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”;    
  6. whereas appropriate and mandated site-specific investigation of soil lead speciation and animal model bioavailability have not been carried out for the Coeur d’Alene Basin — despite EPA policy’s requirement of site-specific investigation and despite the fact that this would have become the largest Superfund site in the history of EPA;
  7. whereas SNRC’s Science Committee has been actively seeking an outside, disinterested, and thorough peer review of EPA science,particularly relating to the human health issue;
  8. whereas language in the Proposed Plan retains to EPA the option of relocation — and possibly involuntary relocation — of residences;
  9. whereas the economic and social impacts of Superfund designation would impose a great hardship on this community and its future prospects;
  10. whereas the Proposed Plan offers no guarantees that monies for the proposed actions inside this community will be either forthcoming or adequate;
  11. whereas the Proposed Plan focuses on blood-lead risk in children 1-6 years old, and Wallace contributed a total of only 43 blood-lead level “observations” over the four survey years, 1996-1999, inclusive (HHHR, Table 6-6a);
  12. whereas overall (i.e., in the CDA Basin sampling as a whole) roughly one-third of all blood-lead “observations” collected  in the blood lead surveys of 1996-1999 were contributed by multiply-participating  children;
  13. whereas the application of this proportion to Wallace survey participants would reduce the number of unduplicated children to roughly 29 -a number too small to support generalizations;
  14. whereas these blood-lead surveys were not conducted in a probabilistic manner;
  15. whereas the number and sampling of dwellings in WalIace was inadequate to the task of determining that 39% of residences require remediation to  1000 ppm  lead (PP, Table 3-1, 3-5);
  16. whereas site-specific lead speciation and bioavailability studies have not been conducted in Wallace;
  17. whereas the problem of creating differential land values and resale prospects through the application of the 1,000 ppm standard has not been addressed in the Proposed Plan;
  18. whereas unnecessary yard remediation activities threaten to increase dust and stress streets, sidewalks, and the community environment;
  19. whereas a large water treatment facility at the mouth of Canyon Creek (a) has not been fully nor adequately described, (b) cannot be feasibly installed at that site, and (c) would disrupt the historical integrity of Wallace — which city as a whole is one of very few on the U.S. National Register of Historical Places;
  20. whereas inadequate specificity attends the description and planned approaches to erosion and drainage issues in Wallace;
  21. whereas the Proposed Plan as a whole offers no specific plan — i.e. does not offer sufficient detail for the making of sound assessments by Wallace and its citizens;

Therefore, be  it resolved that:

this City Council and the City and citizens that it represents call upon the EPA to declare a one-year moratorium on the Proposed Plan such that further review of the science may be carried out and further articulation of proposed clean-up elements may be provided.

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