By Jamie Paparich • June 30, 2020
The for public comment. The EPA offered two webinars to give as many impacted people as possible a chance to learn more about the HHRA, directly from the EPA, to help prepare them for the opportunity to provide comments on the assessment during the public comment period.
I attended the June 10th webinar. They did an excellent job summarizing the over 1,900 page report, as well as presenting a helpful powerpoint presentation. They allowed us to ask questions during the webinar, or offered the option to submit them afterwards.
After attending the webinar and reading the Draft Human Health Risk Assessment, my comments on the HHRA are below.
To begin my comments on the EPA’s 2020 Draft Human Health Risk Assessment (HHRA), I must refer back to the results of the WA Department of Ecology’s Phase I, II, III, and IV Air Monitoring studies, conducted between 1992 through 1998 in and around Northport. These studies found the annual concentration level of arsenic in our air was 0.03 ug/m3, which is 87 to 130 times higher than the ASIL (Acceptable Source Impact Level) value of 0.00023 ug/m3. The annual concentration level of cadmium was 0.01 ug/m3, which is 18 times higher than the ASIL value of 0.00056 ug/m3.
In 2017, due to multiple requests from concerned Northport residents, Ecology’s Air Quality Program specialists conducted an Air Quality evaluation of the area, using the existing air monitoring data from their 1992 thru 1998 assessments, as well as the data from the monitoring Teck conducted in the area between 1999 thru 2009. Their evaluation found that lead, arsenic, and cadmium remain above safety standards. Based on their findings, Ecology requested the EPA conduct a new phase of air quality monitoring as part of their HHRA to better assess current conditions of the area, and potential health risks to the community.
Unfortunately, the EPA disregarded Ecology’s recommendation, choosing not to conduct any new air monitoring of the area as a part of their HHRA. They stated that although levels of arsenic, cadmium and lead all exceeded safety standards in the air monitoring Ecology conducted between 1992 through 1998, and the monitoring Teck conducted between 1999 through 2009, exposure to these elevated levels would likely not expose residents to a cancer risk greater than 1 in 100,000.
However, the EPA did not take into account the other health issues that chronic exposure to these heavy metal toxins cause, or at the very least trigger. Multiple studies have shown long-term exposure to heavy metals, specifically arsenic, cadmium and lead, can progressively lead to multiple autoimmune diseases.
An unusually high number of Northport residents, spanning three generations, have been diagnosed with similar autoimmune diseases. The residents continue to be diagnosed with these rare autoimmune illnesses, as well as specific cancers… proving the levels of arsenic, cadmium and/or lead we are being exposed to are far from safe.
- Toxic effects associated with chronic exposure to cadmium include: gastrointestinal inflammation (ulcerative colitis, Crohn’s), pulmonary edema, neurodegenerative disorders (Parkinson, Alzheimer), immune-mediated chronic inflammatory disease of the central nervous system (Multiple Sclerosis), renal dysfunction and kidney disease. Cancers known to be caused by chronic exposure to cadmium include: lung, prostate and kidney cancer. Although the EPA’s risk-based concentration levels claim only 1 in 100,000 people are at risk of developing cancer, the number of past and present Northport residents diagnosed with one of these cancers proves the EPA’s risk-based concentration is incorrect.
- Toxic effects associated with chronic exposure to arsenic include: diabetes, nervous system complications (loss of sensation in the limbs and hearing problems), immune-mediated chronic inflammatory disease of the central nervous system (Multiple Sclerosis), and heart arrhythmias. Cancers believed to be caused by chronic exposure to arsenic include: skin cancer, cancers of the bladder, lung, liver, colon and kidney cancers. Again, the amount of past and present Northport residents diagnosed with one of these cancers proves the EPA’s 1 in 100,000 risk-based concentration is incorrect.
How did the EPA’s Human Health Risk Assessment not take the below statistics into account when assessing the risk Northport residents are in.
- 34% of the Northport community is suffering from one of the health issues listed.
- Statistically .006% of Americans are diagnosed with ulcerative colitis or Crohn’s. disease. Six percent (6%) of Northport residents have been diagnosed with either colitis or Crohn’s.
- Statistically .003% of Americans are diagnosed with Multiple Sclerosis. Four percent (4%) of Northport residents have been diagnosed with MS.
- Statistically .5% of Americans will be diagnosed with cancer. Twenty percent (20%) of Northport residents have been diagnosed with cancer.
The EPA will never succeed in reducing the risk from our exposure to Teck’s heavy metal toxins because the benchmarks they are using are incorrect. Study after study conducted in our area, spanning decades, by the EPA, Ecology, the ATSDR, and the DOH have all concluded that our chronic exposure to the elevated levels of the heavy metal toxins of concern would, “more then likely” not put our health at risk.
The statistics above, discovered from a 2011 community health survey, prove that not only are these agencies not reducing our risk, they are increasing it by assuring us that we are not in danger.
The health issues plaguing our community is scientific proof that;
- The current safety levels for chronic exposure to arsenic, cadmium, and lead being used as the benchmark to evaluate whether or not there is a risk to human health is not correct.
- The EPA, Ecology, CDC, ATSDR, and the DOH’s practice of concluding communities are safe if their exposure level falls within this benchmark is inaccurate. Autoimmune diseases are linked to chronic exposure to heavy metal toxins at a much lower exposure level, and statistically our community alone has proven the 1 in 100,000 cancer risk based concentration levels don’t add up.
I understand the purpose of the HHRA is to evaluate actions needed to reduce risk to residents. Below are some of the actions the EPA should put into place to reduce the risk of health issues for not only Northport residents, but for the residents of similar communities throughout the United States.
- Long-term air monitors in and around Northport. The results of which could be used, along with the decades of environmental and health studies done of the area, to conduct a study to evaluate the accuracy of the current safety levels for chronic exposure to arsenic, cadmium, lead and other heavy metal toxins of concerns.
- Conduct an epidemiological study of past and present Northport residents. The inaccurate safety levels could be reevaluated using actual human test cases impacted by chronic exposure, through multiple routes of exposure, to documented levels of these toxins. This study could provide invaluable information into the bioaccumulation of, and the health issues caused, or triggered by, chronic exposure to documented levels of multiple (specific) heavy metal toxins, through multiple routes of exposure.
I assume the EPA was given the documentation and is aware of the multiple health clusters that have plagued our community for generations. Whether or not there is a risk to our health is not in question. The real risk is this study, and future studies and assessments, continuing to use the same incorrect exposure safety levels, resulting in the study concluding the community is not at risk.