Regarding Phase 2 2014 site assessment for 1201 E Division…
Now that the Eastern Star is gone and the planned AISD Performing Arts Center is well underway, this email is of public record that you were forewarned. Gincy, please forward this to P&Z as ZA19-1 goes before P&Z 6/5/19 5:30 pm and then before council 6/25/19 6:30 pm.
Note the attached screen shot from phase 1 study identifies 30 LEAKING buried storage tanks of which 7 are less than 1/8 mile away.
Note on another attachment (Phase 2 study) the ON SITE spike reading on BARIUM at 225 mg/kg…
This is troubling in that the ATSDR says, “….a 2-year exposure to 200 mg barium/kg/day resulted in moderate to marked nephropathy”.
Since there was two hospitals, improper disposal of medical waste related to x-rays, Barium Sulfate is plausible….
“Main Eastern Star Home structure with the east and west wings, a kitchen and dining room addition to the north, a hospital building to the southeast connected by a road, and one wash house, one stage coach house, two poultry houses, one dairy barn, one implements shed, stables and a structure housing a water well pump and an underground gasoline tank to the north of the main structure are depicted (1949); Main Eastern Star Home with two additions to the east wing, a hospital addition to the northeast, an addition to the west wing, a Grand Chapter Building (office) to the west of the main structure, and a dwelling, a power plant and 25,000-gallon capacity water tower to the north of the main structure are depicted (1968)”.
Any Barium present in the soil blows around in this Texas wind and is a source exposure by inhalation.
A phase 2 excerpt reads of a concern for on site Arsenic and Lead:
“Both the original and duplicate soil samples exhibited concentrations of arsenic and lead above the applicable TRRP Tier 1 Critical PCLs for arsenic (5.9 mg/Kg) and lead (15 mg/kg); however the concentrations detected were within the 20% RPD. Based on the heterogeneous nature of metals concentrations in soils and laboratory interference associated with laboratory soil analysis, it is not uncommon to see 20% or greater RPDs for metals in soils. Furthermore, based on the soil analytical results with accompanying SPLP data, it does not appear the identified arsenic and lead soil concentrations are subject to TRRP“.
Here is the exoneration mechanism that is essentially a loophole denying actionable levels for clean up of that Arsenic & Lead
Texas Environment recently released a post Hurricane Harvey study about these laxed benchmarks lowering the bar and endangering public health. This is an easy to read resource that prefaces… “On average, for all chemicals targeted by both Texas and the EPA the strictest, Texas benchmarks allow soil pollution at a rate 13.94 times greater than the benchmarks used to score potential Superfund sites. Texas tolerates groundwater pollution at a rate 34.78 times higher.”
Home Rule allows you to adopt the precautionary principle
for starters. Phase 1 study says, “The 1963 Sanborn map indicated that the standalone carport was converted to a power plant and the underground gasoline tank was no longer depicted on-site”.
It is alarming that a power plant may have sat over an abandoned and probably leaking gasoline storage tank (which would explain high lead count as we had unleaded gasoline historically). Phase 1 notes the inability to interview one of two witnesses part of the Eastern Star excavation process, it is my opinion that AISD and the City leaders fail to protect the health of students and faculty in not knowing the disposition of the buried storage tank.
If you take no action after digesting the reports and my cautions via this email, you are hiding behind lax thresholds of actionable clean up needs! The purpose of Home Rule is to be more protective of public health and adopt safer actionable levels of necessary clean up.
Phase 1 (see attached) identifies sensitive groups to pollution exposures (receptors)…..which includes schools …..
and yet AISD Performing Art Center is going in this polluted area.
Of interest in the Phase 1 study was the list of all known pollution locations in the Orphan Summary (gasoline stations, GM, Barnett Shale, etc.) and note that 507 E Abram is on the Brownfield list.