ACTION: We need the Delaware Department of Natural Resources and Environmental Control (DNREC) to install

• gas analyzers &
• PM2.5 monitors near NRG'S Indian River coal plant for data on pollutants.

Currently, the only PM 2.5 monitor in Sussex is at Seaford, well outside the downwind swath of polluted air from the coal plant. Put monitors & gas analyzers in the suspected failure areas of Dagsboro, Millsboro & Lewes. We believe that there is no excuse for failing to monitor arsenic, SO2, NOx, carbon monoxide & fine particulates in locations with high rates of asthma, heart disease & cancer.

• PLEASE WRITE A LETTER TO THE EDITOR ASKING FOR THIS. SEE http://abettersussex.com/LTR.html FOR HOW TO WRITE A LETTER TO THE EDITOR.

…”CCP Goals: We want public officials to take precautionary actions concerning the IRPP and fossil fuel based pollution after timely, locally focused study. We also want statewide improvements in public health protection from environmental exposures in general.”…

 

“Executive Summary

Recommendations to the Environmental Committee of the Delaware Cancer Consortium from Citizens for Clean Power

October 23, 2007

We agree with DNREC that a statewide study of environmental impact on public health is an important priority, and will provide baseline data for many pertinent decisions, if done correctly.

 

We don’t accept this statewide, yet unfunded recommendation, as adequate enough response for the current local population. As we have outlined in this response, we feel a reasonable, timely and cost effective means to assess pollution burden on the cluster region is the next acceptable step in this process.

We agree a preliminary year of air quality monitoring be done (regardless of cancer cluster investigation findings).

We believe that the validity of such measurement will depend on the correct placement of the monitors. We request time to review that methodology and DNREC’s proposal before that monitoring begins.

 

We will express concerns about:

• The Cancer Cluster methods and the limitation to only smoking, migration and occupation;

• The Department of Public Health's (DPH) lack of recommendation of body burden measurements in a timely and environmental medically informed way for this target Indian River population;

• And we express concerns about the lack of investigation of other cluster like patterns of heart disease, special education rates and infant death rates.

 

Stated Expectations:

Here is our summary of the issues that we feel MUST be addressed: (Further in-depth discussion follows the executive summary):

• Improve the design of the tobacco/migration/occupational study of the Indian River cancer rates as we suggest

below. (Consider if outside third party should conduct this study.)

• Include a local focused bio burden study: which is timely, not cost prohibitive or simply focused on immediate, acute exposure data collection. Correctly state the working hypotheses concerning risks of disease and the environment.

• Improve the design of DNREC’s East-West air quality comparative study design. Meaningful information will be blocked if each subject group is within plumes of coal-fired plants. Isolate the IRPP plume, and exclude from Western study group any other exposure to a point source, so as not to minimize contrasts within the two regions.

Subsequently, if it is determined that there is significant enough burden on the local population to warrant precautionary action, we would like to suggest what those precautions could look like.

 

To be very clear: simply collecting more data is NOT a precautionary action. Further study (more data) is simply a basis for informed decisions about precautionary actions. The willingness to collect that data is mandatory prerequisite for public officials charged to protect the public, not simply industrial profits.

 

Potential precautionary actions are:

1. Remediation of the UNLINED fly ash pit at IR, [the Indian River Power Plant].

 

2. State wide moratorium on new fossil fuel based power plant construction until the proposed state wide environmental impact study is complete,

 

3. Immediate insistence on .best available technology (over 90% reductions) (above and beyond the current Multi-Pollutant Regulations),

 

4. Restitution for health care costs from NRG. [NRG Energy, Inc.] http://www.nrgenergy.com/

 

In Depth Discussion

Recommendations to the Environmental Committee of the Delaware Cancer Consortium

from Citizens for Clean Power

Introductory Overview

In light of the difficulties of establishing definitive causation in cancer clusters, we propose a different line of questioning and urge officials to think in bigger terms than what was presented at the recent meeting.

Due to lack of past or current air quality monitor data, one response is to simply start doing the assessments for future use, and start to collect the biomonitor data statewide, as has been suggested.

This approach, while welcomed for future decisions and study of our future needs, is not enough for the public’s need for protection now. We propose that the present question needs to be geared toward assessment of current burden, and that this measurement can be done more cost effectively, more efficiently, and in a more timely manner than DPH and DNREC propose.

PART ONE: CCP RESPONSE TO DPH Recommendations Related to Indian River

CCP Purpose: The primary focus of our inquiries has been consistent: We have concerns about the environmental burden borne by local population near the Indian River coal fired plant with grandfathered emissions regulations and unlined fly ash pit. Establishing the existence of a cancer cluster is just ONE piece of this puzzle.

Here are some data points that argue for further precautionary actions.

1. Cancer cluster does exist in the six zip code area

2. Infant mortality rates, autism/special education, and heart disease data also preliminarily behave in cluster activity.

CCP Goals: We want public officials to take precautionary actions concerning the IRPP and fossil fuel based pollution after timely, locally focused study. We also want statewide improvements in public health protection from environmental exposures in general.

 

SPECIFIC COMMENTS RELATED TO TESTING Hypotheses A, B and C

I. Lack of clear distinction between Control and Subject Groups

We believe that the design of the smoking, migration and occupational study that has been recommended is flawed. Citizens for Clean Power submitted the request to study the six zip codes, but the sampling never pretended to be the only zip codes of concern. (The Fenwick Island area, for example -- directly in the path of prevailing winds from NRG for half the year also shows elevated cancer numbers.) We contend that a zip-code

by zip-code review should be done to determine the bounds of the cluster in eastern Sussex.

Moreover, all the rest of Sussex County is not an appropriate control area in our estimation. As it is now, you potentially are including subjects (those impacted by the coal fired plants in Seaford and Indian River) in the control group.”

 

“Thank you for the opportunity to submit public testimony (attached).  We look forward to continued dialogue at the next meeting or before it if needed.

 Kim Furtado, N.D., Millsboro DE, on behalf of CCP”