The following was sent to the Environmental Protection Agency via their web portal - have not received a response to date:
To Whom it May Concern -
Many Louisville citizens have concerns regarding the annual event held to kickoff the Kentucky Derby Festival, "Thunder Over Louisville" - one of the largest fireworks displays in the Nation. This event is staged over the Ohio River - the #1 most polluted river in North America. From Thunder's website, "To assemble a show the size of Thunder, Zambelli Internationale utilizes eight tractor trailers filled with nearly 60 tons of fireworks shells. The physical setup includes 250 tons of launching tubes, some as high as 10 feet with a diameter of 1½ feet. Two million pounds of sand will pack the firing tubes on 1,800 feet of barges. Almost 700 miles of wire cable connecting 20 firing boards are tied to the command post for synchronization to the music. This is the largest show the Zambellis perform each year, and the Zambellis are the largest fireworks family in the world." - this event generally draws a half million spectators as well as private and rented boats which also view the spectacle nearby from the river itself.
Is Zambelli Internationale currently utilizing Perchlorate free eco-friendly pyrotechnics above the Ohio River? Are they in adherence with EPA guidelines and regulations for pyrotechnics over bodies of water? Has there been an assessment on the detrimental impact to local wildlife habitats, marine life, quality of life, water and air quality for those living near and downstream from this production? Have there been any studies regarding the air & water quality before and after this event? Are local Urban residents living within close proximity to this event informed of the health hazards and what the health impact will be on these residents following this display? The Consumer Confidence Reports for the Ohio River do not paint a pretty picture - I'm hoping the EPA will take action to ensure this devastated river as well as nearby residents suffer no further unnecessary assaults merely for the sake of "entertainment"when there are more eco-friendly options available.
I would like assurances from the EPA that these conditions are being monitored, regulations enforced and the health and well-being of surrounding residents and environment are taken into account and addressed prior to this year's event which is on April 23, 2016.
To date our local Government appears to have turned a blind eye to the environmental and health ramifications of Thunder Over Louisville without accountability or legal recourse "with no strings attached" which is why I have contacted you. Many urban residents, hospitals and offices have no choice but be subjected to the noise exposure and toxins produced by Thunder. The health ramifications from this event can be devastating to those who are unable to temporarily relocate such as the elderly, the disabled, those with respiratory ailments, those with young children and the infirmed.
I would like to request EPA oversight on this event to ensure all precautions are taken to prevent further damage to our Urban, surrounding and downstream residents' health and environment, including but not limited to rigorous adherence to all State and Federal Regulations currently in place for pyrotechnic displays over bodies of water, the impact to nearby residents and those downstream. The Ohio does, after all, lead out to the Mississippi and on to the Gulf of Mexico which is already environmentally challenged.
Thank you for taking the time to address this.
***************
From the U.S. National Library of Medicine:
Children seem to be particularly susceptible to the harmful effects of ambient air pollution. Compared with adults, children have poor defences against PM and gaseous air pollutants, have a differential ability to metabolize and detoxify environmental agents, and have an airway epithelium that is more permeable to inhaled air pollutants. Also, children have a greater level of physical activity than adults; hence, their intake of air into the lungs is much greater than that of adults per day. No studies involving paediatric patients were identified in this field.
Hopefully Louisville Metro Government will make concerted efforts to inform residents living nearby of current and future health ramifications and the projected medical costs associated with those conditions, issue advisories to those with respiratory ailments to take necessary precautions during and weeks following the event and issue public service announcements educating residents and attendees regarding precautionary measures to guard against hearing loss, respiratory failure, tinnitus, trauma, neurological damage or other potential damages to their health and well being and most especially for the children attending this grand display of firepower.
From the U.S. National Library of Medicine:
Children seem to be particularly susceptible to the harmful effects of ambient air pollution. Compared with adults, children have poor defences against PM and gaseous air pollutants, have a differential ability to metabolize and detoxify environmental agents, and have an airway epithelium that is more permeable to inhaled air pollutants. Also, children have a greater level of physical activity than adults; hence, their intake of air into the lungs is much greater than that of adults per day. No studies involving paediatric patients were identified in this field.
Hopefully Louisville Metro Government will make concerted efforts to inform residents living nearby of current and future health ramifications and the projected medical costs associated with those conditions, issue advisories to those with respiratory ailments to take necessary precautions during and weeks following the event and issue public service announcements educating residents and attendees regarding precautionary measures to guard against hearing loss, respiratory failure, tinnitus, trauma, neurological damage or other potential damages to their health and well being and most especially for the children attending this grand display of firepower.
Current presenting sponsors for this year's Thunder Over Louisville are LG&E, KentuckyOne Health (encompassing Flaget Memorial Hospital, University of Louisville Hospital, Frazier Rehab Institute, James Graham Brown Cancer Center, Jewish Hospital, Medical Center Jewish East, Our Lady of Peace, Saint Joseph Hospital, St. Mary & Elizabeth Hospital, Southern Indiana Rehab Hospital, Taylor Regional Hospital, Continuing Care Hospital and VNA Health at Home), Horseshoe Southern Indiana, Meijer, UPS, Valero Oil. and Ford (Thunder on the Ground).
Response received from the EPA today, March 8, 2016:
JT (Public Access)
| From | JT (Public Access) support@publicaccess.zendesk.com |
Mar 8, 8:35 AM
Thank you for your inquiry to the EPA Web site. Your request has been received by the Headquarters Public Access Service, a contractor operated reference and referral service.
We apologize for our delayed response. Due to unforeseen circumstances, your inquiry was not handled in a timely manner. We thank you for your patience while awaiting our response.
You are concerned about pollution from the "Thunder Over Louisville", and wonder if Zambelli Internationale currently utilizing Perchlorate-Free eco-friendly fireworks above the Ohio river.
Please be aware, the Public Access Service is a library reference and referral service and cannot provide regulatory guidance or applicability determinations. We are providing the information and referrals/contacts listed below so that you can seek that support directly from Agency program staff or other information services that can provide that assistance.
Your state environmental agency may be a better resource for this question. Many issues are regulated by the states themselves, and contacting the state directly may be the best action.
Kentucky Department of Environmental Protection may be helpful:http://dep.ky.gov/Pages/default.aspx
If this office is unhelpful, please contact your EPA Regional office. Each regional office contains documentation and statistics on environmental issues specific to the states over which they have jurisdiction. EPA Region 4 serves Kentucky:http://www.epa.gov/aboutepa/forms/contacting-epa-region-4-southeast
EPA in Kentucky: http://www.epa.gov/aboutepa/epa-kentucky
You can also contact your county with any local concerns you may have. Please use this map to locate your county offices:http://www.naco.org/Counties/Pages/FindACounty.aspx.
External Links Disclaimer: Please be aware that links to non-EPA sites do not imply any official EPA endorsement. Furthermore, EPA does not accept any responsibility for the opinions, ideas, data or products presented at those locations, or guarantee the validity of the information provided. EPA does not guarantee the suitability of the information for any specific purpose.
Public Access Reference Service, operated by ASRC Primus
EPA Headquarters
William Jefferson Clinton Federal Building
1200 Pennsylvania Avenue, N.W. (3404T)
Washington, DC 20460
*****************
Which per their suggestion was sent via email to
| To | envhelp envhelp@ky.gov per this website: |
*************
Received response from Bozzell, Derek A (EEC) (EEC) Derek.Bozzell@ky.gov
Ms. Vinch,
The pyrotechnic displays from events such as Thunder over Louisville are brief occurrences, but as you noted, they could result in releases of a number of metals and oxidizers such as potassium perchlorate.
The water intake for Louisville’s Crescent Hill Water Treatment Plant is downstream on the Ohio from the location where Thunder over Louisville has been held in previous years (We would assume it will also be held at that location this year.). The next surface water treatment plant downstream in Kentucky is located at Henderson, approximately 150 miles downstream. Ohio River flow volume at any location, including Louisville, varies hourly and daily, but it is reported by the US Geological Survey that the current flow of the Ohio River at Louisville is 14,457,345 gallons per minute. In spite of the seemingly large amounts (tons) of fireworks that will be detonated at the display, lesser amounts of perchlorate and metals will be released as compared to the total fireworks volume and any resulting concentrations of contaminants further diluted by the large volume of river water. The concentration of perchlorate and metals in the Crescent Hill Treatment Plant intake is likely to briefly peak at a very low level and return to ambient levels within at most a few days. It is possible that any peaks that occur will be too low, as compared to normal conditions in the river, to even detect at the intake. Crescent Hill and downstream water treatment plants routinely monitor intake and finished water for metals; as noted, they currently do not monitor for perchlorate. However, the metals routinely monitored, including samples taken before and after the Thunder over Louisville fireworks event, should act as a reasonable surrogate for concentrations of both metals and perchlorate that may be present in the Ohio River intake water.
If you have further questions regarding the types of fireworks that Zambelli Fireworks uses, you may want to try contacting them directly at their corporate headquarters at 800-245-0397, or their nearest regional office in Ohio at 513-478-6475. You may also want to try contacting the State Fire Marshal, which is the office that permits pyrotechnic displays, at 502-573-1702.
Derek Bozzell
Environmental Compliance Specialist
Division of Compliance Assistance
300 Fair Oaks Lane, Frankfort, KY 40601
502-564-0323 x3246
Fax: 502-564-9720
************
From: Vicky Vinch
Sent: Thursday, March 10, 2016 11:02 AM
To: Bozzell, Derek A (EEC)
Subject: Re: Concerns Regarding Thunder Over Louisville
Sent: Thursday, March 10, 2016 11:02 AM
To: Bozzell, Derek A (EEC)
Subject: Re: Concerns Regarding Thunder Over Louisville
Thank you for your response, Mr. Bozzell - would it then be safe to assume if one catches and consumes fish from this area these fish would be safe for human consumption? If not, are there appropriate fish consumption advisories placed in these areas to allow fishermen to make their own judgment calls?
Much appreciated!
Vicky
*****************
From: Bozzell, Derek A (EEC) (EEC) <Derek.Bozzell@ky.gov>
To: Vicky Vinch
Sent: Thu, Mar 10, 2016 11:07 am
Subject: RE: Concerns Regarding Thunder Over Louisville
To: Vicky Vinch
Sent: Thu, Mar 10, 2016 11:07 am
Subject: RE: Concerns Regarding Thunder Over Louisville
Ms. Vinch,
Perchlorate has been identified to bioaccumulate into aquatic organisms directly from water (bioconcentration) and through the food chain (biomagnification), but generally accumulated levels remain only as long as the exposure. As the level of perchlorate in the water or food goes down, the concentrations in the tissues fairly rapidly also go down. This is an important consideration when evaluating any detrimental effects from eating contaminated fish, fish may be contaminated but for a brief time whereas the fish advisories are determined based on long-term exposures. In fish themselves, the bioaccumulation factor has been determined to be 0.5, approximately half of the levels found in the water or their food will fairly rapidly (within days) appear in the fish. Compared to a number of other environmental contaminants, perchlorate would be considered to have such a low bioaccumulating factor as to not be a bioaccumulating substance of environmental concern. For example, the environmental contaminant mercury may occur at 10,000 to 100,000 times greater concentration in the fish tissues than can be detected in the water (a bioaccumulation factor of 10,000 to 100,000), and once in the fish tissues essentially will stay at those levels for many years.
If you have any further concerns, please feel free to contact me.
Derek Bozzell
Environmental Compliance Specialist
Division of Compliance Assistance
502-564-0323 x3246
Fax: 502-564-9720
SIMPLIFYING COMPLIANCE, IMPROVING PERFORMANCE
*********************
From: Vicky Vinch
Sent: Thursday, March 10, 2016 11:31 AM
To: Bozzell, Derek A (EEC)
Subject: Re: Concerns Regarding Thunder Over Louisville
Sent: Thursday, March 10, 2016 11:31 AM
To: Bozzell, Derek A (EEC)
Subject: Re: Concerns Regarding Thunder Over Louisville
Thank you - I am looking at what I can find with regard to Louisville's Consumer Confidence Reports and this is the best I can come up with - the information is minimal at best: - http://louisvillewater.com/sites/louisvillewater.com/files/user_uploads/pdf%20files/Annual%20Water%20Quality%20Report.pdf Are public advisories issued anywhere regarding immediate risks to fish consumption from this area immediately after Thunder? I do see many people fish from this area. I'd like to take my dog there but I don't want her to get sick if she drinks the water. She's previously gotten sick from drinking the water over at Beckley (The Parklands) - it's next to a sewage plant. People fish there too.
Where would one locate amounts of perchlorate in the surface and ground water amounts in the Ohio at Louisville? I'm also wondering why there are not fish advisories posted on the Indiana side of the Ohio or in Indiana at all at the Ohio? I understand this is not your jurisdiction. Also, in your opinion, is it prudent to continue to pump raw sewage into the Ohio and is that being addressed? I do see work being done by MSD inland to upgrade CSO's. Lots of question, I know. Appreciate any insights. I will follow up with Zambelli & the Fire Marshall although I do not expect a reply from the Fire Marshall unless we've gotten a new one since the last time I'd contacted them.
Thanks,
Vicky
******************************
From: Bozzell, Derek A (EEC) (EEC) <Derek.Bozzell@ky.gov>
To: Vicky Vinch
Sent: Thu, Mar 10, 2016 2:25 pm
Subject: RE: Concerns Regarding Thunder Over Louisville
To: Vicky Vinch
Sent: Thu, Mar 10, 2016 2:25 pm
Subject: RE: Concerns Regarding Thunder Over Louisville
Ms. Vinch,
For information regarding public advisories involving the Ohio River, please see the following Department for Environmental Protection websites:
Perchlorates are not a regular monitoring parameter of Kentucky Pollution Discharge Elimination System (KPDES) permits, and, as such, I am not aware of any sources to find current or regular perchlorate levels.
Please do not hesitate to contact me if you have further questions.
Derek Bozzell
Environmental Compliance Specialist
Division of Compliance Assistance
502-564-0323 x3246
Fax: 502-564-9720
SIMPLIFYING COMPLIANCE, IMPROVING PERFORMANCE
*********************
From: Vicky Vinch
Sent: Thursday, March 10, 2016 2:52 PM
To: Bozzell, Derek A (EEC)
Subject: Re: Concerns Regarding Thunder Over Louisville
Sent: Thursday, March 10, 2016 2:52 PM
To: Bozzell, Derek A (EEC)
Subject: Re: Concerns Regarding Thunder Over Louisville
Thank you, Mr. Bozzell - I have followed the KY fish consumption & swim advisories somewhat regularly yet I rarely see postings at many public lakes. It is saddening, to say the least.
In your opinion would you think it would be prudent to periodically test Kentucky waters for perchlorate levels? Or in reality would it be futile since we already are aware of the mercury and PCB levels which will eventually kill us anyway? Sorry to be so blunt - it's a known issue of mine I'm working on.
What is being done, if anything, to correct and/or control the Mercury/PCB levels in our water here in KY if you don't mind my asking (other than overseas outsourcing industries that cause them)?
I do see work on MSD regarding the CSO's and that is encouraging. Last questions, I promise.
Thanks,
Vicky
********************
From: Bozzell, Derek A (EEC) (EEC) <Derek.Bozzell@ky.gov>
To: Vicky Vinch
Sent: Thu, Mar 10, 2016 4:17 pm
Subject: RE: Concerns Regarding Thunder Over Louisville
To: Vicky Vinch
Sent: Thu, Mar 10, 2016 4:17 pm
Subject: RE: Concerns Regarding Thunder Over Louisville
Ms. Vinch,
Mercury is considered a hazardous waste under the federal Resource Conservation and Recovery Act (RCRA), and therefore its generation, storage, treatment and disposal are regulated. Mercury is monitored and removed from water at wastewater treatment plants. PCBs are managed under the federal Toxic Substances Control Act (TSCA), which addresses production, importation, use, and disposal. PCBs are monitored in Total Maximum Daily Load records.
Derek Bozzell
Environmental Compliance Specialist
Division of Compliance Assistance
502-564-0323 x3246
Fax: 502-564-9720
SIMPLIFYING COMPLIANCE, IMPROVING PERFORMANCE
**********************
Thank you for the info. It's not helping our fish and wildlife any, though. (Nor humans nearby who are breathing this air). I would word it more as "not regulated" or "supposed to be regulated", and "not managed" I understand completely now. Note: no questions.
Will work on it.
Much appreciated. You have been very helpful. Thank you.
Vicky V.
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