Letter from Dr. Lee, Nov. 21, 2009

On November 21, 2009, “The Cape Breton Post” of Sydney, Nova Scotia, Canada printed a letter to the editor from Marlene Kane of Sydney that addressed concerns about health hazards associated with emissions from the Sydney Tar Ponds. My comments on the issue, directed to

D. Ouellette, a concerned citizen with whom I have had contact, follow.

November 21, 2009

Debbie Ouellette:

I would add to Marlene Kane’s discussion of problems with the remediation of the Tar Ponds by noting that even if STPA had prescribed adequate monitoring in accord with today’s standards, it would still not mean that there would be no health hazard associated with volatile and dust emissions from the remediation effort at the Tar Ponds. The fact that odors are detected off-site in residential areas should be of concern since it shows that volatile and other emissions are being transported to the residential areas and could readily be a health hazard to those exposed to the odors.

While odorous chemicals are often characterized as a “nuisance,” it has been well-established that they can, and do in-fact, have adverse health impacts on some individuals. Further, many chemicals that are not odorous, but are hazardous, that can be released from hazardous chemical sites like the Sydney Tar Ponds when the area is disturbed, such as during remediation as being practiced by the STPA. Thus, the absence of odors does not mean that there are no airborne health hazards. However, the presence of odors from a site like the Sydney Tar Ponds is a good indication of potential health hazards. Remediation at sites like the Sydney Tar Ponds areas should be conducted under a dome, and exhaust air should be cleaned prior to release to the environment to control offsite odours and other hazardous chemicals.

I have discussed information on health effects of odors in a number of my reviews, including:

Lee, G. F., and Jones-Lee, A., “Association between Hazardous Chemical Sites and Illness,” Report of G. Fred Lee & Associates, El Macero, CA, January (2007).  http://www.gfredlee.com/Landfills/HazChemSites-Illness.pdf

Lee, G. F., “Comments on Psychological Impact of Offensive Odors,” Report of G. Fred Lee & Associates, El Macero, CA, July (2007).  http://www.gfredlee.com/Landfills/OdorImpacts.pdf

Lee, G. F., and Jones-Lee, A., “Flawed Technology of Subtitle D Landfilling of Municipal Solid Waste,” Report of G. Fred Lee & Associates, El Macero, CA, December (2004). Updated September (2009). http://www.gfredlee.com/Landfills/SubtitleDFlawedTechnPap.pdf

The “Flawed Technology” review cited above contains a summary of information on impacts of odours on health (see page 39). While the context of that discussion is landfills and other hazardous chemical sites, the information is equally applicable to the Sydney Tar Ponds remediation situation.

Thanks to your efforts I have continued to follow the development of STPA’s efforts to remediate the Sydney Tar Ponds hazard chemical site. In 2006, with support from the Sierra Club of Canada, I conducted a review of the STPA-proposed approach for remediation of the Tar Ponds sediments. I commented on the unreliability of the proposed cement-based solidification/stabilization approach to effective and reliably prevent further contamination of the estuary and bay by hazardous chemicals currently present in the Tar Ponds sediments. My papers and reports on these issues are available as downloadable files from our website [www.gfredlee.com] and include:

Lee, G.F., and Jones-Lee, A., “TCLP Not Reliable for Evaluation of Potential Public Health and Environmental Hazards of PCBs or Other Chemicals in Wastes: Unreliability of Cement-Based Solidification/Stabilization of Wastes,” Report of G. Fred Lee & Associates, El Macero, CA, September (2009). http://www.gfredlee.com/Landfill/TCLP_Solidification.pdf

Lee, G. F. and Jones-Lee, A., “Progress toward Remediation of the Sydney Tar Ponds: A Major Canadian PCB/PAH ‘Superfund’ Site,” Journal Remediation 17(1):111-119 (2006). http://www.gfredlee.com/Landfills/STP-Remediation-pap.pdf

Lee, G. F., “Unreliable/Inadequate Information on the Efficacy of Solidification/Stabilization of Sydney Tar Pond Sediments,” Report of G. Fred Lee & Associates, El Macero, CA, February (2007). http://www.gfredlee.com/Landfills/SydneyTPSedSolidif.pdf

Lee, G. F., “Comments on Joint Review Panel Environmental Assessment Report – Sydney Tar Ponds and Coke Ovens Sites Remediation Project,” Report of G. Fred Lee & Associates, El Macero, CA, July (2006). http://www.gfredlee.com/Landfills/STPAESComments.pdf

Lee, G. F., “Assessment of the Adequacy & Reliability of the STPA Proposed Approach for Remediation of the Sydney Tar Ponds’ Sediments,” Presentation to the Sydney Tar Ponds and Coke Ovens Sites Remediation Project Joint Review Panel, Sydney, Nova Scotia, CANADA, PowerPoint Slides; G. Fred Lee & Associates, El Macero, CA, May 15 (2006). http://www.gfredlee.com/Landfills/SydneyTarPondsPowerPt.pdf

Lee, G. F., “Comments on, ‘Remediation of Sydney Tar Ponds and Coke Ovens Sites Environmental Impact Statement, Sydney, Nova Scotia,’ dated December 2005,” Report of G. Fred Lee & Associates, El Macero, CA, USA, May 15 (2006).  http://www.gfredlee.com/Landfills/SydneyTarPondsReport.pdf

It is unfortunate that the STPA has proceeded with its original plan for remediation of the Tar Ponds and has ignored the issues of the unreliability of information developed by STPA upon which it is based. As I indicated in my previous comments and above, the approach proposed and now being implemented will ultimately fail to prevent continued pollution of the estuary and the bay by hazardous chemicals which will ultimately require re-remediation of the Tar Ponds polluted sediments.

G. Fred Lee, PhD, PE, AAEE BCEE

President of G. Fred Lee & Associates

El Macero, California

gfredlee@aol.com

http://www.gfredlee.com

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