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Comments of Kevin M.

Director of Environmental Health
on Behalf of the American Lung Association in Pennsylvania

February 12, 2018

on Health Consultation Public Comment Version
Keystone Sanitary Landfill, Dunmore, Lackawanna County, Pennsylvania

Prepared by Pennsylvania Department of Health
a Cooperative Agreement with the U. S. Department of Health and Human Services
Agency for Toxic Substances and Disease Registry
December 14, 2017

I thank the Pennsylvania Department of Health (PADOH) for its work, with the United States
Agency for Toxic Substances and Disease Registry (ATSDR) and with the Pennsylvania
Department of Environmental Protection (PADEP), to respond to the requests by Frank Farina (a
former Pennsylvania state representative), by Friends of Lackawanna, and by the American Lung
Association in Pennsylvania (ALAPA), to conduct an environmental health study/evaluation of
air quality surrounding the Keystone Sanitary Landfill in Drumore Borough.

In addition to our comments offered at the PADEP hearing on this topic in Throop, Pa. on July
18, 2016, I submit the following comments in response to the public comment version of
PADOH’s Health Consultation document of December 14, 2017.

Comments on Summary section:

RE: Conclusion 1

It is one thing to find that benzene and formaldehyde “are commonly found in outdoor air and the
cancer risk estimates based on community measurements were typical of exposure across similar
communities in the United States.”

It something else to conclude “that chronic (long term) exposure to the chemicals detected in
ambient air near the landfill at the monitored locations is not expected to cause cancer. ” Indeed, this
conclusion is not supported by the statement given as a basis: “Further analyses indicate the
cancer risk estimates for these two contaminants were low and within the U.S. Environmental
Protection Agency’s (EPA) target cancer risk range of 1 in 1,000,000 to 1 in 10,000.” It is clear that
this risk range is not equivalent to zero risk.

If the authors wish to make the case that this is an acceptable or negligible non-zero risk range,
or that the additional risk posed by landfill emissions does not statistically significantly exceed
expected background levels, then that is their prerogative to do so.

RE: Conclusion 2

Compared to Conclusion 1, which incorporates a prospective scope, the authors do not draw
conclusions about prospective risks of short-term chemical exposures. It is this reviewer’s belief
that silence in that regard is not justified. Indeed, in contrast, the fact that even limited sampling
led to findings of several chemicals in excess of their comparison value (CV) or odor threshold
should lead investigators to suspect that there may well be frequent occasions when actual
maximum short-term concentrations are likely to exceed those maximum sample measurements.
It is the effects on the public of such potential elevated concentrations that should be addressed
by the investigators.

- The fact that “issues with the sampling equipment occurred at the one-time high detection of
ammonia, limiting our confidence in the maximum result for this chemical, ” indicates that
more research with respect to ammonia exposures is required, not that the elevated result
obtained should automatically be regarded as a false high.
- The health effects described for methylamine and for acetaldehyde—“mild irritation of the
eyes, nose, throat and respiratory tract” and “irritation of the eyes, skin, and respiratory
tract,” respectively—are described as “[a]cute odor-related” but it is important to note that
those health effects listed are not necessarily limited to being consequences of olfaction. In
other words, physiological irritation phenomena can occur independently of whether a
subject detects an odor, and should therefore be described simply as “acute health effects”
rather than as “acute odor-related health effects” unless the latter can be explicitly
demonstrated to explain all of the former.
- Given the irritation phenomena described for ammonia, methylamine and acetaldehyde in the
“Basis for Conclusion,” and the recognition by ATSDR in its November 2016 “Toxicological
Profile for Hydrogen Sulfide and Carbonyl Sulfide” that “hydrogen sulfide is a respiratory
irritant” (see; excerpt from pp. 17 and
18, as cited below), the question arises as to the potential that exposures to concentrations
at such levels as reported (or at such levels as might possibly occur) might lead to
exacerbation of respiratory symptoms or triggering of asthma episodes.

Respiratory Effects. Exposure to very high concentrations of hydrogen sulfide can result in
respiratory arrest and/or pulmonary edema. Numerous case reports suggest that these effects can
occur after a brief exposure to hydrogen sulfide. Although the exact mechanism is not known,
there is strong evidence to suggest that the rapid respiratory failure and possibly the pulmonary
edema are secondary to the action of hydrogen sulfide on the respiratory center of the brain. There
is also some evidence that the respiratory failure and pulmonary edema may be due to a dose-
dependent inhibition of cytochrome oxidase in lung mitochondria, the terminal step in oxidative
metabolism, resulting in tissue hypoxia. At low concentrations, hydrogen sulfide is a respiratory
irritant. Residents living near industries emitting hydrogen sulfide, such as paper mills, hog
operations, animal slaughter facilities, or tanneries, reported nasal symptoms, cough, or increased
visits to the hospital emergency room due to respiratory symptoms (including asthma). In general,
exposure to hydrogen sulfide has not resulted in significant alterations in lung function. No
alterations in lung function were observed in workers chronically exposed to 1–11 ppm hydrogen
sulfide. However, there is some evidence to suggest that asthmatics may be a sensitive
subpopulation. No statistical alterations in lung function were observed in a group of 10
asthmatics exposed to 2 ppm hydrogen sulfide for 30 minutes (as compared with pre-exposure
values). However, increased airway resistance and decreased specific airway conductance
(suggestive of bronchial obstruction) were observed in 2 out of the 10 subjects.
Although human data are useful in establishing the respiratory tract as a target of toxicity,
concentration-response relationships cannot be established for most of these studies because
exposure levels were not monitored or the subjects were exposed to several sulfur compounds.
Animal data provide strong evidence that the respiratory tract is a sensitive target of hydrogen
sulfide toxicity and can be used to establish concentration-response relationships.

RE: Conclusion 3

Again, it would be appreciated if the authors would attempt to address the issue of prospective
risks, and if they would explore what could or could not be said about KSL or other sites as
explanatory sources of high daily PM2.5.

- It may worthwhile to clarify, in the last statement of “Basis for Conclusion,” that the
form of the NAAQS for the short-term PM2.5 standard requires averaging the annual 98th-
percentile daily 24-hour average over three consecutive calendar years.

RE: Conclusion 4

Given that the data gap is currently unresolved, this conclusion appears to have been put

RE: Conclusion 5

It is appreciated that, given the limitations of the data and the epidemiology, there are restrictions
on what can be said. Still, it would be worthwhile to see what the authors propose as most likely
explanations for the significantly lower and higher cancer incidence rates that were observed.

RE: Recommendations

According to public testimony, the history of the landfill shows significant variability in terms of
the nature and frequency of environmental problems reported. The American Lung Association
in Pennsylvania cannot more strongly emphasize the need for strong oversight, and for
meaningful enforcement of permit requirements, regulations, and odor rules that results in true
deterrence of undesirable effects upon public health, well-being, and quality of life.

ALAPA strongly supports a monitoring program of sufficient robustness to inform the public in
a timely manner of problems with the quality of the air they may be breathing. We support the
establishment of a fence-line air monitoring program that can provide accessible real-time results
for appropriate analytes. The public should be directly involved in the process by which are
determined the siting of the monitors, the choice of analytes, the averaging periods, and the
assurance of operational reliability and independence necessary for public confidence in those

ALAPA also strongly supports prompt and comprehensive public availability of PADEP’s
response and oversight activities at the landfill, and ALAPA also supports the establishment of
the comprehensive odor complaint log as the authors recommend.

ALAPA supports PADOH and ATSDR’s recommendations concerning minimizing gull
populations near KSL and the working face of the landfill, installation and maintenance of
carbon monoxide monitors, and further pursuing vapor intrusion investigations as long as
subsurface conditions remain inadequately characterized to be regarded as perfectly safe.

As always, ALAPA supports the use by residents, especially those identified as particularly at
risk from exposure to air pollutants, of local air quality and wind direction predictions. Special
attention should be paid to those times when periods of light wind may be expected to bring
emissions from the landfill footprint into populated areas.

RE: Limitations

ALAPA appreciates that the authors clearly recognize that the “air sampling information … does
not represent air quality if the landfill expands its operations.” Therefore, in addition to the
retrospective picture provided by the health consultation, it would be extremely helpful for
residents of the area surrounding the landfill also to receive
- The best predictions or range estimates by PADOH and ATSDR regarding their
professional characterization of emissions (types, concentrations, locations) that might be
anticipated in the event the requested Phase III expansion of KSL is carried out;
- Specific recommendations regarding how monitoring of residents’ air quality and
surveillance of residents’ health status should be carried out in the years going forward.

ALAPA supports appropriate evaluation of hydrogen sulfide levels (and perhaps those of other
reduced sulfur compounds) in the future.

Furthermore, given the frequency of acrolein detection and its behavior as a strong respiratory
irritant, ALAPA strongly recommends that PADOH, ATSDR, and PADEP work together to
identify a viable method of detecting and reliably measuring concentrations of this pollutant.
“Deciding not to further evaluate acrolein” because of “data quality concerns with standard
analyses” for this pollutant is not a situation that should be considered acceptable.

Although it is stated that “the selected three months [January to April] do cover the time of the
year when residents reported the most complaints about odors from the landfill,” it appears that
certain facts may contradict that statement:
- First, although it appears the authors identify winter as “the time of year when residents
reported the most complaints about odors from the landfill,” we could find no table or
other enumeration in the public-comment draft cataloguing those odor complaints that
were ascribed specifically to the landfill.
- Second, Table C4 defines Winter as “December-February,” but December, that winter
month with the most complaints, was not part of the testing period.
- Third, if we understand correctly, the community air sampling with SUMMA canisters
and sorbent tubes was carried out between January 29, 2016 and April 29, 2016,
effectively omitting two of the three months of the winter period. Moreover, March and
April, two of three months during which testing did occur, are spring months, and
according to Table C4, are part of the season of year with the fewest complaints.
- Fourth, for the six years summarized, 2011-2016, the months with the most frequent
complaints were, in order: October, December, November, January, August, February,
September, March, July, June, May, and April. In fact, in 2016, 16 of that year’s 38 odor
complaints were submitted in August, nowhere near the testing period selected. And in
the two most recent years reported in Table C4, 2015 and 2016. the months with the most
complaints were August (22%), November (19%), and October (18%), none of which is a
winter month.

We are also concerned that only four odor complaints were reported during the (actual)
February-April period of sampling. At minimum, we are concerned that this may reflect that
emissions were simply not representative of higher rates that appear to occur with more
frequency at other times of the year. And perhaps of greater concern, it is important to learn if
KSL management and staff were aware of dates when sampling was being conducted, and to
learn of any extent to which operators modified their practices to be less likely to produce
emissions. Furthermore, did PADOH and ATSDR evaluate if activities at the landfill were being
modified in any way to respond to the fact that sampling was underway on the collection dates?

There is considerable variability apparent here, and it occurs to us that an analysis of time-logged
specific behaviors and practices being employed at the landfill may provide instructive
information as to the reasons for the wide variation, and perhaps even as to exact sources of the
odors reported. With that knowledge, then better control would perhaps be possible.

RE: Background

Please note the following excerpt from p.7 of the report: “Community members associate the
following health concerns with the landfill: cancer, immune system disorders, nervous system
disorders, birth defects, liver problems, skin problems, respiratory illnesses, muscular problems,
nosebleeds, and headaches.”

Clearly, the authors observe that community members do make these associations. The obvious
question that should be addressed is “Why? Are the community members observing any actual
associations?” To what extent have PADOH and ATSDR attempted to identify if any of these
claimed associations show any apparent relationship to proximity of population to KSL? In
other words, have any attempts been made to study geographic association at levels of resolution
smaller than the ZIP Code level?
RE: Cancer Exposure Evaluation

A correction: Where the text (on p. 14) currently has, “The EPA IUR for benzene is 0.0000078
µg/m3.” this should read, “… 0.0000078 per µg/m3.”

RE: Evaluation of PM2.5 Ambient Air Monitoring Data

It is clear from the data collected and displayed in Table D that there are many days when PM2.5
levels (from whichever combination of sources) pose an increased risk of adverse health
consequences, sometimes not only for populations known as “sensitive groups” but even
occasionally for the entire population of the area. It is therefore clear that there is absolutely no
margin for error, and that any activity at the landfill, or from traffic that services it, that increases
ambient PM2.5 levels should be considered as unacceptable.

We would recommend that the column “AQI Category Range” in Table D could be made much
more useful and understandable to the reader were this column simply to be divided into the
following five columns “Good, Moderate, Unhealthy for Sensitive Groups, Unhealthy, Very
Unhealthy,” with the correct number of days for each of the 20 months considered recorded in
each column.

RE: Report Preparers

A correction: Where the text (on p. 27) currently has, “Principle Investigator” this should read,
“Principal Investigator”

Additional Recommendations:

Although there are many worthwhile aspects of the Health Effects Evaluation, it was
nevertheless surprising that some existing repositories of significant information were not
recognized in the health consultation report for their potential value, let alone accessed and used
in this investigation. The information to which we refer would be the collected health records
and health and administrative logs at the Mid Valley School District’s high school and
elementary center located near the landfill.

As has been done in many public health contexts, such records could, within reasonable
constraints imposed by school officials, subsequent to a rigorous institutional review process,
and after establishment of all appropriate safeguards to protect confidentiality, be accessed by
properly credentialed and vetted public health investigators to look for the following kinds of
- Behaviors of students and administrators with respect to outdoor exposures or air quality
concerns—For example:
o Were any changes made with respect to building use (windows opened or
o Were any changes made in the procedures for student and staff arrival at and
departure from school?
o Were outdoor recesses cancelled or curtailed?
o Were outdoor practices similarly affected?
- History of complaints of odor exposure, any characterizations of those odors, and
observation of symptoms reported by students and staff, (e.g., irritant or toxicity
responses, sneezing, coughing, running nose, burning eyes, scratchy throat, difficulty
breathing), and to what extent symptoms appeared to lead to diagnosable conditions or to
exacerbations of chronic illnesses such as allergies or asthma.
- To what extent do concurrent daily/hourly meteorological records show correlations in
records of wind speed and direction with respect to the locations of the landfill and the
schools at times consistent with the logged changed behaviors or reported adverse health

Given, as we have noted in earlier testimony,
- that a significant portion of Dunmore Borough, including part of the footprint of the
landfill itself, has been identified by PADEP as an Environmental Justice (EJ) Area,
- that 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,
- and that, for many reasons, people in EJ communities also face a greater burden of lung
disease, making them even more vulnerable to these pollutants,
we recommend that the Health Consultation also specifically address the EJ status of the
community as it falls within the areas of concern discussed in the report’s Appendix A. In other
words, a comprehensive assessment should identify the pre-existing EJ-related health challenges
that the community faces and how they interact with additional health challenges posed by
environmental stressors discussed in the report.

Granting that there are deficiencies such as lack of paired pollutant values in both upwind and
downwind locations, and the lack of measurements taken during most of the months of the year
when most odor complaints were recorded, it is nevertheless clear from the report that there are
several occasions on which, even with limited data, non-cancer health effects and detriments to
quality of life are understood to be consistent with exposures to air pollutants (acetaldehyde,
ammonia, methylamine, and hydrogen sulfide) in the vicinity of KSL, and reasonably expected
to be associated with the landfill—and furthermore, that this information, despite its weaknesses,
can begin to serve as a baseline against which to measure future observations.

Specifically, it appears clear to us that better air quality data need to be collected
- During the months when odor complaints are in fact more likely;
- Especially, to the extent possible, at the time of events when air quality is generally
recognized to be more severe;
- In the landfill itself, as close to the working face, and near other potential KSL sources;
after all, if as has been represented, the landfill is not a problematic source, then there
should little objection to such sampling being carried out within the fence-line; and
- Addressing the need better to evaluate upwind and downwind pollutant concentrations.

The real concern here, of course, is what the implications of these findings are for future public
exposures to pollutants, and resulting health risks, under changes in landfill operations. As the
authors of the health consultation document are clear to point out, the information presented in
the report “does not represent air quality if the landfill expands its operations.” Furthermore, the
authors take additional pains to emphasize that “changes are anticipated that could impact the
community’s air quality including (1) landfill operations would move to a working face closer to
residential areas; and (2) the additional weight and composition of landfilled materials might
cause unknown changes in subsurface vapor conditions.” To the degree that the working face is
a likely generator of emissions, and given that proximity between source and receptor tends to
increase exposure, it is certainly possible, if not likely, that such landfill expansion would
increase nearby residents’ exposures, and would therefore result in more frequent, more severe,
and more widespread impacts on the community’s health.

# # #

Submitted by:

Kevin M. Stewart
Director of Environmental Health
American Lung Association in Pennsylvania
3001 Gettysburg Road
Camp Hill, PA 17011