"EPA Seeks Public Input on Interim Guidance for Dioxins in Soil Cleanup Goals"
EPA - Superfund Division
"Development of Draft Recommended Interim Preliminary Remediation Goals for Dioxin in the Soil"
Every governmental agency is broken up into many divisions. As a citizen attempting to navigate a monstrous bureaucracy, it helps if you narrow down the actual Agency, Department, Division and highest person within that division that does intake on information, complaints and inquiries.
While reading this announcement, and knowing the processes that transpired to create a Superfund or Brownfield with dioxins in the soil, I know that Dioxins could have been stopped from entering the soil in the first place. But, the problem of dioxins entering the soil in the first place, is another another division. A different problem with multiple solutions.
We have 50 days from yesterday (12-31-09) to make our voices heard regarding the way dioxins are remediated from soil. It is imperative to have healthy soil, because that is where we get nutrients, food, water is filtered...so many reasons. http://www.regulations.gov/search/Regs/home.html#home EPA SFUND 2009-00907 (Notice titled "Draft Recommended Interim Preliminary Remediation Goals for Dioxin in Soil at CERCLA & RCRA Sites" will be published on 01/17/2009 [hopefully they mean 2010] and have a docket i.d. of EPA-HQ-SFUND-2009-0907. You can review the pre-publication copy of this Notice on the Office of the Federal Register's Electronic Public Inspection Desk Web site at http://www.federalregister.gov/inspection.aspx ).
In case you are not sure about a lot of language used in the Environmental Regulatory agencies, I hope to offer some clarity.
Brownfield's are abandoned or underused industrial sites that due to contamination, or perceived contamination. Often the facility or industry that did use that property were brought to Enforcement by an Environmental Regulatory Agency. There are two sides to every story, but the final outcome is that the U.S. citizens pick up the bulk of the cost when an Industry (Facility) decides or is forced to shut-down.
When a Facility is brought into regulatory trouble {they get pulled over by the pollution police} it is called a Consent to Administrative Order. Case by case violations are considered. Depending on the sophistication of the Industrial owners and staff depends on how punishment or remediation is ordered. Remediation being: an example; Joe Blow Chemical has been dumping their hazardous water out on the back 40 acres of their site. They have been at this practice for 12 years. They are finally reported in a way that gets results. An Inspector from the Govt Agency will go and assess. Soon, the plant is notified and asked to respond within 10 days. It goes from there. Joe Blow will probably have to shut down, unless he is willing to change his ways. His fine will probably be the top amount per violation. He will probably skip town and abandon his plant. It will now be a Brownfields area. Usually the local city, town or Parrish now works to bring another industry in that will promise to clean up and do the remediation. We all know that ain't going to happen without incentive. So, very much incentive, grants and help is available to a business who is willing to go in, clean up, change the operations and stay clean. Those grants and stuff are taxpayer dollars at work.
Now, MoaMoa Chemical is a worldwide conglomerate they have facilities all over the U.S. and globe. They became powerful in the 1940's. They spend a good deal of money to have experts in laws, regulations and how laws and regulations are made. They spend a good deal of money on political campaigns. They know their rights and they use them. They are allowed to appear before Congress and have input into rule and lawmaking. They have tons of money and time to make sure things go their way. They know that generally other citizens who are opposed to blatant pollution for the sake of profit, will not spend the time, take the effort and certainly not the money to get the interest of their Representatives or Senators in matters of the Environment. They are even protected through IRS rules that allows them to simply abandon or refuse to remediate the property they have destroyed. MM is quite sophisticated. They send in their reports in triplicate when only one is required. They will report upsets and spills. They "Self-Disclose". If they are Inspected by a Govt agency, they will have the inspector escorted, requiring the Inspector to return at a better time for the plant. They will not go out of business. They will pay a couple of thousand dollars and move on. This is then what we call a Superfund Project. This means, now the EPA is responsible to make sure this property is rehabilitated and in getting that done, not violating the Regs themselves.
Now. This is an opportunity for citizens worldwide to make Public Comment. We have 50 days from yesterday 12-31-2009, to get all or our comments in. Do you want to have a say in how brownfields are rehabilitated in your back yard? This is your chance. This is the link to the EPA Public Comment ; docket ID number: EPA-HQ-SFUND-2009-00907 http://www.regulations.gov/search/Regs/home.html#searchResults?Ne=11+8+8053+8098+8074+8066+8084+1&N=4294967141+8102 THIS IS GOVERNMENT, THEY ARE ON HOLIDAY BREAK, IT HAS NOT BEEN POSTED YET, BUT JUST USE SFUN 2009, AND CHECK ONES THAT ARE OPEN FOR PUBLIC COMMENT, I WILL CHECK 1/5/10, AND REPOST AN UPDATED LINK TO THE ACTUAL COMMENT YOU MAY WANT. **UPDATE: it is still not posted. I forwarded a note to www.regulations.gov as this has a 50 day comment period beginning December 31, 2009.
Americans making their government work for them are a powerful force. This is a time when everyday people can, do and will have a say.
Many thanks to Lisa Jackson - Chief Administrator of the EPA and all of the staff who are working so hard for the People. Blessings. Happy New Year.
1. U.S. EPA, May 26, 2009 - EPA's Science Plan for activities related to Dioxins in the Environment: Press Release http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm?deid=209690 There are two updates included with the original notice: [09/09], [12/09] and includes a link to yesterday's announcement 12/31/09.
2. U.S. EPA, April 13, 1998 Approach for Addressing Dioxin in soils at CERLA (Comprehensive Environmental Response Compensation Liability Act) and RCRA (Resource Conservation and Recovery Act) sites (PDF) OSWE Diective 9200.4-26
3. TEF (Toxic Equivalency Factor) - The most toxic of the dioxins is (2,3,7,8-TCDD) this is used as a base of comparison of the TEF of a chemical. This measurement is regulated under ...
4. 40 CFR 300 Section 430(e)(2)(i)(A)(2)
5. Cancer risks :read for the math used to determine the toxicity of a chemical and the human chance of getting cancers from exposure.
6. A hazard quotient = ratio of an exposure level for a single substance to a reference dose...
7. EPA's Risk Assessment Guidance for Superfund, ...EPA/540/R-92/003
8. Human Health Risks: http://www.epa.gov/oswer/riskassessment/pdf/hhmemo.pdf
9.IRIS will be the data base for the development of this action....
