The Environment and Health - MMDHD€¦ · E. coli . levels in water have been found to correlate...

The Environment and Health: Vapor Intrusion Failed Septic Systems

All Commissioners' Forum-September 28, 2017 Jennifer Morse, MD Medical Director Mid-Michigan District Health Department

Vapor Intrusion

What is Vapor Intrusion (VI)? • Vapor intrusion (VI) is the build-up of

evaporated volatile chemicals in buildings that overlie soil or groundwater contaminated with these chemicals (ATSDR, n.d.)

• Volatile chemicals are chemicals that evaporate easily into a vapor and enter the air

• These chemicals typically get into the soil and groundwater after a spill or leak from a tank

• Chemicals may be directly beneath the building, or next to a building and spread along utility piping and trenches made for utilities

• Not all chemical spills lead to vapor intrusion • The chemical must be volatile • The soil and foundation beneath the building must allow for the intrusion • Weather conditions, such as wind, must be favorable

3 Agency for Toxic Substances and Disease Registry (ATSDR). (n.d.). Vapor Intrusion. Retrieved February 17, 2017 from https://www.atsdr.cdc.gov/docs/atsdr_vapor_intru. sion.pdf

4 http://www.lawandenvironment.com/2014/11/06/massdep-releases-its-draft-vapor-intrusion-guidance/

What is Vapor Intrusion (VI)? • Many chemical involved in VI have negative health effects, including being linked

to cancer

• Common volatile chemicals involved in VI include: • Tetrachloroethylene (TCE, also known as perchloroethylene, PCE, PERC, and perchlor) • Benzene (also known as benzol)

• TCE: • Used as a solvent for dry-cleaning fabrics, metal degreasing • Health Hazards:

• Exposure to moderate amounts associated with headaches, dizziness, and sleepiness; large amounts may cause coma, irregular heartbeat , liver damage, kidney damage, or death. Skin contact can cause skin rashes.

• There is strong evidence that TCE can cause kidney cancer and some evidence it can cause liver cancer and lymphoma.


What is Vapor Intrusion (VI), cont. • Benzene

• Most commonly from petroleum, crude oil, gasoline, cigarette smoke; can come from natural sources like volcanoes and forest fires

• Health Hazards • Breathing very high levels of benzene can result in death; high levels can cause drowsiness, dizziness,

rapid heart rate, headaches, tremors, confusion, and unconsciousness. • Eating or drinking foods containing high levels of benzene can cause vomiting, irritation of the

stomach, dizziness, sleepiness, convulsions, rapid heart rate, and death. • Long-term exposure causes can cause anemia, excessive bleeding and can affect the immune system,

increasing the chance for infection. • Long-term exposure to high levels of benzene in the air can cause leukemia, particularly acute

myelogenous leukemia, often referred to as AML.


Vapor Intrusion • Many experienced investigators believe that an approach using multiple types

of testing data is the best way to evaluate vapor intrusion pathway • Complex problem with many variables and often limited sampling measurements • Action to protect health may be taken when only a few pieces of evidence available • More evidence may need to be available to be certain no health concerns present

• Types of Sampling • Indoor Air sampling • Outdoor Air sampling • Sub-slab Soil Gas sampling • Soil Gas sampling • Groundwater sampling

• All types of sampling are important


8 http://www.michsafetyconference.org/index.php/why-title-this/environmental-management-division/281-vapor-intrusion-tues-315-pm/file

http://www.michsafetyconference.org/index.php/why-title-this/environmental-management-division/281-vapor-intrusion-tues-315-pm/file




















Examples of Testing Methods

9 http://epa.ohio.gov/Portals/30/ersis/sifu/docs/SIFU%20Sampling%20to%20Evaluate%20Vapor%20Intrusion%20FACT%20SHEET.pdf

Collecting Indoor Air Sample Vapor Pin for Sub-slab Testing

Collecting Sub-slab Sample

Different methods for collecting an air sample from a soil gas

sampling system

Vapor Intrusion for the Regulatory Community by Kristen Kellock, Toxicologist and Joe Victory, Geologist, MDEQ WMRPTD Hazardous Waste Section April 11, 2017 (Michigan Safety Conference)

10 http://www.michsafetyconference.org/index.php/why-title-this/environmental-management-division/281-vapor-intrusion-tues-315-pm/file





















Mitigation Options

11 https://www.epa.gov/sites/production/files/2015-09/documents/oswer-vapor-intrusion-technical-guide-final.pdf

Map of DEQ Vapor Intrusion Investigation Sites As of February 27th

12 http://www.mlive.com/news/index.ssf/2017/02/vapor_intrusion_map_michigan.html

Edmore Cleaners

13 http://www.mcgi.state.mi.us/environmentalmapper/#

Vapor Intrusion • The December 2013 “Guidance Document for the Vapor Intrusion Pathway” MDEQ

rules are currently in effect

• Revisions to the generic criteria will take effect this year which are expected to be much more stringent, as a result of either stakeholder recommendations or MDEQ proposals

• Following more stringent guidelines will cost more money

• The 2018 Budget includes: • $7.8 million, or 1.5 percent, cut to the Department of Environmental Quality (DEQ) • Legislators rejected Snyder’s request to shift nearly $15 million to offset the loss of environmental

cleanup dollars that have dried up nearly 20 years after voters OK’d a ballot measure. • Lawmakers agreed to spend $300,000 more to address vapor intrusion

• Snyder had wanted $1.3 million more • Legislators recently agreed to commit $1 million more to VI

14

http://www.michigan.gov/documents/deq/deq-rrd-VIGuidanceDoc-May2013_422550_7.pdf http://www.ramboll-environ.com/news/environ/mdeq-rescinds-vapor-intrusion-guidance https://content.govdelivery.com/accounts/MIDEQ/bulletins/1a3e6d2

http://www.ramboll-environ.com/news/environ/mdeq-rescinds-vapor-intrusion-guidance





















Septic System Failure

Septic Systems in Michigan • Michigan is known for its fresh water-from Great Lakes to inland

lakes and streams

• Approximately 30% of homes and businesses in Michigan are served by on-site wastewater systems, totally around 1.4 million

• Septic tanks fail around 20-25 years

• Michigan is the ONLY state without uniform standards for how on-site septic systems are designed, built, installed, and maintained • Most septic systems in Michigan are never inspected again after they are

installed • Developing a statewide code could take years • Local government has authority to adopt septic maintenance regulations

• Local government is charged with maintaining general health, safety, and welfare

• Currently, only 11 of 83 counties have local ordinances to address failing septic systems

16

Health Department of Northwest Michigan, & Tip of the Mitt Watershed Council. (2016). The Septic Question. Retrieved September, 2017, from https://www.watershedcouncil.org/uploads/7/2/5/1/7251350/the_septic_question_report-final-web.pdf; http://msue.anr.msu.edu/news/got_water_time_of_sale_septic_inspections_can_protect_water_quality_part_1

Sewage discharging directly to creek. Photo credit: Marquette County Health

Department

https://www.watershedcouncil.org/uploads/7/2/5/1/7251350/the_septic_question_report-final-web.pdf






Septic Systems in Michigan • Failing septic systems can lead to introduction of

bacteria, viruses, and parasites into groundwater and surface water

• ALL groundwater travels toward surface water like lakes and streams

• Failing septic systems can therefore cause contamination of water that can cause illness through direct or indirect body contact (touching the water or touching something that had been in the water), as well as through ingestion (getting water in the mouth)

• Microbial contamination is one of the greatest health risks to swimming areas and fishing harvesting zones where human exposures are the highest

17

Verhougstraete, M. P., Martin, S. L., Kendall, A. D., Hyndman, D. W., & Rose, J. B. (2015). Linking fecal bacteria in rivers to landscape, geochemical, and hydrologic factors and sources at the basin scale. Proceedings of the National Academy of Sciences, 112(33), 10419-10424.

Photo: Barry-Eaton District Health Department

Septic Failure = Contaminated Water • Bacteroides thetaiotaomicron (B. thata) is a bacteria used to track human waste

• It only populates the human intestinal tract

• E. coli has traditionally been used as a “fecal indicator” to determine health risk during water quality monitoring in lieu of detecting pathogens • E. coli is a NORMAL inhabitant of the intestinal tract of humans and other mammals • Only certain strains of E. coli that have taken on specific genetic material (genes) are capable of causing

human illness • However, E. coli levels in water have been found to correlate with human illness

• June 2015, study conducted by Michigan State University and published in the Proceedings of the National Academy of Sciences of the USA: • Studied 64 rivers that drain 84% of the Michigan’s Lower Peninsula • These rivers were tested for B. thata and E. coli; variables such as landscape, geochemical and hydrologic

characteristics where also determined • Testing found that B. theta, and therefore human feces, contaminated 100% of the river systems

studied • E. coli concentration were generally below US EPA recreational water quality criteria

18 Verhougstraete, M. P., Martin, S. L., Kendall, A. D., Hyndman, D. W., & Rose, J. B. (2015). Linking fecal bacteria in rivers to landscape, geochemical, and hydrologic factors and sources at the basin scale. Proceedings of the National Academy of Sciences, 112(33), 10419-10424.

19

Verhougstraete, M. P., Martin, S. L., Kendall, A. D., Hyndman, D. W., & Rose, J. B. (2015). Linking fecal bacteria in rivers to landscape, geochemical, and hydrologic factors and sources at the basin scale. Proceedings of the National Academy of Sciences, 112(33), 10419-10424.; Alexander, J. (2013, May 14). Thousands of failed septic tanks across the state threaten Michigan's waters. Retrieved September 25, 2017, from http://www.mlive.com/environment/index.ssf/2013/05/thousands_of_failed_septic_tan.html

Density of Septic Tanks in Michigan (septics/km3)

Illness Due to Water with Fecal Contamination • Studies since the 1970s have shown that indicators of fecal contamination

including E. coli is a good predictor of GI illness after exposure to recreational fresh water

• High quality multi-year and multi-location study was performed (National Epidemiological and Environmental Assessment of Recreational Water (NEEAR) study) • On report of NEEAR study by Wade, et al (2006), involved beachgoers at two beaches in

Great Lakes Region • One beach on Lake Michigan In the Indiana Dune National Lakeshore, IN • One beach on Lake Erie, near Cleveland, OH • Both beaches were affected by discharges from waste treatment plants

20

Environmental Protection Agency (EPA). (2012). Recreational Water Quality Criteria (Rep.). Retrieved September, 2017, from https://www.epa.gov/sites/production/files/2015-10/documents/rwqc2012.pdf; Wade, T. J., Calderon, R. L., Sams, E., Beach, M., Brenner, K. P., Williams, A. H., & Dufour, A. P. (2006). Rapidly measured indicators of recreational water quality are predictive of swimming-associated gastrointestinal illness. Environmental health perspectives, 114(1), 24.

21 Wade, T. J., Calderon, R. L., Sams, E., Beach, M., Brenner, K. P., Williams, A. H., & Dufour, A. P. (2006). Rapidly measured indicators of recreational water quality are predictive of swimming-associated gastrointestinal illness. Environmental health perspectives, 114(1), 24.

22

Wade, T. J., Calderon, R. L., Sams, E., Beach, M., Brenner, K. P., Williams, A. H., & Dufour, A. P. (2006). Rapidly measured indicators of recreational water quality are predictive of swimming-associated gastrointestinal illness. Environmental health perspectives, 114(1), 24.

Other Public Health Issues with Septic Failure • Excessive nutrients from septic systems from

faulty septic systems lead to nutrient pollution • Phosphorus • Nitrogen

• Contributes to excessive growth of algae and vegetation • Algal bloom can decrease oxygen needed by fish and

other life • Green algae (Cladophora) • Blue-green algae (cyanobacteria) create harmful algal

bloom (HAB) • Produce cyanotoxins that can affect the neurologic system,

liver, gastrointestinal tract, and be irritating

23

Health Department of Northwest Michigan, & Tip of the Mitt Watershed Council. (2016). The Septic Question. Retrieved September, 2017, from https://www.watershedcouncil.org/uploads/7/2/5/1/7251350/the_septic_question_report-final-web.pdf; http://www.michigan.gov/documents/deq/wrd-swas-habs-faq_525893_7.pdf

Green Algae

Blue-Green Algae







Why do septic systems fail? Of those reported to MDEQ in 2015…

24 http://www.michigan.gov/documents/deq/deq-dwmad-eh-onsite-2015_Failure_Report_-_Final_598642_7.pdf

Local Government Options Maintain Status Quo • Advantages of Maintaining the Status Quo

• No immediate cost to the county or townships; no additional staff tasks, paperwork, or fees to manage • Ordinance would not be required • Educational campaigns to county citizens can be conducted for little cost

• Disadvantages of Maintaining the Status Quo • Does not proactively address nutrient levels and pollution in local water resources • Potential for adverse public health impacts • Continued lack of data; we only know about failed systems voluntarily reported to the health department • Does not address concerns of citizens and lake/river associations • Potential to negatively impact property values

25 Health Department of Northwest Michigan, & Tip of the Mitt Watershed Council. (2016). The Septic Question. Retrieved September, 2017, from https://www.watershedcouncil.org/uploads/7/2/5/1/7251350/the_septic_question_report-final-web.pdf

Local Government Options Time of Sale/Point of Sale Program • Require on-site septic system inspection when properties change hands from

one owner to another; typically includes sale and transfer of proper

• Inspections typically performed by the local health department; however, the LHD can chose to allow inspections to be done by other professionals trained and overseen by the LHD

• Can require any needed maintenance be completed prior to transfer of property

• Process used by 11 municipalities in Michigan (and Isabella County Commissioners just passed resolution to support a change to sanitary code requiring POS Inspection)

• Michigan programs find an average of 17% to 25% of septic systems inspected are failing • 5% to 6% found to have illicit connections

26

Health Department of Northwest Michigan, & Tip of the Mitt Watershed Council. (2016). The Septic Question. Retrieved September, 2017, from https://www.watershedcouncil.org/uploads/7/2/5/1/7251350/the_septic_question_report-final-web.pdf; http://www.themorningsun.com/article/MS/20170913/NEWS/170919867







Local Government Options Mandatory Pumping Ordinance • Advantages of the Time of Transfer Inspection Ordinance

• Specific to the local county or township needs • Protects public health by addressing nutrient levels and pollution • Problems discovered are corrected (ideally), adding to the longevity of the system and reducing water contamination • Improved system data collection for the health department and local government, and thus for citizens to best manage water quality • Addresses concerns of local citizens and lake/river associations • Helps protect local property values • Consumer protection by exposing substandard construction issues prior to the signing of purchase agreements; elimination of

unplanned expense by purchasers resulting from the need to replace sewage and water systems after loans have closed • Additional work/business for local well and septic system related businesses • Creation of new business opportunities for registered evaluators from the private sector (if used) • Improved confidence of lending institutions based upon direct knowledge of status of sewage and water supply systems

• Disadvantages of the Time of Transfer Inspection Ordinance • Increased cost of property transfers • Increase length and complication of real estate transactions • Does not capture all of the older systems that need the most attention • Requires passing an ordinance • Requires setting up a process to implement ordinance, including new staff tasks/need for additional staff, paperwork, and

management of fees • Need for collaboration between government jurisdiction, realtors, register of deeds, and third party evaluators and a system for

entering, tracking, and transferring information.


Local Government Options Mandatory Pumping Ordinance • Requires that everyone pumps septic system within a specific time frame and show

proof of doing so

• Some ordinances require inspection in addition to pumping

• Use of reliable software programs to help jurisdiction organize and keep track of process is needed

• Frequency of pumping: • EPA states 4 major factors:

1. The number of people in household 2. The amount of wastewater generated 3. The volume of solids in the wastewater (e.g., is a garbage disposal also used in the home) 4. Septic tank size

28

Health Department of Northwest Michigan, & Tip of the Mitt Watershed Council. (2016). The Septic Question. Retrieved September, 2017, from https://www.watershedcouncil.org/uploads/7/2/5/1/7251350/the_septic_question_report-final-web.pdf

Local Government Options Mandatory Pumping Ordinance MSU Extension recommends pumping every 3 to 5 years based on following guidelines (assuming no garbage disposal present):

29 http://michiganlakes.msue.msu.edu/uploads/files/msue_managing%20shoreline%20property.pdf

Estimated Number of Years Between Septic Tank Pumpings

Number of People in Household

Tank size (gallons) 1 2 3 4 5 6

500 5.5 2.5 1.5 1 0.5 0.5

1000 12 5.5 3.5 2.5 2 1.5

1500 18.5 9 5.5 4 3 2.5

2000 25 12 8 5.5 4.5 3.5

Local Government Options Mandatory Pumping Ordinance, cont. Based on interviews with county officials in Virginia, Pennsylvania (done for The Septic Question Report): • Advantages of the Mandatory Pumping Ordinance

• Specific to the local county or township • Protects public health • Captures older systems that are most critical and maintains newer system • Protects ground and surface water quality by addressing nutrient levels and pollution • Addresses concerns of local citizens and lake/river association • Helps protect local property value • Reliable software programs exist to organize and keep track of the process

• Disadvantages of the Mandatory Pumping Ordinance • Increased cost to property owners, if they haven’t maintained their systems • Potential to be arbitrary, if not scheduled correctly according to actual use of the property • Potential for pumping too often for the best operation of the system • Requires passing an ordinance • Requires setting up a process to implement ordinance, including new staff tasks, paperwork, and

management of fees


Local Government Options Mandatory Inspection Ordinance • Inspections regularly conducted by or overseen by local health department

within a specified time period

• Homeowner is required to do whatever is deemed appropriate, for their specific system, including pumping recommendations

• Repairs are normally required within 60 days


Local Government Options Mandatory Inspection Ordinance Bases on interviews with county officials in Connecticut, Oregon, Rhode Island:

• Advantages of the Mandatory Inspection Ordinance • Specific to the local county or township • Protects public health • Captures older systems that are most critical and maintains newer systems for longevity • Protects ground and surface water quality by addressing nutrient levels and pollution • Protects the system health and avoids arbitrary pumping schedules • Addresses concerns of local citizens and lake/river associations • Helps protect local property values • Reliable software programs exist to organize and keep track of the process

• Disadvantages of the Mandatory Inspection Ordinance • Increased cost to property owners, if they haven’t maintained their systems • Potential to be arbitrary, if not scheduled correctly according to actual use of the property • Requires passing an ordinance • Requires setting up a process to implement ordinance, including new staff tasks, paperwork, and

management of fees


Michigan Municipalities with Additional Septic Regulation Municipality County Description

Milton Township Antrim County Septic Inspection and Property Transfer Ordinance

Barry County Barry County Time of Sale or Transfer Ordinance

Benzie County Benzie County Point of Sale Ordinance

Eaton County Eaton County Time of Sale or Transfer Ordinance

Long Lake Township Grand Traverse County Point of Sale Ordinance

Kalkaska County Kalkaska County Point of Sale Ordinance

Glen Arbor Township Leelanau County Point of Sale Ordinance

Village of Empire Leelanau County Point of Sale Ordinance

Manistee County Manistee Point of Sale Ordinance

Shiawassee County Shiawassee County Point of Sale Ordinance

Washtenaw County Washtenaw County Time of Sale Inspection Requirements Program

Total: part or all of 11 out of 83 counties (13%)

33

The Environment and Health - MMDHD€¦ · E. coli . levels in water have been found to correlate...

Documents

Transcript of The Environment and Health - MMDHD€¦ · E. coli . levels in water have been found to correlate...