality models for utilization in the Northport study area. When the new models are available, the Northport area will be modeled to ascertain the impacts of the Cominco, Ltd. emissions following the imposition of the new treatment technology at that facility. In addition to evaluating the need for further emission reductions at the Cominco, Ltd. facility, the above models will be used to determine pollutant impact “hot spots” and optimum long-term air quality monitoring site locations. Modeling results and technology will be provided to both BC Environment and Cominco, Ltd. to facilitate air quality and pollutant emissions management.”
My Question:
6. What were the results of these air quality models? I am pretty certain I could, from the health survey responses I received, pin-point most of the pollutant impact “hot spots”.
Paragraph 4
You stated; “Furthermore, DOH has offered to review your health questionnaire to assist in the interpretation and address concerns we had on data complication and presentation. An example of a concern we have is the statement in the Northport Project stating the cancers are extremely high. Work done by DOH in the mid-90s and within the past few years does not come to that conclusion.”
My Response:
I provided a copy of my health questionnaire to Glen Patrick over a year and a half ago. As for the work the DOH did in the mid 90’s and the past few years to reach the conclusion that there is not an elevated level of multiple cancers that have been, and continue to be, diagnosed in past and present Northport resident? Well, this is just more evidence to my case that the DOH, ATSDR and EPA are not doing an accurate Human Health Risk Assessment. The DOH cannot rule out elevated cancer cases when all they do is download annual, County wide, diagnosed cancer statistics. The population being as small as it is in Northport, just as the DOH and the EPA has stated and your attached document point out, a County wide statistic study would not accurately reflect an increase in such as small portion of the County, (that small portion being Northport.) Also, many of the residents have moved and I had to do leg work to track them down to obtain complete and accurate data and statistics necessary to complete an accurate health assessment. Meaning, I had to actually go door to door and talk to the present community members. In doing this I got not only their health history, but was able to track down a substantial portion of past residents both impacted and not impacted with health issues.
I look forward to your response and want to thank you again for your willingness to hear out my frustrations and concerns.
Sincerely,
Jamie Paparich

#2

Subject: RE: ASTHO/CDC/NCEH/HCDI Funding for Health Assessment and/or Training Date: Tue, 27 Dec 2011 16:24:55 -0800 From: Dave.McBride@DOH.WA.GOV To: jamie_paparich@hotmail.com
Hi Jamie
I would also like to clarify that the recent work conducted by DOH did not limit the assessment to recreational exposures. As I had previously mentioned, the ATSDR report that Len O’Garro worked on considered a 35 day exposure period as well as a 120 day scenario. His recommendations are on page 25 and the calculations can be found in Appendix C. Furthermore, when conducting fish advisories, advice is not restricted to recreational anglers but applies to the entire population, including, tribal, subsistence and the general population.
You have mischaracterized the air monitoring results from Ecology collected from 1992-97. The Ecology report from August 1999 titled Northport, Washington Air Quality Study: Phase IV Final Report states that “the 24-hour average levels of arsenic and cadmium at all three sites were generally at, or below, the detection limits of 0.01 ug/m3. Quarterly lead averages were below the health based standards. Toxicological analysis of the Phase IV lead data indicate that there should not be any adverse health effects resulting from this level of exposure”. With regards to arsenic and cadmium, the Phase IV Health Risk Assessment states “that both arsenic and cadmium exceed the risk-based concentrations in actual ambient measurements. However, it should be noted that the majority of the data are reported as being at or below the detection limit and have been rounded up from the detection-limit-qualified values reported by the laboratory. In reporting the average, and especially in calculating the 95th percentile, such qualified data tends to skew numbers upward. As a result, the ambient values reported for arsenic and cadmium may be artificially high and may not represent the true risk estimates.” While the detection limits were high, characterizing the levels of arsenic and cadmium as extremely elevated is incorrect. They were below detection limits. Had they been reported at zero or one half the detection limit, the averages and 95th percentiles would be much lower. The report goes on to state that “none of the actual ambient measurements exceeded risk based concentrations.”
My understanding from reading Ecology’s report is that Ecology concluded that air monitoring was no longer necessary. As stated under the section titled Termination of Northport Elementary School and Bennetch farm Sites. “Analysis of Phase II and preliminary Phase IV ambient air data in the Northport area indicated that the pollutant levels do not pose a health threat to inhabitants. It also showed that Sheep Creek and the Northport Elementary School are in similar airsheds. Based on these findings, it was decided to cease operations at the Northport Elementary School site on December 31, 1998. Also, Cominco, Ltd. has closed the Bennetch farm site as agreed to in the Phase IV study design.”
I followed up with Ecology and they confirmed that they do not have any plans for further air monitoring in the area. Having said all that, yes, it would be nice to have additional air monitoring data to reduce the uncertainty associated with the previous monitoring efforts. We will take a look at the ASTHO document you sent.
Furthermore, DOH has offered to review your health questionnaire to assist in the interpretation and address concerns we had on data complication and presentation. An example of a concern we have is the statement in the Northport Project stating the cancers are extremely high. Work done by DOH in the mid-90s and within the past few years does not come to that conclusion.
I would again like to share with you two documents. The first was written by Juliet VanEenwyk, an epidemiologist here at DOH describing the work our office did in regards to health issues in the Northport area – basically it is a peer-reviewed article on some the work that went into the DOH 1994 report on Air Monitoring Data and Evaluation of Health Concerns in the Areas of Northeast Tri-County. The second is an article from the New Yorker on cluster investigations that describes many of the issues that public health officials must consider when conducting such studies.
I believe we both have an interest in improving the health and the environment in the Northport area. I would be glad to discuss any issues you have.
Best regards
Dave
Dave McBride Toxicologist Washington State Department of Health Office of Environmental Health, Safety & Toxicology PO Box 47846 Olympia, WA 98504-7846 (360) 236-3176 Email: dave.mcbride@doh.wa.gov

______________________________________________________________

#3

From: Jamie Paparich [mailto:jamie_paparich@hotmail.com] Sent: Thursday, December 15, 2011 2:47 PM To: McBride, David (DOH); Marc Stifelman Subject: ASTHO/CDC/NCEH/HCDI Funding for Health Assessement and/or Training Importance: High

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.

Sincerely,

Jamie Paparich

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