Comments on EPA ‘s Proposed Plan Relating to Human Health and Supporting Documents

Editor’s note:  The hefty binder compiling weeks and months of commentary and criticism was submitted to the EPA by Shoshone County on February 26, 2002.  It included a lengthy introduction, which is posted below.  (Incidentally, the occasional typo in the original text has been corrected in this post.)  The introduction bore the following subtitle:

Technical comments prepared by Ron Roizen and submitted on behalf of the Shoshone County Commission and the Mayors of Wallace, Mullan, and Osburn, Idaho

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Title page of the binder submitted to EPA on /26/2002 — the Latin at the page’s bottom translates roughly as:  “You’ve [i.e., EPA] done a mountain of work, producing only a ridiculous mouse.”

1.     Introduction

We do not believe that the U.S. EPA has offered a compelling scientific demonstration that a human health problem exists in the Coeur d’Alene River Basin or in Shoshone County. Moreover, we believe that the EPA has violated or strained a number of key rules or standards of competent scientific and scholarly practice  in its attempt  to make the case that a human health problem indeed exists.  Our goal in the following commentary is to describe and document these violations and strains, which include:

  • exaggerating or inflating problem claims
  • selective bias in argumentation & literature citation — thus failing to offer a balanced picture of scientific issues and their associated literatures
  • avoiding scientific topics that would place the local scientific analysis in proper historical and national contexts
  • engaging in scare tactics rather than fully balanced scientific exposition
  • affording inadequate attention to past scientific criticisms and queries
  • failing to live up to EPA’s own standards of scientific adequacy
  • misrepresenting scientific data and literature — and, relatedly, offering persuasive, rather than disinterested, text on behalf of problem claims
  • offering as “established” or “settled” science propositions or claims that are in fact surrounded inadequately  founded  in either theoretical or empirical terms and surrounded in scientific controversy

These objections are directed up and down the chain of offices and agencies associated with the production of the so-called Human Health Risk Assessment (or HHRA) — from TerraGraphics, the chief scientific contractor for the production and revision of the HHRA, to the EPA’s Technical Review Work Group for Lead (TRW), which offered  its scientific blessing to the DRAFT HHRA.     Continue reading

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Why EPA Science Must Be Submitted to Disinterested Peer Review:

Editor’s note:  Below, a “Bill of Scientific Charges” submitted to Idaho Governor Dirk Kempthorne on Feb. 1, 2002.  Above, the segment of the submitted document’s title that followed the colon read as follows:  “A Bill of Scientific Charges relating to the Proposed Expansion of the Bunker Hill Superfund Site to the Coeur d’Alene Basin.”

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(PHOTO CREDIT:  Google Images)

Prepared for:  Governor Dirk Kempthorne

Prepared by:  Shoshone Natural Resources Coalition Science Committee

Date: February 1, 2002

A. Regarding human health: The EPA has not established a compelling scientific case for the key proposition that 5% or more of Basin children have blood-lead levels of  10+ micrograms  per deciliter (µg/dL).

  1. EPA employed an evolving and still unreliable computer simulation model (the Integrated Environmental Uptake Biokinetic or IEUBK model) to estimate Basin blood-lead levels.
  • Subsequent efforts by the SNRC Science Committee to point out and interpret such critical literature have been either ignored or paid lip service only.
  • Literature offering critical perspectives on the IEUBK and its performance has been ignored in the HHRA’s bibliography and analysis.
  • EPA has consistently eschewed the option of using a state-of-the-art epidemiological survey to establish whether the Basin does or does not exceed its blood-lead standard.

Continue reading

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Now we have TMDL rules by decree

Editor’s note:  Published February 23rd, 2002 in the Shoshone News-Press.


(PHOTO CREDIT:  Google Images)

Now that everyone has submitted their comments with respect to the illegal expansion of the Bunker Hill Superfund Box to most of the Coeur d’Alene Basin, it is time to consider the next threat to the economic well-being of the entire region.  That threat is posed by the TMDL rules being proposed.  The term “TMDL” means Total Maximum Daily Loads and refers to daily limits of dissolved metals, suspended solids and nutrients which are transported in the South Fork of the Coeur d’Alene River.

Apparently, both U.S. EPA and Idaho DEQ believe that limits to dissolved metals and solids can be controlled by decree.  Unfortunately, Mother Nature may not agree with TMDL rules being proposed.  Thomas Huxley, a 19th century scientist had a saying: “ The great tragedy of science:  the slaying of a beautiful hypothesis by an ugly fact.”

One might ask the common sense question: How did the valley form in which the South Fork flows?  It is a very simple yet important question, but a definitive answer is obvious.  The South Fork formed the valley itself by erosional processes.  One only has to remember the last significant flooding event in February 1996 to appreciate that the river has not given up its erosive tendencies.     Continue reading

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The Science Committee’s human health overview webpage for the NAS’s panel

Editor’s note:  As the National Academies study panel got going on the work of its study, we thought it would be a good idea to offer them some web pages that would provide guidance respecting our various arguments, publications, and sources.  Below, the web page on the subject of human health.  I don’t have an exact date for when this page was posted at our website, but it would have been (of course) soon after the NAS committee was formed and given its charge.  Links embedded in this piece will be dead and out of date as often as not.  I’ve left them in the text, however, as a spur to “reconnecting” them to their current web locations — perhaps something I can chip away at over the days and weeks ahead.


(PHOTO CREDIT:  Google Images)


Human health has been the hot-button issue in Shoshone County — for both the citizenry and the Science Committee.

EPA calls human health their “top priority” issue in the Basin.  But that designation has an ironic ring for us,  We believe the human health issue has been grossly magnified or manufactured altogether by EPA staff.  The measure of that “problem enhancement” on EPA’s part, we believe, is the shoddy scientific methodology that EPA has brought to the human health issue.

We do not, however, wish to recount the long story of all of our objections and disappoints regarding EPA human health science here.  Instead, our goal is to provide a convenient guide to documents that, we believe, belong in your NAS panel’s evaluation of EPA’s human health science.

To that end, then, this…

Regulatory Sources & Links

As Ron Roizen noted in his presentation to the panel on April 15, 2004, it is important that your group examine the EPA’s 1994 Directive (pdf download) and 1998 Directive (pdf download), which guide lead-related risk assessment at Superfund sites.  Incidentally, it did not miss our attention that the EPA’s 1994 Directive was published in the year following the publication of the Final Report of the Smuggler Mountain Technical Advisory Committee (which report is dated January 27, 1993).      Continue reading

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Fred Brackebusch offers Science Committee’s statement to the GTF

Editor’s note:  The Governor’s Task Force on Human Health met with the Science Committee down in Boise on July 25, 2001.  Fred Brackebusch took the lead and presented a summary of our group’s observations regarding the pitfalls and weaknesses in EPA science re the proposed Coeur d’Alene Basin Superfund site.

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(PHOTO CREDIT:  Google Images)


My name is Fred Brackebusch and I am a member of the Science Committee of the Shoshone Natural Resources Coalition.  On behalf of the other members of the Science Committee, who are here with me today, as well as the wider membership of the Shoshone Natural Resources Coalition, I extend my thanks for inviting us to present our concerns before this committee.

On April 12, 2001 the Science Committee had the honor to engage a panel of USEPA and IDEQ scientists and officials in a discussion of the draft Human Health Risk Assessment for the Coeur d=Alene Basin.  In this conference we lodged a series of key concerns regarding the HHRA’s data, analyses, word usage and logic.  Only recently, on July 13, 2001, we received an unsigned cover letter and a technical memorandum responding to those scientific concerns.  While we appreciate that DEQ took the time and trouble to prepare a response, we must say that the substance of the response does little to allay our concerns that the science described in the HHRA is uncompelling and substandard.

Before turning to the substance of our concerns and our reply to IDEQ’s response, however, some preliminary matters require attention.

First, the Cover Letter of the DEQ response implies that the Science Committee is asking for “scientific certainty, perfection, or irrefutable proof” as a standard.  We reject the notion that our disagreement with IDEQ and EPA science reflects an underlying misunderstanding about the imperfections of real-world environmental science and associated decision making.  We are concerned that certain aspects of the science are sufficiently faulty that the overall conclusions drawn from IDEQ/EPA science may be incorrect.  Thus, instead, we wish to apply a far less demanding standard than perfection, namely, that EPA/DEQ science meet minimum standards of contemporary scientific practice and credibility.      Continue reading

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Highlights of the Science Committee’s meeting with the Governor’s Task Force, July 25, 2001

Editor’s note:  As noted previously on this blog, almost the entire Science Committee made the trip down to Boise in July of 2001, after the Science Summit, to meet with the Governor’s Task Force on Human Health.  The meeting was one in a continuing series of efforts to find a responsive audience with respect to our criticisms of EPA science and that agency’s plans for the expanded Coeur d’Alene Basin Superfund site.  Fred Brackebusch wrote a summary of the meeting after we returned, which is offered below.


(PHOTO CREDIT:  Google Images)

The Science Committee of the Shoshone Natural Resource Coalition met with members of the Governor’s Task Force on Human Health in Boise, Idaho on 25 July 2001.

Task Force members present included:

Jack Riggs, Lt. Gov., Chairman 
Dick Shultz 
Orval Green 
Chuck Moss 
Jim Yost

Steve Allred, Director of DEQ attended as did other representatives of the State.  Three US EPA representatives were also present.

The Science Committee gave its presentation laying out concerns that minimum scientific standards are not being met with respect to human health and lead in the Coeur d’Alene Basin and decisions relating thereto, i.e. cleanup plans.  A copy of the presentation listing 14 points of concern is available from the Science Committee.

Not the least of those concerns are the following:

  • The use of the IEUBK model for lead risk has been put forth by the agencies as “settled science,” when in fact there is considerable controversy over the model in the scientific literature.
  • There has never been a random blood survey conducted in the Basin, and thus the percent of children with blood leads exceeding the 10 microgram per deciliter level of concern is not known.  Yet opportunistically collected blood lead data is utilized by the agencies as if they were representative and correct.
  • Bioavailability of lead minerals has not been studied in the Basin.  Different lead minerals have widely different bioavailabilities yet the agencies insist that “lead is lead” in comparing smelter dust to mineral processing tailings, despite the different mineralogies.

Continue reading

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An Open Letter to EPA Ombudsman Robert Martin

Editor’s note:  This letter, coauthored by Science Committee members, was published at the Science Committee’s web page but not in the local newspaper.  As this letter suggests, the Science Committee, early on, tried every avenue, bent every ear, tested every official it could find respecting EPA’s scientific missteps in that agency’s push for a greatly expanded Coeur d’Alene Basin Superfund site.

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(PHOTO CREDIT:  Zona Desconocida)

To:  Robert Martin
U.S. Environmental
Protection Agency

From: Science Committee
of the Shoshone Natural
Resources Coalition

April 27, 2001
Shoshone County, Idaho  

Dear Mr. Martin,
On behalf of the people of Shoshone County, Idaho, the Science Committee of the Shoshone Natural Resources Coalition begs to draw your attention to the following facts:

The EPA’s Progress Report for Cleanup in the Coeur d’Alene River Basin has just been published.   This document claims that human health represents the top priority in the EPA’s plan for environmental remediation of our area.  Childhood lead exposure is the main focus of this would-be remediation.

Yet, there is no credible nor uncontroverted scientific evidence that child lead poisoning is a problem in our area.

Local physicians do not see childhood lead poisoning cases.

A modern and fully equipped hospital in neighboring Kootenai County has no special programs, wards, nor physician training for child lead poisoning — and they have no caseload for lead as such.      Continue reading

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