RI/FS Human Health Risk Assessment Perspectives from Citizens for a Clean Columbia
- Details
- Published: Friday, 08 May 2020 21:23
Mindy Smith, M.D. M.S.
CCC Board Secretary
In concert with EPA’s release of the draft Upper Columbia RI/FS Human Health Risk Assessment (HHRA), I was asked to work with Citizens for a Clean Columbia (CCC) board members to give our sense of public and CCC perceptions about the document and process of sharing information.
These impressions are based on a fairly recent public meeting and discussions with board members and people from the town of Northport (population about 350 people). We will be interested to see how many of our questions the HHRA addresses, or whether a different forum or report will be required.
One question goes back to 2004, which is when soil removal due to lead contamination on properties within Northport was based on a lead threshold of or exceeding 1000 ppm. Residential soil cleanup voluntarily conducted by Teck between from 2015 – 2018, however, used a threshold of 700 ppm. What does this mean to the future of Northport properties with between 700 – 1000 ppm? EPA is working on this issue separately, and we strongly support this effort to extend cleanup to properties with lead levels at 700 ppm or more.
At the meeting, EPA shared how they estimated the probability of adverse human health effects from lead. However, this information does not address questions about specific human health effects, both past and future. While much of this is outside EPA’s purview, the concerns about remediation and provision of adequate surveillance and monitoring, such as air monitoring, to ensure future protection against adverse health effects from contamination seems relevant. Without knowing which lead level will be selected for remediation, these concerns remain.
There’s on-going interest in soil amendments to reduce lead exposure in areas that do not meet removal action levels and in expanses of undisturbed land. Citizens are asking whether other cutting-edge technologies are being considered as amendments such as hemp or fungus (bioremediation). And what changes in soil contamination occur as areas are burned or otherwise altered. I, along with others, worry that effective amendments will not be found, and that hand washing will provide insufficient protection.
These and other concerns go to the heart of community questions about past and future health effects, influence on property values, availability of legacy funding, additional sampling, and the perceived need for reinstated and expanded air monitoring.
From my perspective, I am also concerned about whether the HHRA will truly reflect risk as it is difficult to know the cumulative effect of contaminants, and there is no clear way to combine lead and non-lead risks into a single risk assessment. Further, the gravity-flow and pumped creek-impoundment water systems used for irrigation and sometimes drinking, like my own water system, have not been evaluated.
While I have confidence in the good will of most of those involved in this process on both sides of the border and the impressive work done over the past 14 years, I do not have confidence in the current administration and whether sufficient clean-up and monitoring will occur now and in the future.
At the state level, the Washington Department of Ecology Air Monitoring Program disappointed us when they
said they had insufficient manpower to apply for an EPA grant for air monitoring in our area. When we suggested citizen volunteers could be trained in data collection, they disagreed.
This is despite DOE’s 2017 report entitled “Preliminary Review and Evaluation of Available Air Quality Monitoring Data and Consideration of Potential Present-Day Health Risks.” This report recommended updated air monitoring be conducted in our area to analyze heavy metals known to be emitted from the Trail smelter which “may further contribute to potential human health impacts.” On the other hand, Ecology’s Toxics Cleanup Program has provided invaluable assistance, including current work to consider further cleanup of the Northport Park shoreline area.
It will be interesting to read the draft HHRA. We’re eager and hopeful to see how many community-based questions will be successfully or fully addressed. EPA’s RI/FS Remedial Project Manager has thus far been very responsive to our comments. Further, to ensure that the public is well informed about the HHRA and able to provide input, EPA has agreed to a 60-day public comment period and will be providing two webinars. In that positive vein, CCC remains very committed to supporting the outreach process and, as necessary, helping collate public input with EPA.