If they only had a RCRA permit...Part 5

So the DTSC tells us in Exhibit 2 that they accept "a cumulative risk that does not exceed a one in one million (10-6) for cancer risk."

That did not sit right with me.  I wrote about California and how it calculates the slope factor for carcinogens and how it applies to the Proposition 65 notification requirements.  So I went about looking for that document.  And I found it:

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So DTSC accepts a 10-6 cumulative risk except when they accept a 10-5 cancer risk. This is one of the main problems in establishing risk.  Sometimes one in a million is okay, sometimes one in ten thousand is acceptable.

Okay, okay, I know what you are thinking.  The SCAQMD found a residential cancer risk of 22 in one million to the nearest residential receptor.  That's a 2.2 to the 10-5 risk and that's over one in 100,000.

Yeah, okay, that creates an increase risk - theoretical mind you - but a risk.  Not sure that 2.2 x 10-5 constitutes "an imminent and substantial danger to the public health or safety or the environment" though, even if you include the leaky stormwater pipes.

My question is, at this point in the discussion, does the arsenic emitted from Exide put the community at an imminent and substantial danger?  Remember our three intrepid reports at the Los Angeles Times?  Here is what they wrote about this risk:

In March, the South Coast Air Quality Management District reported that arsenic emissions from the plant created an elevated risk of cancer for as many as 110,000 people in an area stretching from Boyle Heights to Huntington Park.

I wonder where they got that number?  Oh, that's what the DTSC claims in Exhibit 2 of their justification to order Exide to halt operations:

18. Based on the Health Risk Assessment submitted to the SCAOMD, DTSC has determined that the Facility is operating its furnaces and its air pollution devices in a manner that is not sufficiently protective of human health and the environment, impacting as many as 110,000 residents in a large geographical area that includes portions of Vernon, Maywood, Huntington Park, Commerce, Boyle Heights and unincorporated areas of east Los Angeles. The predominant contributor to both chronic and acute cancer risk and non-cancer hazard is arsenic emissions from the Facility, with the primary human organs that are harmed are the cardiovascular system, central nervous system, developmental system, respiratory system and skin.

What this tells me is that the Exide facility in Vernon, California is pumping into the air enough arsenic to harm 110,000 people, causing cancer and affecting their cardiovascular system, central nervous system, developmental system, respiratory system and skin!

So...what did the SCAQMD find regarding arsenic and Exide?  Let's look at this graphic first:

Page 2 of the report

Before I get into the details of what is going on, I want you to look closely at this graphic paying particular attention to the "y" axis.  Do this while repeating "and non-cancer hazard is arsenic emissions from the Facility, with the primary human organs that are harmed are [sic] the cardiovascular system, central nervous system, developmental system, respiratory system and skin."

If you have read any of my other posts you will understand why this one bugs me.  Do you see how much arsenic was detected in the air around the facility?  Not milligrams (1,000th of a gram), not micrograms (1,000,000th of a gram) but nanograms - 1,000,000,000th of a gram.

Yeppers, that's what we now look at for arsenic in the air.  Nanograms per cubic meter.  So my next question will be, does less than 3.5 nanogram per cubic meter (the highest amount shown on the graph) present an "imminent and substantial danger?"

Remember those loud and angry folks yelling “Shut it down! Shut it down!”?  Those folks look to the DTSC for an answer.  They look to us scientists, toxicologists, experts for an answer to their number one concern "are we being harmed?"  And the DTSC gives them this:

Based on an average of about 2 nanograms of arsenic in each cubic meter of air, Exide is impacting "as many as 110,000 residents."  And "the predominant contributor to both chronic and acute cancer risk and non-cancer hazard is arsenic emissions from the Facility, with the primary human organs that are harmed are the cardiovascular system, central nervous system, developmental system, respiratory system and skin."

Is that an accurate representation of the risk these residence are encountering?


If they only had a RCRA permit...Part 6

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