Citizen Response to U.S. EPA Soil Sampling, Columbus, Ohio

[John Thomas <jnthomas@infinet.com>]

This document, along with all graphics will be available on the Neighbors 
Protecting Our Environment WEB page within a week.  Our URL is:
http://www.infinet.com/~jnthomas/columbus_ohio

With Respect, in Gentleness and Peace.


John Thomas

----------------- Text of Citizen Response Follows -------------------

U.S. Environmental Protection Agency
Columbus Waste-to-Energy Municipal Incinerator
	
Dioxin Soil Sampling Project
~ April 1996 ~


Community Response

Prepared by: John Thomas with input from Teresa Mills and U.S. EPA Region 
5(1)
Prepared for: Neighbors Protecting Our Environment
Completed on: May 8, 1996


Background
During April, 1996, the U.S. EPA released preliminary results from the 
soil sampling project conducted in Columbus, Ohio.  The purpose of this 
study was to determine "the levels of dioxin/furans in soils around" the 
municipal Waste-to-Energy (WTE) facility.  These levels would then be 
compared to "background" levels.  This comparison would hint at any 
"possible impacts from the WTE facility."  In addition, the analysis from 
this effort would indicate the "need" and "locations" for future sampling.(2)

The released report was divided into two sections. The first section, 
"Columbus Waste-to-Energy Municipal Incinerator Dioxin Soil Sampling 
Project," was prepared by the U.S. EPA, Washington, D.C. office.  The 
second section, "Columbus Waste-to-Energy Facility: Soil Sample Site 
Descriptions/Laboratory Analysis Data Sheets," was prepared by the U.S. 
EPA, Region 5, Chicago office.  Accompanying the report was an additional 
fact sheet.

U.S. EPA Conclusions
"Analysis suggests that the cluster of samples on the site of the 
Columbus WTE are influenced by activities at the Columbus WTE.  The 
average toxic equivalent concentration (TEQ) of the four samples is 356 
parts per trillion (ppt).  The cluster of samples just outside the 
Columbus WTE appear as well to have been influenced by the Columbus WTE, 
although the evidence for such influence is weaker than the evidence for 
the on-site samples.  The average TEQ soil concentration is 49 ppt.  The 
14 samples within the city of Columbus average 10 ppt, and the background 
samples have a low average soil concentration of 1ppt."

Federal mandated cleanup levels for dioxins in soil is 1,000 ppt.  Even 
the samples on-site were far below this action level.  While the on-site 
soils do not require cleanup, they are "substantially higher than the 
background" and therefore suggest an impact from the WTE.  This impact 
was also strongly suggested, according to the U.S. EPA, based on "a 
comparison of soil congener profiles [emphasis added] with emissions from 
the 1992 stack emission test."  A congener profile is what the U.S. EPA 
termed a dioxin "fingerprint" during the April availability session.

What is Dioxin
The general terms "dioxin" and "furan" describe a family of chemicals.  
There are 75 related chemicals in the dioxin family and 135 related 
chemicals in the furan family.  Of these 210 different substances, only 
17 are considered to be toxic.  It was these seventeen highly toxic 
members (called congeners) of the dioxin and furan chemical families that 
the U.S. EPA was searching for in the lands surrounding the WTE incinerator.

What is a Dioxin "Fingerprint"
According to the U.S. EPA, a "congener profile can be constructed by 
summing the concentrations of all the 17 congeners and describing the 
proportional contribution of each to the total in terms of fractions."  
For example, for all the on-site samples the total of the average 
concentration of these 17 congeners was 4,833.60 picograms per gram 
(pg/g) of soil.  Downwind, the total of the average concentration of the 
congeners was 4,788.69 pg/g of soil.  On-site, 31% of the total 
dioxin/furan found was contributed by the OCDD congener.  Downwind that 
same congener comprised 81% of the total dioxin/furan found.  At all 
other locations within the city of Columbus, the OCDD congener 
represented 81% of the total dioxin/furan found in the sample.

While each sample shows a peak at the OCDD congener, the peak downwind 
most closely resembles the peak throughout the city (and at the 
background site).  Downwind, throughout the city, and at the background 
site, the OCDD congener represented 81% of the congeners found in each 
sample.  The fact that the OCDD congener represented 81% in each of these 
samples constitutes what the U.S. EPA considers a "fingerprint" match.

U.S. EPA "Fingerprint" Conclusions
According to the U.S. EPA, there was a "fingerprint" match between the 
stack emissions measured in 1992 and the soil taken from the 
incinerator's property in 1995.  The match between emissions and soil 
content is used by the U.S. EPA to strengthen the assertion that the 
dioxins found on site may be related to "past operation of the 
incinerator."  According to the report, however, no "fingerprint" match 
between stack emissions and soil content could be found for locations not 
on the WTE property.

NPE Conclusions
This section contains my analysis based on the U.S. EPA data.  The data 
which I have used is attached at the end of this document.  The 1992 
stack emission results may be found in a study authored by Paul Koval of 
the Ohio EPA.  The March and April 1994, and September 1995 ambient air 
levels surrounding the WTE may be found in the 1995 ambient air study by 
the same author.  Finally, the on-site, downwind, and city wide soil 
values are obtained from the April 1996 U.S. EPA report.

My analysis suggests:
* There was a dioxin "fingerprint" match between the on-site, downwind, 
and city wide soil samples.

* The levels of dioxins and furans found in the soils may have been 
diluted by almost 50 percent due to poor soil extraction practices. 

* While the soil levels fall below EPA action levels, they are not safe 
for children.

"Fingerprint" Match Does Exist
A "fingerprint" match between on-site, downwind, and city wide soil is 
found in the U.S. EPA data.  The U.S. EPA missed this connection due to a 
graphing error.  The downwind samples show a maximum concentration of 
3,893.36 pg/g for the OCDD congener, and a minimum concentration of 1.49 
pg/g for the 123789 HxCDF congener.  The variation in the concentration 
of these two congeners is so great that graphing both values on normal 
graph paper produces a meaningless plot.  The smaller concentration is 
not even visible next to the larger one.  In a situation like this, the 
use of semi-logarithmic graph paper is preferred.

When the congener profiles are graphed on semi-log paper a clear 
"fingerprint" match results (Figure 1.).  Graphed on normal graph paper 
the match is obscured (Figure 2.).

How Deep Did the EPA Dig
Dioxins floating in air eventually fall to the ground.  According to the 
U.S. EPA these depositions of dioxin in soil are fairly stable.  
Accordingly, dioxins once bound to particulates "do not leach (dissolve 
and wash away) or volatilize (turn into gas) easily."(3)  Once in soils, 
dioxins either remain in place or soil erosion carries them into bodies 
of water.  For soil not effected by erosion, it is estimated that "it 
takes between 25 and 100 years for half of a given concentration of 
dioxin" to degrade.(4)

Since dioxins do not dissolve in water they do not migrate down into the 
ground.  Dioxins remain at or near the surface of soil.  When removing 
soils for testing only the upper most soil contains dioxin.  Deeper soils 
would contain much less dioxin or they would be dioxin free.  This is 
reinforced by studies of dioxin in soils.  At Times Beach, Missouri, 
dioxin "below the top inch did not migrate upward to vaporize into the 
air, and it did not migrate downward with the rain - it just stayed 
put."(5)  This suggests that when  removing soils below 2.54 cm (1 inch), 
those soils would be only minimally impacted by dioxin which deposited on 
the surface.

When the U.S. EPA removed soils from locations in Columbus they removed 
soils to a depth of 7.6 cm (3 inches) according to the study report(6).  
To remove soil from the sample location, the U.S. EPA used a tulip 
planter.  This device had a diameter of 7.6 cm (3 inches) and a height of 
7.6 cm (3 inches) according to the study report.  The volume of soil 
removed based on these dimensions was 344.8 cubic centimeters (cm3).  
This soil was thoroughly mixed before the sampling containers were filled.

If the maximum impact from dioxin deposition was to be found in the top 
2.54 cm of soil, then the effect of this mixing was to dilute the dioxin 
present.  The top 2.54 cm of the soil represented only 33% of the total 
volume of soil removed.  This means that 67% of the soil present in each 
sample would have little or no dioxin present.

In addition to this intentional dilution of the soil samples, the U.S. 
EPA's assertion that soils were removed to a depth of only 7.6 cm cannot 
be believed.  Citizens were present when these samples were taken.  After 
the soil "plug" was removed using the tulip planter, no measurements were 
made on the depth of the resulting hole.  This hole may have been 8.9 cm 
(3.5 inches) deep, or 10 cm (4 inches) deep.  According to the U.S. EPA a 
depth of 10 cm in soil sampling could decrease "soil concentrations by 
60%."(7)

Soil Levels Are Not Safe
The U.S. EPA has stated in their draft dioxin reassessment that an 
"acceptable" daily dose of dioxin is .006 picograms per kilogram of body 
weight per day (pg/kg day)(8).  This level represents a risk factor of 
one in a million, meaning that a community exposed to this level of 
dioxins and furans for a 70 year period would experience one cancer death 
for every million persons exposed.  For a 150 pound (68 kg) adult this 
body weight dose translates into a daily dose of .41 pg/day.  This means 
that an adult taking in .41 pg of dioxin and furans every day for their 
entire life should experience a risk of one in a million (10-6) for 
developing cancer(9).

According to the Citizen's Clearinghouse for Hazardous Waste, the "EPA 
has also stated in their soil modeling section of the 1994 dioxin 
reassessment that children under the age of seven engaging in 
hand-to-mouth activity ingest an average of 100-200 milligrams per soil 
event (mg/event)"(10).

According to the U.S. EPA report on the recent soil sampling, sample site 
S21 was located at Scioto Trail elementary school.  The school was found 
to have 4.1 pg/g (ppt) TEQ of dioxin and furans in the surrounding soil.  
One gram is equal to 1,000 milligrams.  Therefore, the school had .0041 
pg/mg TEQ of dioxin in its soil.  At this level, a child playing outside 
of this elementary school, engaging in only one hand-to-mouth action and 
ingesting the EPA minimum estimate of 100 milligrams of soil, would be 
exposed to .41 pg of dioxin.  For an adult, this would represent a cancer 
risk of one in a million.  For a child, the risk is three times greater!  
However, according to the U.S. EPA, a child only ingests soil when 
playing at home and not while playing at school.  Therefore, while 
children playing at Scioto Trail elementary school could be exposed to an 
"adult dose" of dioxin, this exposure could not happen because children 
don't put their hands in their mouth while at school.

Children were also taken on tours of the Waste-to-Energy facility.  The 
average TEQ dioxin level on-site was measured at 356 pg/g (ppt).  This is 
.356 pg/mg of soil.  A child, on-site, engaging in just one hand-to-mouth 
activity, would ingest 35.6 pg of dioxin.  This is 87 times the U.S. 
EPA's "acceptable" dose for an adult.  This represents a cancer risk for 
life time exposure to an adult of approximately one in ten thousand 
(10-4).  Again, a child's risk is greater.  A child, touring the WTE 
incinerator, engaging in one hand-to-mouth activity would receive an 
entire years dose of dioxin.  However, according to the U.S. EPA, a child 
only ingests soil when playing at home and not while touring industrial 
facilities.

Throughout the city of Columbus, on average, the U.S. EPA measured a 
dioxin level in soil of 10 pg/g (ppt).  A child, playing anywhere within 
the city of Columbus (even at home), engaging in just one hand-to-mouth 
soil ingestion event would consume 1 pg of dioxin, or two times what the 
EPA considers an "acceptable" daily dose for an adult.

Conclusion
It is impossible through this study to definitely determine what portion 
of the dioxin found in the soils of Columbus, Ohio, were produced and 
released through the eleven years of operation of the Columbus WTE 
incinerator.  What we do find is a similar congener profile between soil 
samples taken on-site, downwind, and city wide.  We also see a dramatic 
increase in the amount of dioxin found on-site and downwind.  This 
coupled with the 1995 ambient air study which demonstrated a 45% decline 
in dioxin concentrations after the incinerator closed, suggests that 
there was an impact from the operation of this facility.

While the concentration of dioxin in the soils surrounding the WTE 
facility does not alarm the U.S. EPA, we find the soils to be unsafe for 
children to play on.  This conclusion is based on estimates and 
guidelines published by the U.S. EPA.  The agency has set the cleanup 
level at 1,000 pg/g of soil.  This level is too high!  Children playing 
at Scioto Trails elementary school, or anywhere in Columbus, are being 
placed at risk based on the dioxin levels found in our soils.

~ Notes ~


(1) On May 7, 1996 a conference call was held between citizens and U.S. 
EPA Region 5.  The purpose of this conference was to discuss the 
questions raised by this document.  Present were John Thomas, Teresa 
Mills, and Joan Seeman representing the citizens of Columbus and Phil 
Gehring, Ginny Narsete, Carole Braverman, Dwain Winters, Mat Lorber, and 
George Czerneick representing the U.S. EPA.

(2) Quotes from U.S. EPA Fact Sheet, November 8, 1995.

(3) Lois Marie Gubbs, Dying From Dioxin: A Citizen's Guide to Reclaiming 
Our Health and Rebuilding Democracy (Boston: South End Press, 1995) 40.

(4) Ibid. 42.

(5) Ibid. 42.

(6) U.S. EPA, Columbus Waste-to-Energy Municipal Incinerator Dioxin Soil 
Sampling Project, (Washington, D.C.: U.S. EPA, April 1996) 7.

(7) U.S. EPA, Estimating Exposure to Dioxin-Like Compounds, Volume III: 
Site-Specific Asessment Procedures, EPA/600/6-88/005C, (Washington, D.C.: 
U.S. EPA, June 1994) 7-112.

(8) Lois Marie Gubbs, Dying From Dioxin: A Citizen's Guide to Reclaiming 
Our Health and Rebuilding Democracy (Boston: South End Press, 1995) 26.

(9) This "acceptable" daily dose varies according to body weight.  Women 
and children would experience higher risks.

(10) U.S. EPA, Estimating Exposure to Dioxin-Like Compounds, Volume III: 
Site-Specific Asessment Procedures, EPA/600/6-88/005C, (Washington, D.C.: 
U.S. EPA, June 1994) 2-14.