AMERICAN LUNG ASSOCIATION. IN PENNSYLVANIA
Comments of Kevin M. Stewart on Behalf of the American Lung Association in Pennsylvania before the Pennsylvania Department of Environmental Protection Hearing on Municipal Waste Management Landfill Expansion Application #101247-A142 Submitted by Keystone Sanitary Landfill, Inc. Dunmore and Throop Boroughs, Lackawanna County Mid Valley Secondary Center Throop, Pennsylvania, July 18, 2016
Good evening. I thank you for this opportunity. My name is Kevin Stewart. I serve the American Lung Association in Pennsylvania (ALAPA) as its director of environmental health. I have also served on the Department's Air Quality Technical Advisory Committee since 2007. The American Lung Association strongly supports safe, healthful air for all. We are especially concerned about the acute and chronic effects of air pollution on the health of vulnerable populations, including people with lung diseases such as asthma, lung cancer, and chronic obstructive pulmonary disease (COPD), the elderly and children. First, our positions on three main topics- waste management, environmental justice and the public's right-to-know: 1) The American Lung Association supports programs and policies to reduce the health and
environmental impacts associated with refuse disposal by: source reduction, material reuse, and recycling, composting or using other safe non-combustion alternatives to
dispose of all remaining waste. The American Lung Association supports the safe .control of emissions from landfills and composting facilities. 2) A significant portion of Dunmore Borough, including part of the footprint of the landfill itself, has been identified by the Department as an Environmental Justice Area. The American Lung Association's policy on environmental justice supports the protection of all people from the harm of air pollution, especially those who suffer disproportionate exposure from local sources of emissions. We recognize that, for many reasons, people in . EJ communities also face a greater burden oflung disease, making them even more vulnerable to these pollutants. page 1 of2
American Lung Association in Pennsylvania
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Furthermore, the American Lung Association supports regular, thorough assessments of the impacts to nearby communities from sources of dangerous air pollutants, and supports the aggressive targeting of these sources for cleanup. In short, the American Lung Association' s position is that communities already bearing substantially more than their fair share of the burden of environmental impacts should have those burdens mitigated-and they certainly should not be expected to bear even greater burdens. 3) The American Lung Association adheres to the general principle that people have a right to know about their exposure and their potential exposure to deleterious agents, under normal and worst-case conditions, reflecting both historical and anticipated future exposures, and what their risks of adverse health effects are from past, future, and cumulative exposures. Only then can the community and the Department make an informed decision about whether a certain facility, land use, or change in operation should be permitted. lbis leads to the current situation at hand-first, regarding the need for those regular, thorough assessments: 1) The public and their health advocates don't yet have a comprehensive, well-reasoned, and substantiated interpretation of the results even from the Department's Mobile Analytical Unit's (MAU) work of a year ago, let alone from the more recent survey involving 30 days of sampling between January 28 and April28 of the current year.
2) Âˇ A comprehensive study of health-related data should also be prepared for the communities in close proximity to the landfill facility. This can serve two purposes: a. To provide the best analysis possible for characterizing any historical associations between past exposures and the health record; and b . To provide a suitable baseline against which any future concerns about health consequences may be measured.
3) Any assessment must fully recognize, not only irritant and toxic effects, but all health consequences of exposure to emissions with substantial odors (e.g., hydrogen sulfide and other reduced sulfur compounds, aldehydes, amines) as they exacerbate stress, cause mental and emotional distress, and recognizably interfere with quality of life. 4) In conclusion, no decision about moving ahead with future permits for this facility should be made until these studies have been completed and subject to a substantial period allowing for public review, critique, revision, and then consultation regarding the ultimate findings. Though time does not permit, I have included in my written comments a brief critique of the MAU results in the absence of a more rigorously conducted interpretation, and with respect to
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American Lung Association in Pennsylvania
the three-month sampling period performed this year, we already have some preliminary concerns: 1) 2015 MAU results a. There often appears to be so much variability within the background data that this results in the limits of detection for candidate air toxic gases being extremely high, blinding us to the actual behavior of the pollutants of concern. b. Nevertheless, the fact that on some occasions there was still breakthrough out of the zone of uncertainty, especially when the levels reported are much higher than accepted reference concentrations for these air toxins, clearly justifies concerns that the true long-term exposures to those pollutants must be more reliably characterized. c. For a single example: What are people to think about a maximum result, taken at face value, of around 700 micrograms per cubic meter for the Class A carcinogen benzene in the context of an EPA reference concentration of only 30 micrograms per cubic meter? 2) 2016 three-month sampling period a. Although the sampling done for the Health Consultation was originally anticipated to be performed in the winter months-with the understanding that that was the season during which complaints logged by the Department were most frequent-it is important to point out that the testing actually took place more during meteorological spring than winter. b. Therefore the thirty days of sampling conducted during this period may be representative neither of the period of greatest concern for airborne emissions nor of year-round averages, and we recommend sampling be carried out that covers more days and other seasons, such that reliability of the results can be scientifically demonstrated. c. The potential for degradation of the sampled compounds, between instant of capture and the time of analysis, has been suggested for some reactive compounds associated with landfill operations; this concern must be addressed rigorously in the final report.
In conclusion, the American Lung Association in Pennsylvania commends those public officials who have courageously stood with the people in recognizing the seriousness of this issue for the tens of thousands of Lackawanna County residents, many living in Dunmore and Throop, who deserve relief from environmental threats to their health.
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