Summary of Testimony of Thomas Falasca, DO FACA FACPM
Secretary, Erie County Medical Society

Erie School Board

October 30, 2008

I’m Dr. Tom Falasca, past president and current secretary of the Erie County Medical Society, speaking for the Society. Thank you for the opportunity to testify here today.

The Erie County Medical Society believes that the residents of Erie County should have the most complete information available on matters affecting public health. Of concern to us is information in the Plan Approval Application for Erie Renewable Energy’s proposed tires-to-energy plant. The application was prepared by The Hillcrest Group, LLC and submitted to the Department of Environmental Protection December 6, 2007.

The emission limitations proposed for the tire plant are enormously liberal, exceeding the present emissions of the worst polluting county industries combined (data for worst polluting industries are from PA Environment Facility Application Compliance Tracking System for 2006).

One such pollutant is invisible particulate matter smaller than 10 microns in diameter (a micron being one one-thousandth of a millimeter). The danger of these invisibly small particles exceeds that of larger, visible particles. The larger particles are either exhaled or they are trapped in the mucus of the large upper airways and then coughed up. The micron-sized particles remain suspended long enough to traverse the larger airways and reach the alveoli, the minute terminal air sacs where the oxygen in the air is absorbed by the blood. In the alveoli these invisibly small particles remain trapped, causing lung disease and other pathologies.

Further, the hazard of these invisible particles is incremental. Each time the concentration of particles increases by 10 micrograms per cubic meter of air (a microgram being one one-millionth of a gram), the risk of death from lung cancer increases by 8%, the risk of death from heart disease increases by 6%, and the risk of death from all causes increases by 4%. (Data of the American Cancer Society as published in the world’s most widely read medical periodical the Journal of the American Medical Association (Vol. 287, No. 9: 1132-1141), Arden Pope, MD, et al.) Moreover, there is no safe level. The danger begins increasing with the very first particle inhaled. There is “No evidence for a threshold … the concentration-response relation [between fine particles and mortality] was quite linear across the entire range of exposure.” Concentration-Response Relation between PM2.5 and Daily Deaths, Joel Schwartz (Harvard School of Public Health), Environmental Health Perspectives, Vol. 110, No 10, October 2002. Again, the World Health Organization states “There is no safe level for particulate matter emissions,” Current Science, Vol. 77, No. 3, 10 August 1999

Our concern is this: The minute particulate matter emission of the 10 worst county polluters combined is 159 tons annually; but the projected emission limitation of the tire plant alone is 230 tons annually. This single facility would more than double the fixed point industrial load of these particles.

We are concerned with many pollutants and toxins in addition to invisible particulate matter.

Carbon monoxide is familiar to us all. The emissions of carbon monoxide from the county’s 10 worst industrial polluters combined amount to 602 tons annually. To this, the tire plant alone would add 690 tons more, thus greater than doubling the current amount.

Nitrogen oxides are pollutants that in themselves are suspected of causing genetic mutations. Moreover, they react with water vapor and organic particles in the air to form ozone and nitric acid, two potent lung and airway irritants. Again, the county’s 10 worst industrial emitters combined generate 68 tons of nitrogen oxides annually. The tire plant’s projected limitation is 354 tons annually, consequently increasing the current figure more than six-fold.

Lead, “There is no safe level of lead in the body” (World Health Organization (WHO) Toxicology pamphlet No. 1). “Even very low exposure levels [of lead] compromise children’s later intellectual development and lifetime achievement. No threshold for these effects has been demonstrated.” Lead Exposures in U.S. Children, 2008: Implications for Prevention, Environmental Health Perspectives, Vol 16, No 10, October 2008. Ronnie Levin (EPA), Mary Jean Brown (CDC).

Data are available on the county’s four worst lead emitters and they indicate that those four together produce 41.4 pounds annually. The tire plant’s projected limitation is 65.3 pounds annually, thus increasing the current figure more than 2.5 times.

Mercury is another substance for which there is no safe level in the human body (World Health Organization [WHO], Environmental Health Update, September 2007). General Electric is the only recorded mercury emitter in Erie County and it produces 0.2 pounds annually. The projected limitation for the tire plant is 3.2 pounds, a 16-fold increase.

Sulfuric acid is yet another potent respiratory irritant. The only other listed emitter is the Erie Waste Water Treatment Plant which emits 0.16 tons annually. The projected emission limitation for the tire plant is 10 tons annually, an increase of greater than 60-fold.

Arsenic is a known poison and carcinogen causing lung, skin, bladder, and liver cancer. The National Academy of Sciences estimates the lifetime risk of cancer is 1 in 100 from drinking water with the miniscule arsenic level of only 50 parts per billion. Erie County presently produces 0.4 pounds annually. The projected emission limitation for the tire plant is 2.21 pounds annually, again more than a six-fold increase.

The above substances are linked to cancer, asthma, bronchitis, pulmonary edema, chronic obstructive lung disease, kidney damage, nervous system damage, stroke, and coronary artery heart disease1, 2, 3, 4, 5, 6. These are disabling and deadly diseases that cause their victims intense prolonged suffering and impose on the health care delivery system an expensive and resource-consuming demand.

In conclusion, we, the physicians of the board of the Erie County Medical Society feel that the above data clearly suggest that this tire plant would double, triple, quintuple, and in at least one case increase by 15 times and in another by 60 times, the fixed point industrial load of health endangering pollutants and thereby significantly increase the incidence of pollution-related illness in Erie County. Thank you. I’ll be happy to take any questions.

1. Nawrot, Nemmer and Nemery, American Journal of Respiratory and Critical Care Medicine, Vol 173, pp 948-952 (2006).
2. Maheswaran, Haining, and Brindley. European Heart Journal 2005 26(23):2543-2549.
3. Stiles and Lie. Higher Air Pollution levels Increase Risk for CV Events in Women. Medscape Medical News.
4. Lawrence Berkely Labs.Gov. How Can Air Pollution Hurt My Health?
5. Miller, Siscovick, and Sheppard. Long-Term Exposure to Air Pollution and Incidence of Cardiovascular Events in Women. New England Journal of Medicine, Vol 356:447-458, Feb. 1, 2007.
6. Goldstein, Inge F. and Goldstein, Martin. How Much Risk? A Guide to Understanding Environmental Health Hazards. Oxford University Press, 2002, p 310.