Childhood cancer crisis & a toxic legacy: Tell EPA-sample for vapor intrusion into homes
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"Diagnosed with terminal brain cancer at age 13 and with only 3 months and 13 days left of her tragically short life, Emma Grace Findley captured the hearts of not only her community but inspired many around the US and world. Today, we fight in her memory and are inspired by her spirit to answer why so many children in our community face this battle." - Kari Rhinehart, community leader who lost her daughter in 2014.
For nearly a decade, the vibrant community of Johnson County, IN has been fighting dual battles: their rising childhood cancer rates and the frustration of their own health and environmental agencies minimizing public concern.
Upon independent investigation into several local toxic legacy sites, it has become clear that there are significant unresolved issues and data gaps. Families in Johnson County and beyond may continue to be unknowingly exposed to hazardous chemicals if these are not addressed. Sign our petition urging the US Environmental Protection Agency to conduct vapor intrusion sampling of the homes in Johnson County and to reevaluate a leaking former industrial site for inclusion on the National Priorities List.
RISING CHILDHOOD CANCER RATES
"To see the look on his face when we get a phone call of a new diagnosis is heartbreaking. I know what is going through his mind. 'Another one? Relapse? Will I relapse?' Those thoughts are something no child should ever have to wonder." - Stacie Davidson, community leader and stepmother of Zane Davidson, who is in remission after 3 1/2 years of being treated for Acute Lymphoblastic Leukemia.
The latest National Cancer Institute (NCI) data shows that the age-adjusted cancer incidence rate for children under 20 in Johnson County (22.2) is higher than the state average (17.3); even more alarming is the rates in Johnson County are rising. According to the community and local news outlets, approximately half of the children diagnosed since 2009 have lived or spent significant time in Johnson County's small town of Franklin.
An investigation released by the Johnson County Health Department in December 2017 concluded that, "The difference between the observed number of childhood cancers diagnosed in Johnson County and the number expected was not statistically significant."
Any objective observer can see that what is significant is elementary school children developing cancers typically seen in 60-year old adults. What is significant is that childhood cancer rates continue to rise. What is significant is the storied history of poor housekeeping practices at Johnson County sites that contaminated the surrounding environment.
One critical piece that has been left out of the human health conversation has been a comprehensive investigation into child-specific exposure factors from several contaminated sites in Johnson County. Without additional sampling efforts to address fundamental data gaps, the sites and off-site areas remain incompletely characterized and the human health risk analyses reliant on assumptions.
A TOXIC LEGACY
The nonprofit advocacy group, Edison Wetlands Association (EWA) has investigated over 25,000 pages of confidential government reports, memos, and test results for contaminated sites in Johnson County, many of which had previously never been reviewed by the community. The EWA and its team of technical advisors have found that human and environmental impacts have not been adequately characterized at one site in particular, the former Amphenol Corporation.
The former Amphenol Corporation (aka Franklin Power Products) site operated under several other owners and operators during its 55-year history in Franklin, IN. From 1963 to 1983, electrical parts were manufactured on the approximately 15 acre site, with metal hydroxide sludge, volatile organic compound (VOC) solvents and thinners (including trichloroethylene (TCE) and 1,1,1-trichloroethane), and cyanide solutions reported as some of the wastes generated, stored in tanks, and leaked directly into the ground.
Some of the many poor housekeeping practices at this site included a leaking plating room floor that discharged chemicals into the subsurface, and a damaged sewer line that also drained wastewater contaminants into the surrounding environment. In a 1985 Site Assessment report, high levels of up to 19,000 parts-per-billion of TCE and 13,000 parts-per-billion of 1,1,1-trichloroethane were reportedly detected in onsite groundwater, along with a witches' brew of other hazardous chemicals. Cleanup activities, which included installation of a groundwater treatment and recovery system, under the RCRA Corrective Action program were said to be complete in December 1998.
In January 2007, the Indiana American Water Company (INAWC) stopped using two drinking water wells in Franklin's Webb Wellfield due to detection of 1,2-dichloroethylene (1,2-DCE) contamination exceeding Maximum Contaminant Levels (MCLs). A third well was abandoned in 2012, and TCE above MCLs was also detected near the drinking water wells. According to the water company and its attorneys, a toxic plume containing volatile organic compounds (VOCs) had migrated from the Amphenol site to its wellfield which served approximately 50,000 people. Amphenol Corporation argued that the VOC contamination found in the wellfield had no link to its site.
VOCs easily become vapors/gases, and many are toxic to multiple body systems. TCE, for example is classified by the International Agency for Research on Cancer as carcinogenic to humans by all routes of exposure. Children are especially vulnerable due to "critical windows of development" (World Health Organization) that are not present in adults.
Maximum Contaminant Levels (MCLs) and other standards set by agencies often do not take into account highly sensitive populations, like children, or the synergistic effects of exposure to multiple chemicals. It is generally agreed in the academic community that there is no safe dose of a carcinogen, as "even small doses may have a relevant biological effect" (National Academies of Science, Advancing Risk Assessment).
DATA GAPS THAT NEED TO BE ADDRESSED
According to EWA research, the Amphenol site was evaluated for inclusion on the USEPA's National Priorities List (NPL) nearly 30 years ago in the late 1980s, when preliminary scoring worksheets were completed using the Hazardous Ranking System (HRS).
The total projected score for the site (with observed release to groundwater) was calculated as 44.60, well over the threshold of 28.50 that qualifies sites for inclusion on the NPL. In 2017, vapor intrusion - a fancy way of describing toxic gases leaking into homes, schools, and other buildings - was added to the HRS criteria. Although vapor intrusion may be one pathway of children's unacceptable exposures to contaminants in Johnson County, the site has not been reevaluated using the new criteria.
Vapor intrusion was first identified as a potential issue for the Amphenol site as early as December 1995, even though nearly a year before an onsite recovery system (ORS) began operating to pump and treat contaminated groundwater. A memo written by a federal USEPA hydrogeologist warned, "Contaminants may volatilize from a NAPL [non-aqueous phase liquid] source in the vadose zone or from contaminated groundwater. It is not clear whether transport of such contamination and risks to nearby residential areas were considered in the previous documents."
A draft report was submitted to the EPA the following year, which "theoretically" determined that there was "little" indoor air risk to adjacent homes from groundwater seeps, as the hypothetical risk fell within the 10^-4 to 10^-6 range - meaning that it would be acceptable if 1 in 10,000 to 1 in 1,000,000 people got cancer as a result of exposure to contaminants. It was noted in the document that the model used was "limited" and that the "conclusions have not been validated with field data."
Not only has the vapor intrusion risk not been comprehensively evaluated since this time, but there is no indication that the residential homes ever had actual indoor air quality monitoring performed. The most recent round of groundwater data provided to EWA shows that even in 2016, the highest concentrations of volatile organic contaminants (VOCs) were detected in monitoring wells near the residential areas adjacent to the site. This raises even more concerns as to the possibility for harmful chemicals to seep into indoor spaces or to impact private drinking water wells in the region.
In accordance with EPA's Child-Specific Exposure Factors Handbook, the Amphenol site and off-site areas, including residential homes, should also be evaluated for children's and other sensitive populations' differing vulnerabilities and exposure pathways before it can be determined that human exposures are under control.
As more children in the community continue to get diagnosed and families increasingly feel unsafe in their homes, it is long overdue that the agencies prioritize meaningful community involvement in investigating this site and others - and this includes sampling the 'human environment' where children live, sleep, and play.
OUR VISION AND HOW YOU CAN HELP
The Edison Wetlands Association (EWA) is organizing and funding the first round of sampling the homes in Johnson County to determine a) if toxic vapors are migrating from the subsurface into the homes, and b) if concentrations of select contaminants detected in the indoor air are above human health criteria. The EWA strongly requests the US Environmental Protection Agency to join the EWA in taking split-samples to most efficiently fill data gaps and adequately delineate the extent of contaminant movement into the residential areas.
It is by design that EPA's mission includes protecting both human health and the environment. Furthermore, Presidential Executive Order 13045, "Protection of Children From Environmental Health Risks and Safety Risks" directs federal agencies to "make it a high priority to identify and assess environmental health risks and safety risks that may disproportionately affect children." We are calling on the USEPA to fulfill this mission and Executive Order 13045 by conducting sampling with the EWA, reevaluating the Amphenol site using the new vapor intrusion criteria, and addressing public concerns at our first meeting with the Johnson County community in June 2018.
No child should have to develop cancer or lose their life because they grew up in the wrong zip code. Take action and sign our petition now - the families of Johnson County and anyone who believes children have the right to grow up in a safe and healthy environment are counting on you!
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