East Palestine Follow-up Water Quality Results

Background

As discussed in our last post, Justin C. Johnston collected additional water samples related to East Palestine on March 21, 2023. Samples were collected at Big Pine 02, Big Pine 04 and Big Pine 07 locations. Samples were tested for Semi-Volatile Organic Compounds (SVOCs) and Diesel Range Organics (DRO) at all sites since those components were identified in samples collected February 17, 2023. In addition, a dioxin sample was collected at Big Pine 04. Water was low and clear on March 21, 2023 because there had been no rain for several days. Note that most of the SVOCs that were identified in the February 17, 2023 samples were a class of compounds also called Polycyclic Aromatic Hydrocarbons, or PAHs. All PAHs are SVOCs, but not all SVOCs are PAHs. For simplicity, we will simply refer to them here broadly as SVOCs and assume them to broadly constitute a significant health risk since they are typically considered carcinogenic as described in prior News Blog posts on our website. If you are doing independent internet searches, consider including “PAHs” in your searches for context.

A rain event of 1.25″-1.5″ occurred in the area on March 23, 2023. To capture the run-off event, Big Pine collected additional samples at Big Pine 02, Big Pine 03, Big Pine 04, and Big Pine 07. These were all tested for SVOCs with the exception of Big Pine 04, which was also tested for dioxin.

ALS Global completed all laboratory analytics for our samples. They were processed in the Holland, Michigan laboratory.

A map showing the locations of these sites can be found on the story map here: East Palestine Train Derailment Water Quality (arcgis.com).

Photos of sites on March 21 and March 24 are provided below for reference.

Results

Big Pine received the results of SVOCs for both sampling events and those are available here March 21, 2023 Pre-Rain Sample Results and here March 24, 2023 Run-Off Sample Results.

I expected that the low clear water on March 21, 2023 would reflect mostly groundwater contributions and that previously identified SVOCs would either not be present or would be reduced relative to samples collected on February 17, 2023 even if SVOCs were still present in the environment because the SVOCs would be mostly on the ground surface, where it would require a run-off event to capture them. If the SVOCs had infiltrated however, they would potentially still be present in the groundwater contribution to streamflow.

I expected that the turbid run-off laden water on March 24, 2023 would reflect substantial run-off in addition to groundwater contributions to stream flow and that previously identified SVOCs, if still present, would be found in potentially higher amounts as a result of the greater run-off that occurred relative to the February 17, 2023 event (that event had approximately 0.1″ to 0.39″ of rain in the previous 24-hours compared to 1.25″-1.5″ on March 24, 2023). Conversely, if rain events between February 17, 2023 and March 24, 2023 had washed much of the SVOCs from the ground surface of the watershed downstream, then I expected we would find a reduction in the SVOCs relative to February 17, 2023.

Big Pine 02 on March 21, 2023 had detections of SVOCs and also an Oil Range Organic (ORO). The detections were above the Minimum Detect Levels but below the Report Limit for the analytes detected. Given that this site is not downstream of the derailment to receive spill materials, the ORO is unlikely related to the derailment. It appears that there is another source of contamination in South Branch Brady’s Run, furthermore the levels of contaminants did not reach the Report Limits for the analytical methods used. No other site on March 21, 2023 had any detections, indicating that contaminants are not present in groundwater contributions to the streams in detectable concentrations.

On March 24, 2023, no site had any detections of any analytes. Minimum Detect Levels (MDL) for several analytes in the February 17, 2023 sampling event were around 0.41µg/l. Those same analytes were analyzed to MDLs of 0.10µg/l for both March 21, 2023 and March 24, 2023. Therefore, it appears that the SVOCs that were present in the run-off on February 17, 2023 are no longer present in detectable concentrations as of March 24, 2023.

This implies that 1) the SVOCs infiltrated the ground surface to a depth that minimized their transport into streams via run-off but that also is not yet in detectable concentrations in the groundwater contributions to the streams, 2) the SVOCs have been absorbed by organic materials that prevented them from being washed into streams via run-off, 3) the SVOCs may have been carried downstream into other areas of the larger Ohio River and Mississippi River watershed where they have been substantially diluted, or 4) some combination of these pathways may have prevented the SVOCs being in our samples.

Many of the SVOCs that were found previously were hydrophobic (do not dissolve in water) and lipid soluble (dissolve into organic materials). So It is possible that the contaminants have been taken up by plants, fungi, bacteria and other organisms, preventing them from entering run-off. If this is the case, then the SVOCs may still be found in the soils and/or plant materials in the watershed. A recent news report was published indicating that scientists from Ohio State University will be searching for SVOCs in crops. Here is a link to that article: Ohio scientists to test East Palestine crops for potential toxins | WSYX (abc6onyourside.com). It will be very interesting to know what they find.

Our Dioxin results are still outstanding and I don’t expect to see those results until mid-June. When we receive them, we will post them on our News Blog as we have our other results.

We have scheduled an informal file review at PADEP to see if other water samples may have been collected pre-derailment that would provide a baseline for Big Pine 04, Coalbank Run. That is scheduled for May 4, 2023. If the informal file review has interesting information, we will present that in a future post as well. We don’t know what might be there yet.

Opinions

What follows below is editorial and my own opinions and thoughts after my experience completing this independent investigation. Others may have different thoughts and interpretations

The lack of SVOCs found in the water samples is tentatively good news for residents that experienced the plume. I will avoid making any conclusions until we know where they went. The case may be that the contaminants have washed downstream. However, that really just means it is someone else’s problem, likely someone that doesn’t even have any idea that they are encountering these contaminants at all. My understanding is that water treatment facilities can and do treat for these in our drinking water, so it may not be a problem for people using treated water. It may be a problem for others in the greater Ohio River and Mississippi River watershed that use water that is not professionally treated. It may also be a problem for life in and around the watershed, including fish, birds, livestock, and other animals.

If instead of being washed downstream, the contaminants are hiding just beneath the ground surface or were taken up in organic matter where they are not susceptible to run-off, then we may need to be prepared for when these SVOCs migrate to the groundwater where there will likely be a long-term problem with these contaminants slowly migrating into streams in low concentrations for many years.

If they are still in the watershed in low concentrations, what can be done? For treating streams in particular, Norfolk Southern and government agencies may want to consider a series of constructed wetlands as a treatment mechanism along various streams in the various watersheds that were potentially impacted by the controlled burn plume. These could be an effective, relatively affordable, low maintenance, long term solution to the SVOCs/PAHs. Some of the bacteria and fungi that grow in the wetlands are often able to biodegrade PAHs into their component, non-carcinogenic pieces (Biodegradation aspects of polycyclic aromatic hydrocarbons (PAHs): a review – PubMed (nih.gov)). This is a real treatment, rather than temporarily isolating or transferring the problem to a different location. This is something tangible that Norfolk Southern and state agencies should be investigating as soon as possible. Constructed wetlands can provide additional benefits beyond being a “natural filter” including providing habitat for wildlife.

I would like to make some points regarding TRUST. We did this study because of a perceived lack of trust observed on social media. Specifically, a lack of trust in Norfolk Southern and state agencies including Ohio Environmental Protection Agency (OEPA) and Pennsylvania Department of Environmental Protection (PADEP). Do I believe they can or should be trusted now? Unfortunately, I think they have not done a good job when it comes to deserving public trust. Norfolk Southern has been fighting transparency, for obvious reasons of trying to limit their liability regarding this matter. For the state agencies, that should be doing their utmost to protect the public 1st, it appears they are similarly trying to limit their liabilities as well, politically or otherwise. OEPA is doing a lot of work, but they are making poor judgements on quality. PADEP is not adequately resourced to appropriately monitor or respond to the situation.

OEPA is using a laboratory with analytical methods and/or calibration standards that are not providing the lowest feasible or even practicable Minimum Detect Levels (MDL). Yes, they are using “EPA Approved Methods” (those are air quotes), but they are not producing the best results they can. Had OEPA used different analytical judgement or calibration standards to lower their MDL, they would have detected the SVOCs that were probable carcinogens and that were in the water after the controlled burn event. Had they done so, they would have likely been able to show declines in these contaminants in the water over time. Just because the analytical method is “EPA Approved” doesn’t mean that the way the analytical chemistry is being performed is being done the best way possible.

The identified analytical method in the OEPA reports for SVOCs is 8270D, which is the same method that was used by ALS Global for our samples. Both Pace Analytical and ALS Global are National Environmental Laboratory Accreditation Program (NELAP) certified labs. The 8270D Method is published at Method 8270D: Semivolatile Organic Compounds by Gas Chromatography/Mass Spectrometry, part of Test Methods for Evaluating Solid Waste, Physical/Chemical Methods | US EPA ARCHIVE DOCUMENT if you would like to read it yourself. One interesting point is that the method does not require a specific MDL, rather it directs how to determine the MDL based on calibration standards (Note: In the method, it calls MDL the Lower Limit of Quantitation or LLOQ if you are searching for it).

Section 9.10 states,

“The LLOQ is the lowest concentration at which the laboratory has demonstrated target analytes can be reliably measured and reported with a certain degree of confidence, which must be ≥ the lowest point in the calibration curve. The laboratory shall establish the LLOQ at concentrations where both quantitative and qualitative requirements can consistently be met.”

So it is based on the lab demonstrated ability to achieve accurate results at lower concentrations plus the calibration curve. The calibration curve is based on calibration standards that are used. Calibration standards are solutions with a known concentration of analyte that are typically prepared by the laboratory analyst to calibrate the equipment.

Section 7.7 states,

“7.7 Calibration standards – A minimum of five calibration standards should be prepared at different concentrations. At least one of the calibration standards should correspond to a sample concentration at or below that necessary to meet the DQOs of the project. The remaining standards should correspond to the range of concentrations found in actual samples but should not exceed the working range of the GC/MS system.”

So this tells us that the MDL can be adjusted based on 1) the range of the gas chromatograph/mass spectrometer (GC/MS) equipment and 2) what calibration standards are selected by the analyst. The concentrations in the calibration standards are supposed to be selected based on the “DQO”. What is the DQO?

Section 1.6 tells us,

“The information contained in this method is provided by Environmental Protection Agency (EPA or the Agency) as guidance to be used by the analyst and the regulated community in making judgments necessary to generate results that meet the data quality objectives (DQOs) for the intended application.“

Per the EPA Approved method, it is “guidance” and there are judgement calls being made by the analyst to determine what calibration standards to use and by extension, what MDLs will result. There may be lower limits that a lab can achieve, so it may be as simple as OEPA asking the laboratory if they can increase the sensitivity of certain analytes. If the lab has documented ability to increase their sensitivity, they could do so. If the lab cannot because of equipment limitations, or lab accreditations, then OEPA could always reach out to a different lab.

I reached out to Eurofins Test America, Pace Analytical, and ALS Global to get quotes for running the samples for this effort. ALS Global was the first to respond and be able to have bottles ready for sampling. The costs were reasonable and within the range of other labs, including what I expect Pace Analytical have been charging OEPA. So this is NOT A COST ISSUE. It might be a contract issue as it takes time to set up contracts (because government loves red tape), but that really is a matter of resolve and desire of an agency to get a job done (and cut through the red tape). If there was really a desire to respond appropriately, they could have made the adjustments.

News Nation ran a story on my results. Firm detects cancer-causing chemicals in water near East Palestine (newsnationnow.com)

They presented my report to OEPA and asked them for comment. To which OEPA responded, “All the samples published at epa.ohio.gov/eastpalestine for the public to review were collected following federally accepted standards. We stand by those results.”

The EPA approved method includes making judgement calls, describes the method as “guidance” (as opposed to a rule) and uses “qualitative” as a descriptor. It is not a hard and fast recipe of a method. It requires good judgement. In my opinion, I find OEPA judgement in this case to be poor, though that depends on what the agencies data quality objectives (DQO) were, per the method itself. There lies the crux of the matter at hand when it comes to public trust.

There was a lack of public trust in OEPA and other responding agencies from the outset. Continuing to use analytical methods that appear to be “dumbed down” when alternatives with better sensitivity are available is clearly counterproductive to building public trust. The fact that they did not improve their MDL and continue to publish results that have poor sensitivity today does not give me a lot of confidence in the agency’s willingness to put the public 1st. It shows that their “Data Quality Objectives” in this case were intended to reinforce a public message that the water is fine, even when it wasn’t in my opinion (though apparently is improving for the time being).

Pennsylvania Department of Environmental Protection (PADEP) didn’t do any better than OEPA either. However, their transgressions (my opinion) were less about their lab analytics and more about their sampling regime. If you read the PADEP website regarding their response at Ohio Train Derailment (pa.gov) you will find that they only collected surface water samples at 5 sites, within a 1-mile radius of the derailment. From their website, “As of March 10, DEP has collected samples from five surface water bodies within the one-mile radius.” That is less effort and cost than I put into the independent sampling, funded by Big Pine Consultants LLC alone. You will further note that no results have been posted after those samples were collected. So too few samples collected, over a month after the derailment, and we are still waiting for the first results to come back from PADEP. Meanwhile, my small company has been able to complete sampling at 9 different locations, multiple times for some of them, and have results to report to you less than 2 weeks after collecting the samples. That is the result of a PADEP that has lost its way, but I don’t blame the staff. I blame the system.

Back in 2009-2010 after the great recession, under then Governor Ed Rendell, the state gutted PADEP by laying off hundreds of staff. It has not been restored since. The Southwest DEP now has one aquatic biologist and a couple of water quality specialists. They have other responsibilities that were ongoing before the derailment, and I suspect that they did not have the bandwidth to respond and monitor the situation adequately.

Add to the lack of biolgists, a dire analytical laboratory situation. Whether it is budget issues or labor protections, I am not certain, but I have been told by a SW PADEP employee (will remain anonymous for their protection) that all of their analytical samples must be sent to the state lab in Harrisburg, PA. They are required to schedule the samples weeks in advance to boot. They don’t really have a choice to switch labs to get better results or to expedite sampling or testing. They have a single lab for the entire state and have to schedule when the samples can be submitted and wait many weeks for them to be processed. It is not the type of setup that we need when time is of the essence, as was clearly shown by this effort. By the time PADEP sampled on March 10, the damage may not have been detected.

In PA, we have over worked biologists, and an under resourced lab in Harrisburg that is required to process ALL samples. There is no willingness in the state by any political party to do what it takes to properly monitor the environment. PADEP should have contracted to have more support to respond to this incident outside of its own internal staff. They should have contracted to have at least an option to use private labs in situations like East Palestine so that there is not a long wait to schedule to collect samples and another long wait to get the results back. Although I can say what PADEP “should have done”, I have no visibility into whether or not the political environment could allow those things to happen. During my career, I have seen obvious problems that seemed like they could be easily fixed, but special interests on both sides of the aisle have typically been behind stopping the right things from happening. I am not sure how to fix the political problem that is preventing the right things from happening. I do think we, the people of Pennsylvania, need to ask and hold our elected officials and bureaucratic agencies accountable.

When PADEP makes the statement on its website, “While we believe there are no known concerns for water or soil quality for Pennsylvania residents, DEP will conduct independent testing of private wells for at least six months and up to one year and continue monitoring surface water and soil quality.” I think it is important for the public to take them to task and ask tough questions. We deserve to know,

1. How many samples are you collecting?
2. Where are you collecting them?
3. How often are you collecting them?
4. Are you timing your sampling for rain events and run-off?
5. What media (soil, groundwater, stream sediments, surface water, etc.)?
6. What are you testing for? VOCs? SVOCs? PAHs? DRO? GRO? Dioxins?
7. What lab are you using?
8. What are their MDLs?
9. Why did you design your sampling program the way you did? What questions will it answer?
10. Who is doing the sampling?
11. When will you be getting results back?
12. When will the results be publicly available?
13. When you say “we believe”, who is “we” specifically? Is there a voice of dissent? Who are they and what do “they” believe?
14. What happens in 6 months if you are finding contaminants?
15. What happens if it takes 12 or 24 months or more for contaminants to migrate to wells or streams?

The list above is not all inclusive. Every situation is different and more questions may need to be asked and answered.

I did this work because I observed a lack of public trust in our state agencies. I thought I could help by verifying results independently. What I have learned is that the lack of public trust is warranted to an extent. I do not see a broad conspiracy to hide information from the public, but there are certainly parts of the response that are broken. They are broken at a level that is unfair to the people in East Palestine, OH, Darlington, PA and the surrounding areas, especially “downwind”, which is getting much less attention in media. If we want to be able to trust our public agencies, they need to do better.

All Rights Reserved

The opinions above are mine alone. My name is Justin C. Johnston, MS, MBA, President of Big Pine Consultants LLC and I wrote this article myself. We have received no funding or assistance from OEPA, PADEP, Norfolk Southern, any other agency associated with the response effort, or company related to the East Palestine derailment or response. We were also not contracted by any attorneys that may be preparing lawsuits against Norfolk Southern or any agencies or entities involved in the response. We self-funded this work and performed it on our own.

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