DOE Dioxin Level Comment Period Ends 1/21/11

THERE IS NO SAFE LEVEL OF EXPOSURE TO DIOXIN

Submitted to Shelton Blog by Connie Simpson

TO:
Joyce Mercuri, Ecology Project Manager,
Joyce.Mercuri@ecy.wa.gov

Len O’Garro, State Health Official
Lenford.O'Garro@doh.wa.gov

RE: Dioxin levels in Oakland Bay

Dear Ms. Mercuri and Mr. O'Garro:

I realize the letter I previously sent to you, Ms. Mercuri, was too general and did not specifically address my concerns as a registered nurse, mother and grandmother, regarding the unbelievable statements of our state government regulators that the unusually high levels of dioxin in the sediment of Oakland Bay are acceptable!

I have always believed in the honor and ethics of public service. I believe that most of our public employees go to work everyday, sometimes to jobs with enormous political pressure and confusing mandates, committed to doing the best job they can. I apologize if the tenor of this letter comes across as "irate"; however, I cannot disguise my incredulity that the levels of dioxin cited could by any stretch of the imagination be considered safe. Further, how is it possible your agency is unaware of, or does not comment on, the biomass to energy plants (seven facilities reportedly in the permitting process) planned for western Washington, most adjacent to waterways?

Dioxin is now present in nearly every corner of the world due to the ignorance and laxity of regulatory bodies, and greed of corporations and industry. Below, I quote the World Health Organization's key points on dioxin. (My italics.)

Dioxins and their effects on human health
Fact sheet N°225
May 2010
Key Facts:

Dioxins are a group of chemically-related compounds that are persistent environmental pollutants.

Dioxins are found throughout the world in the environment and they accumulate in the food chain, mainly in the fatty tissue of animals.

More than 90% of human exposure is through food, mainly meat and dairy products,. Many national authorities have programs in place to monitor the food supply.

Dioxins are highly toxic and can cause reproductive and developmental problems, damage the immune system, interfere with hormones and also cause cancer.

Due to the omnipresence of dioxins, all people have background exposure, which is not expected to affect human health. However, due to the highly toxic potential of this class of compounds, efforts need to be undertaken to reduce current background exposure.

Prevention or reduction of human exposure is best done via source-directed measures, i.e. strict control of industrial processes to reduce formation of dioxins as much as possible.

And, below is a portion of the EPA report on dioxins which, as you can read, are related to the toxic and lethal Agent Orange used in the Viet Nam war, and from which, there were hundreds of thousands of victims-- some who are still suffering today. (My italics.)

Evaluation of the EPA Reassessment:

Dioxins and dioxin-like compounds (DLCs) are released into the environment from several sources, including combustion, metal processing, and chemical manufacturing and processing. The most toxic of these compounds is TCDD, often simply called dioxin. Many other types of dioxins, other than TCDD, and DLCs share most, if not all, of the toxic characteristics of TCDD.

In the past, occupational exposures to TCDD, other dioxins, and DLCs occurred in a variety of industries, especially those involved in the manufacture of trichlorophenol (used to make certain herbicides) and PCBs. (PCBs contain some forms that are dioxin-like and, when heated to high temperatures, may also be contaminated with dibenzofurans, which are also dioxin-like.)

Much of the knowledge about the health effects of TCDD, other dioxins, and DLCs in humans comes from studies of relatively highly exposed workplace populations. Widespread use of certain herbicides containing TCDD, other dioxins, and DLCs, as well as some types of industrial emissions, resulted in local and global contamination of air, soil, and water with trace levels of these compounds.

These trace levels built up in the food chain because TCDD, other dioxins, and DLCs do not readily degrade. Instead, they persist in the environment and accumulate in the tissues of animals. The general public is exposed to TCDD, other dioxins, and DLCs primarily by eating such foods as beef, dairy products, pork, fish, and shellfish.

This EPA report does talk about "industrial workers and veterans" having higher exposure levels than the general public, hence, higher consequences to exposure. Despite this caveat, my family and I will not wade in the water of Oakland Bay, we will not buy shellfish from Shelton/Mason County sources, and we will look, with suspicion on your agency as being incompetent in protecting us from needless health risks. The bottom line is: there is no safe level of exposure to dioxin. That is despite the fact that most humans, at least for a time, survive exposure.

Because reports such as those I've included are part of your work, you are undoubtedly aware that there are literally thousands such reports that could be cited. Not one of them, of the twenty or so I read, said to knowingly ingest dioxins. Every one of them described serious, sometimes fatal, consequences to dioxin exposure.

It seems your agency does not know about the imminent industrial boom planned for Mason County, near the banks of Oakland Bay. Adage LLC, and (Simpson) Solomon LLC are planning to-- conservatively estimated-- triple the current amount of chemical and particulate emissions. How can your department release a statement of safe levels of dioxin when, within a very short time, these levels will exponentially increase? Since your study of Oakland Bay is unlikely to be repeated any time soon, it behoves your department to, at the very least, be cautious in it's endorsement as safe-- shellfish for human consumption, and working environments for shellfish harvesters, (the most likely individuals to suffer from maximum exposure to toxins in sediment).

Can you promise us a repeat study in the year after these two mega-watt biomass to power plants begin their (dangerous) contribution to our environment-- and the sediments of Hood Canal, Puget Sound and Oakland Bay? If not, I cannot understand how your report, in good conscience, can be considered a reassurance to the citizens living, eating and playing near these areas.

Please consider further efforts to clean the dioxins from our local waterways, and to prevent future dioxin deposits by industry (or any other source) in our beautiful Washington State waterways, instead of hiding behind unrealistically hopeful health statistics and political spin which allow polluters to continue. I think our state agencies should be more facile, and interested--given our economic dependence on our waterways and their products--than ship-of-state-federal-agencies which are slow to respond to data, in updating regulatory information. Rather, it seems, state agencies often abandon common sense and point to out-dated regulatory levels-- which will most likely catch up, but, at what cost to human and environmental health?

Thank you for your attention to this important topic.

Yours truly,

Constance Simpson RN

Shelton, WA

SHELTON BLOG NOTE:

Department of Ecology Comment Period Deadline is January 21st.

The public has until January 21st to submit comments or technical questions concerning the Oakland Bay study to:

Ecology Project Manager, Joyce Mercuri
360-407-6260 or Joyce.Mercuri@ecy.wa.gov

Also address health concerns to:

State Health Official, Len O’Garro
360-236-3376 or Lenford.O'Garro@doh.wa.gov

To learn about the Oakland Bay Sediment Study:

http://www.ecy.wa.gov/programs/tcp/sites/oaklandBay/oaklandBay_hp.htm

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