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A project of People’s Action Institute

February 14, 2018

Re: Comments on the Health Consultation Public Comment Version
Keystone Sanitary Landfill, Dunmore, Lackawanna County, Pennsylvania
Prepared by the Pennsylvania Department of Health
December 14, 2017

Comments Submitted by Stephen Lester, Science Director
Center for Health, Environment & Justice
Falls Church, VA

Submitted via email to Env.health.concern@pa.gov

These comments are submitted on behalf of the Center for Health, Environment & Justice a
project of People’s Action Institute on the ATSDR’s Health Consultation Public Comment
Version, Keystone Sanitary Landfill, Dunmore, Lackawanna County, Pennsylvania, released on
December 14, 2017. CHEJ, based in Falls Church, VA, was founded in 1981 by Lois Gibbs, the
community leader from the Love Canal neighborhood in Niagara Falls, NY. We provide
organizing and technical assistance to grassroots community groups nationwide.

The Center for Health, Environment & Justice (CHEJ) has been providing technical and
organizing support to the grassroots community-based group Friends of Lackawanna (FOL) and
to the residents of the Dunmore/Throop area since 2015. We have closely followed activities
related to operations of the Keystone Landfill including providing technical assistance to Friends
of Lackawanna on air emissions, surface water contamination and general environmental
testing data that have been collected to evaluate the risks that the landfill poses to people
living in and around Dunmore and Throop. In particular, I have reviewed the air tests that were
conducted by the Pennsylvania Department of Environmental Protection (PA DEP) in April and
June of 2015. This relationship led to this review of the Health Consultation Public Comment
Version, Keystone Sanitary Landfill, Dunmore, Lackawanna County, PA.

The Agency for Toxic Substances and Disease Registry (ATSDR) Health Consultation report was
prepared in response to a request from a Pennsylvania state representative as well as from
community members “to conduct an environmental health study and evaluate air quality
around the landfill (ATSDR Report, p.7). According to ATSDR, this health consultation “is
principally focused on our public health evaluation of PADEP’s 2016 ambient air sample results
(ATSDR Report, p. 8). In addition, ATSDR also evaluated “available data on particulate matter in
ambient air in the area, subsurface investigation, as well as rates of cancer in the community”
(ATSDR Report, p. 8).

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In my capacity as science director at CHEJ for more than 30 years, I have had the opportunity to
review many of ATSDR’s Health Assessment and Health Consultation reports. Unfortunately,
this report suffers from many of the same fundamental flaws and limitations that I have seen in
similar documents that greatly limit the evaluation and assessment of public health risks
considered by the agency. The most significant of these flaws is the reliance on limited available
environmental and health data to draw conclusions and recommendations. I am also concerned
that ATSDR failed to conduct an analysis of the cumulative risks the residents living near the
landfill face and how the use of limited environmental and health data impacts its analysis and
evaluation of the public health risks posed by the Keystone Landfill. These and other concerns
are discussed below.

1) ATSDR’s public health evaluation including its analysis and conclusions are based on
limited environmental data collected by the PA DEP.
ATSDR’s public health evaluation including its analysis and conclusions are based on limited
environmental data collected by the Pennsylvania Department of Environmental Protection
(ATSDR Report, p. 8). This data was collected from ambient air samples using summa canisters
and sorbent tubes from January to April 2016 at two community monitoring stations (Mid
Valley High School and Sherwood Park) and at one location near the landfill (ATSDR Report, p.
9). The samples were collected over a 24-hour period every three days during the sampling
period. The samples were analyzed for 75 volatile organic compounds (VOCs); 20 reduced sulfur
compounds; 3 carbonyl/aldehyde compounds; ammonia; methanol; methylamine; and
trimethylamine (ATSDR Report, p. 9).

Although the PA DEP had collected previous air samples, that data was not evaluated by ATSDR
in its public health consultation report because of problems with the methods used to collect
the samples (ATSDR Report, p. 8). As a result, the data collected using the summa cannisters
was the only data that ATSDR relied upon in making its conclusions and recommendations in
the health consultation report. Thus, the only data that ATSDR considered in its public health
evaluation resulted from two ambient air samples collected intermittently over a 3-month
period and analyzed for a limited number of substances based on the earlier testing. This
testing is limited by the short sampling period (three months) which does not represent the full
range of exposures that might occur throughout a full year (ATSDR Report, p. 26). In addition,
only having two community and one landfill sample clearly limits the understanding of the
potential air emissions coming from the Keystone Landfill and its impact on the residents living
nearby.

The previous air sampling conducted by PA DEP occurred in April and June 2015 and in March
2016 (ATSDR Report, p. 8). On each of the sampling dates, two samples were collected from the
Keystone Landfill property and four samples were collected from different public locations in
the community outside the landfill property. These samples were collected using an Open Path
Fourier Transform Infrared (OPFTIR) spectrometer system as part of PA DEP’s Mobile Analytical
Unit (MAU) (ATSDR Report, p. 8). This sampling system collected an instantaneous
measurement of contaminants that are present in air at the time of the sampling. This is

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literally a moment in time “snapshot” of the potential chemicals present in the air. Most
ambient air testing is collected over periods of time such as 60 minutes, 4 hours, 12 hours or 24
hours. This testing only measures chemicals present at the precise instantaneous moment that
the sample is collected. Data collected this way cannot reflect what the residents living around
the landfill might be exposed to over a 24-hour period or even longer.

Because of this inherent flaw in the testing method, the data that was generated has limited
value for assessing public health risks. ATSDR put it this way: “This method has limited utility for
public health assessment because of its high detection limits and because the instantaneous
readings cannot be converted into appropriate exposure values for evaluation of potential
health effects” (ATSDR Report, p. 8). These data “were not evaluated for further assessment”
by ATSDR (ATSDR Report, p. 8). A summary of this data is however included in ATSDR’s health
consultation report (see Appendix C).

2) ATSDR failed to analyze how using only existing available data impacts its analysis and
evaluation of the public health risks posed by the Keystone Landfill.
While ATSDR does acknowledge the limitations of the available data that was collected by the
PA DEP (see ATSDR Report, pp. 25-26), they nonetheless drew conclusions and made
recommendations based on this very limited testing. The agency fails to discuss or even
acknowledge how the limited testing impacts its analysis and evaluation of the public health
risks posed by the Keystone Landfill. The agency also failed to provide any recommendations on
the need for and value of additional testing. This is an enormous disservice to the residents of
Dunmore and Troop and to the public in general.

It would have been very helpful to the residents to have had the benefit of an analysis that
discusses how the limited testing may underestimate or even overestimate the true daily
exposures that may be occurring in the vicinity of the landfill. They would have benefited from
a discussion of what testing (where, when and for what substances) would have provided more
meaningful data. Recommendations along this line would have been a valued contribution to
the public understanding of the testing that was done.

The residents invited ATSDR to come to Dunmore because there was hope, if not trust, that the
agency would conduct a fair and honest analysis and evaluation of the public health risks posed
by the Keystone Landfill. This means more than simply acknowledging that the available data
was limited and then drawing conclusions as though this data was adequate to do so. It means
providing a balanced discussion of how the limited data impacts the analysis and evaluation of
the public health risks posed by the landfill.

For example, the first conclusion reached by ATSDR is 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 or harmful non-cancer health effects under the landfill’s current operating
condition” (ATSDR Report, p. 22). The agency based this conclusion on the limited data that was

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collected by PA DEP. There is no discussion, however, of whether this data is adequate and
sufficient to evaluate the long-term/chronic public health risks posed by the landfill. How can a
single sampling event intermittently collected over a 3-month period at only two locations in
the community and analyzed for a limited number of substances be sufficient to draw
conclusions about the long-term public health risks posed by the landfill? At best, this is an
educated guess, an opinion on what the future health risks might be. It is certainly not a hard
conclusion of what the true risks might be. This is especially true given the qualifier in the
conclusion “…under the landfill’s current operating conditions.” Clearly, there is no guarantee
that the current operating conditions reflect the norm or even the average state of the
operating conditions that occur at the landfill. It certainly does not reflect any worst-case
scenarios that might occur such as an accident, explosion or fire at the landfill.

3) ATSDR failed to consider cumulative risks in its health evaluation.
Perhaps the greatest flaw in this health evaluation is ATSDR’s failure to consider the cumulative
risks of living near the Keystone Landfill. Numerous substances were found in the ambient air
around the landfill (see Appendix C). Each of these substances was evaluated against a single
comparison value to determine if it exceeded that guideline or not. This approach would have
been fine if the public was exposed to a single substance or to only a handful of substances, but
that is not the case. Many substances were found in the samples collected from the community
locations and from the locations near the landfill. Furthermore, air exposures were the only
route of exposure considered in this assessment. Cumulative exposure is a measure of how the
public is exposed in the real world. People are exposed to all of the chemicals coming from the
landfill for varying periods of time from all routes of exposure. Unfortunately, this health
consultation fails to consider concurrent multiple routes of exposure and in fact, does not even
mention it. This is also a huge disservice to the people of Dunmore and Throop who have asked
ATSDR to evaluate the public health risks posed by living near the Keystone Landfill.

4) ATSDR used limited comparison values to evaluate the air sampling data.

ATSDR used various comparison values including its own – Cancer Risk Evaluation Guides
(CREGs) and Minimal Risk Levels (MRLs); EPA ambient air quality guidelines and Reference
Concentrations (RfC); values generated by the National Oceanic and Atmospheric
Administration (NOAA); several state values (TX and CA) and different odor threshold values to
evaluate the public health risks posed by the substances found during the air sampling (see
Appendix C). They had to use so many comparison values because no one set of values matched
the many substances found in the ambient air. It is not clear however, why certain comparison
values were chosen. For example, why did ATSDR use values developed by the Texas
Commission on Environmental Quality (TCEQ) and the California Air Resources Board (CARB)?
The agency should have included some discussion of why these comparison values were used
and not values generated by other states. In addition several of the values that were used
(NIOSH RELs and ACGIH values) are intended to protect workers and are not appropriate
comparison values for community settings. These values should not have been used, especially
without more in-depth discussion.

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An option that the agency should consider is the air guidance values developed by the state of
Massachusetts Department of Environmental Protection called Threshold Effects Exposure
Limits (TELs). These TEL values “are used to evaluate potential human health risks from
exposures to 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” (see
http://www.mass.gov/eea/agencies/massdep/toxics/sources/air-guideline-values.html).

Using these values provides another perspective and understanding of the potential health risks
posed by the substances found in the air of the community. For example, in April 2015, the
results of the PA DEP air testing conducted at Sherwood Park identified 14 different substances,
six of which 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.

5) The cancer data that was evaluated was limited to only considering data by zip code.
ATSDR evaluated cancer incidence by using available data organized by zip code areas. This is a
standard analysis that has very little meaning or value in answering the question of whether
chemicals from the Keystone Landfill regardless of what exposure pathway taken is affecting
the health of the residents who live near the landfill. It is not surprising, but very disappointing
that ATSDR would choose to use such an insensitive and largely irrelevant measure to evaluate
the health risks posed by the landfill. A zip code area is a broad surrogate for exposure that
defines everyone who lives in the zip code as being equally exposed. Whether someone lives
within a block or two of the landfill or whether they live at the farthest point in the zip code
from the landfill, everyone is considered equally exposed. In fact, there are large variations in
exposure between those people in the zip code who live extremely close to the landfill and
those in the zip code who do not. This a very blunt and insensitive measure of exposure and
does little if anything to answer the question of whether chemicals from the landfill are
affecting the health of the residents who live near the landfill.

The assumption made by ATSDR when it chose to use zip codes as a surrogate for exposure is
that people who live in zip code areas closest to the landfill would have greater exposure to
chemicals associated with the operation of the landfill and thus be at greater risk of developing
adverse health problems, in this case, cancer. But by using this exposure metric, ATSDR greatly
reduces a critical element in any health assessment and that is to identify the people who have
been exposed to chemicals from the landfill. This approach greatly reduces the likelihood that
this analysis would identify any relationship between the landfill and health outcomes. At a
minimum, ATSDR should have included a discussion of the limitations of this analysis.

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6) ATSDR found that there is insufficient data to evaluate the current and future
potential exposures and subsequent health risks due to the migration of chemical
vapors from the landfill, a process known as vapor intrusion.
Vapor intrusion is the movement of volatile chemicals from a source such as the landfill through
soil and into the basement of buildings such as homes located near the landfill. This is a
common exposure pathway and public health risk for people living or working in buildings
located near landfills. The primary concern is the potential for homes to explode due to the
buildup of methane gas migrating from the landfill. The secondary risk is the infiltration of
volatile organic chemicals that travel in the gas from the landfill into the nearby homes. This is a
significant health risk that ATSDR has rightly included in its assessment. What they found was
that a “data gap exists for assessing current and future exposures from subsurface vapor
migration from the landfill into residences” (ATSDR Report, p. 12). They also point out that
changes in the operation of the landfill could impact future subsurface vapor migration
pathways.

The recommendation made by ATSDR to address this data gap is extremely weak. It simply
suggests that the PA DEP “consider working with the landfill to perform vapor intrusion
investigations in the Swinick community…” (ATSDR Report, p. 27). The agency’s
recommendation to investigate the vapor intrusion pathway from the Keystone Landfill should
have been directed to the PA DEP requiring additional testing by the PA DEP not the landfill
operator who has no incentive to determine the extent of vapor intrusion occurring from its
landfill. Testing for vapor intrusion in nearby homes and along pathways between the landfill
and nearby homes should be done by the PA DEP not the landfill operator. Their credibility in
conducting such testing properly and in a fair and objective manner would be extremely low.

7) Despite limitations in the data available to ATDSR, the agency still found that some of
the contaminants detected in ambient air near the landfill could have caused
transitory adverse health effects for members of the community.
Despite many limitations, ATSDR does conclude that “acute (short-term) exposure to some of
the contaminants detected in ambient air near the landfill could have caused transitory health
effects for sensitive populations, such as pregnant women, children, older adults and people
with respiratory disease” (ATSDR Report, p. 23). Benzene and formaldehyde, both known
human carcinogens, were detected above ATSDR’s Cancer Risk Evaluation Guides (CREGs) but
within EPA’s target risk range ...” (ATSDR Report, p. 22). The EPA target risk ranges from a low
risk of one-in-one million (1E-6) to a high risk of one in 10,000 (1E-4). This risk range is intended
to be used when evaluating risks at federal Superfund sites, primarily for establishing cleanup
levels. It is not intended for initial site assessment. Usually an acceptable risk level of one-in-
one million is used as trigger or red flag during initial testing and site assessment. If this level is
exceeded, then more testing is required. This is the situation at Dunmore. The broader risk
range should not be used to dismiss the levels found in the ambient air in the community.

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In addition, there were peak short-term (daily or 24 hour) PM2.5 exposure concentrations that
could have harmed people’s health (in every month measured for the daily average) (ATSDR
Report, p. 23). Ammonia exceeded the ATSDR comparison value at the Mid Valley High School
and other substances - methylamine, acetaldehyde and hydrogen sulfide - exceeded various
odor thresholds which can result in acute adverse health effects (ATSDR Report, p. 23). These
findings are consistent with testing conducted by the PA DEP in March and April 2015. It also
speaks to the transitory nature of air emissions and to the limited picture of potential air
emissions provided by air testing. It likely represents the tip of the iceberg and an
underestimate of the everyday exposures from the landfill.

8) ATSDR defined its objectives for the health consultation without consulting with
community leaders.
It is unclear how the ATSDR determined what the main objectives of the health consultation
would be. This is critically important because these objectives drive the analysis and
conclusions reached by the agency. ATSDR defines the main objectives of the health
consultation as: 1) to determine if exposure to contaminants in ambient air surrounding the
landfill poses a public health risk to the community near the landfill under the landfill’s current
operating conditions; 2) to evaluate available environmental information for other potential
community exposure pathways of concern related to the landfill; and 3) to address concerns
about cancer rates in the community by summarizing the most recent cancer incidence data for
the population living near the landfill (ATSDR Report, p. 1). There is no discussion of whether
these objectives were discussed with representatives of the community including Friends of
Lackawanna. There is no discussion of whether these objectives are consistent with answering
the questions the community has about the public health risks posed by the Keystone Landfill.
There is no point in conducting this health consultation if it cannot answer the questions the
community has about the public health risks posed by the landfill.

The following suggestions are offered to ATSDR to improve its Health Consultation report for
the Keystone Landfill in Dunmore, Lackawanna County, Pennsylvania.

1) ATSDR should address whether the available ambient air samples are adequate and
sufficient to properly evaluate and assess the public health risks posed by the
Keystone Landfill.

2) ATSDR should conduct an analysis of how using only existing available environmental
data impacts its analysis and evaluation of the public health risks posed by the
Keystone Landfill.

3) ATSDR should discuss how additional testing data would impact the analysis and
evaluation of the public health risks posed by the Keystone Landfill.

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4) ATSDR should include an analysis of cumulative risks in its evaluation of the public
health risks posed by the Keystone Landfill.

5) ATSDR should provide its reasons for choosing the comparison values that it used
including selected state values. The agency should also include a balanced discussion
when sampling data such as the results for benzene and formaldehyde exceed one
comparison value (CREGs) but not another (the EPA target risk range).

6) ATSDR should expand its use of comparison values to evaluate the air sampling data
to include values such as the state of Massachusetts Department of Environmental
Protection Threshold Effects Exposure Limits (TELs).

7) ATSDR should include a discussion of the limitations of evaluating the cancer data by
using zip codes as a surrogate for exposure.

8) ATSDR should direct the PA DEP to conduct additional testing to determine the extent
of vapor intrusion occurring from the Keystone Landfill. Testing for vapor intrusion in
nearby homes and along pathways from the landfill to nearby homes should be done
by the PA DEP not the landfill operator who has a clear bias.

9) In the future, ATSDR should always define its objectives for a Health Consultation in
consultation with community leaders.

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