February 1, 1999
To: The Honorable Carol M. Browner
Mr.Robert J. Martin
Administrator National Ombudsman
U. S. Environmental
Protection Agency U. S. Environmental Protection Agency
401 M Street S.
W.
From: Olympic Environmental Council, Protect the Peninsula’s Future, Washington Toxics Coalition, and the environmental groups and private citizens as attested on the attached roster of cosigners.
Subject: A petition for the establishment of dioxin remediation goals based on health risk and incorporating current scientific evidence.
Several communities in EPA Region X are facing remediation issues resulting from the closing of industrial facilities with site assessment in various stages of completon at a number of the locations. Analytical results of sampling for contamination in varoius media are being reported, and extensive contamination by dioxin and numerous other chemicals was found to exist at both on- and off-site locations.
At this point in time, it is clear that remediation is required at most,
if not all, of the sites.
EPA's Region III has prepared tables of
risk-based goals for chemical concentrations in various media that correspond to
fixed levels of risk. The cancer risk level used in calculating the tables was
one cancer per rnillion exposed individuals. The cancer risk-based soil
concentration for dioxin is not included in current version of the tables, but
it has been calculated elsewhere to be four parts per trillion (4 ppt) using
EPA's standard assumptions for exposure and cancer toxicity.
EPA,
however, has promulgated a policy of using a target concentration of one part
per billion (1,000 ppt) as a residential standard for dioxin cleanup. That
concentration correlates with a cancer risk of five in ten thousand which is 500
times greater than the risk-level that is used for all the other chemicals in
the Region III risk-based tables. This discrepancy in the cancer risk level for
dioxin defies justification, considering that EPA’s maximum dioxin
concentration allowed for disposal in hazardous-waste landfills is one
pbb.
Whereas, EPA's dioxin reassessment concluded that:
** For
non-cancer effects, such as damage to the reproductive, endocrine, and immune
systems in birds, fish and mammals, including humans, dioxin is much more toxic
than previously believed.
** Some of dioxin's powerful effects are observable in humans at dioxin exposure levels already occurring in the U. S, population.
** Some more highly exposed members of the population may be at risk for
a number of adverse effects including developmental toxicity, reduced
reproductive capacity in males based on decreased sperm counts, higher
probability of experiencing endometriosis in women, and reduced ability to
withstand immunological challenge.
** Modeling estimates suggest that, if dioxin and related compounds are adding to the human cancer burden, current background exposure may result in upper-bound population cancer risk estimates in the range of one in ten thousand to one in a thousand attributable to dioxin and related compounds.
** The body burden of the more heavily exposed individuals in the general population is already at the level at which adverse health effects are seen.
There is concern that the one ppb policy is obsolete and not protective of human health and the environment. Accordingly, we request that the EPA revoke the obsolete one ppb policy and develop health-risk based standards for the cleanup of dioxin and dioxin-like compounds in all environmental media, and that the standards incorporate the best and most current scientific information available.
Please reply in the care of the address shown below.
Carl Larkins
Project Coordinator
702 Roberson Rd.
Sequim, WA
98382
Respectfully submitted:
Darlene
Schanfald
Char
Apgood
Laurie Valeriano
Olympic Environmental
Council
Protect the Peninsula‘s
Future
Washington Toxics Coalition
3632 O’Brien
Rd.
208 Ward
Lane
4649 Sunny side Ave. N, #540-E
Port Angles,WA
98362
Sequim, WA
98382
Seattle, WA 98103
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