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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The Village of DePue: Looking at red dots - Part 6

In the Chicago Tribune news article that started this series of posts, my eyes sent a signal to my brain when I read this:

But many say the involvement of Northwestern University's Environmental Advocacy Center — which is providing DePue with free legal representation — has given them some much-needed clout and could help the town finally realize its goal of eliminating or containing the contamination.

My brain told me that something must be happening there in DePue if Northwester University's Environmental Advocacy Center has gotten involved.

Now I know nothing about Northwestern University or their advocacy center.  My interest was piqued because they - a university - had gotten involved, and, that involvement was with a center that had the term "environment" in its name.

"University" plus "environment" equals "you got my interest."

So when I then read this:

"All the complaining we've done, we've learned that there's good reason for us to be worried about the type of cleanup we get here."

...I'm wondering what the heck is going on in DePue?

I work in the environmental field and I have worked for a plethora of private companies and governmental organization that deal with remediation and site cleanup.  I also have worked for hundreds of companies that are guilty of past behavior - the ones who get tagged as Potentially Responsible Parties (PRPs).  I know how my industry - including the regulators - behave in this type of situation where contamination from previous activities - legacy property - has initiated a cleanup order.

I know how it works.  I know the sampling that must be done.  I know the qualifications of the guys who collect and analyze and interpret the results.  They are not perfect, and they get it wrong, but the overall methodology does not leave too many stones unturned.  There is tons of data from these sites and everything is made available for public feedback.

So with that in mind, my curiosity piqued, and reading "we've learned that there's good reason for us to be worried about the type of cleanup we get here,"  I set out to see for myself.

I don't see anything to be worried about...yet.

According to the Press Release that appears on the Cleanup DePue organizations website, these folks contend:

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. Visit www.CleanUpDePue.org to see an interactive map that details the way-above-normal concentrations of pollutants at hundreds of contaminated sites.

I went looking for these "way-above-normal concentrations of pollutants at hundreds of contaminated sites."

I am giving the Cleanup DePue folks the benefit of the doubt by not dismissing their claims.  I don't automatically think their  "just a bunch of hicks out here crying about our town being contaminated."  With Northwest University involved, and being told in the Press Release:

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. The website and map were built under grants from the Initiative for Sustainability and Energy at Northwestern (ISEN) and the Environmental Chemical Sciences Program of the  National Science Foundation's Division of Chemistry, Northwestern University Chemistry student interns worked over six month to analyze, interpret, and enter the data that you see on the map." 

...I'm thinking I hit the goldmine in being able to use viable data to support a claim of risk.

The Press Release tells me there is an  "interactive map that details the way-above-normal concentrations of pollutants at hundreds of contaminated sites," and that map was put together with funds provided by the University and the National Science Foundation, and "Northwestern University Chemistry student interns worked over six month to analyze, interpret, and enter the data that you see on the map," I'm looking a good, sound, peer reviewed, scientifically valid information.

I started writing Post Number 1 because of what I know about the industry - my industry - and the claim that "we've learned that there's good reason for us to be worried about the type of cleanup we get here."

What did they learn?  What are they being told?  Does that data Northwestern University "worked over six month to analyze, interpret, and enter" into the interactive map detail "the way-above-normal concentrations of pollutants at hundreds of contaminated sites."

My last two posts dealt with Mr. Garcia, a science teacher at DePue High School "who had his class sample soil and water to document unsafe concentrations of pollutants."  I looked at this data.  Nothing that even comes close to "way-above-normal concentrations."

Now it's time to look at the rest of the data.  I have looked at a few of the red dots on the map already:

 Now I would love to spend my two days before Christmas looking at all those red dots.  Even I'm not that nerdy to do that.  Instead, I'm going to bias my chance of finding a "way-above-normal concentration" somewhere close to where the contaminated sites are.

Once again.  I do not care about what is on the contaminated site.  I only care about what comes off that site and the exposure level the folks in DePue are forced to live with.  If you tell me that there is "way-above-normal concentrations" present then I expect to see them.  "Way-above-normal concentrations" would be an indication of exposure and we could estimate the risk of a health affect from the contaminants these folks are exposed to.

That's how we do it.  We are looking to estimate the dose that is being received by the people who live in DePue.  "Way-above-normal concentrations" would indicate a dose that could be "jeopardizing the health and well-being of the children, families and wildlife in DePue.”

So where should I start looking...

Here is what we know about where the contaminated property is located and its proximity to where people live.:

Source

OU-1: South Ditch Contaminated Sediments
OU-2: Phosphogypsum Stack
OU-3: Former Plant Site Area (FPSA)
OU-4: Off-site Soils
OU-5: DePue Lake Sediments and the Flood Plain

From the map above, it looks like samples from OU-4 represent the concentrations for contaminants that DePue folks would be exposed to.  What I find there - where people live, work, and play - would support the claim:

"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."

Mr. Garcia's samples did not support that claim.  So what did they find in the soil samples collected where people live?  I expect the contamination in OU-2 and OU-3 to be "way-above-normal concentrations."  I need the concentrations to be below soil screening levels in the areas where people live.

Wait a minute!  The website allows me to download an Excel file that has all the soil sampling data that has been collected!  I can look at it all.  Less bias on my part, less randomness, less leaving something out.  Cool!

I can then look at all the samples for OS-4 and find out which samples have the highest concentrations of the 12 contaminants Mr. Garcia looked at.  I don't care about potassium, sodium, manganese, pH, or anything else.  I want to look at the metals we normally consider toxic - the RCRA 8 and copper, nickel, and zinc, but I'll list the others simply because they are there.

I am also going to assume that the values entered into this spreadsheet are in mg/kg - ppm concentrations.  Looking at OU-4 data, I have 125 individual sample results.

So here is what I found:

Yellow = Chemicals of Concern for public health.  Red indicates the highest concentration found that exceeds the soil screening level for residence chronic health.  If the highest value is not in red, there were no samples that exceeded the SSL and those sites do not pose a human health risk for that chemical at that concentration.

So...life would have been a heck of a lot easier for me if they were all less than the screening level.  I could have ended this series of posts with a brief statement of no concern.  But some of the OU-4 samples did come show a concentration above the screening level.  How much higher will determine my concern.

Source

Before we get into this, a little reminder about the generic soil screening levels I am using:

The generic SSLs [are] calculated from the same equations used in the simple site-specific methodology, but are based on a number of default assumptions chosen to be protective of human health for most site conditions.  Generic SSLs can be used in place of site-specific screening levels; however, they are expected to be generally more conservative than site-specific levels. (Page 3)

Because I am doing this research in real time, I am writing about what I see and what I find out.  It would be easy for me to ignore things, such as the Thallium, but I want my work to stand scrutiny.  If it cannot be explained then more work will need to be done.  I am trying to provide information as well as support the claim that there are "way-above-normal concentrations of pollutants at hundreds of contaminated sites."

So far we have levels for some chemicals of concern (in red) that exceed the generic SSL.  I need to pause here and change my initial assumption that there is nothing to worry about based on Mr. Garcia's samples.  There are sample sites where the townsfolk of DePue have access to that appear to exceed the level that is accepted to be protective of public health.

The question I need to ask now is; "do any of the seven chemicals in red that exceed the SSL pose a health risk at that concentration?"  If yes, how many locations are at an unsafe level and where are they located?

Dang...two day to Christmas and I am going to be looking at an Excel file.  Maybe there is something there that they see...maybe...


Next post: The Village of DePue: "A" is for Arsenic - Part 7

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