Friday, August 04, 2023

Pascagoula


According to bombshell reporting by The Guardian and ProPublica, the US EPA recently approved production of new alternative fuels that are so carcenogenic they could cause cancer to nearly everyone exposed to their exhaust.

A headline like that is so incredible that it invites disbelief.  Why would EPA approve something so deadly? Even in its darkest, Reagan and Trump years, the EPA wouldn't allow almost certain additional cancer deaths. So why now in the theoretically reinvigorated EPA of the Biden Administration?

Development of the new fuels, designated for boats and planes, is part of a program to develop new “climate-friendly” alternatives to petroleum-based fuels. The new fuels, to be produced at a Chevron refinery in Pascagoula, Mississippi, will be made from recycled plastics.  Could the EPA have ignored the cancer risk just so they could say they approved a new alternative fuel made from recycled plastic?

Full disclosure: alert readers may recall that I've consulted with Chevon at their Pascagula refinery back in 2005. My work there was not related to development or production of the new alternative fuels, but with management and long-term care of their on-site waste-management and -disposal units. I spent most of the summer of 2005 at the refinery until my work was cut short by Hurricane Katrina, and in the course of that summer, developed personal friendships with many of the refinery workers and managers. But after the project finally ended, those friendships and relationships came to amicable ends as we all went about our separate lives. 

But back to the question at hand - why would EPA approve production of such carcenogenic fuels?  The cancer risk was based on EPA's own assessment and calculations, and in a statement, the Agency claimed they "considered the full range of values described in the risk assessment to develop its risk management approach for these” fuels. However, the statement also claimed that the cancer-risk estimates were “extremely unlikely and reported with high uncertainty.” 

Because it used conservative assumptions when modeling, EPA claimed it had significantly overestimated the cancer risks posed by both the jet and marine fuels. The agency assumed, for instance, that every plane at an airport would be idling on a runway burning an entire tank of fuel, that the cancer-causing components would be present in the exhaust, and that residents nearby would breathe that exhaust every day over their lifetime.

The latter assumption of life-long exposure is standard for chemical risk assessments.  In fact, the cancer calculations are generally expressed in terms of "additional lifetime cancer risks."  The goal is to limit that lifetime risk to one in a million (1:1,000,000).  The calculated lifetime cancer risk of the new fuel products is 1.3:1, meaning every person exposed to it over the course of a full lifetime would be expected to get cancer.

If one were to ignore the conservative assumptions common in risk assessments, such as a complete exposure pathway and lifetime duration of that exposure, almost any chemical could be deemed non-carcenogenic, if not non-harmful. For example, when performing risk assessments to calculate acceptable concentrations of pollutants in groundwater, I was forced by EPA and the states to make the unrealistic assumption that residents drank two liters of impacted groundwater each day over 70 years, as if they didn't supplement their drinking-water requirements with bottled water or other drinks. I had to further assume they didn't move to a different residence with a different source of water from the day they were born until their 70th birthday, and that the concentration of the pollutants in that drinking water didn't change over the course of those 70 years.  

If I were allowed to assume that people drank only half of their 2 liters of water each day from their own wells (which also assumes that their tap water isn't from a municipal source), that they only resided at their homes for, say, 25 years, and that concentrations of the contaminants would naturally dissipate over time due to dilution, almost any concentration of most chemicals would be well within the 1:1,000,000 threshold.  There wouldn't be a need to clean up most of the groundwater contamination in the U.S. 

But that would neither be "safe" nor within regulatory thresholds of acceptable risks.  The conservative assumptions are added to the risk assessment to account for the uncertainties inherent in estimating carcenogenic risk.

So the real question is why the EPA is willing to ignore the conservative assumptions in the risk assessment for these "climate-friendly" alternative fuels but not in other cases. Are the climate benefits of the alternative fuels great enough to outweigh the risks of those exposed to the fuels themselves? Is it acceptable to allow some people to develop additional cancers so that the greater population can enjoy a better climate? Or is it a policy issue - are the political pressures to develop alternative fuels so great that the EPA is willing to ignore health concerns?

These are the real questions that aren't being discussed.

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