Posts Tagged ‘Northport Air Monitoring’

Electronic Petition for Air Monitoring in Northport, WA – Please sign!!

ATTN: If you are a past or present Northport WA resident, or a resident of a community nearby, or if you simply care about the community of Northport PLEASE read the petition below. If you agree and would like to sign the petition; 

  1. Copy & paste this sentence: “This is my signature for the 2017 Northport WA Air Monitor Petition” – **along with your name, address, phone# and/or email** into the comment section below. 
  2. Hit enter- that’s it! 

It’s that simple! If you don’t want to put your personal information (address, etc.) in comment section, you can email the sentence along with your personal information instead to: northportproject@hotmail.com

Please forward this on to anyone who might be interested in signing.
PETITION:

I believe the EPA and the Washington State Department of ecology should plan and institute a comprehensive air monitoring program from Northport to the Canadian border. The program should be developed with community input, include a minimum of three monitoring stations, and continue with no predetermined termination date. 
Questions?  Email me (Jamie Paparich) directly at: northportproject@hotmail.com

Ecology’s Air Quality Assessment Concludes Air Monitors Needed in Northport

by Jamie Paparich

 

In 2008 I began looking into the decades of toxins the Canadian smelter, Teck, had been allowed to dispose of into Northport’s air, water and soil, literally slowly poisoning us.  The further I looked into it the more disillusioned I became with our Government agencies, specifically the EPA, the ATSDR, and the DOH.  There was one agencies that surprised me.

 

The WA State Dpt. of Ecology represents the state of Washington in working with Tribal, federal, and local government organizations who are addressing imageslong-term concerns over the smelter’s contamination, on cleanup and community outreach.

 

Ecology has conducted eleven independent studies in our area evaluating smelter contamination between 1992 through 2017.  The Dpt. of Ecology surprised me because their studies were scientifically, technically, and logically well thought out and conducted with total accuracy.  The most significant difference between Ecology’s studies, as compared to the other agencies, was simple; they were ethical and honest. They did not slant their results, or blame “data gaps” as a recurring reason as to why their studies could not be completed, and they did not manipulate the wording to make it seem the results of their research was not something Northport residents, Teck, or their own agencies should be concerned with; referring to Northport as an “intermediate health hazard”.

 

Ecology’s study conclusions statethe facts, the actual levels of toxins found, and the danger the levels found of arsenic, cadmium and lead in our air and soil could likely put the residents of Northport in danger.

 

Ecology has proven again and again they worked for us, to protect us.

 

In the 4 air monitoring studies they conducted between 1992-1998 each of the studies concluded that levels of arsenic and cadmium were consistently found to be way above the Acceptable Source Impact Level (ASIL) set by the EPA.   Ecology provided their findings to the EPA because Ecology conducted these studies to provide the EPA with information as to whether or not they should allow Teck a renewed air permit for a new source (Kivcet smelter.)  Although Ecology’s results provided accurate reasons not to allow Teck a new air permit.  Instead, the EPA approved the new permit and Ecology’s air monitoring results were never discussed or shared with anyone, including the residents being impacted by the air.

 

In 2007 Ecology sampled sediments in Lake Roosevelt and the upper Columbia River.  Their results concluded that widespread industrial slag could forensically be tied to Teck Resources, and that it had contaminated the soil and water from Lake Roosevelt, up through the Columbia River to the Canadian border.  In 2006 Teck, under the supervision of the EPA, began a remedial investigation of the area.  The study is still ongoing.  What the EPA and Teck have been able to accomplish from an eleven year study is not a fraction of what Ecology’s 2007 study accomplished.

 

In 2012 Ecology conducted soil and sediment sampling in upland, non residential areas.  Teck, and the EPA, were conducting similar testing.  The levels of lead, arsenic, zinc, cadmium and mercury Ecology discovered were so high they petitioned the EPA to fast track sampling of residential soil, fearing residents exposed to these heavy metals at levels this high, specifically children, were in more danger than originally thought.

 

The EPA pushed Ecology’s petition through and Teck conducted sampling of 74 properties in 2014 and removed contaminated soil from 14 residential properties and 1 tribal allotment in 2015.  In 2016 they began a second round of residential property soil sampling.  The results of this sampling has not been published.    This would not have been accomplished without Ecology.

 

Residents of Northport have long worried that it is the air that continues to trigger the several, rare health issues a large majority of residents have been diagnosed with.  When Teck began their remedial investigation, under EPA supervision, we requested air monitoring again and again.  It was always pushed to the back burner, or we were told there was no funding, or no evidence to support more monitoring was needed….even though the monitoring done of the air by Ecology between 1992-1998 showed levels of arsenic 200 times higher than safety standards, and levels of cadmium were 18 times higher than safety standards.

 

In working with the Citizens for a Clean Columbia (CCC), Ecology listened to our concerns and agreed with them.  They explained that there were so many old studies to go through, dating as far back as 1931, and so many missing years not monitored, that it would be a difficult analysis to conduct.  After discovering Teck had an air monitor in Northport from 1992 – 2009 they requested those monitoring results. They then collected results of air monitoring Teck had collected near the Canadian border from 2007-2014.  Armed with studies done on our air in 1931, from 1992 through 2007, and the border monitoring through 2014, Ecology asked their Air Quality Program specialists to use this data to evaluate conditions in the upper Columbia River valley and assess whether more air monitoring is needed.

 

Based on there assessment, they concluded additional air monitoring in the upper Columbia River valley is necessary. 

 

Ecology will now share their analysis with the EPA and Teck, requesting additional air monitoring be done as a part of their remedial investigation evaluating the smelter-related pollution impacts done to our environment and health.

 

If the EPA and Teck agree to this Ecology would work with the EPA and public health officials to further assess health concerns once the additional monitoring is performed and data is collected. Ecology expects EPA would use the data to inform a human health risk assessment.

 

Without this data the human health risk assessment the EPA is required to conduct of the area would be no different than the assessments the DOH and the ATSDR conducted in 2004, invaluable, inaccurate, and a waste of more time and money.

 

Northport residents who continue to be diagnosed with the rare, similar health issues that plagued the two generations before them do not have any more time to waste.

 

A special thank you to The Washington State Department of Ecology, specifically John Roland and Chuck Gruenenfelder

“An underdog never loses, they find a different way to win the fight.”

– Unknown

AIR MONITORING IN NORTHPORT: PART II

Summary of Ecology’s Northport Air Quality Studies, Phases I – IV, (1992-1998) 

 

ECOLOGY/EPA  ACRONYMS

Screening Acronyms used by Ecology and EPA in testing certain heavy metal toxins:

    • Acceptable Source Impact Level (ASIL): Toxins must be found at or below the ASIL set by the EPA based on Standard ambient air background levels throughout the State.
    • Risk Based Specific Concentration Level (RSC): Toxins found at or above the RSC set by the EPA are considered high enough to pose as a risk to the environment and human health.

ARSENIC SAFETY/RISK LEVELS SET BY EPA:

  • The ASIL:  .00023 micrograms per cubic meter (ug/m3)
  • The RSC:  0.0023 ug/m3

CADMIUM SAFETY/RISK LEVELS SET BY EPA:

  • The ASIL:  .00056 ug/m3
  • The RSC:  0.1164 ug/m3

 

 

PHASE I:   Dec. 15, 1992 – Feb. 13, 1993

• Five air monitors installed

• 100 samples of particulate matter (PM) collected and analyzed for lead, arsenic, and    particulate matter.

PHASE II:   Aug. 10, 1993 – Oct. 30, 1993

• Seven air monitors installed

• The particulate filters were scanned for 30 toxic metals, cadmium, zinc, antimony, lead, copper, arsenic, and manganese.

• Computer Modeling conducted to better “understand the probable sources of pollutants…”

RESULTS:  Phase I & Phase II

ARSENIC

Arsenic exceeded EPA’s ASIL and RSC levels in both phases.

    • Phase I – maximum arsenic level detected:  .25 ug/m3
    • Phase II – maximum arsenic level detected: 0.1164 ug/m3

CADMIUM (*Cadmium was only tested in the Phase II air monitoring.)

Cadmium exceeded EPA’s ASIL and RSC levels in phase II.

    • Phase II – maximum cadmium level detected:  .0474 ug/m3

COMPUTER MODELING

The results of the computer modeling done in Phase II confirmed “…the monitoring data results in predicting that winds and pollutants from the (Teck) smelter can easily travel down the Columbia River Valley to produce moderately high pollutant concentrations in the study area.”

 

PHASE III:   Nov. 3, 1993 – Aug. 6, 1994

• One monitoring site – located 3 miles NE of Northport on “Paparich”

• Metals evaluated – lead, arsenic, cadmium

RESULTS:  Phase III

ARSENIC

Arsenic exceeded EPA’s ASIL and RSC levels in phase III

    • Phase III:   Arsenic maximum yearly average:  .12 ug/m3

CADMIUM

Cadmium exceeded EPA’s ASIL and RSC levels in phase III

    • Phase III:   Cadmium maximum yearly average:  .04 ug/m3

 

PHASE IV:   Sept. 5, 1997 – Dec. 31, 1998

• Three monitoring sites in Northport

• Metals evaluated – arsenic, lead, cadmium, zinc

RESULTS:  Phase IV

ARSENIC

Arsenic exceeded EPA’s ASIL and RSC levels in phase IV

    • Phase IV:   Arsenic maximum yearly average:  .02 ug/m3

CADMIUM

Cadmium exceeded EPA’s ASIL and RSC Levels in phase IV

    • Phase IV:    Cadmium maximum yearly average:  .01 ug/m3

 

CONCLUSION

In conclusion;  of the four Air Monitoring Studies conducted by Ecology between 1992 thru 1998 the level of arsenic and cadmium consistently exceeded all safety levels.  Ecology agreed to approve Teck’s request for a new permit in 1996 for a new “KIVCET” smelter, with the condition that phase IV of the air monitoring proved the new Kivcet smelter reduced the levels of arsenic and cadmium to safe levels in and around Northport.  The results of phase IV proved only that the levels stayed the same, still unsafe.  Ecology approved the permit anyway, but concluded in phase IV that they would “continue its efforts to fine- tune the MM5, CALMET and CALPUFF air quality models for utilization in the Northport study area. …(I)n addition to evaluating the need for further emission reductions at the (Teck) facility, the above models will be used to determine pollutant impact “hot spots” and optimum long-term air quality monitoring site locations (in Northport).”

No air monitoring has taken place in Northport since the conclusion of phase IV in 1998.  For 18 years the community of Northport has been exposed to unsafe levels of arsenic and cadmium, levels the Department of Ecology knew about, and warned the EPA about…..but no one warned the residents of Northport.

The EPA is currently, and so far unsuccessfully, trying to obtain funding from Teck to install air monitors in and around Northport.  The Ministry of Environment in Canada recently fined Teck 3.4 million dollars for their spills into the Columbia River.  Perhaps, the Canadian Ministry could provide the funding for the air monitors needed 3 miles down river from Teck?  Doubtful.

How can you help get air monitors in Northport?  I will share how in part 3 of the air monitoring blog next week!

EPA ANSWERS NORTHPORT QUESTIONS: Property Values, Livestock, Air & Water Quality

Recently I received questions from a concerned Northport resident regarding land value, livestock permits, economic value, and air and water quality;  in reference to the EPA/Teck Upper Columbia Studies and Clean-up.

I forwarded those questions along to our EPA Project Manager, Laura Buelow. Laura, Kay Morrison, (Community Involvement Coordinator), and Marc Stifelman, (EPA Toxicologist), responded to these questions. I found both the questions and answers informative and wanted to share them for any other interested Northport residents.

Below are the questions submitted from the Northport resident, and the EPA’s answers.

 

LAND VALUE
Q:   How does this affect the value of the land for taxes, finance, appraisals, selling?

A:   The Steven’s County assessor is a good place to start, also check with your realtor or John Cochran. John is our contact on the Washington Realtor’s Association (http://www.warealtor.org/ )

Q:   Are people having problems selling land due to the contamination?

A:   We have heard that property is being sold, but don’t have any details past that.

Q:   Is there a land conservation group willing to purchase the land at fair market value?

A:   Kay did a search on the term “land conservation groups in Washington state” and found a lot of information that residents may want to look into. We don’t currently have a relationship with any land conservation group. Here are a few of the links residents might try, as well as this google search:

https://www.google.com/#q=land%20conservation%20groups%20in%20washington%20state

http://www.landscope.org/washington/programs/wa_programs/

http://iwjv.org/partner-state/washington-state-conservation-partnership

Q:   How can you sell the land if there is contamination – are we liable for the contamination for the next owner?  Who pays for the testing?  Who is responsible for the clean up now and in the future?

A:   EPA will not hold residents liable for this contamination. Washington has disclosure requirements that can be found on the state’s website:
REAL PROPERTY TRANSFERS — SELLERS’ DISCLOSURES
The testing is being paid for by Teck American, Inc as part of the remedial investigation/feasibility study. The testing in 2016 will be conducted by Teck and their contractor, with oversight by EPA. The soil clean ups that were performed in 2014 were paid for by Teck and conducted by Teck’s contractors with oversight by EPA. If additional soil clean ups are necessary, the landowner will not be responsible for the cost.

Q:   Future clean up – how many years for re-testing? Who pays for the testing and clean up in the future?

A:   We’ll determine if, and where, additional areas need to be sampled based on the 2016 study. We can’t guarantee that we’ll do another round of testing, and we don’t have additional residential soil sampling scheduled out past 2016.

Q:   Is the ground becoming contaminated via air – water?

A:   EPA believes the data shows that the soil became contaminated from historic smelting operations at the Trail smelter, specifically the metals coming out of the smelter stacks (air). The smelter has been in operation since the 1890s. In the 1990s, the smelter went through a major improvement and the air emissions significantly decreased. We have received requests from the community to perform air monitoring and we are looking into the existing data to determine if additional air monitoring is necessary for the remedial investigation/feasibility study. Our focus right now is getting residential properties sampled.

ECONOMIC

Information: These are good questions for the Washington State University extension office for Stevens County – their website is http://ext100.wsu.edu/stevens/
 
From the web site:
“Washington State University Stevens County Extension connects the people of Stevens county to the research and knowledge bases of the state’s land grand research university providing solutions to local problems and stimulating local economies.  Our county-based educators work with partners in your communities to provide educational programs and leverage the broad resources of a major university to resolve issues and create a positive future for the residents of Stevens county.”

Q:   Can we produce and sell food/livestock raised on contaminated field?  I read that we have to get a special permit for that?

A:   Individual soil sampling results would need to be discussed specifically with Laura Buelow, EPA Project Manager (buelow.laura@epa.gov).

Q:   If so, does the produce/livestock have to be tested?

        A:   See above

AIR & WATER QUALITY
Q:   How often is either tested?  How do we get theses tested?

A:   Air was last tested in the U.S. by Ecology in the 1990s. Teck monitors air in Trail and we are working to get as much of that data as possible. Several studies have been completed under the remedial investigation/feasibility study. We have sampled river water, beaches, fish, sediment, and soil. The results of each study are compiled as Data Summary Reports and listed at this website: http://www.ucr-rifs.com/ The website is run by Teck specifically for this study and has more background information. EPA’s most recent fact sheet that gives a summary of everything done to date is here: https://www3.epa.gov/region10/pdf/sites/ucr/fact_sheets/UCR_Site_Invest_SU_Nov_14.pdf

ECONOMIC DEVELOPMENT
Q:   How can the community develop future economic bases?  How can we draw companies here?

A:   This is outside the scope of our work at this stage of the study. There is an organization called the Tri-County Economic Development District (http://tricountyedd.com/ ) that serves Northeast Washington – Ferry, Pend Oreille, and Stevens Counties.

Q:   What studies are being done on the wildlife and vegetation and the affects of the pollution has on them?  Forest health?

A:   The ecological risk assessment is part of the RI/FS and it will determine if there is any issues with the plants and animals.

Q:   There seems to be a lot of studies done at universities – are any doing studies here?

A:   Contact Jamie Paparich at The Northport Project: northportproject@hotmail.com

Q:   How many groups are involved with this?  Coordination?  Meeting Schedules?  Funding?  Accountability?

A:   EPA and Teck signed a Settlement Agreement in 2006, which is a legal contract that sets out how the study will be conducted. Teck funds all of the work. EPA also has an agreement with the U.S. Department of the Interior, Washington Department of Ecology, the Colville Tribe, and the Spokane Tribe to participate and provide input on all of the sampling plans and documents. Teck funds these parties as well. There is also the Citizen’s for a Clean Columbia (the CCC). They have a technical advisor and Teck funds the time for the advisor. EPA has had community meetings in Northport approximately every 6-8 months for the last 3 years, mostly focused on the soil sampling.

Here is a link to EPA’s page with legal / enforcement documents, including the 2006 agreement:  https://yosemite.epa.gov/R10/CLEANUP.NSF/UCR/Enforcement

Q:   Is there a early warning system in place that goes out to the residents when pollutants are released in the river?  Like a reverse 911.

A:   Ecology receives the notice of spills from the Trail smelter.

Q:   How come the fines Teck pays to Canada for environmental discharges are not distributed to the US?

A:   I’m not sure what these fines would be. Teck is paying to all of the remedial investigation/feasibility study.

 

AIR MONITORING IN NORTHPORT

 smoke stack

Necessity of Air Monitoring in Northport, WA:   Part I

 

The WA Department of Ecology’s air monitoring studies completed in Northport from 1992-1998 showed extremely elevated levels of arsenic (200 times higher than the national standard), and cadmium (see the results below in part II).

No air monitoring has been done since 1998.

So has Northport continued to be exposed to these dangerous levels of arsenic and cadmium since Ecology confirmed this, 18 years ago?  Is that why residents continue to be plagued with similar auto immune diseases their parents and grandparents had?   

The EPA is currently working on obtaining air monitoring in the area, but since Teck is conducting the RI/FS of the area it is a matter of convincing them to cooperate. 

Keep reading to learn how

_________________________________________________

Necessity of Air Monitoring in Northport, WA:   Part II

Summary of Ecology’s Northport Air Quality Studies,

Phases I – IV, (1992-1998) 

 

ECOLOGY/EPA  ACRONYMS

Screening Acronyms used by Ecology and EPA in testing certain heavy metal toxins:

    • Acceptable Source Impact Level (ASIL): Toxins must be found at or below the ASIL set by the EPA based on Standard ambient air background levels throughout the State.
    • Risk Based Specific Concentration Level (RSC): Toxins found at or above the RSC set by the EPA are considered high enough to pose as a risk to the environment and human health.

EPA AIR EMISSION SAFETY LEVELS

 

Arsenic Safety/Risk Levels:

  • The ASIL:  .00023 micrograms per cubic meter (ug/m3)
  • The RSC:  0.0023 ug/m3

Cadmium Safety/Risk Levels:

  • The ASIL:  .00056 ug/m3
  • The RSC:  0.1164 ug/m3

 

RESULTS OF AIR MONITORING STUDIES (4 phases) 

 

PHASE  I  &  PHASE  II

PHASE I:   Dec. 15, 1992 – Feb. 13, 1993

• Five air monitors installed

• 100 samples of particulate matter (PM) collected and analyzed for lead, arsenic, and particulate matter.

PHASE II:   Aug. 10, 1993 – Oct. 30, 1993

• Seven air monitors installed

• The particulate filters were scanned for 30 toxic metals, cadmium, zinc, antimony, lead, copper, arsenic, and manganese.

• Computer Modeling conducted to better “understand the probable sources of pollutants…”

RESULTS:

ARSENIC

    • Phase I –     maximum arsenic level detected:  .25 ug/m3 
    • Phase II –    maximum arsenic level detected:  0.1164 ug/m3
    • Results –   Arsenic exceeded EPA’s ASIL and RSC levels in both phases.

CADMIUM

** Cadminum was only tested in the Phase II air monitoring
    • Phase II – maximum cadmium level detected:  .0474 ug/m3
    • Results –   Cadmium exceeded EPA’s ASIL and RSC levels

COMPUTER MODELING

The results of the computer modeling done in Phase II confirmed “…the monitoring data results in predicting that winds and pollutants from the (Teck) smelter can easily travel down the Columbia River Valley to produce moderately high pollutant concentrations in the study area.”

__________________________________________________

PHASE III

PHASE III:   Nov. 3, 1993 – Aug. 6, 1994

• One monitoring site – located 3 miles NE of Northport on “Paparich”

• Metals evaluated – lead, arsenic, cadmium

RESULTS

ARSENIC

    • Phase III:   Arsenic maximum yearly average:  .12 ug/m3
    • Results:   Arsenic exceeded EPA’s ASIL and RSC levels in phase III

CADMIUM

    • Phase III:   Cadmium maximum yearly average:  .04 ug/m3
    • Results:   Cadmium exceeded EPA’s ASIL and RSC levels in phase III

__________________________________________________

PHASE IV

PHASE IV:   Sept. 5, 1997 – Dec. 31, 1998

• Three monitoring sites in Northport

• Metals evaluated – arsenic, lead, cadmium, zinc

RESULTS

ARSENIC

    • Phase IV:    Arsenic maximum yearly average:  .02 ug/m3
    • Results:    Arsenic exceeded EPA’s ASIL and RSC Levels in phase IV

CADMIUM

    • Phase IV:    Cadmium maximum yearly average:  .01 ug/m3
    • Results:   Cadmium exceeded EPA’s ASIL and RSC Levels in phase IV

 

CONCLUSION

In conclusion;  of the four Air Monitoring Studies conducted by Ecology between 1992 thru 1998 the level of arsenic and cadmium consistently exceeded all safety standards.  The levels found were high enough to pose a risk to our environment and human health.Ecology concluded in phase IV monitoring that they would:

continue its efforts to fine- tune the MM5, CALMET and CALPUFF air quality models for utilization in the Northport study area. …(I)n addition to evaluating the need for further emission reductions at the (Teck) facility, the above models will be used to determine pollutant impact “hot spots” and optimum long-term air quality monitoring site locations (in Northport).”

No air monitoring has taken place in Northport since the conclusion of phase IV in 1998.  For 18 years the community of Northport has been exposed to unsafe levels of arsenic and cadmium, levels the Department of Ecology knew about, and warned the EPA about…..but no one warned the residents of Northport, and no one has bothered to follow up.

The EPA and Ecology are currently, and so far unsuccessfully, trying to obtain funding from Teck to install air monitors in and around Northport. 

We can assist the EPA  and Ecology in obtaining this funding.  

Keep reading to find out how.

_________________________________________________

Necessity of Air Monitoring in Northport, WA:   Part III

 

**See letter to copy/sign/paste/send to EPA contact requesting air monitoring at end of article**

So, it was established in the air monitoring conducted by Ecology from 1992-1998 that the levels of arsenic and cadmium in Northport’s air was much higher than safety standards, and risk based concentrations.  The levels of Arsenic were actually 200 times higher than those found at the worst smelter Superfund site in the world, Tacoma Smelter.   Our air was not safe.

EPA and Ecology have been unable to further monitor Northport’s air because of lack of funding, and honestly we fall pretty low on their priority list.  They are currently trying to get Teck to fund air monitoring in the area as part of the Superfund clean-up agreement. Teck is arguing that they are not responsible under CERCLA law for their air emissions.

What the EPA and Teck did not share with the public is that Teck did continued to monitor Northport air, with one monitor, between 1994-2006

Tucked away in appendix G of Teck’s Upper Columbia River remedial investigation/feasibility study, volume 2, is the results of this air monitoring.  Arsenic and Cadmium continue to be way above safety standards and risk based concentrations.  The EPA was not even aware this data existed, or that they had access to it, until I asked them about it. 

To help EPA obtain the funding for air monitors in Northport a demand must be shown. 

If past and present Northport resident, and residents of surrounding communities, copy, paste, and sign the below letter and send it to our EPA project manager, Laura Buelow at buelow.laura@epa.gov, our chances increase ten fold.

 

Please, take five minutes to do this.  Those five minutes can help protect generations of Northport residents to come.

 

____________________________________________

LETTER TO EPA PROJECT MANAGER

(COPY, PASTE, E-MAIL TO:  buelow.laura@epa.gov)

Ms. Beulow:

I am writing to ask EPA to consider an air monitoring study in and around Northport, WA. I believe that the results of the residential soil study clearly show that a formal air monitoring study should be performed in the study area. Aerial deposition of contaminants did occur in the study area and it needs to be determined if this contamination is ongoing.

The results of the four air monitoring studies conducted by the Department of Ecology in Northport between 1992-1998 found levels of arsenic and cadmium to consistently exceed the ASIL and RSC levels.  At the levels reported, the EPA considers them high enough to pose as a risk to the environment and human health.

The results of the air monitoring Teck conducted in Northport between 1994 – 2006 can be found in the EPA/Teck Report: Upper Columbia River remedial investigation/feasibility study, volume 2, appedix G. Unfortunately, Arsenic and Cadmium continue to be way above the ASIL & RSC safety standards and risk based concentrations.

Based on this information, along with ongoing health studies in the area, it seems logical that the contamination is ongoing.

An air monitoring study should be performed for a minimum of 18 months at  the following locations:  Two high level lead contamination site (established in the residential soil study results),  and at one low level lead contamination control site.  Two high level arsenic/cadmium site (established in Ecology air monitoring study), and at one low level arsenic/cadmium site.

Some or all of these sites may need to be monitored over a longer period, depending on the results of the 18-month study.

Sincerely,

name

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