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A project of People’s Action Institute

February 14, 2018

Re: Comments on the Health Consultation Public Comment Version
Keystone Sanitary Landfill, Dunmore, Lackawanna County, Pennsylvania
Prepared by the Pennsylvania Department of Health
December 14, 2017

Comments Submitted by Stephen Lester, Science Director
Center for Health, Environment & Justice
Falls Church, VA

Submitted via email to Env.health.concern@pa.gov

These comments are submitted on behalf of the Center for Health, Environment & Justice a
project of People’s Action Institute on the ATSDR’s Health Consultation Public Comment
Version, Keystone Sanitary Landfill, Dunmore, Lackawanna County, Pennsylvania, released on
December 14, 2017. CHEJ, based in Falls Church, VA, was founded in 1981 by Lois Gibbs, the
community leader from the Love Canal neighborhood in Niagara Falls, NY. We provide
organizing and technical assistance to grassroots community groups nationwide.

The Center for Health, Environment & Justice (CHEJ) has been providing technical and
organizing support to the grassroots community-based group Friends of Lackawanna (FOL) and
to the residents of the Dunmore/Throop area since 2015. We have closely followed activities
related to operations of the Keystone Landfill including providing technical assistance to Friends
of Lackawanna on air emissions, surface water contamination and general environmental
testing data that have been collected to evaluate the risks that the landfill poses to people
living in and around Dunmore and Throop. In particular, I have reviewed the air tests that were
conducted by the Pennsylvania Department of Environmental Protection (PA DEP) in April and
June of 2015. This relationship led to this review of the Health Consultation Public Comment
Version, Keystone Sanitary Landfill, Dunmore, Lackawanna County, PA.

The Agency for Toxic Substances and Disease Registry (ATSDR) Health Consultation report was
prepared in response to a request from a Pennsylvania state representative as well as from
community members “to conduct an environmental health study and evaluate air quality
around the landfill (ATSDR Report, p.7). According to ATSDR, this health consultation “is
principally focused on our public health evaluation of PADEP’s 2016 ambient air sample results
(ATSDR Report, p. 8). In addition, ATSDR also evaluated “available data on particulate matter in
ambient air in the area, subsurface investigation, as well as rates of cancer in the community”
(ATSDR Report, p. 8).

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8). 20 reduced sulfur compounds. ammonia. This sampling system collected an instantaneous measurement of contaminants that are present in air at the time of the sampling. As a result. I am also concerned that ATSDR failed to conduct an analysis of the cumulative risks the residents living near the landfill face and how the use of limited environmental and health data impacts its analysis and evaluation of the public health risks posed by the Keystone Landfill. Although the PA DEP had collected previous air samples. methylamine. On each of the sampling dates. 1) ATSDR’s public health evaluation including its analysis and conclusions are based on limited environmental data collected by the PA DEP. These samples were collected using an Open Path Fourier Transform Infrared (OPFTIR) spectrometer system as part of PA DEP’s Mobile Analytical Unit (MAU) (ATSDR Report. This data was collected from ambient air samples using summa canisters and sorbent tubes from January to April 2016 at two community monitoring stations (Mid Valley High School and Sherwood Park) and at one location near the landfill (ATSDR Report. p. These and other concerns are discussed below. two samples were collected from the Keystone Landfill property and four samples were collected from different public locations in the community outside the landfill property. methanol. 8). In addition. 26). The previous air sampling conducted by PA DEP occurred in April and June 2015 and in March 2016 (ATSDR Report. I have had the opportunity to review many of ATSDR’s Health Assessment and Health Consultation reports. p. The samples were analyzed for 75 volatile organic compounds (VOCs). the data collected using the summa cannisters was the only data that ATSDR relied upon in making its conclusions and recommendations in the health consultation report. Unfortunately. p. The samples were collected over a 24-hour period every three days during the sampling period. that data was not evaluated by ATSDR in its public health consultation report because of problems with the methods used to collect the samples (ATSDR Report. Thus. This testing is limited by the short sampling period (three months) which does not represent the full range of exposures that might occur throughout a full year (ATSDR Report. 9). 3 carbonyl/aldehyde compounds. p. 8).In my capacity as science director at CHEJ for more than 30 years. The most significant of these flaws is the reliance on limited available environmental and health data to draw conclusions and recommendations. the only data that ATSDR considered in its public health evaluation resulted from two ambient air samples collected intermittently over a 3-month period and analyzed for a limited number of substances based on the earlier testing. p. 8). this report suffers from many of the same fundamental flaws and limitations that I have seen in similar documents that greatly limit the evaluation and assessment of public health risks considered by the agency. only having two community and one landfill sample clearly limits the understanding of the potential air emissions coming from the Keystone Landfill and its impact on the residents living nearby. and trimethylamine (ATSDR Report. This is 2 . p. ATSDR’s public health evaluation including its analysis and conclusions are based on limited environmental data collected by the Pennsylvania Department of Environmental Protection (ATSDR Report. p. 9).

22). For example. Because of this inherent flaw in the testing method. Most ambient air testing is collected over periods of time such as 60 minutes. p. if not trust. 25-26). This means more than simply acknowledging that the available data was limited and then drawing conclusions as though this data was adequate to do so. the first conclusion reached by ATSDR is that “chronic (long-term) exposure to the chemicals detected in ambient air near the landfill at the monitored locations is not expected to cause cancer or harmful non-cancer health effects under the landfill’s current operating condition” (ATSDR Report. 8). 4 hours. It means providing a balanced discussion of how the limited data impacts the analysis and evaluation of the public health risks posed by the landfill. These data “were not evaluated for further assessment” by ATSDR (ATSDR Report. This testing only measures chemicals present at the precise instantaneous moment that the sample is collected. p. 2) ATSDR failed to analyze how using only existing available data impacts its analysis and evaluation of the public health risks posed by the Keystone Landfill. 12 hours or 24 hours. when and for what substances) would have provided more meaningful data. The agency fails to discuss or even acknowledge how the limited testing impacts its analysis and evaluation of the public health risks posed by the Keystone Landfill. While ATSDR does acknowledge the limitations of the available data that was collected by the PA DEP (see ATSDR Report. The residents invited ATSDR to come to Dunmore because there was hope. ATSDR put it this way: “This method has limited utility for public health assessment because of its high detection limits and because the instantaneous readings cannot be converted into appropriate exposure values for evaluation of potential health effects” (ATSDR Report. they nonetheless drew conclusions and made recommendations based on this very limited testing. the data that was generated has limited value for assessing public health risks. A summary of this data is however included in ATSDR’s health consultation report (see Appendix C). The agency based this conclusion on the limited data that was 3 . The agency also failed to provide any recommendations on the need for and value of additional testing.literally a moment in time “snapshot” of the potential chemicals present in the air. pp. Recommendations along this line would have been a valued contribution to the public understanding of the testing that was done. It would have been very helpful to the residents to have had the benefit of an analysis that discusses how the limited testing may underestimate or even overestimate the true daily exposures that may be occurring in the vicinity of the landfill. This is an enormous disservice to the residents of Dunmore and Troop and to the public in general. 8). Data collected this way cannot reflect what the residents living around the landfill might be exposed to over a 24-hour period or even longer. They would have benefited from a discussion of what testing (where. p. that the agency would conduct a fair and honest analysis and evaluation of the public health risks posed by the Keystone Landfill.

Unfortunately. Each of these substances was evaluated against a single comparison value to determine if it exceeded that guideline or not. Many substances were found in the samples collected from the community locations and from the locations near the landfill.collected by PA DEP. ATSDR used various comparison values including its own – Cancer Risk Evaluation Guides (CREGs) and Minimal Risk Levels (MRLs). an opinion on what the future health risks might be. It is certainly not a hard conclusion of what the true risks might be. this health consultation fails to consider concurrent multiple routes of exposure and in fact. values generated by the National Oceanic and Atmospheric Administration (NOAA). why certain comparison values were chosen. 4 . of whether this data is adequate and sufficient to evaluate the long-term/chronic public health risks posed by the landfill. explosion or fire at the landfill. Perhaps the greatest flaw in this health evaluation is ATSDR’s failure to consider the cumulative risks of living near the Keystone Landfill. this is an educated guess. there is no guarantee that the current operating conditions reflect the norm or even the average state of the operating conditions that occur at the landfill. does not even mention it. air exposures were the only route of exposure considered in this assessment. 3) ATSDR failed to consider cumulative risks in its health evaluation. why did ATSDR use values developed by the Texas Commission on Environmental Quality (TCEQ) and the California Air Resources Board (CARB)? The agency should have included some discussion of why these comparison values were used and not values generated by other states. however. but that is not the case. This approach would have been fine if the public was exposed to a single substance or to only a handful of substances. People are exposed to all of the chemicals coming from the landfill for varying periods of time from all routes of exposure. How can a single sampling event intermittently collected over a 3-month period at only two locations in the community and analyzed for a limited number of substances be sufficient to draw conclusions about the long-term public health risks posed by the landfill? At best. This is especially true given the qualifier in the conclusion “…under the landfill’s current operating conditions. They had to use so many comparison values because no one set of values matched the many substances found in the ambient air. There is no discussion. It is not clear however. especially without more in-depth discussion. several state values (TX and CA) and different odor threshold values to evaluate the public health risks posed by the substances found during the air sampling (see Appendix C). For example. Numerous substances were found in the ambient air around the landfill (see Appendix C). It certainly does not reflect any worst-case scenarios that might occur such as an accident.” Clearly. Cumulative exposure is a measure of how the public is exposed in the real world. These values should not have been used. Furthermore. EPA ambient air quality guidelines and Reference Concentrations (RfC). In addition several of the values that were used (NIOSH RELs and ACGIH values) are intended to protect workers and are not appropriate comparison values for community settings. This is also a huge disservice to the people of Dunmore and Throop who have asked ATSDR to evaluate the public health risks posed by living near the Keystone Landfill. 4) ATSDR used limited comparison values to evaluate the air sampling data.

An option that the agency should consider is the air guidance values developed by the state of Massachusetts Department of Environmental Protection called Threshold Effects Exposure Limits (TELs). At a minimum. there are large variations in exposure between those people in the zip code who live extremely close to the landfill and those in the zip code who do not. ATSDR greatly reduces a critical element in any health assessment and that is to identify the people who have been exposed to chemicals from the landfill. Overall. It is not surprising.acetaldehyde. by far the highest concentrations of contaminants outside of the landfill property were found at the Sherwood Park location. This a very blunt and insensitive measure of exposure and does little if anything to answer the question of whether chemicals from the landfill are affecting the health of the residents who live near the landfill. six of which exceeded the Massachusetts DEP TEL values . naphthalene and triethylamine. Whether someone lives within a block or two of the landfill or whether they live at the farthest point in the zip code from the landfill. in this case. cancer. the results of the PA DEP air testing conducted at Sherwood Park identified 14 different substances. ATSDR should have included a discussion of the limitations of this analysis.html). But by using this exposure metric. Using these values provides another perspective and understanding of the potential health risks posed by the substances found in the air of the community. This is a standard analysis that has very little meaning or value in answering the question of whether chemicals from the Keystone Landfill regardless of what exposure pathway taken is affecting the health of the residents who live near the landfill. including sensitive populations such as children. In fact.gov/eea/agencies/massdep/toxics/sources/air-guideline-values. carbon disulfide. 5) The cancer data that was evaluated was limited to only considering data by zip code. These TEL values “are used to evaluate potential human health risks from exposures to chemicals in air. For example. ATSDR evaluated cancer incidence by using available data organized by zip code areas. These guidelines are set at concentrations intended to protect the general population. in April 2015. naphthalene and triethylamine.mass. everyone is considered equally exposed. These findings are significant since many of these substances are toxic and hazardous substances. m-xylene. benzene. A zip code area is a broad surrogate for exposure that defines everyone who lives in the zip code as being equally exposed. The assumption made by ATSDR when it chose to use zip codes as a surrogate for exposure is that people who live in zip code areas closest to the landfill would have greater exposure to chemicals associated with the operation of the landfill and thus be at greater risk of developing adverse health problems. benzene. from adverse health effects over a lifetime of continuous exposure” (see http://www. 5 . The following chemicals were either only found at the Sherwood Park location or were found at the highest concentrations: acetaldehyde. This approach greatly reduces the likelihood that this analysis would identify any relationship between the landfill and health outcomes. but very disappointing that ATSDR would choose to use such an insensitive and largely irrelevant measure to evaluate the health risks posed by the landfill. methanol. ethylene.

. Benzene and formaldehyde. 23).. It is not intended for initial site assessment. 22). This is a significant health risk that ATSDR has rightly included in its assessment. They also point out that changes in the operation of the landfill could impact future subsurface vapor migration pathways. This is a common exposure pathway and public health risk for people living or working in buildings located near landfills. such as pregnant women. The recommendation made by ATSDR to address this data gap is extremely weak. were detected above ATSDR’s Cancer Risk Evaluation Guides (CREGs) but within EPA’s target risk range . then more testing is required. This risk range is intended to be used when evaluating risks at federal Superfund sites. The secondary risk is the infiltration of volatile organic chemicals that travel in the gas from the landfill into the nearby homes. p. This is the situation at Dunmore. 12). 7) Despite limitations in the data available to ATDSR. the agency still found that some of the contaminants detected in ambient air near the landfill could have caused transitory adverse health effects for members of the community. What they found was that a “data gap exists for assessing current and future exposures from subsurface vapor migration from the landfill into residences” (ATSDR Report. p. ATSDR does conclude that “acute (short-term) exposure to some of the contaminants detected in ambient air near the landfill could have caused transitory health effects for sensitive populations. The broader risk range should not be used to dismiss the levels found in the ambient air in the community. older adults and people with respiratory disease” (ATSDR Report. 6) ATSDR found that there is insufficient data to evaluate the current and future potential exposures and subsequent health risks due to the migration of chemical vapors from the landfill.” (ATSDR Report. Vapor intrusion is the movement of volatile chemicals from a source such as the landfill through soil and into the basement of buildings such as homes located near the landfill. a process known as vapor intrusion. It simply suggests that the PA DEP “consider working with the landfill to perform vapor intrusion investigations in the Swinick community…” (ATSDR Report. 6 . If this level is exceeded. Usually an acceptable risk level of one-in- one million is used as trigger or red flag during initial testing and site assessment. The EPA target risk ranges from a low risk of one-in-one million (1E-6) to a high risk of one in 10. 27). Despite many limitations. primarily for establishing cleanup levels. p. The agency’s recommendation to investigate the vapor intrusion pathway from the Keystone Landfill should have been directed to the PA DEP requiring additional testing by the PA DEP not the landfill operator who has no incentive to determine the extent of vapor intrusion occurring from its landfill. Testing for vapor intrusion in nearby homes and along pathways between the landfill and nearby homes should be done by the PA DEP not the landfill operator. Their credibility in conducting such testing properly and in a fair and objective manner would be extremely low. both known human carcinogens.000 (1E-4). The primary concern is the potential for homes to explode due to the buildup of methane gas migrating from the landfill. p. children.

Lackawanna County.In addition. There is no discussion of whether these objectives were discussed with representatives of the community including Friends of Lackawanna. It is unclear how the ATSDR determined what the main objectives of the health consultation would be. p. 7 . It likely represents the tip of the iceberg and an underestimate of the everyday exposures from the landfill. This is critically important because these objectives drive the analysis and conclusions reached by the agency.methylamine. 1). 8) ATSDR defined its objectives for the health consultation without consulting with community leaders.exceeded various odor thresholds which can result in acute adverse health effects (ATSDR Report. and 3) to address concerns about cancer rates in the community by summarizing the most recent cancer incidence data for the population living near the landfill (ATSDR Report. acetaldehyde and hydrogen sulfide . 3) ATSDR should discuss how additional testing data would impact the analysis and evaluation of the public health risks posed by the Keystone Landfill. The following suggestions are offered to ATSDR to improve its Health Consultation report for the Keystone Landfill in Dunmore. 2) ATSDR should conduct an analysis of how using only existing available environmental data impacts its analysis and evaluation of the public health risks posed by the Keystone Landfill. 23). Pennsylvania. there were peak short-term (daily or 24 hour) PM2. There is no point in conducting this health consultation if it cannot answer the questions the community has about the public health risks posed by the landfill. p. ATSDR defines the main objectives of the health consultation as: 1) to determine if exposure to contaminants in ambient air surrounding the landfill poses a public health risk to the community near the landfill under the landfill’s current operating conditions. p. 2) to evaluate available environmental information for other potential community exposure pathways of concern related to the landfill. It also speaks to the transitory nature of air emissions and to the limited picture of potential air emissions provided by air testing.5 exposure concentrations that could have harmed people’s health (in every month measured for the daily average) (ATSDR Report. Ammonia exceeded the ATSDR comparison value at the Mid Valley High School and other substances . There is no discussion of whether these objectives are consistent with answering the questions the community has about the public health risks posed by the Keystone Landfill. 23). 1) ATSDR should address whether the available ambient air samples are adequate and sufficient to properly evaluate and assess the public health risks posed by the Keystone Landfill. These findings are consistent with testing conducted by the PA DEP in March and April 2015.

Testing for vapor intrusion in nearby homes and along pathways from the landfill to nearby homes should be done by the PA DEP not the landfill operator who has a clear bias. The agency should also include a balanced discussion when sampling data such as the results for benzene and formaldehyde exceed one comparison value (CREGs) but not another (the EPA target risk range). 7) ATSDR should include a discussion of the limitations of evaluating the cancer data by using zip codes as a surrogate for exposure.4) ATSDR should include an analysis of cumulative risks in its evaluation of the public health risks posed by the Keystone Landfill. 8 . 6) ATSDR should expand its use of comparison values to evaluate the air sampling data to include values such as the state of Massachusetts Department of Environmental Protection Threshold Effects Exposure Limits (TELs). 5) ATSDR should provide its reasons for choosing the comparison values that it used including selected state values. 8) ATSDR should direct the PA DEP to conduct additional testing to determine the extent of vapor intrusion occurring from the Keystone Landfill. 9) In the future. ATSDR should always define its objectives for a Health Consultation in consultation with community leaders.

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