REPORT: Leading Lead Expert tells TCEQ Plan for Exide Fails to Protect Frisco Children and Community
In professional comments prepared for submission to the TCEQ, Howard Mielke, PhD.,Â one of world’s leading experts on lead and its toxicity, states:
“Given the emerging science of lead and the current understanding of its impact on young children, the current agreement to limit emissions to over 600 lbs of lead per year does not protect the Frisco community.
“I have conducted original and primary research on lead in the environment and the response of children to lead.Â The following are emerging facts that must be carefully deliberated in making decisions about the of lead emission releases into a populated community.
- The emerging science indicates that although the CDC states there is no known safe lead level, they continue to use the 10 Âµg/dL guideline which was established 20 years ago.Â Current research indicates distinctive and replicated learning and IQ deficits at exposures of 2 Âµg/dL.Â
“Children are much more vulnerable at far lower quantities of lead in the environment than previously recognized.
“…The larger the amount of lead in the soil of a community the higher the blood lead exposure of the young children.Â Particularly relevant to the Frisco, a community where the soil lead is relatively low there is an especially steep rise in blood lead.Â In the communities of Frisco located within 1 mile of Exide, just meet soil lead levels of 20-100 ppm. Â Â Currently, there is a small or no margin of safety.Â
- Frisco, TX is a vibrant and rapidly growing town.Â Families with young children are relying on the city to maintain a safe and sustainable environment for their children.
- Note that there are 12 childcare center, 3 playgrounds, and 7 elementary schools within a 2 mile radius of the Exide facility.Â These child oriented facilities are valuable community assets that must be protected from Exideâ€™s lead emissions. (See Map)
“Legacy lead is an important issue for Frisco, TX.
Â “Soil on Exide property is likely to be particularly lead-contaminated and this soil is a potential source of airborne lead.Â
“During drought and late summer and early fall, when soils become dry, re-suspension of lead contaminated soil may set the low limit for controlling childrenâ€™s exposure.Â This was an important finding within another smelter community of El Paso, TX.Â (See research by Mileke and others on soil – in summer months – as a lead exposure pathway.)
“Given the emerging science of lead and the current understanding of its impact on young children, the current agreement to limit emissions to over 600 lbs of lead per year does not protect the Frisco community.Â
“Concern has been expressed that the allowable emissions are in reality being limited to 2000 lbs. per year.Â Given the emerging science, the prudent course of action is to regulate using only the best available technology; currently this would cut emissions of the Exide recycling facility to less than 20 lbs of lead per year. Â
“Meeting this emission would place the Frisco Exide into the ranks of a world class facility and congruent with the image of Frisco as a world class community.”
You can download the full text of Dr. Mileke’s comments to the TCEQ below: