Part Two: 190 ppt Indoor Dioxin standard guarantees continuing toxic exposure inside homes
Currently, US EPA has no standard safe level criteria for indoor dioxin contamination. A level of 190 ppt was arbitrarily chosen behind closed doors by Beazer East, PGC and other agencies. Other sites have had the inside of nearby residences cleaned up by the responsible party for a median indoor contamination level of 61 ppt. This unscientifically derived number of 190 ppt is over 27 times above Florida’s safe level standard for dioxin in residential soil and over 6 times above Florida’s safe level standard for dioxin in commercial/industrial soil. And 3 times higher than the level other sites have received indoor cleanups for.
Excerpt from USEPA Indoor Dust Study Data Report May 23 2013:
“The purpose of the sampling was to compare concentrations in household dust that may be related to the former Koppers facility (located at 200 NW 23rdAvenue) to background levels and consider possible actions to reduce exposures. Background samples were taken in homes well away from the Site which would not have been impacted by site contamination. EPA has reviewed the results considering background data and a risk-based screening value. It was determined that no remedial actions are required. The risk-based screening value for dioxin derived by EPA for potential exposure to dust in homes is 190pg/g (ppt) dioxin. (TCDD-TEQ). EPA derived this risk-based screening value for dioxin by utilizing a July 2011 document entitled the Indoor Dust investigation/Interpretation Plan, Stephen Foster Neighborhood, Gainesville, Florida (hereafter referred as “Plan”)-which includes exposure assumptions and a toxicity values that were agreed to by the Indoor Dust Dioxin Workgroup convened by the Florida Department of Health made up of federal, County, State and community representatives.”
The purpose of the sampling was not to find the dioxins associated to Koppers and remove them, it was to compare “background” samples to Stephen Foster Neighborhood samples and consider possible actions to reduce exposures. No real action involved with that. If SFN samples are close enough to “background” levels, they feel there is no health risk no matter what those dioxin levels are. The inmates are running the asylum. Samples were taken from background homes (vaguely defined as “well away from the site”). In the PGC USEPA Indoor Dioxin Dust Study Report 11-30-2014 “Site and Near Site Properties” are mismarked on the map. They state “given community concern that dust from the Koppers site is widespread, selection of background houses is a critical element of the sampling program. This workgroup, however, was unable to define a particular distance to be considered background.” Unable to define background delineation, they plowed ahead with samples from what they called “background houses” as if just calling them that was enough to make it true. Chlorinated dioxins were found in all the background houses, one as high as 77.3 ppt. This indicates the delineation of indoor dioxin contamination goes further than the “background” homes used in the 2012 indoor dioxin testing. Instead of re-testing the background homes with the highest results, they made an assumption the dioxin came from an inside source and just lumped it in with the rest of the results. That’s just plain wrong. These chemicals can be molecularly fingerprinted. The entire report is filled with theories, assumptions, and ambiguity. There is no magic force field that stops this Koppers dioxin contaminated dust at 6th Street.
The risk-based screening value of 190 ppt for indoor dioxin was determined using exposure ASSUMPTIONS and toxicity values that were AGREED TO by the workgroup of the “Plan”. Since THERE IS NO Florida Department of Environmental Protection (DEP) or USEPA standard FOR INDOOR CONTAMINATION, who set this “acceptable” indoor level of 190 ppt dioxin for Stephen Foster residents? Remember that the Florida outdoor residential Soil Cleanup Target Level (SCTL) is 7 ppt. The Florida outdoor Commercial/Industrial (SCTL) is 30 ppt. It was “representatives from the community” (actually, it was only PGC representing the community-because other community groups were not allowed to participate) and the responsible party (Beazer East, Inc.) that were part of the workgroup the EPA allowed to set this standard. Don’t take our word for it. It says so right on the second page of the Indoor Dust Investigation/Interpretation Plan, Stephen Foster Neighborhood, Gainesville, Florida.
“In November 2010, the Florida Department of Health (DOH) formed an indoor dioxin dust workgroup of county, state, and federal agency representatives. The purpose of this workgroup is to develop an indoor dust investigation/ interpretation plan and present it to U.S. Environmental Protection Agency (EPA). In March 2011, the workgroup added representatives from the community and the responsible party. The workgroup formulated this plan during several conference calls. “
FDEP and EPA will not cleanup below background levels. If the responsible party can represent background levels of dioxin to be sufficiently high, the comparison difference to near site homes will be decreased and will therefore guarantee no cleanup or assumed health risk in the households of the contaminated area. The standard being not only influenced, but set by the responsible party to an arbitrarily inflated level of 190 ppt for indoor dioxin contamination is an ironclad homerun that seals the deal on no household cleanups or relocation using the test results Beazer East bought. You would think the FDEP and City of Gainesville would want their OWN independent test results to base health risk to citizens, rather than the “test results” force fed by the responsible party who paid their consultants to determine the scope of the contamination they would be responsible for cleaning up. This is much like a judge asking a criminal to choose the punishment for their own crime, and then not batting an eye when it’s merely a slap on the wrist.
How dare the FDOP take test results from the responsible party and spend tax dollars and hours and hours working out formulas for cancer slope studies, health risk assumptions, and even toxicity theories for resident grown zucchinis based on German vegetable test results (no zucchini was sampled in the Stephen Foster neighborhood), and then use their sanctified authority to shout out to the public there is no health risk from Koppers contamination like it was based entirely on undisputed fact and not figures supplied by the for-profit company required to clean up the Superfund site.
Don’t be deceived. Beazer East, Inc is in the business to make money off the remediation of contaminated sites. The less money they spend on cleanup, the more profit they make. They paid $10 for the nearly 90 acre Koppers site, close to downtown and the University of Florida. The property is tax appraised at almost a million dollars. The EPA accepted an indoor contamination standard of 190 ppt made by the responsible party behind closed doors and expects the affected residents to believe it to be an acceptable health risk. Why should we accept that inflated level when other sites have had nearby residences cleaned up by the responsible party for a median contamination level of 61 ppt. We’re tired of “reports” that declare everything is fine and pull out the kitchen sink to discredit toxic trespass from Koppers while using vague language and disassociated facts as its basis. People have died and continue to die from Koppers contamination.
None of the members of PGC live in the affected area. It should also be noted that the President of PGC is a realtor who owns property in the Stephen Foster neighborhood.