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The Creek Song

Nice song, so they closed the area to the public because of asbestos?

No, the BLM closed it because they don't have the desire/skill to manage it properly. They got the EPA to say that Chrysotile could pose serious health risks but they also got them to remove the part that says the risks could be much lower or perhaps zero. Below is a copy of an e-mail from Rick Cooper, the head of the Hollister Field Office, to the EPA. He is asking them what to tell people when they ask why he closed it if the risks could be zero? He says the whole basis of the decision to close it is health risks. Well, the magic words "and perhaps zero" never made into the final Draft Environmental Impact Statement. Rick Cooper wants Clear Creek closed by any means necessary...period.

The e-mail also mentions the fact that the models used were based on studies of occupational exposure, not infrequent recreational exposure.

Here ya go. Gotta love the Freedom Of Information Act :thumbup
(the underlines and quotation marks are mine)


Rick Cooper/CASO/CAIBLM/DOl

To Arnold Den/R9/USEPAJUS@EPA, Jere Johnson
cc Karl Ford/NOC/BLM/DOl@BLM
04/11/2008 01:42 PM
bcc Janet BedrosianfCASO/CNBLM/DOl

Subject Uncertainty in model


Jere and Arnold,

Just reading through the executive summary. The last paragraph places some doubt as to the adequacy of the model used. The risks could be lower or 0. I am aware that EPA has been consistent in mentioning this and it was in the previous draft.

"Uncertainty related to the toxicity parameters of the risk assessment includes the application of the IRIS and OEHHA asbestos toxicity models, which were developed from epidemiological studies of occupational exposures, to infrequent and episodic recreational exposures. This uncertainty could mean that the actual risks could be much lower than those estimated in the CCMA assessment and perhaps zero. Another uncertainty, adjustments for early-lifetime childhood exposures, could mean that the actual risks are higher than those estimated in the report."

I am sure BLM will be asked “why make an emergency decision on a model that may not accurately portray the risks to the public?” The basis for the decision is the model’s depiction that most of the activities exceed the acceptable risk range of 1 in 10,000.

Any thoughts on a reponse


Rick Cooper

Field Manager
Hollister Field Office
20 Hamilton Court
Hollister, CA 95023
phone: (831) 630-5010





WoodsChick
 
I hope this gets submitted in a thousand comment letters on the DEIS/ RMP...

Of course, this has probably been already commented on, and thisis a public forum, so Rick Cooper is already planning his defense.

Hmmm... our counter to his counter should be...
 
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