Tuesday, January 22, 2013

The Village of DePue: Wants and Needs - Part 16

I suspected all along that the main issue with the folks in DePue was based solely on one issue; nothing short of complete removal of the contamination will meet with their acceptance.
  • What DePue wants is removal.
  • What they need is exposure to these contaminants lowered to a level that we understand to be safe.
  • What DePue wants is the pile gone.
  • What DePue needs is future exposure to these contaminants at or below the concentrations we understand to be protective of their health.
  • What DePue wants is to wake up in the morning with the knowledge that the pile is no longer there.
  • What DePue needs is day-to-day existence without coming in contact with contaminants from that operation in concentrations that can cause harm.
Wants and needs.  Which should prevail?

Just so y'all know, I come from the industry of dig it up and remove it.  That's how I made my money.  I made piles like the one in DePue go away.  I spent a lot of other peoples money doing that and in the end, produced more risk to human health and the environment than had we left it in place.

Let's make sure we are clear on this.  There are many situations that warrant the removal of a material and placing it someone else's backyard.  It is a balance of risk that must - MUST - motivate that decision.  Not cost, not perception, not fear, not market, not nothing but looking at the risk.

I did not come to this leave-it-in-place acceptance easily.  It was not until I went back for my Master's that I was able to understand this.  It is all about risk.

As I have many times before, they drilled into our heads in the Environmental and Occupational Health program for the Masters in Public Health at Texas A&M's Health Science Center's School of Rural Public Health this thing I now call the K.C. Donnelly Risk Paradigm:



In one of my past posts I wrote (corrected a bit):
In a nutshell, just because a chemical is there, or could be generated, does not mean it will result in an adverse health effect.  Not only does it need to be released into the environment, it has to travel to the receptor, the receptor has to be exposed to it, and the chemical then has to enter into the body.  Even then there is no automatic negative health effect guaranteed since the body does a really good job of ridding these nasty chemicals as well as fixing the problems - including damage to DNA that could result in cancer - even if uptake does occur.
What I am advocating for is moving away from focusing on the chemical and instead looking at the uptake - or dose - that the receptor could reasonably be anticipated to get into their system.

When Gabby Garcia - the young lady in the picture...:



...hears her fellow townsfolk call the mound behind her a "pile of black death” and is told that the soil in White City Park contain heavy metals that Northwestern University says "in general leads to increased incidence of neurological issues and cancer" she becomes concerned and I get agitated.










My agitation is the result of a perception of risk based on the mere presence in the area of a chemical.

In my first post on DePue I ended with a few questions:
So what necessitated an article in the Chicago Tribune about the pace of hazardous waste cleanup?  Why does the paper claim that this pace "frustrates DePue residents?"  Why does Northwestern University's Environmental Advocacy Center think they can "help the town finally realize its goal of eliminating or containing the contamination."  And, for me, why is there "good reason for [DePue] to be worried about the type of cleanup [they are getting]?"
I'm a skeptical type by nature, so I don't believe what I read and hear until I look into it a bit more.  It was the press release that really got me looking, this one statement in particular:
Visit www.CleanUpDePue.org to see an interactive map that details the way-above-normal concentrations of pollutants at hundreds of contaminated sites.
That statement just did not ring true.  If you read any of my previous posts you'll see that I am critical of how agencies look at risk.  If anything they are too conservative.  The folks who make decisions for the public on the health and safety involving a contaminated property do so in a way that is preventative.  There was no way, as I saw it when I read that statement, that Illinois EPA would allow this to happen:
The slag and waste left behind continue to leach heavy metals and carcinogens into ground water that runs off into Lake DePue, which flows directly into the Illinois River. Contaminated debris blows onto public and private property throughout the village and surrounding natural areas, exposing residents -- more than a quarter of whom are children under the age of 16 -- and local wildlife to arsenic and heavy metals such as lead, mercury and cadmium.
I'm skeptical...so I looked.

After 15 posts on this topic and after looking at the data presented in the the CleanUpDePue.org web page, I have found a reasonable answer to my questions.

First. The folks in DePue are frustrated because the plan does not include removal of the slag pile.

Second: The slow pace is because the relationship between the three parties, Illinois EPA, PRPs, and DePue, has expanded to include elected officials and lawyers.  These two additions are even less likely to not understand what the exposure risk is in DePue necessitating more "studies" by the Illinois EPA to show the original plan they concur with is safe.

Third: Contaminated debris does not appear to blow onto public and private property - or if it does - the contaminants it carries are below health-based thresholds.  I base this on in part the samples Mr. Garcia collected and had analyzed.  These concentrations are not "disturbing" or" elevated."  They are below soil screening levels and Illinois EPA cleanup objectives (see Post 4). And the leaching?  According to the Illinois EPA:
The DePue Group constructed and began operation of the Interim Water Treatment Plant (IWTP). The IWTP can treat up to 100 gallons per minute of contaminated surface water and groundwater intercepted from the North Ditch, slag pile drains, and shallow interceptor trenches associated with the IRM walls. Treated effluent had been discharged to the South Ditch until June 1, 2000, when the treated effluent was rerouted to the Illinois River via the River Water Line.
Forth: The type of cleanup proposed for DePue, as detailed in the letter to the Illinois House and Senate, appears to be sound based on the level of contamination where the folks in DePue live, work, and play - OU-4.  The final plan for the other OUs, including the slag pile, appears to be protective of public health.

There was one more question I asked that I felt was relevant.  The press release states that the residents "more than a quarter of whom are children under the age of 16" are being exposed to "way-above-normal concentrations of pollutants at hundreds of contaminated sites."

I said "show me the data!" and the CleanUpDePue.org web page delivered.  You can read about what I found in OU-4, the area where people live, work, and play, starting with this Post.

Here is what I concluded about those "way-above-normal concentrations":
Because I know that the cleanup objectives and screening levels are very health protective, these average exceedances are nothing that would cause me a concern.  That's not to say I would recommend nothing being done about them.  I did go to the website.  I did look at the interactive map.  I did crunch the numbers from the Excel sheets they provided.  What I found does not come close to how I view "way-above-normal."
I also asked the question; what does "real remediation" mean?  According to their petition it means:
...full restoration of Lake DePue, removal of the slag pile and other hazardous substances from the plant operation’s site and the entire DePue community.
Removal of the waste presents an ethical problem of sorts since it takes it from one backyard and places it in someone else's.  I wrote about that in this Post.

The bottom line for me and for the Illinois EPA is finding an answer to this question; would the folks in DePue be exposed to less contamination if the pile were removed?  Based on what I have read about the site and contamination areas, removing the slag pile would provide no decrease in exposure.  Additionally, the measures in place and the proposed remedy make the risk of leaving the waste in place an acceptable and sound plan for protecting public health now and in the future.

I want to protect Gabby from actual exposure, not protect her from a pile behind a fence.  This is why you have heard me say "I don't care about what is in the pile, I only care about what comes out."

Because of all the things that Illinois EPA and the PRPs have done to date, that pile of black death is no more dangerous than a lion in the zoo.  If it does not come out of the cage it cannot hurt you.

The power to get some wants is in the hands of DePue.  All the PRPs have to do is meet the law and requirements set forth by Illinois EPA.  Right now they know they can wait this out while the politico's and agency come to a decision, and those guys won't move without more "studies" which become necessary because DePue finds the proposed plan unacceptable, which delays the cleanup of OU-4.

It sucks that a big pile of contamination will be left there.  Time to move on and makes sure Gabby is safe and protected from that pile now and many years into the future.  Get OU-4 cleaned up to soil screening or Illinois EPA cleanup objective levels.

Oh, and a new state-of-the art community center would make that bitter pill a little easier to swallow PRPs.  Throw in some exercise equipment and maybe fund a music and PE program for Gabby and her fellow students and public health just got better too.

Wants and needs...


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