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[Thanks, JM, for this tip]
Wilma Subra is a technical adviser for the Louisiana Environmental Action Network. Subra reviewed environmental reports from Lockheed Martin at the request of the Brandenton Herald (FL).
Recently, the Herald published Subra’s resume and key findings from Subra’s report. The key findings are below. You can also click here [MS WORD, 69KB] for a detailed timeline of what has transpired in Tallevast.
Key Findings:
1. According to Lockheed Martin Corp., Addendum 3 to the Site Assessment Report contains sufficient information for the Florida Department of Environmental Protection (DEP) to base an approval of the Site Assessment phase. Such an approval by the DEP will allow Lockheed to proceed with the preparation of a Final Remedial Action Plan. However, the latest report lacks key information and in some cases includes inaccurate information. It should not be the basis on which to proceed to a Final Remedial Action Plan phase.
2. DEP must require that the lacking information be generated, the inaccurate information corrected, and a fourth Addendum to the Site Assessment be issued and available for public comment, prior to consideration of allowing Lockheed to move to the Final Remedial Action Plan phase…
3. One of the objectives of the Site Assessment is to evaluate current exposure and potential risks of exposure to humans and the environment, including multiple pathways of exposure. The site assessment failed to include information on vapor intrusion and volatile organics being transported into homes in the residential areas, churches, businesses and the community center from Volatile Organic Chemicals (VOCs) in the shallow groundwater.
4. The VOCs in the shallow groundwater pose a risk to human health through inhalation. That exposure pathway must be evaluated as an important part of the site assessment.
5. Lockheed has acknowledged that although VOCs in the groundwater are a potential concern, inhalation is not considered to represent a significant exposure pathway because air concentrations are presumed to be low. Presumption of low concentrations of toxic chemicals is not acceptable.
6. Lockheed used the low concentrations presumption to omit the study of groundwater vapor intrusion into homes.
7. Lockheed used the lack of human exposure to groundwater contaminates to justify not considering relocation of residents since the community supposedly no longer uses individual water wells.
8. Lockheed failed to evaluate the vapor intrusion pathway of the toxic off gassing of VOCs into residential homes.
9. If the FDEP does not require the vapor intrusion pathway and indoor air quality to be investigated as a part of the Site Assessment, the Remedial Action Plan will fail to address a critical human health exposure pathway and continue to allow the community to be exposed to the toxic chemicals of concern.
10. The groundwater table beneath the residential area is less than 5 feet below the ground surface. Toxic volatile organic chemicals in excess of criterion are present in the shallow groundwater beneath the residential areas at depths of 0 to 30 feet below ground surface in the Upper Surficial Aquifer System and 35 to 45 feet below ground surface in the Lower Surficial Aquifer System.
11. The Upper Surficial Aquifer System groundwater 15 to 20 feet below ground level in the residential areas contains 1,4-Dioxane, PCE, TCE, cis-1,2-DCE, 1,1-DCE and 1,1-DCA in concentrations in excess of Screening Criteria.
12. The Lower Surficial Aquifer System groundwater 35 feet below the ground surface in the residential area contains 1,4-Dioxane, PCE, TCE, cis-1,2-DCE, 1,1-DCE and 1,1-DCA in excess of Screening Criteria.
13. FDEP must require that the transport of volatile organic chemicals from the shallow groundwater beneath the residential areas into the homes of people living on top of the groundwater plume and the human exposure pathway be evaluated as part of the Site Assessment.
14. It is critical to evaluate this human health pathway during the Site Assessment phase and not allow the Remedial Action phase to proceed until the magnitude and extent of human health exposure is defined.
15. This evaluation could lead to an additional recommendation in Section 5.2 of the Site Assessment Report that would require an evaluation of groundwater off gassing impacts to human health that could result in relocation of residential areas over the groundwater plume.
16. One of the significant findings of the Site Assessment Report is that the horizontal and vertical extent of COCs above GCTLs in site groundwater has been delineated. But the vertical extent of the groundwater contamination plume has not been determined for the entire plume area. There are not adequate wells below groundwater strata exceeding GCTLs throughout the plume to define the vertical extent of the plume.
17. Two other significant findings of the Site Assessment Report are that the vertical extent of chemicals of concern or COCs above GCTLs in site groundwater is limited to within approximately 200 feet below ground surface water and in the Lower Arcadian Formation Sands and Floridan Aquifer System is not impacted with site COCs above groundwater cleanup targeted levels.
18. These findings fail to present the fact that chemicals of concern have migrated into the Lower Arcadian Formation Sands and Floridan Aquifer System as documented by testing of the minimal number of monitoring wells installed in the two water bearing zones.
19. Chemicals of concern including TCE and PCE are present in groundwater formations deeper than 200 feet below ground surface and have been detected in groundwater to depths of 365 to 385 feet below ground surface.
20. Chemicals of concern have impacted the Lower Arcadian Formation Sands and the Floridan Aquifer System.
21. Samples of private water wells were collected and analyzed as part of the Site Assessment process. Lockheed made a decision to not include some of the results in the Site Assessment report and will submit the data to the DEP under separate cover. This is not acceptable.
22. The 2006 Private Well Survey Data that was submitted to DEP under separate cover on May 22 indicates that samples from several wells to the north and east of the Booth well showed contamination, yet those wells, in particular Well 98 on Trey Desenberg’s property, arenot within the plume. This indicates that both the horizontal as well as vertical extent of the plume has not been defined and needs further study.
23. Test results of private wells not included in the Site Assessment contained concentrations of 1,4-Dioxane, TCE and cis-1,2-DCE in concentrations, in some cases, in excess of groundwater targeted cleanup levels.
24. Lockheed has suggested that these private wells were beyond the limits of site impacted groundwater and beyond monitoring wells which had non-detectable concentrations of the chemicals of concern found on the former American Beryllium Company site.
25. There are many individual plume maps for specific chemicals within the overall composite plume map. Examination of individual plume maps indicate that other plumes traced back to the plant may be contaminating those private wells.
26. The entire Private Water Well Data set must be required to be provided in the Site Assessment Report and the DEP must require that Lockheed do additional testing to delineate groundwater contamination outside the current plumes and determine if the source material for the plumes of the unreported private water wells are interconnected to the former beryllium facility plumes or originated from the former plant.
27. Only one on-site surface water sample has been collected and analyzed throughout the testing and evaluation phases of the former ABC facility site. No on-site or off-site sediment samples have been collected and tested for COCs. This constitutes a lack of data on which to fully characterize the former ABC facility site and the surrounding area known to be impacted by the contaminated groundwater plume.
28. Sediment sampling and analysis for COCs must be performed in order to complete the characterization needed to finalize the Site Assessment phase.
29. DEP should require a more proactive remedy than the cleanup strategies proposed by Lockheed in the site assessment. That proactive remedy should include: relocation, contaminated groundwater removal or bioremediation at hot spot areas in addition to the Interim Remedial Action, and removal of contaminated soil from on the industrial site and from the residential yards.
SOURCE: Wilma Subra, Subra Company, “Comments on Site Assessment Report Addendum 3, Former ABC Facility, Tallevast, Florida, submitted to DEP by Lockheed Martin on April 26.”
The Ithaca Journal (NY) reports:
Cornell University sent the 2005 Annual Report Executive Summary [PDF, 24K] for the Chemical and Radiation Disposal Sites. Highlights for the radiation site include: areal extent of the paradioxane plume was significantly smaller than in 2003; no radionuclides or volatile organic compounds (VOC) were detected in groundwater above limits; one surface water sample was positive for paradioxane; and the groundwater recovery system pumped 3.7 million gallons during the year. Highlights for the chemical waste site include: the area of the VOC plume remained stable with trichloroethylene (TCE) detected above 5ug/l in 7of the 21 monitoring wells; low levels of TCE detected in surface water on airport property; and 2.3 million gallons of groundwater pumped from the disposal site and 10.6 million gallons from the plume control system. The Groundwater Treatment Plant processed the nearly 16 million gallons to the discharge limits with the exception of dissolved iron and generated 1.25 tons of spent activated carbon and bag filters.
The former Radiation Disposal Site (RDS) and former Chemical Disposal Site (CDS), located just north of the Tompkins County Airport.
The two former disposal sites are located one-third of a mile apart, just north of Tompkins County Airport. The shaded areas indicate where the groundwater is believed to be contaminated by chemicals migrating from the sites.
The Press & Sun-Bulletin reports that the ATSDR has done a follow-up to its initial study and confirmed that diseases and birth defects are elevated:
The document [PDF, 1.3 MB], published by the Agency for Toxic Substances and Disease Registry with the state Department of Health, is an update of a study in August that found high rates of testicular and kidney cancers, birth defects of the heart and low birth weights in areas polluted with industrial solvents, including trichloroethylene (TCE).
They’ve ruled out a number of other possible causes, but aren’t yet willing to say that residential exposure to toxins has resulted in these diseases:
The updated study, dated May 26 [...] took into consideration additional factors that could explain poor birth outcomes, including the mother’s age, education, race, number of previous live births, and the amount of prenatal care she received. But they didn’t influence the findings.
[...]
“It (poor birth outcomes) isn’t explained by prenatal care or these other factors,” said Karolina Schabses, an epidemiologist with the state Department of Health.
But there are other possibilities still being considered, mainly exposure to factory emissions or chemical gases seeping in the ground, or occupational exposure. They seem like logical suspects, but they are difficult to pin down.
“You work through the steps and you try to come to a conclusion. There is a huge realm of possibility of the things we are dealing with,” Schabses said.
It sounds to us as if the the DOH is either trying to keep expectations very low or laying the foundation for a politically palatable finding of inconclusive causation.
Come to think of it, isn’t it strange that Departments of Health are so quick to emphasize the uncertainty? It almost sounds like a known and popular polluter ploy. You never see Departments of Health out there declaring “There is a cause here, dammit, and we’re going to find it.” Wonder why that is?
Meantime, it seems like whatever NY DOH’s goal, the approach is having its intended effect:
To the layman, it seems like a matter of common sense: Toxic chemicals cause illness. But waiting for years of detailed study to determine exactly who was exposed to what, at what levels, for how long and to what effect have proven frustrating for community members, said Frank Roma, a member of the Western Broome Environmental Stakeholders Coalition.
“Every time I talk to anybody, it’s on people’s minds,” he said.
Will they ever find an answer?
“I’m hoping for it. It seems to be out of reach,” he said.
In December of 2004, Lenny Siegel from the Center for Public Environmental Oversight (CPEO) published this report, entitled “El Toro and the Potential for Vapor Intrusion.” After reviewing documentation and touring the base, Lenny concludes:
In summary, I am not satisfied with the Navy’s outright dismissal of
vapor intrusion – to indoor or outdoor air – as a risk at El Toro. I
think it’s unlikely to be a serious problem, but I believe air sampling
is necessary before ruling it out. The entire situation seems to be
saved by the reuse plan and the division of the property between sale
and lease parcels. The sections most likely to be sources of VOC vapors
are not being sold, and they are not planned for continuous human
presence. Measures, such as institutional controls, should be
implemented to keep it that way.
Read the full report here.
Can be downloaded here (375 KB, PDF)
The Press & Sun-Bulletin reports on the findings of a new study that reveals kidney cancers, testicular cancers, and birth defects are elevated in Endicott.
Update: The health study document can be downloaded here.
For Immediate Release
June 9, 2005
Contact: Amanda Evans: (626) 399-1049 (cell)
PEOPLE DESERVE PROTECTION FROM TOXIN, TCE, SAY COMMUNITY MEMBERS & PHYSICIANS
Irvine, CA — June 9, 2005 — Citizen activists, physicians, exposure victims, and cancer survivors will testify before the National Academy of Sciences today about the groundwater contaminant, Trichloroethylene (TCE). Neil Fischbein, who runs the TCE Blog, explains “The NAS Committee will have a choice: protect people or save polluters money.” Representatives of an informal national community coalition are asking that
the EPA be allowed to implement recommendations from its 2001 health risk assessment for TCE wherein EPA declared TCE was as much as 65 times more toxic than previously known and is highly likely to cause
cancer in humans.
The Department of Defense and the Halogenated Solvents Industry Alliance (HSIA), a TCE manufacturers’ representative, have challenged the more protective regulations recommended by EPA. Their challenge led to a TCE health risk review project by NAS, of which today’s meeting and citizen testimony are a part.
In 1997 the Air Force used its cost of clean-up as an excuse to recommend the EPA raise safety limits for TCE, potentially exposing people to levels of TCE deemed unsafe by federal law. “Because the current remediation
level is extremely difficult to achieve,” it wrote, “remediation costs are very sensitive to even small changes in this level. Re-evaluation of TCE…can reasonably be assumed to result in a remediation level significantly greater than [the current safety standard].”
In 2003, after EPA proposed lower, more protective TCE safety levels, the Air Force calculated it would cost the Air Force $1.25 billion in extra clean-up costs and would cost DOD as a whole an extra $5 billion. This
would raise DOD’s total cost for TCE clean-up to $10 billion.
Jennifer Sass, a senior scientist with the National Resources Defense Council (NRDC), is not swayed by the DOD’s cost concerns. Sass told the Academy’s Committee in April that TCE is likely to cause people
neurological diseases, immune system problems and cancer. She emphasized that infants and children are at particular risk because of the potency of TCE in their small systems. “Leaving the public exposed to TCE at
unacceptably high levels during this lengthy deliberative process is a failure of the regulatory agencies to carry out their mission to protect public health,” she said. “We continue to request that EPA implement its Draft 2001 Health Assessment immediately.”
Cheryl Buchanan, a former Cheshire, Connecticut resident whose hometown was exposed to high levels of TCE for two to three decades and now exhibits elevated cancer rates says, “TCE has had a devastating effect on my family, friends, and neighbors. And now polluters are trying to avoid the evidence in front of them because it is too expensive to clean up. The truth is scary. But I wasn’t given the choice to ignore the realities of TCE exposure. They shouldn’t be given that choice either.”
# # #
From a past article in the Poughkeepsie Journal (NY):
Thanks D.
The NAS has recently posted its summary of the closed session of the April 20 and 21 TCE meetings in DC:
The following committee members were present at the closed sessions of the meeting:
Scott Burchiel, Mary Davis, Kelly Dix, Mark Goldberg, Rogene Henderson, Evan Kharasch, Serrine Lau (via conference call), Jose Manautou (via conference call), Gail McCarver, Harihara Mehendale, Thomas Smith, Leslie Stayner (April 20 only), Rochelle Tyl (via conference call), Jack Vanden Heuvel, and Janice Yager
The following topics were discussed in the closed sessions:
1. Standard NRC discussion of policies, procedures, conflict of interest, and bias
2. Interpretation of the statement of task, plan of action, and report outline
3. Schedule and location of future committee meetings
The following materials (written documents) were made available to the committee in the closed sessions:
TCE-66: Article
Williams-Johnson, M.M., A.E. Ashizawa, and C.T. DeRosa. 2001. Trichloroethylene in the environment: public health concerns. Human Ecological Risk Assessment 7(4):737?753.
TCE-67: Document
Agency for Toxic Substances and Disease Registry (ATSDR). 1997. Toxicological profile for trichloroethylene (TCE). Atlanta, GA: U.S. Department of Health and Human Services, Public Health Service.
TCE-68: Document
ATSDR (Agency for Toxic Substances and Disease Registry). 1997. Public health assessment for U.S. Marine Corps Camp Lejeune military reservation. Camp Lejeune, Onslow County, North Carolina. Atlanta: US Department of Health and Human Services.
TCE-69: Report
ATSDR (Agency for Toxic Substances and Disease Registry). 2003. Progress report: survey of specific childhood cancers and birth defects among children whose mothers were pregnant while living at U.S. Marine Corps Camp Lejeune, North Carolina, 1968-1985. Atlanta: US Department of Health and Human Services.
TCE-70: Document
ATSDR (Agency for Toxic Substances and Disease Registry). 1998. Volatile organic compounds in drinking water and adverse pregnancy outcomes: U.S. Marine Corps Camp Lejeune, Onslow County, North Carolina. Atlanta: US Department of Health and Human Services.
TCE-71: Questions about TCE
ATSDR (Agency for Toxic Substances and Disease Registry). Reported health effects linked with trichloroethylene (TCE) and tetrachloroethylene (PCE) exposure. Available at the website of the Agency for Toxic Substances and Disease Registry of the U.S. Department of Health and Human Services.
TCE-72: Fact sheet
ATSDR (Agency for Toxic Substances and Disease Registry). Past exposure to VOC-contaminated drinking water at U.S. Marine Corps Base Camp Lejeune. Available at the website of the Agency for Toxic Substances and Disease Registry of the U.S. Department of Health and Human Services.
TCE-73: Public Agenda
TCE-74: Provisional Roster
TCE-75: Biographical Information
TCE-76: Letters
Letter dated April 16, 2005 from Amanda Evans, Founder and President, Victims of TCE Exposure?A lasting Legacy. Attachments include letters from individuals exposed to TCE at the View-master factory in Beaverton, Oregon.
TCE-77: Document
ATSDR (Agency for Toxic Substances and Disease Registry). 2004. Feasibility investigation of worker exposure to trichloroethylene at the View-Master factory in Beaverton, Oregon. Atlanta: US Department of Health and Human Services.
TCE-78: Testimony
Dugard, P. 2005. Clarification of the CDC biomonitoring program as it relates to trichloroethylene.
TCE-79: Article
Edwards, H. 2003. Family blames health woes on Dickson’s landfill. Available at the website of The Tennessean.
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