Berkeley Body Burden Study: Health Risk for Pacific Steel Casting/title> <meta name="Description" content="City of Berkeley comments to the Health Rish assessment process for Pacific Steel Casting, Berkeley."> <meta name="Keywords" content="Body, Burden, Berkeley, East, Bay, Oakland, West, GCM, Global Community risk Health assessment Monitor, Pacific Steel Castings, Pacific Steel, nickel, manganese, toxic air contaminant"> <link href="css/style.css" rel="stylesheet" type="text/css"> <style type="text/css">  </style> </head> <body leftmargin="0" topmargin="0" marginwidth="0" marginheight="0"> <table width="800" border="0" align="center" cellpadding="0" cellspacing="0"> <tr> <td width="753" background="images/bg_1.jpg"><img src="images/BBS1header.gif" width="800" height="133"></td> </tr> <tr> <td valign="top"><table width="800" border="0" cellpadding="0" cellspacing="0"> <tr> <td width="153" valign="top" bgcolor="#AABFCB"><table width="151" border="0" cellpadding="0" cellspacing="0"> <tr> <td width="151" height="200" valign="top" bgcolor="#D5DDE2"><img src="images/Button-risk.gif" width="150" height="200"></td> </tr> </table> <table width="150"> <tr> <td background="images/btn_bg.jpg"><div align="center" class="xstyle"><a href="proposal.htm">Proposal & Process </a></div></td> </tr> <tr> <td background="images/btn_bg.jpg"><div align="center"><span class="xstyle"><a href="testarea.htm">Test Area</a></span></div></td> </tr> <tr> <td background="images/btn_bg.jpg"><div align="center"><a href="health.htm">Health Impacts </a></div></td> </tr> <tr> <td background="images/btn_bg.jpg"><div align="center"><a href="history7.htm">Public Health</a></div></td> </tr> <tr> <td background="images/btn_bg.jpg"><div align="center" class="menu"><a href="resources.htm">Resources</a></div></td> </tr> <tr> <td bordercolor="#C2D1DA" background="images/btn_bg.jpg"><div align="center"><span class="xstyle"> <a href="press.htm">News/Comment </a></span></div></td> </tr> <tr> <td bordercolor="#C2D1DA" background="images/btn_bg.jpg"><div align="center"><a href="team.htm">Project Team</a></div></td> </tr> <tr> <td bordercolor="#C2D1DA" background="images/btn_bg.jpg"><div align="center" class="xstyle"><a href="contact.htm">Contact</a></div></td> </tr> <tr> <td bordercolor="#C2D1DA" background="images/btn_bg.jpg"><div align="center" class="menu"><span class="xstyle"><a href="index.htm">HOME</a></span></div></td> </tr> </table> <span class="xstyle"><img src="images/Button-monitor.gif" width="150" height="36"></span> <table width="150" bgcolor="#A6BBC8"> <tr> <td background="images/btn_bg.jpg"><div align="center"><a href="history.htm">Air Monitoring Main</a></div></td> </tr> <tr> <td background="images/btn_bg.jpg"><div align="center" class="xstyle"><a href="history1.htm">Grant</a></div></td> </tr> <tr> <td background="images/btn_bg.jpg"><div align="center"><a href="history2.htm">94710 Sources </a></div></td> </tr> <tr> <td background="images/btn_bg.jpg"><div align="center"><a href="history3.htm">Procedures & Map </a></div></td> </tr> <tr> <td background="images/btn_bg.jpg"><div align="center" class="menu"><a href="history4.htm">Sampling Results </a></div></td> </tr> <tr> <td bordercolor="#C2D1DA" background="images/btn_bg.jpg"><div align="center"><a href="history5.htm">Data Summary</a> </div></td> </tr> <tr> <td bordercolor="#C2D1DA" background="images/btn_bg.jpg"><div align="center"><a href="history6.htm">Media Coverage</a></div></td> </tr> <tr> <td bordercolor="#C2D1DA" background="images/btn_bg.jpg"><div align="center" class="xstyle"><a href="history8.htm">Press Release </a></div></td> </tr> </table> <span class="xstyle"><img src="images/Button-guide.gif" width="150" height="36"></span> <table width="150"> <tr> <td background="images/btn_bg.jpg"><div align="center"><a href="psc-spanish.htm">Spanish</a></div></td> </tr> <tr> <td background="images/btn_bg.jpg"><div align="center" class="xstyle"><a href="psc-english.htm">English</a></div></td> </tr> </table></td> <td width="600" valign="top"><table width="650" border="0" cellpadding="0" cellspacing="0"> <tr> <td width="751" bgcolor="#A9ABB1"><img src="images/spacer.gif" width="1" height="2"></td> </tr> <tr> <td background="images/bg_4.jpg"><blockquote> <p class="style17"><strong>Health Risk Assessment from Pacific Steel Casting</strong></p> </blockquote></td> </tr> <tr> <td bgcolor="#BFC0C4"><img src="images/spacer.gif" width="1" height="2"></td> </tr> <tr> <td background="images/bg_dotted.jpg"><img src="images/spacer.gif" width="1" height="1"></td> </tr> <tr> <td valign="top" bgcolor="#D5D6D9"><table width="650" border="0" align="center" cellpadding="0" cellspacing="0" bgcolor="#FAF1EC" class="tdbgx"> <tr> <td colspan="3" valign="top"><ul> <li>Excerpt from: <a href="#HRA1">Comments on HRA from Michael P. Wilson, Ph.D., MPH</a> Commissioner, Community Environmental Advisory Commission<br> To: Berkeley City Council, March 13, 2007</li> <li><a href="#HRA">Comments on HRA from the City of Berkeley </a></li> <li><a href="risk1.htm">Comments on the HRA from TetraTech EM Inc.</a><a href="risk1.htm"> </a><br> <span class="style6">Note: Tetra Tech was a paid consultant to the City of Berkeley </span></li> </ul> <blockquote> <p><strong><a name="HRA1"></a>Above excerpt from: Comments on HRA from Michael P. Wilson, Ph.D., MPH</strong> Commissioner, Community Environmental Advisory Commission</p> <p>"The Bay Area Air Quality Management District is overly constrained in its capacity to protect public health in Berkeley to a degree that reflects modern science.</p> <p>The District's permit for PSC allows more, not less, toxic pollution from PSC. In 2005, the District granted the plant's request to increase its emissions from 90 to 95 tons, or 520 pounds per day, 19 tons more than the plant currently emits.</p> <p class="style19">"The District relies on health risk assessments (HRA) as the trigger to compel industrial polluters to reduce their emissions into Bay Area cities. With the exception of actions taken by the District in the dry cleaning industry, the District has not been able to use the results of a health risk assessment to compel any industrial polluter in the Bay Area to reduce its emissions of toxic substances. This reflects the weaknesses of the HRA process: its focus on cancer, its high threshold for action (100 excess cancers in one million), the lack of attention to multiple sources, its ease of manipulation, and so forth."<a href="history7.htm"> -More- </a></p> <p align="center">**************</p> <p><strong><span class="style19"><strong><img src="images/nickel.gif" width="130" height="120" align="right"></strong></span>Comments by City of Berkeley in HRA </strong><br> <br> <a name="HRA"></a>The Health Risk Assessment for Pacific Steel Casting raised many concerns. Below are some of the City of Berkeley's comments to the Bay Area Air Quality Management District regarding the HRA process.</p> <p>To: Scott Lutz<br> BAAQMD<br> 939 Ellis Street San Francisco, CA 94109</p> <p><strong>Pacific Steel Casting Emissions Inventory Report Comments</strong></p> <p>Thank you for the opportunity for commenting on the Emissions Inventory Report for Pacific Steel Casting (PSC) and for extending the comment period until January 20, 2007.</p> <p>The most important comment here is that we cannot fully review the Emissions Inventory Report or subsequent <span class="style19">health risk assessment</span> without significant amount of data being made available to the City and our consultant. PSC has labeled some of the information requested by the City and <a href="risk1.htm">TetraTech EM Inc.</a> as "Trade Secret". Additional information requested for the full human health risk assessment (HHRA) review is written up in this communication.</p> <p>Please accept this as interim comments that the BAAQMD can consider prior to approval of the Emissions Inventory Report. When we receive the additional documentation, we can continue the review of the Emissions Inventory Report and HHRA.</p> <p>We anticipate that a frill disclosure of all documentation listed and explanations for questions raised will be made available to the City and our consultant prior to approval of the Emissions Inventory Report and initiation of the health risk assessment.</p> <p class="style19"><strong><em><img src="images/mang.gif" width="130" height="120" align="right"></em></strong>Emissions Inventory Report - In general, given the sensitive nature of the site, we believe the Emissions Inventory Report does not adequately characterize the toxic emissions.</p> <p>The Emissions Inventory Report refers to Figures 3-6 but these figures have been deemed trade secrets and are not available for review. It is difficult to confirm potential emissions points, potential fugitive emissions and specific emittants without reviewing the full operational schematics.</p> <p><span class="style19">PSC contracted the Avogadro Group to test for dioxins in the in the thermal sand recycling unit of Plant 703 and the pouring, cooling and shakeout stack of Plant 1603. Research indicates that dioxins are found in emissions from electric arc furnaces </span>(U.S. Environmental Protection Agency (EPA), 2003. "Exposure and Human Health Reassessment of 2,3,7,8-Tetrachlorodibenzo-p-Dioxin (TCDD) and Related Compounds". Office of Research and Development. EPA/600/P-00/00l/Cb. Washington. DC. December.). <span class="style19">Why were the electric arc furnace emissions not tested?</span></p> <p>In light of the numerous studies along the freeways, and the large number of noncompliant days this winter, it is unusual not to see monitoring data for particulate (PM) emissions. As you know, the City has already determined that many high risk residential uses in the area of PSC are incompatible with the level of particulates in the air. Adding more PM from PSC into an already high ambient conditions is an adverse impact to the community. We have already requested PM monitoring data be made available, please assure us that this will be included in any future testing.</p> <p>For maximum hourly throughputs that were calculated by using the annual throughput divided by the hourly usage, this is, in reality, only an average hourly throughput. Therefore, this cannot be considered a maximum hourly throughput rate. This adjustment for maximum hourly emissions rate will be important as the HARP modeling includes acute scenarios that are based on max hourly rates.</p> <p>Different annualized reporting periods were used for throughput calculations depending on the specific plant. Please document why these start and end dates were chosen and provide documentation to verify this and compare to past years (at least 10 years of data in tabular form would be ideal) so that we may get a better idea of potential future variations in throughput/emissions and risk.</p> <p>Please provide maintenance and operations data that describes and documents PSC's monitoring protocol for breakthrough on carbon adsorption systems. These systems are only as effective as the controls put in place to ensure their efficiency.</p> <p>Please provide additional information, as it is developed, related to input parameter values to be used in the HARP modeling. The most important of these input data are sensitive receptor location, physical stack information and confirmation that all sources have been captured including ancillary sources such as emergency backup generators. It should also be noted that facility related mobile sources have a high potential to impact sensitive receptors from an inhalation pathway standpoint. Mobile sources, such as the truck fleet delivery of raw goods, materials and finished products, have not been considered in this Emissions Inventory Report.</p> <p class="style19">Answers to these questions are of critical importance to the results of HHRA. Once the Emissions Inventory Report is used to establish inputs for the HHRA a higher level of precision and accuracy will be required to ensure both Acute and Chronic risks are adequately characterized. We would also request that the input transaction files (tra) for the HARP modeling be shared with the City of Berkeley and our consultant prior to the modeling.</p> <p>PSC has operated its facilities with large open doors and in some cases, the factory "skin" is old and in need of repair. Are PSC's operations in this manner in keeping with BAAQMD conditions? It is unlikely that the statement on Page 17 of the report suggesting the factory can maintain a negative pressure to eliminate fugitive emissions is dependable. Has BAAQMD should consider all potential fugitive emissions sites for monitoring based on observed conditions and practices.</p> <p>Title V - We believe it is premature to conclude that PSC is in compliance with BAAQMD Regulation 2, Rule 6 (Title V - Federal Operating Program) based on the information we have reviewed to date. <br> <br> We have several ongoing concerns related to this matter. First and foremost, we have not yet reviewed any Compliance Assurance Monitoring (CAM) information that adequately documents PSC compliance with the Synthetic Minor Operating Permit (SMOP) limit of 95 tons per year (tpy) of Precursor Organic Compounds (POC). We would like to review PSC's CAM protocol and a CAM summary report for each year the SMOP has been in effect, that is 2002 to the present. Without a CAM summary that clearly demonstrates emissions/controls it is difficult to assess compliance with Regulation 2, Rule 6. We have also noted that the SMOP limits have changed over the years from 90 tpy to 95 tpy and we would like an explanation for this.</p> <p>Mr. Bateman's letter (9/9/05) requiring expansion of the SMOP to include Plant # 187 that CAM becomes even more critical. Based upon review of correspondence from early 2006 it is unclear if PSC has met the requirements to document meeting the SMOP threshold of 95 tpy of POC emissions. To make a compliance determination it is imperative that PSC or BAAQMD provide a clear, concise CAM summary report for each year of operation under the SMOP.</p> <p class="style19">PSC has been in operation since the 1940's. PSC is a major source facility for Volatile Organic Compounds (VOCs) based on emissions inventory information, this site has been emitting VOCs greater than Title V major facility thresholds for many years. At the time of application in 2001 they had a reported Potential to Emit (PTE) of 475 tons of VOCs. Based on permitting records it appears that PSC didn't engage the BAAQMD and apply for a Title V permit until 2001. CFR 40 Part 70, the Federal Operating Permit Program, was originally codified as part of the Reauthorization of the Clean Air Act in 1990. <br> </p> <p class="style19"> Most state Title V programs were commenced and put in place in the mid-1990's. It is of concern that PSC was not brought into the Title V program until approximately 6 years after the time in which other similar facilities throughout the US. would have been required to apply for a federal operating permit. This delay in applying for a Title V permit gave PSC a fill six years of operating in violation under CFR 40 Part 70 thereby circumventing certain facility-wide restrictions on air pollution during that time.</p> <p>We have a concern over the timeframe from the initial application for a SMOP to the time that BAAQMD actually reviewed and provided comment on the application. More than a fill year elapsed between application and permit review and approval by the District. This delay allowed PSC to emit without proper regulatory oversight for an additional year.</p> While we are aware of the OEHHA has not allowed for all potential health risk reviews, it is our conviction that particulates are sufficiently a concern that new requirements for testing should include PM2.5 and PM 1 0 stack and fugitive emission testing. <p><br> </p> </blockquote></td> </tr> </table></td> </tr> <tr> <td><img src="images/spacer.gif" width="1" height="1"></td> </tr> </table></td> </tr> </table></td> </tr> <tr> <td background="images/bg_3.jpg"><table width="100%" border="0" cellpadding="0" cellspacing="0"> <tr> <td align="center" valign="middle" background="images/background.gif" class="style6"><font color="#000000"><a href="index.htm">HOME</a><span class="menu"> || <a href="proposal.htm">Proposal</a></span> ||<a href="process.htm"> Process</a> ||<a href="testarea.htm"> Test Area</a> || <a href="health.htm">Health</a> ||<a href="history.htm">Monitoring</a> || <a href="resources.htm">Resources </a>|| <span class="menu"><a href="press.htm">News/Comment</a></span> || <a href="team.htm">Team</a> || <a href="contact.htm">Contact</a></font></td> </tr> <tr> <td align="center" valign="middle" background="images/background.gif" class="style6"><span class="style20">Berkeley Air Monitors © 2009-2010 All Rights Reserved</span></td> </tr> </table></td> </tr> </table> </div> <p align="center" class="style6"> </p> </body> </html>