CRITIQUE OF: "2001 Annual Ground Water Monitoring Report for The Bridge" *
*(NOTE: quotes from the Annual Report are in italics, my comments in plain type, J.P., SFGTF)
DELAY - Robert Rubin's consultant, Stuart Cohen, of Environmental & Turf Services, Inc. ("ETS") didn't complete his "2001 Annual Ground Water Monitoring Report for The Bridge" until December 30, 2002 and submitted it to the Town on January 2, 2003. This is unacceptable. It should have been prepared and handed in much earlier in the year-at least by March 1, 2002-so the Town could act on its contents, if need be. This whole project has been riddled all along in such unconscionable delays of every stripe.
"Executive Summary":
PAGE i - "Sample volume from some of lysimeters for some of the samples was either limited or non-existent…"
A Problem as lysimeters are the first line of defense and we need complete and accurate readings from them.
PAGE i - Re. pesticides - "All concentrations were less than 5 ppb and near the detection limit (the minimum reporting limit), and all are at least a factor of 10 lower than health-based and regulatory standards."
MISLEADING - There is no health data for the metabolite triadimenol. When there are no studies or data on a chemical it gets a catch-all "guideline" of "50ppb" (as MTBE once did. MTBE had a guidline of 50ppb, which was lowered to 10ppb when health studies started to accrue on its dangers to health). Mr. Cohen's implication is that this metabolite, triadimenol, is safe. It has not been proven safe. Similar chemicals to triadimenol have a "standard" -as opposed to "guideline" of between 1-5ppb. Triadimenol showed up in a lysimeter at 3.0 on 6/28/01. MR. COHEN MUST BE MORE FORTHCOMING REGARDS A "GUIDELINE" AND A "STANDARD"!* Also, according to a fact sheet prepared by the Breast Cancer Group: "One in Nine" created from EPA data in Albany Triademenol's parent Triadimefon, which was applied to the golf course is: "a possible human carcinogen; decreased blood cell count; eye irritant; absorbed through skin; overexposure apparently causes hyperactivity followed by sedation"
PAGE (ii) Cohen says the drainage collection system near MW-4 was "modified"? --How?
*NOTE: and, "guidelines" or "standards" does not preclude t6he fact that it can still be adverse to one's health.
PAGE I-I "Results of each sampling event hav been previously sent to the Town, its consultant (Dr. Petrovic), Audubon International (Nancy Richardon), and the Suffolk County Water Authority (SCWA)."
WHEN? My Freedom of Information Requests show that the Town, nor Dr. Petrovic, the Town's consultant, had these until a long time after the sampling events. According to the "Monitoring Agreement" the Town should have received these results at the same time as he Suffolk County Water Authority and that didn't happen. In fact, SCWA didn't even receive the sample results in a timely matter. WHEN, then, on what dates did Mr. Cohen furnish sample results to SCWA? To Petrovic? To Town (Murpree)?
PAGE I-2 Why couldn't the lysimeters be installed until "after the golf course was built"? There are other golf courses who've installed them before the course was built. According to the (Petrovic & Cambareri Report 1/5/99) they should have been installed before any baseline sampling was to take place.
PAGE I-2 When did they start taking the field history reports?
Were they daily?
Has Dr. Petrovic seen the entire logs? (what period?)
PAGE II-1 "(The lysimeters at G&-3 could not be sampled in 2001 because the devices did not hold a vacuum.)"
Why didn't they get them fixed? A year went by? Longer?
PAGE II-2 Reference is made to the "Natural Resource Management Plan (ETS, 2000)"-the one they gave to Audubon International?
PAGE II-2 Pesticides applied for disease: " Spotrete (thiram; Chipco (iprodione); Bayleton (triadimefon); Rubigan (fenerimiol); Banol (propamacarb); Banner (propiconazole); Trimmit (paclobutrazol); Cleary's 3336 (thiophanate-methyl) and TurfShied (organic fungicide)"
PAGE II-3 "It is important to note that the sod that was purchased and planted also likely received pesticide applications. For example, the farm that grew the sod often uses Bayleton (triadimefon)."
SOD MANIFESTS This is precisely the data I kept asking for since August 2000 after the sod was laid down! The Town was to have gotten manifests from the sod growers about what was applied to the sod. I asked repeatedly for this information in FOIA requests, but they never had it, or, if they did, furnished it t me. And, in the "informational meeting" with Dr. Petrovic on Dec 4, 2001, I asked if chemicals applied to the sod would affect the groundwater and Dr. Petrovic said: "No"
PAGE II-3, 4 In his "Nutrient Applications", Mr. Cohen doesn't give the total poundage/gallons of nutrients used, other than in term of "lbs/1000 sq. ft." He talks about the "active" ingredients but not the "inert" ingredients which amount to over 52,000 lbs! That, he conveniently forgets about. As far as "inert" ingredients go, in a 1997 seminar, Dr. Michael Surgan, Chief Scientist of the NYS Attorney General Environmental Protection Bureau said that "inerts" can be "as dangerous," or, "more dangerous" than the "active" ingredients themselves.
The EPA says, "pesticides contain both 'active' and 'inert' ingredients…An active ingredient is one that prevents, destroys, repels or mitigates a pest, or is a plant regulator, defoliant, desiccant or nitrogen stabilizer…An inert ingredient is simply any ingredient in the product that is not intended to affect a target pest. For example, isopropyl alcohol may be an active ingredient and antimicrobial pesticide in some products; however, in other products, it is used as a solvent and may be considered an inert ingredient…"
Alarmed by the public's misunderstanding of "inert" and "active" ingredients, the EPA issued a "Pesticide Regulation Notice" in 1997 asking manufacturers to: "voluntarily substitute the term 'other ingredients' as a heading for the 'inert ingredients' " on labels. The EPA did this because: "Many consumers are mislead by the term 'inert ingredient', believing it to mean 'harmless.' Since neither federal law nor the regulations define the term 'inert' on the basis of toxicity, hazard or risk to humans, non-target species, or the environment, it should not be assumed that all inert ingredients are non-toxic." Mr. Cohen should enumerate the inert ingredients contained in all the pesticides and in all the products used in fertilizer applications.
PAGE II-4 Cohen makes reference to pesticides protocols. The Town went along with the protocols put forth by Cohen in 1997 even though Councilwoman Martha Rogers promised us otherwise when she voted for the golf course on 1/14/97. The Town should be ashamed of itself for letting him get away with this. In fact, your ex-director of the Department of Land management, Robert Duffy, swore to me they'd never be allowed to use 2,4, D a component of agent orange, yet, it's on the allowable list for use after 2 years. The Town could have chosen to eliminate the use of certain pesticides, but they didn't. Why didn't they?.
NOWHERE IN HIS REPORT DOES COHEN MENTION "LOW-FLOW" SAMPLING WHICH THY WERE TO DO BY TERMS OF MONITORING AGREEMENT AND PETROVIC & CAMBRERI REPORT 1/5/99. Why aren't they using this method? Dr. Petrovic in ALL his reports also does not mention this. WHY?
PAGE II-6 "October 1st-3rd (2001)
"One pesticide (paclobutrazol - 4.22 ppb) and one metabolite (triadimenol - 1.0 ppb) were detected in MW-4. Paclobutrazol and triadimenol both have default New York guidance value of 50 ppb. Paclobutrazol has a lifetime drinking water Health Advisory Level (HAL) of 460 ppb."
If people are getting paclobutrazol from other sources, food, etc, some may be over the 460 ppb HAL levels, and, these HAL values don't take into account children, pregnant women, elderly, immune compromised. And, Health Advisory Levels do not mean that they won't have an adverse affect upon your health below that level. HALs also don't take into account the adverse synergistic effects of all the chemicals we're exposed to.
PAGE II-6 "All nitrate-N detections were well below the response trigger of 10 ppm."
As it stands, there is less than 0.2ppm nitrates in the Suffolk County Water Authority's public wells in the Noyac area. That's pure-that is, "non-detectable." The Town will be allowing contamination up to 10ppm. The ambient amount of nitrates found in water on the South Fork is only 1.5ppm! To allow 10ppm is a wanton degradation of this critical resource. As it's against Town Code, which has a "non-degradation" policy.
PAGE II-7 "Resampling Event (January 30, 2002)"
"…paclobutrazol detection in MW-4 at 3.8 ppb…"
[Cohen says, Not enough water in sandy soil for many lysimeter samples-not assuring-so they limited the tests to only certain chemicals-Paclobutrazol, triaimenol-that they had enough water for and not the other chemicals that were used]
PAGE III-1 "Field Notes" -
Leggette, Brashears & Grahm (LBG) were contracted to take samples and provide copies of field notes including name of person collecting samples. Petrovic's Reports' Six and Seven said some of these logs lacked "signatures". Since they aren't signed-how do we know who is really doing the sampling? Petrovic also complained in Reports III, IV, V, of logs not being turned over and in Reports VI, VII of missing Fed Ex receipts for test samples. -Without signatures, Fed Ex receipts, how do we know who's sampling. The Town should get a sworn statement from LBG that only their personnel has conducted ALL the sampling and Fed-Ex-ing to date.
PAGE III-2 "Quality Control Samples and Lab QC"
- Cohen underplays all the problems of quality control that Petrovic criticized in his reports including the fact that any deviations from protocol that occurred that were to be conveyed in writing (but weren't).
PAGE IV-3 re. differences in values in upgradient and downgradient wells- "may reflect a ground water flow divide that is so pronounced it is reflected in different geochemistry between upgradient and downgradient wells."
Petrovic should have commented on the ramifications of these all-important potential fluctuations of the local groundwater flow divides, but didn't.
PAGE IV-4 re. MW-4 "golf course drainage system terminated near MW-4 with minimal treatment (natural filtration) of the drainage water This system was modified in 2002, and no pesticides nor metabolites have been detected in MW-4 since that time."
Before the modification MW-4 was the recipient of chemicals triadimenol, paclobutrazol and elevation in nitrates. MW-4 is near the golf course boundary and Rugg's Path and people's homes downgradient of it.
 South Fork Groundwater Task Force
PO BOX 2360 Sag Harbor, NY 11963
Phone/Fax: 631 - 725 - 6200
Site By: Hamptons Online
|
|
|
