The citizens of Troy deserve to know what pollutants they are exposed to and what the health risks of the exposures are. They also deserve, especially when there is no safe level of exposure for the pollutant in question, like lead, to have permits in place that reduce emissions to the maximum extent that proven technology, technology already demonstrated and in use, can achieve.

The first step toward clearing the air is for someone to inform the citizens of Troy about their exposure to lead and other pollutants. Sanders Lead is not a bad company, they have generally met the limits for emissions and they have made plans to meet new stricter requirements that the U.S. Environmental Protection Agency set forth in January of this year. Companies will do, they must do what is necessary to meet the EPA requirements to continue to operate. The problem is that there is no safe level for exposure to lead.

Ideally, Sanders Lead would step forward by providing the public with data on both past emissions and emissions expected after extensive facility emission control upgrades and health information. Or, either or both ADEM or EPA should provide the information. Also, for those nearest the plant who likely have been exposed to lead at higher levels, either Sanders Lead or the regulatory agencies should arrange with someone like the Center for Disease Control (CDC) or another appropriate agency to test those who want to be tested for blood lead levels.

The CDC still considers the level of concern for blood lead levels to be 10 micrograms per deciliter. The CDC refuses to lower the this level despite research that shows that there are significant loss in IQ points for each microgram per deciliter of lead in blood even down at 2 or 3 micrograms per deciliter. Data are also emerging that indicate health effects in adults from blood lead levels lower than 1o micrograms per deciliter. Folks in Troy, especially those within 2 to 3 km of the secondary lead smelter and especially any with children should be fully informed of the risks and what they can do to lower them.

The second step for clearing the air involves reducing lead emissions from Sanders Lead to the lowest possible level. Sanders Lead will reduce the emissions at least enough to meet the new EPA requirements and probably more. The problem is that the requirements do not appear to go as far as they might to require the use of existing technology to reduce lead emissions. The U.S. EPA should strengthen its rules to require secondary lead smelters to apply existing technology that can reduce emissions below those that will be achieved under the January 2012 rule. The CDC should revise its blood lead level number lower to a more protective level.

Responsible agencies should also do what is needed to keep lead out of our waters. One doesn’t have to be a chemical engineer to understand that removing lead from Sanders Lead wastewater prior to it going to the Troy wastewater treatment plant is almost certainly more efficient and effective than trying to remove it at the plant. And, if it is removed at the WWTP it goes into the sludge and then perhaps migrates into groundwater? Perhaps that is why the NPDES permit for the Troy WWTP has been administratively extended for over two years.

Michael William Mullen

Choctawhatchee Riverkeeper