Times Beach Risk Assessment

[Cdstelzer@aol.com]

793164286 phoenix

I am a reporter for the Riverfront Times in St. Louis. Recently, I submitted
a list of questions to the EPA, Missouri Department of Natural Resources
(DNR) and Syntex. These are the three parties that signed the consent degree
that calls for the operation of a dioxin incinerator at Times Beach, Mo. The
plans involves burning the contaminated soil at Times Beach and from 26 other
dioxin sites in Eastern Missouri. 
        The DNR has refused to far to respond to my questions. The EPA
replied on Feb. 27. 
        I am posting one of my questions and the answer that the EPA gave in
response. I have also included an opposite view from Pat Costner, a
Greenpeace chemist.
        In its risk assessment, the EPA doesn't appear to factor in the
pre-existing average body burden from dioxin. This amount is considered by
the EPA itself to be an excessive threat to human health. The EPA's own
standard calls for protecting human health to one-in-a-milllion excess cancer
deaths. The EPA claims that the incinerator will cause less than
one-in-a-million excess cancer deaths.  
        Since the general population is already exposed to dioxin at a level
that causes more than one-in-a-million excess cancer deaths any additional
dioxin that enters the environment is bound to raise that estimate. 
        I am requesting that medical and scientific experts submit their
opinions about the safety of dioxin incineration, specifically the Times
Beach incinerator.  Send e-mail to cdstelzer@aol.com or phone or fax me at
314/781-1270. 

 The EPA has estimated in its Times Beach risk assessment that a worst-case
scenario would involve the release 0.15 nanograms of dioxin per cubic meter
of air.  The EPA reassessment on dioxin concluded that the average American
already carries nine nanograms of dioxin per kilogram of body weight. 
      At 13 ng/kg, sex hormones are diminished in men; at 47 ng/kg, decreased
growth is observed in children. Dioxin is a probable human carcinogen and is
know to cause immunological and reproductive problems.        Many of the
residents of Eureka and vicinity are likely to have higher levels of dioxin
already in their body because they are either former Times Beach residents or
veterans of the Vietnam War, who were sprayed with Agent Orange. 
       All of the effected population has already been exposed to dioxins in
the course of their everyday lives. The EPA has concluded that the entire
population of the country is already at risk and that everyone is already
over-exposed to dioxin.  
 Specifically, the EPA estimates that the average dose of 0.006 picograms ( a
thousand times smaller than a nanogram) of  dioxin now produces one excess
cancer in a million (see Schecter, Arnold, "Dioxin in U.S. Food and Estimated
Daily Intake,"   Chemosphere, Vol. 29, 1994, p. 2261). Dioxin particularly
harms infants because it can pass through the mother's placenta and is in the
mother's milk.
            How can  the EPA claim that there will only be one additional
cancer death from the Times Beach incinerator given the above facts?

The EPA's reply:
In the event of such an emergency, the kiln gases ar vented through a
separate system which utilizes a propane flame control emissions.
     The draft risk assessment evaluates the fate and transport of
contaminants potentially emitted fromthe stack and evaluates reasonable
maximum exposure scenarios. Air moeling performed in the draft risk
assessment demonstrates that a dioxin emission rate of 0.15 nanograms per dry
standard cubic meter does not result in a significant dosage to any
individual even at the point of maximum impact. The draft risk assessment
concludes that at the point of maximum impact, there will will be less than
one incidence of cancer in a population of one million people exposed at that
point.

Greenpeace chemist Pat Costner's analysis:
Burn time
8 months.  Costner calculates that, if the incinerator project meets its goal
of only eight months of actual burning, 

"The 0.129 grams of TCDD that they are saying alright. That exceeds the
exceptable intake over that eight month period for 768 million people. That's
pretty phenomenal, isn't it?

"EPA is currently ... an acceptable daily intake and that daily intake is
associated with a cancer risk no greater than one-in-a-million.  That amounts
to about .01 picograms per kilograms of body weight per day. Now for an
adult, who would weigh about 70 kilograms, that amounts to about seven-tenths
of a picogram per person per day. Over an eight month period, a 240 day
period, that comes to 168 picograms per person for an eight month period ...
(explains equation here).

There contention is accurate that all of this dioxin will not reach people,
but my point here, and the important point here -- we already have a
population and an environment that is grossly contaminated in toxological
terms with dioxin. It is absolutely unconscionable to proceed with avoidable
activities that will add to that already excessive burden. I mean this is
avoidable.
     EPA admits and everybody knows that we already have a population and an
environment that are grossly overburdened. It is irrational and it should be
criminal to proceed to carry out avoidable activities that add to that
burden. That's about as clear as I can say it.