Thursday, January 10, 2013

The Village of DePue: What's in store for OU-4 - Part 12

I began writing this series of posts because I was skeptical of the claims made in the Chicago Tribune in an an article titled "Pace of hazardous waste cleanup frustrates DePue residents."

My skepticism was elevated when I read in the DePue Press Release that:
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 had no idea where these posts would lead me.  But one thing I knew, is that there was a claim of contamination and numbers to back that claim up with:
Visit www.CleanUpDePue.org to see an interactive map that details the way-above-normal concentrations of pollutants at hundreds of contaminated sites.
So a bit skeptical, and curious, I went in pursuit of an answer to the claim that the people in DePue are exposed to "way-above-normal concentrations of pollutants at hundreds of contaminated sites."

Now this trip down the blogosphere can be a bit onerous if one is grasping at straws for information that will support, substantiate, or refute a statement of "way-above-normal concentrations of pollutants at hundreds of contaminated sites."  So when I saw that the folks in DePue had Northwestern University on their side, my skepticism started to wane a bit.  Maybe there was something going on to substantiate a website called CleanupDePue.org demanding that "responsible parties, Exxon Mobil and CBS/Viacom return to DePue and clean up their mess."

Instead of saying - as I usually do - show me the numbers, which is tantamount to stating "show me the beef!"  I instead asked myself "what is the beef?"

The Cleanup DePue Press Release quotes Nancy Loeb, the director of the Environmental Advocacy Clinic at Northwestern University School of Law’s Bluhm Legal Clinic, as claiming:
“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.”
So there I was, Mr skeptical, looking at two claims telling me and anyone who visits their web page that there are "Way-above-normal concentrations of pollutants at hundreds of contaminated sites" and the clean up plan "leaves backyards, playgrounds and Lake DePue without real remediation.”

What I know about the site - and I am privy to just what a citizen living in DePue has access to - is that there are five areas - called "operable units (OU)" - designated as contaminated.
Source
When dealing with contaminated property, we normally look to see who or what is going to be adversely - or negatively - affected.  What I write about - and have set this series of posts on - is an impact to public health.  I am only concerned about exposure to a chemical contaminant whereby the contaminant can enter into the human receptor.  Basically, what we need are two conditions to have the possibility of a health effect;  exposure and dose.

My primary concern is where exposure can take place day in and day out.  That limits my research to OU-4 which is where the people of DePue live, work, and play.  Here is what I am told about Operable Unit 4: Off-site Soils:
  • Includes plant area residue used as fill throughout the Village of DePue, including in residential yards, public parks and other public areas, alleys, etc.
  • Additional metal contamination is present as a result of air deposition of contamination from the plant area.
 From a public health standpoint, that's the area that will present the two components - exposure & dose - necessary to perform a risk calculation.

What's nice about this, and I had no idea of this when I started writing these posts, is that I have access to all the sample data.  It's not perfect, but it does paint a picture of what the potential exposure is.

When I looked at the data for OU-4 (see previous post) I found that there were 125 samples of soil that had been collected from this area.  Although they tested for a number of metals and salts, my concern is to look at the ones that present the greatest potential for a health effect based on toxicity and concentration found.

These Chemicals of Concern (CoCs) are what we focus on.  So for OU-4, there are four heavy metals that I need to address; Arsenic, Barium, Cadmium, and Lead.  The other metals, including zinc, are all under soil screening levels in the 125 soil samples collected.

For the 125 soil samples 102 samples have one or more of the four CoCs above a soil screening level or cleanup objectives.  Of these 102, the data shows:
  • 97 of 102 samples have arsenic above the background 11.3 mg/kg
  • 6 of 102 samples have barium above the Illinois objective 5500 mg/kg
  • 19 of 102 samples have cadmium above the Illinois objective 78 mg/kg
  • 36 of 102 samples have lead above the Illinois objective 400 mg/kg
Now there are a ton of ways to spin this statistical data.  I'm not going to play that game.
  • The highest concentration of arsenic is 4.2 times higher than background.
  • The highest concentration of barium is 1.6 times higher than the Illinois cleanup objective.
  • The highest concentration of cadmium is 1.9 times higher than the Illinois cleanup objective.
  • The highest concentration of lead is 2.0 times higher than the Illinois cleanup objective.
For 102 samples, those are the highest possible exposure a person living in living, working or playing OU-4 could have.

With that in mind, let's look at what an average exposure would be for the 102 samples.  If you are paying attention, I am not going to include the 23 samples below a level of concern.  In this way, I can get a pretty good feel for what an high sided average exposure would be in OU-4:
  • The average concentration of arsenic is 1.7 times higher than background.
  • The average concentration of barium is 1.2 times higher than the Illinois cleanup objective.
  • The average concentration of cadmium is 1.2 times higher than the Illinois cleanup objective.
  • The average concentration of lead is 1.3 times higher than the Illinois cleanup objective.
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, what it does indicate is that this statement:
Visit www.CleanUpDePue.org to see an interactive map that details the way-above-normal concentrations of pollutants at hundreds of contaminated sites.
...is not supported.  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."

Additionally, the claim that "contaminated debris blows onto public and private property throughout the village and surrounding natural areas, exposing residents" is not supported by the analytical data from the samples collected by Mr. Garcia's, the local high school science teacher.

Nancy Loeb, the director of the Environmental Advocacy Clinic at Northwestern University School of Law’s Bluhm Legal Clinic, asserts that the cleanup plan that has been submitted:
"...does nothing to stop contamination from seeping into the groundwater, and leaves backyards, playgrounds and Lake DePue without real remediation.”
My read on that leads me to conclude that apparently the potentially responsible parties (PRPs) - Exxon and CBS - have said that OU-4, the off-site soil area where the good people of DePue live, work and play, "poses no significant risks."

I kind of concur.  However, and there's that nasty little bit of ethics I spoke about in my last post, I believe that these PRPs have a moral obligation to reduce the risk to an acceptable level.  Are they really telling the folks that live in DePue that they are going to nothing about the soil that exceeds the Illinois cleanup objectives?

Ms. Loeb tells us:
"and they delivered a superficial plan that barely touches many of the contaminated areas...and leaves backyards, playgrounds and Lake DePue without real remediation.”
How can this be?  What is supposed to happen in DePue regarding the soil in OU-4?

Well I went looking for an answer to that question.  Here is what I found in a document dated August 10, 2012 from the Illinois EPA to the Illinois General Assembly House and Senate:

Source
OU-4 is going to be cleaned up so that the levels are below a health risk threshold.  Low exposure equals low risk.  Safe.  Why is Ms. Loeb telling DePue that this "leaves backyards, playgrounds and Lake DePue without real remediation.”  It does not.  So what's the beef here?

Oh...I see...so that's what this is all about.


Next post: The Village of DePue:  Put it in someone else's backyard - Part 13

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