March 8, 2016 Friends of Lackawanna 201 S Blakely Street PMB #305
Dunmore, PA 18512 Dear Friends of Lackawanna: I have completed my review of the air tests that you sent to CHEJ. These air tests were conducted by the Pennsylvania Department of Environmental Protection (DEP) in April and then again in June of last year (2015). Two samples were collected from the Keystone Sanitary Landfill property and four samples were collected from different public locations in the community outside the landfill property. The two samples from the landfill were identified as Landfill Leachate Pool and Landfill Working Face. The four samples from the outside the landfill property were identified as Sherwood Park, Swinick Neighborhood, Mid-Valley High School Athletic Field and Mid-Valley High School Parking Lot. The June samples appear to have been taken at the same general location as the April samples, but there is no specific statement to that effect in the lab reports from DEP. This testing provides a good initial picture of the contaminants coming from the landfill, but unfortunately there are many limitations and inconsistencies in the testing methods and procedures that limit what can be drawn from this data. These limitations and inconsistencies are addressed in this Letter Report. In addition, I also focus on the results of the air sampling conducted at Sherwood Park, the location where the most contaminants at the highest concentrations were found among the four off-site community sample locations. I have prepared a summary table that includes the air test results from the landfill property and from the Sherwood Park Location. To the best of my understanding, this park is also a highly active public site that is used by numerous youth groups. Included in the table are all the positive values (readings above the reporting limit) for each of these 3 locations. In addition, I looked for some standard risk values to compare the data in order to help evaluate the significance of the results. The only standard for air testing that I could find was the state of Massachusetts Department of Environmental Protection Threshold Effects Exposure Limits (TELs). These TEL values â€œare used to evaluate potential human health risks from exposures to 1
chemicals in air. These guidelines are set at concentrations intended to protect the general population, including sensitive populations such as children, from adverse health effects over a lifetime of continuous exposure.â€? Air Test Results at Sherwood Park Table 1 provides a summary of the analytical results of the air samples collected at Sherwood Park, the Landfill Leachate Pool and the Landfill Working Face. The results from both the April and June testing are included in this table. This analysis shows that in April 2015 the air testing conducted at Sherwood Park by the Pennsylvania DEP identified 14 different substances in the air. Six of these substances exceeded the Massachusetts DEP TEL values - acetaldehyde, benzene, carbon disulfide, methanol, naphthalene and triethylamine. The following chemicals were either only found at the Sherwood Park location or were found at the highest concentrations: acetaldehyde, benzene, ethylene, m-xylene, naphthalene and triethylamine. These findings are significant since many of these chemicals are toxic and hazardous substances. I have attached to this Letter Report a brief summary of the toxicity of many of these substances. In the June 2015 sampling, only 7 substances were found at Sherwood Park, only 2 of which exceeded the MA DEP TELs - benzene and naphthalene. The variability in the sample results especially between samples collected from the community and the landfill are discussed in detail below. Included in Table 1 are the analytical results of the air samples collected at the Landfill Leachate Pool and the Landfill Working Face. In April 2015, 9 substances were found in the sample collected from the Landfill Leachate Pool and 13 substances were identified in the sample from the Landfill Working Face. In June 2015, 10 substances were found in sample by the Leachate Pool and 21 substances were identified by the Landfill Working Face. There was no consistent pattern in the data between the substances identified on the landfill property and the samples collected at Sherwood Park, though I would have been surprised to see this given the small number of samples that were taken. I was quite surprised, however, to see several substances in the air at Sherwood Park, namely carbon disulfide, acetaldehyde, naphthalene and triethylamine. These are quite unusual substances to be found in ambient air. These are not common volatile substances such as benzene, xylene or toluene, all three of which were also found in the air samples collected from Sherwood Park. However, these substance were not consistently found in the landfill samples. Carbon disulfide was found in April in both the Landfill Leachate Pool sample and at Sherwood Park. It was not found at either location in June. Carbon disulfide was found at the Landfill Working Face in June but not in April. Similarly, triethylamine was found in April in both the Landfill Leachate Pool sample and at Sherwood Park. It was not found in either location in June. It was not found in either the April or June sampling at the Landfill Working Face. Neither 2
naphthalene nor acetaldehyde was found in either sample collected from the landfill property in either April of June. It is not clear however, if in fact these substances were not present in these samples in either April or June or whether the reported “Non-detect” results were an artifact of the poor sampling methods and procedures. I discuss this issue in detail below. It’s possible that the source of the carbon disulfide and triethylamine at Sherwood Park is the landfill, especially given the proximity of the park to the landfill, but more testing needs to be done to ascertain whether in fact this is the case. In addition, research is need to determine if there are other potential sources of these two substances in the area. Sampling Methods and Procedures The air sampling data generated by the Pennsylvania’s Department of Environmental Protection (DEP) are difficult to interpret for a number of reasons listed below. As a result, the testing conducted by the DEP is very limited in scope and provides very little good data to evaluate the potential ambient air contamination present in the community coming from the landfill.
Variation in Reporting Limits: The reporting limits used by DEP were often different for the same chemical from one sample to another. Reporting limits are values below which chemical levels will not be measured. Reporting limits are essentially equivalent to detection limits in this case. This means that some chemical levels may not have been reported for a location, even though the levels reported were similar or even higher than the results for the same substance at other locations. For example, in the April sampling, the reporting level for benzene was 146 parts per billion (ppb) at Sherwood Park, but 315 ppb at the Landfill Working Face. This means that although there may have been comparable levels of benzene at the landfill (which would point to the landfill as a possible source of the benzene), no value was reported at the landfill due to the higher reporting/detection limit used to analyze the landfill samples. Similarly, the reporting limit for carbon disulfide for the sample collected from the Landfill Working Face in April was 540 ppb and 68 ppb at Sherwood Park. This inconsistency was just as prevalent in the June samples. For example, the reporting limit for benzene in the sample collected from the Landfill Working Face in June was 5,163 ppb, 87 ppb for the Landfill Lagoon Pool and 31 ppb at Sherwood Park. DEP did not say why the reporting limits varied so much between these two samples types (off-site vs. on-site). Timing of the Measurements: DEP only took a single four-hour measurement for each collected air sample. This is a relatively short sampling period that provides a limited “glimpse” of the air quality present during this sampling period. In addition, in most instances, only a single measurement was actually taken further limiting the “picture” of the air quality during this limited sampling period. This single reading is reported as a maximum concentration. This limited picture of the air quality could be drastically 3
altered by simple changes in operational practices at the Keystone Sanitary Landfill. For example, operational changes between the first and second measurement dates could have significantly affected the levels of chemical compounds measured in the ambient air when only a single snap-shot of the air was taken during a 4-hour sampling window. Thus, any changes in practice would complicate the interpretation of the data and would not accurately represent the long-term exposure of the community to air pollutants coming from the landfill. Lack of Quality Assurance/Quality Control Procedures: DEP did not disclose any Quality Assurance/Quality Control procedures with the lab analysis reports for either the April or June 2015 sampling results. As a result, it is not clear if any such methods were used. It is standard operating procedure for all environmental sampling to include Quality Assurance/ Quality Control procedures, so I would expect that it was done in this instances. However, since there was no mention of it in the lab analysis reports, whether it was done or not has to be questioned. Lack of Control Data: DEP failed to include the levels of any chemical compounds found in the air samples collected from the control (upwind) location. Instead DEP used computer software to adjust the levels of the chemical compounds in the samples collected from the other locations. In doing so, they removed the concentration of any contaminants found in the control samples. This means that 1) we don’t know the actual levels of the chemical compounds in the upwind sampling location and 2) there are no values with which to compare the chemical levels at other sampling locations such as Sherwood Park. Limited Information on Time Weighted Average (TWA): Some of the data reported by DEP was generated by calculating a “time weighted average”. However, DEP did not report how they calculated their time weighted averages. Consequently, we do not know how many measurements were taken to create the averages. Additionally, the majority of chemical compounds in the DEP report do not have TWAs, which likely means that only one measurement was taken for each sampling period for each chemical analyzed. Fewer measurements mean a lower sample size and less reliable results.
Summary Conclusions and Recommendations Ambient air testing conducted by the Pennsylvania Department of Environmental Protection (DEP) in April and June 2015 in Dunmore, PA clearly show contaminants in the ambient air on the Keystone Sanitary Landfill property and at Sherwood Park. Two samples were collected from the landfill property and four samples were collected from different public locations in the community outside of the landfill property during both sampling dates. In April 2015, the results of the air testing conducted at Sherwood Park identified 14 different substances, six of which 4
exceeded the Massachusetts DEP TEL values - acetaldehyde, benzene, carbon disulfide, methanol, naphthalene and triethylamine. Overall, by far the highest concentrations of contaminants outside of the landfill property were found at the Sherwood Park location. The following chemicals were either only found at the Sherwood Park location or were found at the highest concentrations: acetaldehyde, benzene, ethylene, m-xylene, naphthalene and triethylamine. These findings are significant since many of these substances are toxic and hazardous substances. The concentrations of the contaminants identified varied substantially from one sampling date to another with no consistent pattern between samples taken at different locations or at different times. Sometimes the chemical concentrations decreased between the first and second sampling dates, and sometimes they increased. Other times, substances were reported as “not present” because they were not found at concentrations in excess of their reporting limit. It is not clear however, if in fact these substances were not present in these samples for either the April or June sampling events or whether the reported “not present” result was an artifact of the poor sampling methods and procedures used by DEP. In many instances, chemical levels were not reported for a location, even though their reporting/detection limits were similar or even higher than the results for the same substance at other locations. As a result, it is difficult to draw any clear conclusions from this analytical data. I am especially concerned about the finding of carbon disulfide, naphthalene, acetnaphthalene and triethylamine in the ambient air at the park. These substances are quite unusual and you would not typically find them in ambient air. However, these substance were not consistently found in the landfill samples and it is unclear if this is because the landfill is not the source or whether this result is a due to the poor analytical methods used by DEP. These methodological problems include a wide variation in reporting limits, limited sampling times, the lack of analytical data for the control air samples and limited information on Time Weighted Average (TWA) sampling. Given these limitations, I would recommend the following next steps. 1) More air testing is need to more accurately evaluate the ambient air quality in the neighborhood around the Keystone Sanitary Landfill. 2) Consistent reporting/detection limits should be used for the same substance from sample to sample. 3) Longer sampling times should be used. 4) Additional testing should especially focus on the Sherwood Park area because of the high levels of contaminants already found there, the proximity to the landfill and because of the high amount of public activity, especially by youth groups at the park.
5) DEP should release to the public any Quality Assurance/Quality Control procedures used as part of the ambient air testing conducted in Dunmore in April and June 2015. 6) Analytical data for the upwind control site needs to be made available to the public. 7) The procedures used by DEP to calculate its time weighted average values needs to be made available to the public. I hope these comments are helpful. Please do not hesitate to contact me if you have any questions or if you need any additional information. Sincerely,
Stephen Lester Science Director Attachment
Table 1. Maximum Concentrations of Measured Chemicals at Sherwood Park and Keystone Sanitary Landfill Sites in April and June 2015 Compared to Threshold Effect Exposure Limits (TELs) set by the Massachusetts Department of Environmental Protection (all measurements in parts per billion or ppb) 6
Chemical Compound 1,2,4-Trimethyl benzene 2-Methyl Butane 2-Methyl Pentane 3-Methyl Pentane Acetaldehyde Ammonia Benzene Carbon Disulfide Carbon Monoxide Chloroform Ethane Ethanol Ethylbenzene Ethylene Formaldehyde iso-Butane Methane Methanol Methyl mercaptan Methylamine m-Xylene Naphthalene n-Butane n-Hexane Nitric Acid Nitrous Acid Nitrous Oxide n-Octane n-Pentane o-Xylene Propane Styrene Toluene Triethylamine
20 100 0.2 0.032 27.21 27.21 69.09 13.61 2
46.96 21.23 0.24
Sherwood Park April June 2015 2015 167 212 48 211 54 26 6 11 60 138 13 68 51 27 10 27 6 15 338 45 15 -
Landfill Leachate Pool April June 2015 2015 341 2783 194 66 94 206 19 53 1590 651 118 842 455 141 61 57 459 103 14 -
Landfill Working Face April June 2015 2015 99 267 605 114 43 52 50 336 51 80 215 368 339 1669 1024 87 46 1881 498 565 683 33 22 13 1 1901 638 1552 343 126 63 18 973 36 -