Government agencies are ignoring the fears of residents — and the warnings of scientists — by firing up the dioxin incinerator
BY C.D. STELZER
first published in the Riverfront Times (St. Louis), April 26, 1995
It’s only a couple of miles from here to Interstate 44, but it seems like a couple hundred. No traffic, no noise, no fast-food fanfare. Only scrawny oaks clutching thin-skinned ridges, and the bone-white bluffs rising in the distance on the opposite bank of the Meramec River.
A Sunday morning drive down Lewis Road can be like taking a pill, a tranquilizer. But the transient tranquility belies the angst that now resides in this part of southwest St. Louis County. Down this same road, Ann Chase, a pregnant high school teacher worries about the health of her unborn child. In another household, Mary Derrick, a registered nurse listens to her teenage daughter ask whether she will become infertile from the potential chemical exposure they both now face. Meanwhile, on a nearby farm, Ann Dollarhide and her husband decide not to replenish their cattle herd because of the threat of future contamination.
For these people, the possible health hazards posed by the planned Times Beach dioxin incinerator are an imminent concern. All three families live in the vicinity of Crescent, Mo. — the town at highest risk — since the Missouri Department of Natural Resources (DNR) issued the permit for the incinerator to operate on April 14. Crescent’s more populous neighbor, Eureka, is also located within the projected impact zone. All together more than 11,000 residents dwell inside the three-mile radius designated in the risk assessment prepared for the Environmental Protection Agency (EPA).
The EPA, DNR and Syntex, the company liable for the more than $118 million cleanup, are doggedly sticking to the terms of their 1990 court-negotiated consent decree, which calls for burning 100,000 cubic yards of dioxin contaminated soil and debris from Times Beach and 26 other sites in Eastern Missouri. The widespread contamination is the result of a waste-oil hauler spreading the highly-toxic materials in the early 1970s. To reassure residents of the safety of their cleanup plan, all three responsible parties draw from the conclusions of the risk assessment published last fall. According to those findings, stack emissions will cause less than one excess cancer incident per million population, which is considered well within the bounds of protecting public health.
But the Times Beach risk assessment conflicts with the EPA’s own safety standards regarding dioxin exposure. Furthermore, scientists consulted by the Riverfront Times have raised serious objections about the content of the risk assessment, the methodology employed in carrying it out and the actual purpose it serves.
Before the DNR issued its permit earlier this month, federal and state officials hesitated to be interviewed for this story, and the project coordinator for Syntex failed to return calls placed to him.
Here are a few things the EPA, DNR and Syntex have been in no hurry to talk about:
* The Times Beach risk assessment fails to factor in the pre-existing (background) dioxin levels of the exposed population. By not considering this, it significantly downplays the potential dangers of further dioxin exposure from additional incinerator emissions.
* The EPA’s projections on incinerator emissions are based on scientific assumptions. Although the agency maintains the incinerator will not cause any measurable increase in background levels, the risk assessment admits that “uncertainties in the sampling and analysis of dioxins … may lead to invalid conclusions … .”
* No health study has been done in advance to determine the existing (background) level of dioxin exposure of residents who live near the incinerator site. Many of those who do live nearby are former Times Beach residents who have likely been overexposed to dioxin in the past. Blood level testing by the Missouri Department of Health will begin in ernest only now that the incinerator has been given permission to operate. If the health department finds health problems developing, it has no regulatory authority to shut down the incinerator.
* The risk assessment only calculates potential carcinogenic and reproductive risks even though dioxin is now known to cause immunological and developmental problems at low levels of exposure.
* The risk assessment estimates the operation of the incinerator will result in one emergency release a week that would bypass anti-pollution devices and spew 350-pounds of particulate matter into the air. In the last two years, problems at an EPA dioxin incinerator in Arkansas have included numerous breaches in safety, resulting in excess releases of dioxin into the environment. Environmentalists now suspect dioxin exposure may have risen in the vicinity of the faulty incinerator.
Chemist Pat Costner, a dioxin expert for the environmental group Greenpeace, has a long memory of the Arkansas debacle and advises against repeating similar mistakes in Missouri. “EPA admits and everybody knows that we already have a population and an environment that are grossly overburdened (by dioxins),” says Costner. “It is absolutely unconscionable to proceed with avoidable activities that will add to that already excessive burden. It should be criminal.”
The reliability of the Times Beach risk assessment is questionable, because it omits a very basic variable from the equation — the average American is already overexposed to dioxin — according to the EPA’s own standards.
A decade ago, the EPA established that a daily intake of 0.006 picograms of dioxin toxic equivalents (TEq) per kilograms (pg/kg) of body weight results in one excess cancer per million, during a 70-year life span. It has been the agency’s conservative goal to protect public health to this limit. That goal has not been reached, however. As it now stands, the EPA estimates the average American adult ingests between three to six picograms of dioxin-like substances per day, mainly through food. If the existing background levels of dioxin were included in the Times Beach risk assessment, the EPA limits on allowable dioxin exposure would have already been exceeded before the incinerator belched one picogram from its stack.
This 0.006 benchmark has long been the subject of debate. The current dioxin reassessment now under review may ultimately raise the acceptable limits to 0.01 pg/ng of body weight per day. The World Health Organization, Canada and Germany use a different model and have set the acceptable daily dose of dioxin at 10 pg/kg.
Despite the varying standards, it is easy to deduce that dioxin is lethal in very small doses — a picogram is one trillionth of a gram.
In a worst-case scenario, the EPA has estimated the incinerator would emit 150 picograms (or 0.15 nanograms) of dioxin per cubic meter of air. That amount equates to one additional cancer incident per five million population, according to EPA calculations. In January, the St. Louis County Council used the figure as the standard for its air quality ordinance. The EPA and Syntex took immediate exception to the local law, claiming they were bound to protect human health to only the one-in-a-million standard (Emission Control, RFT, Feb. 1). But it’s clear that measure of safety is not going to be adhered to either.
Another way to look at it is by average body burden. The typical American already carries about nine nanograms of dioxin-like substances per kilogram (ng/kg) of body weight. A nanogram is a thousand times more than a picogram, or one billionth of a gram. At 13 ng/kg, sex hormones decrease in males; at 47 ng/kg, developmental problems have been observed in children, according to the EPA’ s recent draft reassessment of dioxin. The results of that study are still under review, and shouldn’t be confused with the “site specific” Times Beach risk assessment, which has underwent far less scientific scrutiny. Although still deliberating over the dangers of dioxin itself, the EPA has refused to place a moratorium on the Times Beach project even though it is known that incineration is a primary means by which dioxin enters the environment. The EPA also refuses to further consider any alternative technologies that are now capable of disposing of dioxin.
Despite evidence the entire population is already overexposed, Bob Feild, the EPA’s project manager at Times Beach sees little to be alarmed about in regard to Times Beach.
Feild argues dioxin levels in the environment are already decreasing and that hazardous waste incinerators are far less responsible for dioxin emissions than medical or municipal waste incinerators or cement kilns. This point is hammered home in the risk assessment as well: the “emissions burn at Times Beach would not result in any discernable increase in the background dioxin concentrations in the various media.” But the document also includes this warning: “uncertainties in the sampling and analysis of dioxins in these background media (air, soil, water, food) and the estimation of the levels in the media at Times Beach may lead to invalid conclusions when comparisons are made in background levels.”
This built-in uncertainty hasn’t dissuaded Feild one bit.”We are aware that there is a significant background risk there,” says Feild. The EPA official, nonetheless, remains confident that additional incinerator emissions at Times Beach will be insignificant and have no additional adverse effect on human health.
“If you consider the background concentration of dioxin exposure that we’re already all exposed to, you wouldn’t be able to see the incremental risks due to the incinerator,” says Feild. “So that’s why from a policy standpoint EPA doesn’t look at the entire risk. We look at … comparing the incremental risks to the total risk.” says Feild.
Feild’s own awareness of dioxin exposure is open to question, however. When asked about the EPA’s longstanding acceptable daily intake level of 0.006 pg/kg, the Times Beach project manager denied any such standard ever existed. “I don’t know where that number came from, I would have to check the source on that. I’ve been talking to the people that are involved in the reassessment of dioxin. They are telling me that there is no such number. So I don’t where that number came from or what it represents.”
The number is referred to as recently as last year in scientific articles by experts such as Barry Commoner of Queens College, Tom Webster of Boston University and Arnold Schecter of the State University of New York. The published caveats of these scientists on the dangers of dioxin stand in stark contrast to the assurances of the man responsible for the Times Beach risk assessment, Kishor Gala, who works for CH2M Hill in Denver, a consulting firm hired by the EPA.
“You have a one in three chance of getting cancer, anyway,” says Gala. ” So a one-in-a-million chance, how much more of a risk is it than one in three?” When asked to factor in the already existing background levels for dioxin, Gala quickly recalculated the odds, however. “From dioxin, I would think that you have a one in 10,000 chance (of cancer death) from the background(exposure), which is still much less than one in three or one in four from car smoke and cigarette smoke,” says Gala. “So … the exposure is still insignificant compared to the other exposures.”
Pat Costner, the Greenpeace chemist, doesn’t agree. “What they’re saying is, `Well, everybody is already so exposed that a little bit more doesn’t make a difference.’ That’s insane,” says Costner. “That’s totally irrational. It’s like standing in a swimming pool with weights on your feet and the water is up to your nose and somebody is saying a little more is not going to hurt you.”
Costner is not alone in her opinion.
David Kriebel, an epidemiologist at the University of Massachusetts at Lowell, participated in a National Academy of Science (NAS) review of Agent Orange, a defoliant used in Vietnam that contained dioxin. The NAS panel studied all the available literature on the subject at the behest of the Department of Veterans Affairs . In 1993, Kriebel and other scientists belatedly concluded dioxin causes three forms of cancer and other health problems in Vietnam War vets.
Although the dioxin issue is still mired in controversy, Kriebel has come to another reasonable conclusion, this one pertaining to Times Beach incinerator. ” If you want to know what the risks that someone faces are, you ought to add together the risks of so-called background (exposure) and the risk of some new technology that you are planning to add,” says Kriebel.
After ten years of battling incinerator projects, Paul Connett, a chemist at St. Lawrence University in upstate New York, has formed his own assessment of the strange socialized alchemy that has come to be called risk assessment.
“I think the whole risk assessment exercise is a political one. I see little indication that it’s ever used to do anything but promote a project. I think it puts a technical smoke screen between decision makers and the concerns of the public,” says Connett. “They would like to make you believe that risk assessment is a scientific exercise. I believe strongly that it’s a pseudo-scientific exercise. It’s not really science. It’s not based upon data, it’s based upon theoretical assumptions.”
Quite simply, nobody knows what the dioxin levels currently are of people who live near the planned incinerator. And there has been no rush to find out. Many former Times Beach residents still live in the area and have likely been overexposed in the past, but nobody’s knocking on their doors. A new Missouri Department of Health study on dioxin exposure will correspond with operation of the incinerator. But if the state agency detects increased dioxin in blood levels, after the incinerator is fired up, it has no power to shut down the project other than to pass on its concerns to the DNR.
Ellen K. Silbergeld, who works in the department of epidemiology and preventive medicine at the University of Maryland at Baltimore, has conducted many risk assessments herself. She is also associated with the Environmental Defense Fund, as is Peter L. deFur. The two authors collaborated on a chapter about risk assessment for a text book, Dioxins and Health published by Plenum Press late last year. Here is their conclusion on the subject:
“… It is critical to estimate where on the dose curve an individual or a population already falls. If the population or individual is already exposed to doses that exceed the level of acceptable risk … then different assumptions … no longer matter for purposes of making public policy.
“Much of the population of industrialized societies, where dioxins and related compounds have been released through industrial discharges, incinerator emissions, and dispersive uses of contaminated chemicals and herbicides, is already above the low dose range of exposures. … Under such conditions, the only prudent public policy is to take all feasible actions to reduce ongoing exposures and environmental inputs.”
Feild argues that the reducing ongoing exposures is what the EPA’s current plan is all about. In his opinion, the continued danger posed by the 27 dioxin sites in Eastern Missouri is reason enough to go ahead with incineration. The water main leak on North Second Street last summer, which flooded one of the dioxin sites is an example of what can happen, if the cleanup is delayed further, the EPA official says. “We have kids trespassing at some of these sites, … playing in contaminated areas,” says Feild. “I was at a site a couple of weeks ago, where I saw a couple of cattle grazing on the contaminated area. We know we have problems at these other sites. We need to clean them up. Excavating them and storing (the dioxin-contaminated soils) is not a permanent solution, because these storage facilities that we constructed are failing.”
When the 1994 EPA draft reassessment is read directly, however, it becomes evident that any further dioxin releases into the environment are not what the doctors have ordered (see sidebar).
ESTER stands for “Environmentally Safe Temporary Emergency Relief.” It’s the EPA’s euphemism for what is commonly called a dump stack in the incineration trade. If there is a glitch at the Times Beach dioxin incinerator, say an electrical outage, ESTER will be activated.
The executive summary of the risk assessment claims ESTER “assures that moderately high destruction of organic contamination occurs.” According to the summary, “the ESTER system includes automated provisions for feed and main burner shut-off, igniting the ESTER propane burners, routing of kiln gases to the ESTER stack and controlled venting of the gases in the secondary combustion chamber and gas cleaning system.”
What the ESTER system doesn’t include is any of the anti-pollution devices that are part of the primary burner. Under emergency situations, the ESTER stack will vent emissions directly.
According to the EPA: “During a full-scale operation, a typical ESTER event may occur at a frequency of once per week and last for several minutes. However, for the purpose of this risk assessment … it is conservatively assumed that … ESTER events may occur on a daily basis … Because of the absence of a gas cleaning system, approximately 350 pounds of treated particulate matter may be emitted during a typical ESTER event.”
“When I first saw that number, it seemed like a lot,” says Feild of the EPA. “But if you look at the major sources throughout St. Louis that are operating on a continual basis, that is not the tremendously high number that it appears to be on the surface.”
Chemist Connett is not so optimistic. He says the EPA’s history in dioxin incineration is anything but exemplary. “If they had a good track record on this it would be one thing, but they keep fucking up. I mean they really did make a huge mistake in Jacksonville (Ark.). They made a complete bloody mess of it,” says Connett. “It has become clear that the people who had their dioxin levels measured in their blood before this thing went online have now got higher levels in their blood. So it’s a failure.”
Connett is referring to the Vertac dioxin incinerator in Jacksonville, Ark., which has repeatedly been cited for unsafe emissions. In spite of its dubious safety record, the 8th U.S. Circuit Court of Appeals in St. Louis has rebuffed attempts to shut down the Vertac incinerator, ruling that the federal courts have no jurisdiction over Superfund sites until after the EPA completes a cleanup. The Agency for Toxic Substance and Disease Registry (ATSDR) in Atlanta referred questions on last year’s blood tests to the Arkansas Health Department. An epidemiologist for the state agency told the Riverfront Times that the test results were still unavailable. The long delay in releasing the test data has led some environmentalists to speculate that dioxin blood levels have risen in the vicinity of the incinerator.
“We know from all the other technological experiences in our lives that things don’t always go the way they’re supposed to,” says Kriebel, the epidemiologist from the University of Massachusetts. “If the thing breaks down, the logical consequence of that is contaminating the air with dioxins.” says Kriebel. “It probably can under ideal operating conditions be made to do what the engineers think it should do.” (But) I’m just not convinced that we know how to monitor those things well enough over the long run that we really ought to trust what they’re ideal specifications say that they are doing.”
After being left untended for more than two decades, the EPA remains possessed with a burning desire to dispose of Eastern Missouri’s dioxin contaminated soils by fire. An alternative technology, base-catalyzed decomposition (BCD), which the agency approved for another Superfund cleanup, has been rejected by the agency for use at Times Beach.
“BCD is a very promising technology, but our agency got together and evaluated it and determined that you could not use the Koppers demonstration in North Carolina as an indication one way or another whether or not the process would be effective for dioxin,” Feild says.
The EPA’s current position on BCD technology has been altered, however.
In an internal memo from last summer, Timothy Oppelt, the director of the EPA’s Risk Reduction Engineering Laboratory in Cincinnati, wrote that “we believe given the characteristics of the soils at Times Beach, the BCD process will be able to remediate site soils … the only exception are plastics and rubber materials that have a tendency to clog (the) thermal desorption chamber and will require incineration.” According to the risk assessment, less than five percent of the contaminated materials at the 27 dioxin sites in Eastern Missouri are comprised of anything other than soil. Inexplicably, Oppelt later reversed his decision and recommended against the use of BCD at Times Beach.
The Meramec River forms an oxbow from which the town of Crescent most likely takes its name. On the opposite bank, towering limestone palisades have been sculpted over eons by the spring-fed waters that push this Ozark landscape to within 20 miles of St. Louis.
There are few signs of change here — nothing to suggest that the biochemistry of the area may soon be altered — no indication the surrounding land has been sectored into 625 quadrants by the EPA as a part of its Times Beach risk assessment.
Inside one of those invisible boxes Ann Chase recalls the past as she struggles to come to terms with her future.
“I have lived here in this house for four years, but my family has lived in this community since 1939,” says Chase, a history teacher at Lindbergh High School. Chase would like to raise her own family here, but shadows of doubt are forming just outside her window. The Times Beach risk assessment asserts that the public faces no danger of reproductive health problems from the potential emissions from the planned incinerator, but Chase is not so sure.
“We’re probably the closest house to where the incinerator will be, says Chase. “I have two young children and I’m expecting a third in early summer.” The 32-year-old pregnant mother estimates that her home is between a quarter to half-a-mile from the Times Beach incinerator site.
Fetuses, infants and small children are the most susceptible to the health problems caused by dioxin. A dioxin-exposed mother passes the toxin to the child through the placenta during pregnancy and afterwards from breast feeding.
“It is a big concern to me, because I did nurse my other two children and I intend to nurse this one,” says Chase. Her concerns are heightened because she grew up near the contaminated Times Beach site and may already have more than an average amount of the chemical in her own body.
“It seems to me real foolish for the government to burn something toxic in a populated area,” she says.
The school teacher’s trepidations are echoed by others in the community, including Ann Benning Dollarhide, who owns a 300-acre farm nearby. Dollarhide and her husband have halted plans to purchase cattle because of the threat of incinerator emissions. Consumption of beef and dairy products is one of the primary ways dioxin is ingested by humans. “We are very apprehensive about starting our operation up again, if this incinerator goes in, because of the food chain,” says Dollarhide. “How could we feel good about selling cattle to other people that graze on land that could be tainted with dioxin?”
Compared to Chase, Mary Derrick, is a newcomer to the Crescent area. The registered nurse at St. Luke’s Hospital has lived here for a little over a year. Her family’s home is located about a mile-and-a-half away from the incinerator site.
Prior to relocating, Derrick says her husband had a chance encounter with an EPA official at a restaurant. According to Derrick, the official gave assurances the community was in no danger, she says.
The Derricks liked that idea. They had read articles in the press that parroted the same line. It made them feel more secure about moving to the Eureka area. But since learning more about the subject, Derrick has changed her mind.
Lately, the nurse has been doing some homework on dioxin with her youngest daughter, who is in eighth grade. The history that the two have uncovered has alarmed them both.
After waste-oil hauler Russell Bliss sprayed a stable in Moscow Mills, Mo. in 1971, birds, cats, dogs and horses started dying in rapid succession. The stable owner’s children developed headaches and rashes. One of them began hemorrhaging severely and required hospitalization.
“They say that (our) arguments are all based on emotion,” says Derrick. Well, we wouldn’t be emotional if the facts didn’t lead us to be emotional. When you see those facts, there’s no way that you can deny that there is definitely some danger there. They’ll admit to you that it is one of most carcinogenic and toxic chemicals known to man, but we’re supposed to trust them that they’re going operate an incinerator in a safe manner.”
C.D. Stelzer (firstname.lastname@example.org)