Hi David –
1. Why would the Department of Ecology chose to handicap the study by using a monitoring method that would only allow the detection limits of these toxins to be recorded at a minimum detection level of 0.01 ug/m3, which, since it was higher than the health risk based values, made it impossible to know if the actual value was closer to the health risk based concentration or closer to zero? As you stated, “detection limits used do (did) not allow accurate statements about risk”.
You go on to say;
My Response:I apologize for not explaining why I stated in my previous e-mails that I found the levels of arsenic and cadmium to be extremely high. Let me explain what lead me to this interpretation of the data.
Our farm (referred to as “Paparich” or “Paparich site”) was the location of both TSP and PM-10 Air Monitors from August 1993 – October 1993, also known as Phase II of the Northport Air Monitoring Study and the location of the only air monitors used in the 9 month Phase III Northport Air Monitoring Study.
The levels of arsenic and cadmium recorded from these monitors were consistently recorded at, what I interpreted to be, extremely high levels in comparison to the health risk based concentration levels they were compared against.
From specific data recorded daily from the PM-10 monitors on our property in Phase II, (i.e.; on August 26, 1993 the level of Furnace Arsenic was logged at .0043, the level of ICP Arsenic was logged at .0044, and Cadmium at .0017 from the PM-10 monitor), it is clear that the detection limits were much more specific and accurate than the detection limit of 0.01ug/m3 used for Phase III and Phase IV monitoring….and that all arsenic and cadmium recordings were, on average, consistently higher than their ASIL’s. So it is no surprise that both Phase I and Phase II studies found that “both arsenic and cadmium concentrations in the Northport study area pear to exceed their respective ASIL values significantly.” The Maximum metal concentrations found for arsenic and cadmium in the Phase II Air Quality Monitoring Study, at our air monitors were; .0691 for Arsenic and .0282 for Cadmium (Table 5 of the “Air Monitoring Data and Evaluation of Health Concerns in Areas of Northease Tri-County, April 1994). The Acceptable Source Impact Levels (ASIL’s) for Arsenic is .00023 and .00056 for Cadmium (Table 9 of the “Air Monitoring Data and Evaluation of Health Concerns in Areas of Northease Tri-County, April 1994).
I can say this with certainty because it seems the detection limits for Phase I, III and possibly III of the air monitoring tests were not crippled with the minimum detection limit of 0.01ug/m3 used in the Phase IV air monitoring studies as I mentioned above.What makes me so certain is my Grandfather had received not only a binded copy of the “Air Monitoring Data and Evaluation of Health Concerns in Areas of Northeast Tri-County” (which included results of the daily air samples collected at all air monitor locations, including our farm in Phase I & II air monitoring studies), he also received computer print out copies of the daily air samples recorded at the monitors located on his property. He also was asked by Ecology and DOH employees if he would be willing to record the air monitor readings and record the results on the many days Ecology and DOH employees were unable to make it up to Northport to record the data for themselves during both the 3 months the monitors were operated on his farm for the Phase II air monitoring, and also for the 9 months following the Phase II air monitoring, which was Phase III. The only air monitors used for Phase III were the monitors on our property. He gladly did this, willing to assist in anyway he could. He was also given copies of the hand written results he recorded and even the ones he did not. Luckily he kept copies of these hand written entry logs, as well as the computer generated logs the Department of Ecology (or possibly the DOH?) provided him.
These logs show that 0.01 ug/m3 was not chosen as the minimum detection limit due to the capability of laboratory equipment, etc., since lower concentrations we’re accurately recorded over the 12 months (3 months in Phase II and 9 months in Phase III) the monitors were on our property. The logs also show that concentration levels of arsenic and cadmium were consistently found to be close to or usually higher than their health risk based concentration levels .
I understand that since Phase II was only for 3 months, and ASIL values are for yearly averages, they could not say with certainty these elevated levels would result in an accurate ASIL. Which is why Phase III was planned. The purpose of Phase III was to continue monitoring the area the highest levels of both heavy metal toxins had been reported in the 3 months the air was monitored in Phase II….our farm (“Paparich” or “Paparich site”).
Phase III air monitoring continued on our property from November 3, 1993 through August 6, 1994, because, as stated in the Northport, Washington Air Quality Study: Phase III; “to provide the necessary additional nine month monitoring data for a valid annual comparison.”
The NorthportWashington Air Quality Study: Phase III concluded: “Following the conclusion of the Phase III study and the ensuing data analysis, it became apparent that both arsenic and cadmium still exceeded their respective ASIL values but to a lesser extent.”
- I am still baffled as to why it is stated the detection limit for both phase III and phase IV was 0.01 ug/m3 since the Phase III daily monitoring results, clearly show the actual detection limits were lower than the set detection limit of 0.01ug/m3?
- Why would Ecology want to handicap their study by placing a detection limit at 0.01ug/m3? Especially since the entire purpose of Phase III was to ensure the 3 month results of arsenic and cadmium levels were accurate.
- Again, why would Ecology not only handicap the Phase IV study with the same detection limit of 0.01ug/m3, but why weren’t monitors used in the Phase IV study placed on our property again, to ensure complete accuracy in the study?
I interpreted the levels of arsenic and cadmium to be extremely elevated based on the results of the Phase I and Phase II Air Quality Studies done in Northport (“Air Monitoring Data and Evaluation of Health Concerns in Areas of Northease Tri-County, April 1994), and based on the actual results of the Northport Air Monitoring Study: Phase III.
Below is the actual results of the Phase III monitoring study – followed by the explanations as to how they were able to conclude that the predicted cadmium concentration (based on the expected reductions to follow two years later) would reduce cadmium to acceptable levels to protect human health, and the explanation how the 95th percentile predicted arsenic concentrations (also based on expected reductions) would still be above the ASIL, and would most likely result in an excess cancer rate of 1 in 10,000.
ACTUAL ASIL’S FOUND FOR ARSENIC & CADMIUM IN PHASE III AIR MONITORING:
“The annual average arsenic level at the Paparich site from August 13, 1993, through August 6, 1994, was 0.02 μg/m3 when analyzed by GFAA and 0.03 μg/m3 by ICP. These values are 87 and 130 times higher, respectively, than the ASIL, value of 0.00023 μg/m3 (annual average). GFAA and ICP arsenic data are tabulated, averaged, and compared to the arsenic ASIL, in Appendix B, Tables 3 and 4, respectively.”
“The annual average cadmium level at the Paparich site from August 13, 1993, through August 6, 1994, was 0.01 μg/m3, which is 18 times the ASIL, of 0.00056 μg/m3 (annual average). ICP cadmium data for the study are tabulated, averaged, and compared to the cadmium ASIL, in Appendix B, Table 5. “
MANIPULATED ASIL’S “to be” FOUND FOR ARSENIC & CADMIUM
Under the Health Evaluations for Arsenic and Cadmium in the conclusion of the
NorthportWashington Air Quality Study: Phase III, it states the following:
- “Concentration values were then adjusted downward to reflect expected reductions from new control technologies added to the Cominco, Ltd. smelter in spring of 1997. Emissions were reduced by the predicted factors of 76% for lead, 85% for cadmium, 65% for arsenic and 74.5% for sulfur dioxide (Cominco, Ltd. Air Permit Modification Application).
- Health Evaluation for Cadmium
“With regards to smelter modifications to control cadmium, Ecology concludes that the proposed modifications appropriately reduce air concentrations of cadmium to an acceptable level for protection of human health.”
- Health Evaluation for Arsenic
“Comparison of the 95th percentile predicted air arsenic concentration in Northport to the risk based concentrations (see Table 3 above and Table 5 below) indicates that arsenic risks range between 1 in 100,00 to 1 in 10,000.”
“Cominco, Ltd. emissions may still result in an excess cancer risk of as much as 1 in 10,000 for the town of Northport, and Ecology recommends further emission reductions whenever possible.Northport, Washington Air Quality Study: Phase III;
Why I still interprete the levels of cadmium and arsenic to be extremely elevated from the results of the Phase IV Air Monitoring Study is because there is no evidence to support actual detection limits were available below the 0.01ug/m3 detection limit imposed on the study.
They did not even monitor air at the same location Phase II and Phase III had taken place on. Along with the fact that the results of the Phase IV Ambient Averages for Cadmium and Arsenic concentrations still exceeded their ASIL values, making the probability that Ecology would rely on such an inaccurate detection limit of 0.01ug/m3 to prove their gamble on deducting the actual levels found of arsenic and cadmium in phase III to approve Cominco’s permit was a very big mistake.
Also, in Appendix A (page A-2) of the Northport, Washington Air Quality Study: Phase IV – Final Draft it concludes that;
“As noted in the Phase III report, these risk estimates should incorporate considerations from other exposure media, such as ingestion of contaminated soils, water, or house dust. Because such data are lacking, the described risk estimates are associated with some uncertainty.”
I apologize for the lengthy e-mail, and I hope you can help me with some of my questions, or lead me in the right direction.
I will get back to you shortly on your questions regarding my Health Questionnaire and the breakdown of the information I have received.
Thank you again for not only answering my questions quickly, but honestly and accurately as well.I really do appreciate it David –
Hope you have a Happy New Year and I look forward to working with you in the upcoming year –
Sincerely,Jamie Paparich______________________________________________To read Phase III of the Northport Air Quality Study go to: http://www.ecy.wa.gov/biblio/98210.htmlTo receive a copy of the Phase IV Northport Air Monitoring report (Final) please email me at: Northportproject@hotmail. (The final Phase IV air monitoring data /text is not available online.Email request to:
Subject: RE: ASTHO/CDC/NCEH/HCDI Funding for Health Assessment and/or Training
Date: Wed, 28 Dec 2011 10:58:16 -0800
CC: firstname.lastname@example.org; email@example.com; firstname.lastname@example.org; JROL461@ECY.WA.GOV; CHGR461@ECY.WA.GOV; Joanne.Snarski@DOH.WA.GOV
I’ll try to address your questions. I will also check with Ecology staff to see whether they can provide any additional information that address specific questions and concerns.
Questions from paragraph 2 (questions 1-4)
The way the data were presented can lead to confusion and it does appear that the statements are contradictory. At issue is the detection limits used to measure arsenic and cadmium. The detection limits used in the study were higher than health criteria. In the study, the values were measured at or below the detection limit. If the detection limit is then reported when there was a nondetected value, it was “above” the health criteria. So in this case, most of the values, whether detected or not, would lead to a value above the health criteria. The actual value could be close to the detection limit or it could be close to zero. You are correct to point out that the detection limits used do not allow accurate statements about risk which is why I disagreed with your interpretation that the values are extremely high.
As stated in the Phase III report, comparison of the 95th percentile air arsenic concentration in Northport to risk based concentrations indicated that cancer risks ranged between 1 in 10,000 to 1 in 100,000. DOH evaluated morbidity and mortality data for Northport did not find increased rates of lung cancer or respiratory illness. A comparison of an individual’s estimated dose from inhaled arsenic to EPA’s reference dose for non-carcinogenic effects by Ecology indicated that health effects associated with arsenic exposure are not expected to occur in the Northport community.
Questions from paragraph 3 (questions 5 & 6)
Most of your questions I will have to refer to Ecology. I was referring to monitoring at the Northport Elementary School and Bennetch farm. I am not aware whether Ecology received data from the Sheep Creek site for 1999. I will check with Ecology to see whether they received that data. My assumption is that they did given that it was a requirement of the air permit.
Questions from paragraph 4
When I was tasked with the Upper Columbia Project (Nov 2010) I asked Glen Patrick and Juliet Van Eenwyk about their involvement so I could come up to speed on the various issues. After conferring with Glen and Juliet, my understanding is that they had specific questions/concerns on the health survey that were not provided. The following is Juliet’s response to my inquiry about the survey and how the data were presented in the newsletter.
To my knowledge, no one from DOH was involved in helping to develop the questionnaires. At one point, it looked like Jamie might send us the results. I think the questionnaire is fine. The only thing we asked her to do was to add something to let us know how questionnaires were linked in terms of families, since some of the conditions she was tracking have genetic/familial components. For things like lung cancer (and interestingly, the questionnaire doesn’t include lung cancer), we generally like to know about smoking, but given the diversity of diseases and that those of known etiology have multiple risk factors and that many are of unknown etiology, not going down the risk factor route makes sense. So, bottom line, the survey instrument is fine, but it would be helpful to know whether some of the diseases ran in families.
Data compilation and presentation
The way in which data were compiled and presented has some weaknesses. Our (DOH’s which included Glen and me and a few others) bottom line to Jamie was that we could not interpret the results from the data she sent. We agreed to look at the results if we could get individual questionnaires with some indication of family relationships among respondents so that we could address some of the weaknesses in her summary. She basically sent us what is in the newsletter, unless Glen and Nancy have gotten something more recently. For me to interpret data, I would really want to know
· Numbers of respondents in each generation and numbers of people with specific diseases by generation (with familial links) For example, with 16 brain aneurisms/tumors and the 1st generation getting tumors and the 2nd generation getting aneurisms, I would really like to know how many tumors (and what kind of tumor), how many aneurisms, and how many people in each group by disease and generation. I’m not sure why brain tumors were combined with aneurisms, since the etiologies are likely to be different (I would need to check the literature about etiology, but I know that most brain tumors are of unknown etiology. I don’t know whether either brain tumors or aneurisms have been associated with metals.) I have the same concern with Parkinsons and what the newsletter has as multiple scoliosis, but I assume is supposed to be multiple sclerosis. While early stages of these conditions and metals poisoning can be similar, my understanding is that metals do not cause either (although causes are for the most part unknown) and that a diagnosis of PD or MS does not imply previous overexposure to metals. My concerns are combining what might be 2 diseases with different etiologies and not knowing what the numbers are for the diseases separately.
· There is no indication of what ages people are being diagnosed, although those data were collected. The newsletter does indicate some diagnoses at early ages, but for things like prostate cancer, age at diagnosis is important to know whether there is more prostate cancer than elsewhere. For other diseases, I’m not sure whether diagnosis at a relatively young age is unusual. For example, I think that thyroid diseases are often diagnosed at relatively young ages. Again, I would need to do more research to see whether this was unusual.
· It would be good to have references for selection of background rates, as well as a description of what they represent, e.g., prevalence, new diagnoses each year, etc. I am assuming that they are prevalence. However, since prevalence can vary irrespective of exposure to metals, I think some of the background rates might need readjustment. For example, Northport was historically an iodine deficient area and so it might be reasonable to compare to other areas with historical iodine deficiencies than a general population. Some of the goiter in the first generation, for example, might be related to historical iodine deficiency. MS is also more prevalent in northern latitudes and so it might be good to get background rates for northern latitudes. Also, for arthritis, the survey captures those who “strongly suspect” they have arthritis. One can’t compare those with diagnosed arthritis for background with diagnosis plus undiagnosed in Northport.
· I find presenting percents as the proportion of people answering the survey as problematic. I would rather see the finding presented as a rate, that is the number reporting a diagnosis divided by the total population (ideally this would also be adjusted by age). For many of the conditions reported, rates do not seem higher than expected and for cancer, this is true even looking at percent of respondents (33% of respondents reported cancer and about 1/3 of us will get cancer at some point in our lives). My concern is that people with diseases completed the survey while healthy people did not. Accepting the 375 as the population, 5 people with PD and MS, for example, approximate background rates; arthritis falls below background.
· It gets difficult to interpret rates if many folks answering the questionnaire have moved out of the area. I would like to know what proportion of the respondents are from out of the area. I don’t mind throwing a few people into a numerator who might have moved from the area, but when we start putting substantial numbers in, we are likely to have skewed results. Also, how many healthy people moved away and had healthy children?
· In addition to these relatively general issues, I have specific issues with some diseases, but I feel I have spent enough time on this. As one example, what does it mean that those with cancer developed it “50-60 years after first exposure.” The survey does not capture exposures.
A few more notes:
· I looked at thyroid disease very carefully when I did the study in the mid-1990s and rates of thyroid disease were not higher than in areas of historical iodine deficiency.
· I also looked at cancer in the mid-1990s and did not find elevations. Nancy did a better, more recent look at cancer and also did not find elevated rates. She can likely get that to you.
· I would also confirm with Nancy what she used as a denominator to get a handle on whether 375 is at all close to our current estimates that could also be off. We won’t really know until 2010 census data come out. As I recall, the 5-7 mile radius around Northport has more like 600 people, but Nancy will know.
I hear your frustrations and concerns. You are correct to point out that in a small community such as Northport it is difficult to ascertain whether certain health outcomes are elevated or not. I do not think this is a function of whether or not DOH, ATSDR, and EPA are doing accurate health assessments but rather what can be concluded about small numbers statistically. I would encourage you to work with our epidemiologist to address their concerns/questions raised to strengthen the results of your survey.
I’m sure we’ll be talking in the future.
Have a happy New Year.
Washington State Department of Health
Office of Environmental Health, Safety & Toxicology
PO Box 47846
Olympia, WA 98504-7846
Web site – http://www.doh.wa.gov/ehp/ts/DEFAULT.HTM
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