Letter: Roizen to DEQ and Cd’A Tribe re LMP Addendum

Editor’s note:  I posted this letter to Ed Tullock, at the Idaho Department of Environmental Quality’s Coeur d’Alene Regional Office, and Philip Cernera, at the Coeur d’Alene Tribe, on January 24, 2003.

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(IMAGE CREDIT: Google Images)

COMMENT ON THE ADDENDUM TO THE LAKE MANAGEMENT PLAN

Dear Messrs. Tulloch and Cernera:

The introduction to the proposed draft Addendum to the Lake Management Plan (A-LMP) offers a series of five recent changes in the situation of Lake Coeur d’Alene and the Coeur d’Alene Basin that, in turn, are employed as wouldbe justifications for the need for the Addendum‘s creation.

The third of these five wouldbe justifications is titled ” Superfund Basin wide RI/FS” and begins with the following two sentences:

In 1996, a human health blood lead study was conducted by the State of Idaho.  This study indicated that a significant percent of children tested in the Basin, outside the current 21 square mile Bunker Hill Superfund site had elevated blood lead concentrations.

I will focus my comment almost exclusively  on these two sentences, referring to them  hereinafter as “the quotation.”     Continue reading

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Ron Roizen’s presentation to the NAS panel in Wallace

Editor’s note:  This presentation’s full title was, “A Critical Examination of the Main-Line Argument of the Coeur d’Alene Basin HHRA: Presentation to the National Academy of Sciences Panel.”  It was read to the panel, at the memorial gym of Wallace’s old high school, as part of the SNRC Science Committee’s offerings on April 15, 2004.

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Michael Faraday, Christmas Lecture (IMAGE CREDIT:  Google Images)

I.  Introduction

My name is Ron Roizen and my presentation focuses on the human health aspect of EPA’s science in the Coeur d’Alene Basin.

Human health is the subject of the Human Health Risk Assessment or HHRA.

This is it. As a document, it is a beautiful piece of work — its maps, charts, and tables are beautifully constructed.

So impressive is its artistry that it may be hard to believe that its contents could be deeply flawed.

My goal today is offer some of the reasons why we are so critical and so unhappy with this document. To do this most efficiently, I will focus on the “main line” of the HHRA’s argument and analysis only.

Incidentally, nearly all of that main argument is available in Section 6 of the HHRA.

What did the HHRA try to accomplish? How did it make the attempt? How well did it do?

II. Excluding the Basin or Parts Thereof from the Superfund Site

Before turning to those questions, I’d like to consider one goal the HHRA did not try to accomplish.      Continue reading

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Basin hearing may determine valley’s future

Editor’s note:  Published May 18, 2002 in the Shoshone News-Press.

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Ship of Fools (IMAGE CREDIT:  pinterest via Google Images)

An important public meeting is scheduled for this coming Monday, May 20, 7 p.m. in Kellogg at the Idaho Dept. of Health and Welfare (35 Wildcat Way, Suite B).

The need for this hastily arranged meeting arose at the first meeting of the new “New Basin Commission” (“NBC,” whose formal name is the Basin Environmental Improvement Project Commission), held on the afternoon of May 3 at the ranger station in Silverton.  The NBC is comprised of one representative from the state of Idaho, the federal government, the Cd’A Tribe, the state of Washington and (one each) Shoshone, Kootenai and Benewah counties.

At this May 3 meeting, Steve Allred – director of the Idaho Department of Environmental Quality (DEQ) and the NBC commissioner representing the state of Idaho – presented a draft proposal to the NBC.  This document offered a variety of potential cleanup-related projects that the NBC might, in turn, submit to EPA in order to secure some $2 million in funding that EPA has made available as start-up monies for the NBC.  Mr. Allred’s draft proposal offered brief narratives descriptions of a half-dozen cleanup projects or expenditures.     Continue reading

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Combining 2001’s blood lead data

Editor’s note:  This, another internal memo I wrote for the county commissioners, dated November 15, 2001.  Its full title was:  “Combining Panhandle Health District’s and the Spring Health Fair’s blood lead data on children in 2001.”  It was also labeled as “Technical Advisor Note — N3.”

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(IMAGE CREDIT:  Google Images)

  1. The Idaho state Board of Health and Welfare (BH&W) recently announced that it opposes the EPA’s expansion of “The Box” and supports instead a program of year-round monitoring of blood-lead levels for the Basin (see SHOSHONE NEWS-PRESS, 11/11/2001, p. A6).
  2. The board’s mention of year-round monitoring may derive from comments taken at a recent Shoshone Natural Resources Coalition luncheon attended by three BH&W members . At said luncheon Mr. Robin Stanley noted that PHD blood samplings were always taken in mid-summer, the dustiest time of the year, probably in order that blood-lead measures be maximized — thus implicitly misrepresenting the Silver Valley’s true blood-lead situation.
  3. In light of the BH&W’s new stress on year-round blood-lead monitoring, it is interesting to assess the impact of combining two recent blood-lead surveys on apparent blood-lead exceedance rates in our area — that is, (a) PHD’s summer survey and (b) a spring survey conducted in a Bealth Fair sponsored by the Mullan and Wallace School Districts in April, 2001.    Continue reading
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Summary of EPA survey’s performance-evaluating questions

Editor’s note:  This piece was a memo I prepared for the county commissioners in my then-capacity as technical consultant respecting EPA matters.  It was dated October 25, 2001.

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(PHOTO CREDIT:  Google Images)

The EPA conducted a public opinion survey in the Coeur d’Alene River Basin this past summer. It was a postal (or mail-out) survey involving two subsamples: (a) all members of the EPA’s mailing lists in the region (the returned sample, N=334); (b) a so-called “random” sample of the general population, which sample was drawn from a database of community addresses (returned sample, N=142).  Additionally, a small number of citizens who were not sent questionnaires by the EPA nevertheless obtained and returned completed  forms (returned  sample, N=17).

By most standards, the scientific quality of the survey must be regarded as quite poor: the brief questionnaire harbored a number of design weaknesses, the response rate was too low to allow for confident population projections , and the sampling universe was ill­-defined. Hence, any analysis of this survey must be regarded with caution.     Continue reading

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City of Wallace’s Resolution Regarding the EPA’s Proposed Plan

Editor’s note:  The City of Wallace passed a resolution on February 12, 2002 calling for a one-year moratorium on the implementation of the EPA’s Proposed Plan.

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City of Wallace, Idaho (PHOTO CREDIT: Google Images)

RESOLUTION #2002-145

  1. Whereas “community acceptance” provides a key element in the EPA’s evaluation of its own Proposed Plan (PP, Table 7-1, p.7-1) for the Coeur d’Alene Basin, including this community;
  2. whereas this democratically elected City Council represents the interests of the citizens of this community;
  3. whereas key elements of the proposed clean-up — for example the site or sites of proposed repositories — have not been identified in the Proposed Plan, thus withholding important concerns from our community and its citizens;
  4. whereas a human health problem has not been compeIIing nor uncontrovertedly demonstrated in our community;
  5. whereas the Shoshone Natural Resources Coalition’s (SNRC) resolution of April 12, 2001 called for a moratorium on human-health-related clean-up activity unless and until “the human health issue can be either demonstrated or disconfirmed by adequate scientific evidence”;     Continue reading
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An open letter to DEQ and EPA

Editor’s note:  This item, below, is something of an historical footnote and afterthought with respect to the other posts offered at this blog.  It was written in December, 2009 — that is, four years or so after the publication of the NAS report.  My letter was also published in the Shoshone News-Press, I think on December 30th too, but I’m not certain of the exact date.

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(PHOTO CREDIT:  Google Images)

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Dear Mr. Peterson,

I received your letter dated December 15th, with its request that I either invite DEQ to test my yard or explain why I decline testing.

My answer is that I decline testing.

I have two reasons: 

(1) The first reason is bad science.  I believe that my yard is not a threat to public health and I believe that the science behind the claim that it is a threat is faulty and uncompelling.

(2) The second reason is to protect the voluntary character of the cleanup.  I wish to join with others who, by rejecting DEQ’s requests, are in turn testing the proposition that participation in the yard remediation program in the expanded Coeur d’Alene Basin Superfund site is indeed entirely voluntary and will remain so in the future.

Let me discuss each of these reasons briefly.      Continue reading

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