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EPA vinyl chloride data is 1,000 times lower than the Unified Command data

Volatile Organic Compound (VOC) Levels Of Concern Ignored

[Update #2 – 3/19/13 – In Paulsboro, a blue-collar town wrestles with industry

Bill Wolfe, head of the New Jersey chapter of Public Employees for Environmental Responsibility, said he doesn’t think the companies or the state will install air monitors around town.

“They don’t want to open that door, to go for fence-line air monitoring,” said Wolfe, a former DEP employee. “That would open Pandora’s box.” – end update

[Update #1: 12/24/12 – Philadelphia Inquirer coverage – they needed to find a professor to validate what I was telling them, but yet still missed the federal and state regulatory side of the story and failed to even mention the PEER investigation request, see:  Some responders say Gloucester County was unprepared for Paulsboro chemical emergency –

But according to readings provided by officials leading the cleanup, the chemical level at 11:59 p.m. that day in non-evacuated areas was 9.4 parts per million, nearly 1 part per million more than in the evacuated area.

That “calls into question the science behind the evacuation zones and how they were delineated,” said Bill Wolfe, executive director of the New Jersey chapter of Public Employees for Environmental Responsibility and a former policy analyst at the state Department of Environmental Protection.

Similar qualms were expressed by Paulsboro residents at community meetings. Nevertheless, local officials have hailed the performance of the workers who led the response.

But, as I discuss below, EPA claims that all air monitoring results were below 1 part per BILLION, 9,400 TIMES LOWER that Unified Command reported data.  ~~~ end update]

There has been significant media attention focused on the Paulsboro toxic train wreck.

The chemical of concern is vinyl chloride (VC), a highly toxic and carcinogenic gas – 180,000 pounds of VC  was released from the derailed tanker car.

According to EPA monitoring data, at no time was there an unacceptable health risk.

EPA levels are reported in parts per billion:

EPA’s sampling results were compared to screening values designed to protect people’s health and developed for this incident based on an assumed exposure for vinyl chloride of 350 days for one year. All of the detected values were within or below the EPA’s acceptable cancer risk range of one in one million (.0877 parts per billion) to one in ten thousand (8.77 parts per billion).

How – at the same time – can EPA conclude “all values” were below EPA screening values when they previously found air monitoring data exceeded “levels of concern”:

Results of the mobile TAGA and stationary instrument readings showed that levels of vinyl chloride fluctuated. From November 30 to December 5, EPA monitoring found periodic exceedances of the level of concern. When the level was exceeded, EPA immediately informed the NJDEP and the U.S Coast Guard so that decisions could be made to protect the responders and the nearby community. Because the monitoring results showed some levels above the level of concern, the EPA supported the county and the town in their decision to evacuate residents within a defined area. The EPA continued its TAGA bus work until the train recovery operation was completed.

But, in addition to internally inconsistent conclusions, the EPA data and conclusions conflict with the Unified Command data.

According to the Unified Command website monitoring data – data were reported in parts per million.

VC levels ranged as high as 9.4 ppm (12/4/12) – over 1,000 times HIGHER than EPA data:

Source: Unified Command website (link above)

What explains this huge difference?

Maybe an intrepid reporter might ask EPA why the EPA is reporting values in parts per billion but the Unified Command is reporting data in parts per million?

Why is TAGA bus data is 1,000 times lower than the Unified Command hand held monitoring data?

Also ask EPA about their health screening value, which looks to be 1 ppb (part per billion).

As I previously wrote, the ATSDR set an “Minimal Risk Level” (MRL) as a screening value to consider potential health effects for acute exposure (1-15 days).

The ATSDR MRL for VC is 0.5 ppm (parts per million) or 500 ppb. The intermediate duration MRL was 0.03 ppm – or 30 ppb.

That would make the EPA 365 day health sreeening level 30 – 500 times LOWER than ATSDR.

What health effects is EPA basing the screening level on? What populations? Waht exposure periods? What risk ranges? Why are these key critical assumptions not standardized or coordinated with the Unified Command data reporting?

Does EPA consider health effects on children? Children are more susceptible to VC, as EPA’s IRIS database states: (@ p. 35)

As discussed above and in Section 5.3.5.1, several studies provide evidence for increased sensitivity to VC-induced carcinogenesis in early-life and prenatal exposures in experimental animals. Early-life data on humans, however, are lacking because most exposures have been limited to occupational groups. Nevertheless, many of the factors likely to be responsible for early-life sensitivity in animals are present in humans. Recommended adjustments to quantitative risk estimates to account for early-life sensitivity are given in Section 5.3.5.1. 

The children’s health issue is key, given the proximity of schools, and the prior work done under EPA’s National School Outdoor Air Toxics Program.

As we’ve noted, Paulsboro High School was 1 of 63 schools in 22 states selected by EPA nationally.

According to EPA:

In 2009, as part of a new air toxics monitoring initiative, EPA, state and local air pollution control agencies monitored the outdoor air around schools for pollutants known as toxic air pollutants, or air toxics.  The Clean Air Act includes a list of 187 of these pollutants. Air toxics are of potential concern because exposure to high levels of these pollutants over many decades could result in long-term health effects.

EPA selected schools after evaluating a number of factors including results from an EPA computer modeling analysis, the mix of pollution sources near the schools, results from an analysis conducted for a recent newspaper series on air toxics at schools, and information from state and local air pollution agencies.

As we’ve also noted, (see: EPA School Air Toxic Data Misleading) – the issue of children’s health risk due to exposure to volatile organic chemicals remains unaddressed by EPA.

Here are the prior EPA Paulsboro High School data.

Note that the benzene levels range from 0.6 ug/cubic meter (ppb) to 1.5 ug/cubic meter, well below the EPA 30 ug/cubic meter screening value (which, frankly, is difficult to believe, given proximity to the refinery and other chemical facility emission sources.)

So, in addition to conflicting data on actual vinyl chloride levels and health effects, virtually none of the media coverage has mentioned the volotile organic chemicals that have been detected at high levels in the community during the VC air monitoring.

According to the Unified Command:

Real-time air monitoring was conducted for volatile organic compounds (VOCs), lower explosive limit (LEL), vinyl chloride, and oxygen using stationary AreaRAEs and/or hand-held instruments such as the MultiRAE and colorimetric detector tubes. Analytical air sampling was conducted at 7 stations for volatile organic compounds using EPA method TO15. Table 1 and Table 2 below display data summaries for AreaRAE and hand-held instrument data, respectively.

Look at the last line above – VOC on 12/4/12 were 868 ppm– this was the highest and not a sustained level.That is 868,000 ppb!

Here are more typical VOC results, from 12/3/12:

VOC is a term for a number of chemicals, unfortunately, individual VOC chemical specific data were not reported.

However, a likely significant component of VOC’s is benzene, which is highly toxic and carcinogenic. (Benzene is a Class A carcinogen, like VC, a known human carcinogen. There are very few Class A carcinogens.)

To put the VOC data in context, the DEP screening value for acute air exposure (inhalation) to benzene is 1,300 ppb.

1 ppm is equal to 1,000 ppb

So if just 1% of the VOC detected (500 ppm = 500,000 ppb VOC detected) was benzene, then there are significant health risks are presented by the VOC levels detected in Paulsboro.

(Example: if benzene were just 1% of 500,000 ppb VOC values detected, that equates to 5,000 ppb, or nearby 5 times DEP screening value and is over 150 TIMES higher than EPA’s 30 ug/m school screening value!)