Re: Info request: lead cleanup

[Laura Olah <olah@speagle.com>]

[NOTE: LAURA'S RESPONSE IS IN ALL CAPS.]

Bergeisen, Gershon H. wrote:

> Why do you want to clean up soil that is already below 400 ppm? 
Background
> soil lead levels are over 500 ppm in over 90% of the US. 

BRIEFLY:
-- COMPLIANCE WITH THE STATE AND EPA-APPROVED RCRA REMEDIAL GOALS FOR
THE SITE
-- BACKGROUND LEVELS AT THIS SITE AND IN FACTCOUNTY-WIDE ARE 30 PPM
-- PROTECTION OF ECOLOGICAL RECEPTORS -- ECOTOX NUMBER RECOMMENDED BY
USEPA REGION V IS 30 PPM
-- THE U.S. ARMY HAS A RESPONSIBILITY TO CLEANUP TO THE EXTENT
PRACTICABLE -- THEY HAVE PROVIDED NO EVIDENCE THAT MEETING THE CLEANUP
-- MULTIPLE CONTAMINANTS/ADDITIVE EFFECT NOT FACTORED IN ESTABLISHED
REMEDIAL GOALS, REEMPHASIZING THE NEED TO AT LEAST MAINTAIN THESE
NUMBERS
-- LOW-LEVEL LEAD EXPOSURE AND CHILDREN'S COGNITIVE FUNCTION; RECENT
STUDIES INDICATE ACCEPTABLE LEVELS ARE MUCH LOWER THAN FORMERLY THOUGHT

EVEN IF THE STATISTICS YOU SITE WERE CORRECT, THE ARGUMENT THAT 90% OF SOILS
IN THE U.S. HAVE UNSAFE, ELEVATED LEVELS OF LEAD AND CONSEQUENTLY REMEDIAL
GOALS FOR LEAD FOR THE REMAINING 10% SHOULD BE DRIVEN UPWARDS TO EQUALLY
POLLUTED LEVELS IS A FALSE ARGUMENT. THE LEAD LEVELS HERE BEFORE THE
MILITARY WERE 30 PPM. SOIL LEAD LEVELS ARE 30 PPM COUNTY-WIDE. THE HIGHEST
'BACKGROUND' LEAD LEVELS IN THE ENTIRE STATE ARE 100 PPM AND FOUND IN A LEAD
MINING AREA, SO THIS NUMBER IS SOMEWHAT COMPROMISED. 

>The only cost effective way to clean up soil lead is to remove the soil
>and replace it with clean soil. But where will you get the clean soil
>that had a lead content of less than 500 ppm?

THIS ARGUMENT IS AGAIN FALSE. YOU HAVE ONLY ASSESSED THE COST IN TERMS OF
IMMEDIATE DOD CLEANUP DOLLARS. WHAT DOLLAR VALUE DO WE PLACE ON HUMAN
HEALTH, ON CLEAN SOIL, ON OUR CHILDREN, ON CLEAN DRINKING WATER, AND CLEAN
AIR? IS THERE NO VALUE IN THESE? IS THERE NOT A FINANCIAL COST TO US AS A
SOCIETY? ANY REALTOR, TEACHER, HEALTH CARE PROFESSIONAL, OR PARENT CAN TELL
YOU SUCH THINGS DO HAVE GREAT VALUE, AND YES, EVEN A DOLLAR VALUE. 

> take a look at the Three Cities Study conducted by Johns Hopkins, UNC and
> Harvard that showed that for every reduction in soil lead of 1000 ppm, you
> reduce blood lead in a child by 1 microgram/L, assuming that the child eats
> 100 gm of soil a day for 30 years. Do you have studies to show the benefits
> of reducing soil lead from 150 to 30?

EVERY DAY WE LEARN MORE AND MORE ABOUT THE DAMAGE ENVIRONMENTAL TOXINS HAVE
ON HUMAN HEALTH. WHEN I FIRST STARTED THIS WORK, THE DRINKING WATER STANDARD
FOR LEAD WAS 50 PPB, NOW IT IS 15 PPB. WILL IT GO DOWN AGAIN? ENDOCRINE
DISRUPTORS ARE ANOTHER READY EXAMPLE OF A DANGER PREVIOUSLY UNKNOWN. 

THERE IS ALSO THE GREATER, OVERRIDING ARGUMENT THAT SOMEWHERE AND AT SOME
POINT WE MUST HOLD CHEMICAL INDUSTRY, INCLUDING THE U.S. MILITARY,
ACCOUNTABLE FOR THE ENVIRONMENTAL DAMAGE THEY HAVE CAUSED. ALLOWING AND EVEN
PROMOTING SUBSTANDARD CLEANUPS SENDS A CLEAR MESSAGE: IF YOU MAKE A BIG
ENOUGH MESS, THAT IS SO PERVASIVE AS TO PRECLUDE A "PRACTICABLE" CLEANUP,
THEN YOU'RE OFF THE HOOK. ON THE OTHER HAND, DEMANDING A COMPREHENSIVE
CLEANUP THAT MAY INDEED BE EXPENSIVE IN THE SHORT TERM, PROVIDES AN INCENTIVE
TO CHANGE DISPOSAL, MANUFACTURING, AND TRAINING ACTIVITIES AND PROVIDE LONG
TERM SOLUTIONS OUR MILITARY'S POLLUTION BY PROMOTING AND DRIVING SOURCE
REDUCTION INITIATIVES. EXAMPLES INCLUDE USING INERT PRACTICE MUNITIONS THAT
CAN BE RECYCLED, ELIMINATING LEAD FROM MUNITIONS, AND RESEARCH AND
DEVELOPMENT INITIATIVES. THROWING OUR HANDS UP DOES LITTLE FOR THE EARTH,
INSTEAD WE SHOULD CARE FOR THE LAND, THE WATERS, AND THE AIR AS THE GREAT AND
WONDERFUL GIFT THEY ARE. AND FINALLY, TO ANSWER YOUR QUESTION, WE WILL HAVE
NO TROUBLE FINDING SOILS THAT HAVE LEAD LEVELS BELOW 30 PPM, INDEED THE ARMY
CAN FIND IT A FEW METERS AWAY. 

INCIDENTALLY, MY QUESTIONS WERE RHETORICAL. I THINK IT WOULD BE BEST IF
WE JUST AGREE TO DISAGREE. 

-- 
Laura Olah, Executive Director 
Citizens for Safe Water Around Badger
E12629 Weigand's Bay South
Merrimac, Wisconsin 53561
olah@speagle.com
Phone (608)643-3124 Fax (608)643-0005
Website http://www.speagle.com/cswab