December 4, 1991
Dear Ms. Swearingen:
I have read the materials that you sent me on the WTI proposed incinerator. My particular interest is in the area of neurotoxicology of lead in children, and as a result I was especially interested in the potential for this heavy metal to be released into the proximate environment of children.
Lead is a long known neurotoxin. For about 100 years we have known that children who are exposed to lead can suffer permanent brain damage. Careful research over the past 15 years has established that at extremely low levels, well below those that produce clinical symptoms, lead lowers IQ scores and produces attentional and language impairment. Recent studies by my group (New England Journal of Medicine 1990) have shown that these deficits are fixed, associated with a seven-fold risk for nongraduation from high school, and a six-fold risk for reading disabilities. The definition of lead toxicity in children has been revised progressively downward over the past decade to accommodate new scientific data. In 1978, the definition was 30Ag/dl. This has recently been reset to 10Ag/dl by the Public Health Service.
The material that you sent me states that the incinerator is expected to burn 176,000 tons of organic waste and treat 82,000 tons of inorganic waste. The company's statement is that the annual emissions of lead will be 4.7 tons. I could not find documentation on how this estimate was made and believe it could be a gross underestimation. Does it for example, take into consideration the burning of used motor oil? Or storage batteries? The Council on Competitiveness has recently overruled EPA and exempted the burninq of batteries from banninq.
I also note that there is a primary school situated in the direction of the plume at 1100 foot distance. This means that the children who attend this school will be exposed to the fumes of 9400 pounds of lead each year, in addition to the other pollutants. I have not attended to either fugitive emissions or the spillage from trucks carrying waste to the incinerator or carrying the bottom ash away.
Based upon these scanty data, and I must say that the estimates by WTI are the skimpiest I have seen, I can say that the risk to the brains of the children attending school near the stacks, during their most critical period of development, will be put at substantial risk. These children have no say in this matter, and it is our responsibility as adults and government to speak for them.
I also find the testing scheme medically inadequate and morally derelict. It is using the children as sentinels for the incinerator's control. We do not use children as guinea pigs or mine canaries.
Herbert L. Needleman, M.D.
Professor of Psychiatry and Pediatrics