The Village of DePue: Batter up! - Part 3

At some point a decision must be made.  When it involves a determination of risk, that line we draw in the sand, that line that says "safe," is not always easy to see and even less easy to understand.

I wasn't always this way in my thinking.  In fact, up until about 2008, I would have sided with the folks in DePue.  I would have sided with them because I had not made the jump from making a decision based on the perception of risk to one based on the understanding of risk.

It was not until I entered into the Master's program at Texas A&M's School of Rural Public Health's Environmental and Occupational Health program that the light bulb clicked on.  I have been dealing with hazardous waste and remediation of contaminated sites since 1984 and I did not understand the basic concept of risk for adverse health effects - which is the driver for cleanup levels and remediation plans.

Perhaps it was because in 1984 we were just learning about how chemical contamination effects a population and without a lot of data we assumed that the presence of chemical A equaled the health concern seen when exposure to chemical A took place.  For the bulk of my career, if chemical A was present the assumption was that there was risk.  So for the longest time the remediation method was to remove it.

No chemical A, no risk from chemical A.

But that ignores the basic concept of toxicology, the dose.  In other words, just because chemical A is present, if the dose is not high enough there will not be any adverse health effects.

For years my understanding was this: If chemical A can cause health effect B, then chemical A presents a health risk. In other words, my thinking had been skewed to automatically think that the mere presence of the chemical in the area automatically implies risk.

Enter the Donnelly Risk Paradigm (see this post):

    

I had been automatically programmed to think chemical = health effect, completely ignoring all the steps necessary to bring about that health effect.  Once I understood this, my focus shifted from perception of harm to trying to actually quantify harm.

So when I say" It does not matter if it is there, what matters is the dose (uptake)" hopefully you will see where I am coming from.  This is the same concept the EPA uses with the toxicity characteristics for hazardous waste.  We do not care how much of the toxic chemical is in the waste.  What we care about is what will come out (release).

That's what the RCRA TCLP is all about.  We assume a material is a hazardous waste if it will release a chemical above a threshold.  We assume that the mere ability to release the chemical presents a risk.  However, in reality, there are three more steps necessary to associate that release with a health effect; transport, exposure, and uptake.  And even if there is uptake, that uptake must be at a high enough dose (unit of chemical to unit of body weight) to manifest the health effect.

Same concept is in play in DePue.  We have a bunch of contaminated sites where a bunch of chemicals know to cause various health effects are present.  Here is the thinking of those behind the "Clean Up DePue" web page:

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.

The reason this has become a news story is that a plan has been adopted that these folks at "Clean Up DePue" find unacceptable:

“The companies spent millions of dollars on consultants in an attempt to show that this SuperFund site poses no significant risks, and they delivered a superficial plan that barely touches many of the contaminated areas, leaves the slag pile and other waste in place, does nothing to stop contamination from seeping into the groundwater, and leaves backyards, playgrounds and Lake DePue without real remediation.” 

All of this boils down to this:

“The consent order required the responsible parties to come up with the plan, supervised by the Illinois EPA. I don’t know how to respond to that plan. It’s not even close to what’s needed.” 

So I will ask:  What is needed?

Well according to Mr. Garcia, the science teacher at DePue High School, ExxonMobil and CBS is:

"jeopardizing the health and well-being of the children, families and wildlife in DePue,”

Okay, so now we have a baseline to start with.  At this present time, folks like Mr. Garcia, believe that the current conditions are "jeopardizing" public health.  Therefore, a remediation plan that does not remove the contaminant will continue to jeopardize the health and well-being of the children, families and wildlife in DePue.

So my question is, are the children, families and wildlife in DePue coming in contact with contaminants from the contaminated site that will jeopardize their health?

Enter the data...

In my last post I randomly chose one of the 1,976 samples that were taken that just so happen to also be at the baseball field where Mr. Garcia's science class took a soil sample.  With that data I can make a general statement about the risk for that particular area.

First, we must agree on a few things:

1. We are going to accept the samples as representative of the area as a whole.
2. We are going to accept that there is a level of contaminant - a threshold - that "can be tolerated by the organism with essentially no chance of expression of the toxic effect.” (EPA)

We are going to draw a line in the sand...

You must agree to those two concepts before we move on.  If you have a different concept, then let me know.

I am doing this in real time, so I do not know what the data is going to lead me to conclude.  What I do know is that what works for the baseball field is what will apply to all areas where the children, families and wildlife in DePue live, work, and play.

So lets look at the data we have...

Mr. Garcia's science class found:

Source

The "Contamination Map" on the "Clean Up DePue" web page shows two samples that were collected:

"The map shows the location for 1,976 samples taken by the companies over the past several years, exactly which contaminants were found in each sample, and the health risks of residents’ prolonged exposure to these contaminants."

Here is what is shown for location "6" on that map:

Expanding Sample GYP-MW-15LS we see:

Source

Wow...that's a lot of numbers.  Numbers = data.  Data = good.

Okay, that's what we have.  This makes sense to me, but is there anywhere on the "Clean Up DePue" website or the Chicago Tribune article where these numbers are explained?  Oh sure, it states "Contaminants above MCL for drinking water." but it does not explain how that concentration is  "jeopardizing the health and well-being of the children, families and wildlife in DePue,”

If you have read any of my previous posts you should know by now that I hate, HATE, hate it when a threshold is used without explanation or relevance to the situation in play.  I can make sense out of this data and relate it to risk.  But look at it from the standpoint of a non-scientist.  How would a normal person interpret "Contaminants above MCL for drinking water?"  What's that mean to them?  What's their thinking when they click on that little red question mark and read:

MCL: MCL stands for Maximum Contaminant Level and is the US Environmental Protection Agency's "level of a contaminant in drinking water below which there is no known or expected risk to health." EPA standards for human health risk in soil are relatively close to those set for drinking water.  On this website, secondary MCLs (those related to aesthetics such as water taste or smell) which are exceeded are marked in yellow, whereas primary MCLs (those related to health) which are exceeded are marked in red. 

As my wife would say "too many words" or as they say on the website Reddit "Too long, Didn't Read - TL;DR."  What they see, if they look at this data is "Contaminants above MCL for drinking water."  What do you think enters into their thinking when a value exceeds something called a "Maximum Contaminant Level?"

Are the folks who put this web page together being purposely disingenuous or are they just plain ignorant to what those values mean?  I am not using ignorant in a derogatory way here.  I just get a bit annoyed when statements such as  "Contaminants above MCL for drinking water" are used without context or proper explanation.  I do not expect the townsfolk of DePue to understand this, so when I read that they have assistance from Northwestern University's Environmental Advocacy Center, I expect someone at the University level to understand the context and present the information correctly.

And if no one at Northwestern University's Environmental Advocacy Center understands the difference between a health based MCL (Primary) and and Ascetic level (Secondary) then they need to quit advocating for the environment because they are misleading people in believing there is a problem when there most likely is none.

First, it is putting stress into the lives of the people who live in DePue.  Stress is a public health concern.  Second, it is taking money that could be spent actually helping the citizens of DePue and spending it on things that do not and will not benefit the the health and well-being of the children, families and wildlife in DePue,”

But I digress...

Back to the question of risk at the baseball field.  Do those mg/kg and mg/L numbers for all those chemicals mean that the health and well-being of the children, families and wildlife in DePue are being jeopardized?


Next post: The Village of DePue: I'll take information for $200, Alex - Part 4

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