Pacific Steel Casting:
A Citizens Guide to Understanding the Issues


Pacific Steel Casting Emits Increasing Amounts of Known Toxic Pollutants

  • These substances are known to be toxic to people. Children are particularly vulnerable.
  • Among other things, they are carcinogens, neurotoxins, and respiratory toxicants.
  • Even at low levels they pose a hazard to health because they persist in the environment and accumulate in our bodies.
  • Emissions have increased significantly over the last few years.
  • The most current available data are for 2005. It's reasonable to assume pollutants have continued to increase based on the growing number of public nuisance complaints in more recent years.

Sources: Center for Occupational and Environmental Health, School of Public Health, UC Berkeley; U.S. Agency for Toxic Substances and Disease Control; California Air Resources Board.

Total Particulates Released by Pacific Steel Casting

  • Particulates are implicated in premature deaths from cardiovascular and respiratory illnesses.
  • West Berkeley has some of California's highest rates of hospital admissions for asthma in children.
  • From 2002-2005, total particulates from PSC increased 13.7%; PM 2.5 (smaller, more hazardous fine particles) increased 11%.
  • PSC accounts for 59% of all industrial PM 2.5 emissions in 2005.

Source: California Air Resources Board

Total Particulates Released by Pacific Steel Casting

Toxic Air Emissions (in pounds)

  • Manganese emissions are up over 50%
  • Formaldehyde emissions are up almost 130%
  • Benzene emissions are up a whopping 160%

Source: California Air Resources Board

Toxic Lead Emissions (in pounds)

  • Lead emissions up almost 130%

Source: California Air Resources Board

Pacific Steel Casting is the Only Industrial Source of These Toxic Pollutants

  • 100% of all Lead
  • 100% of all Manganese
  • 100% of all Phenol
  • 100% of all Zinc
  • 100% of all Cresol
  • 100% of all Copper

Source: California Air Resources Board

Pacific Steel Casting is the Major Industrial Source for These Toxic Pollutants

  • 64% of all Benzene
  • 81 % of all Formaldehyde
  • 99% of all Nickel
  • 59% of all small particles

Source: California Air Resources Board

Pacific Steel Casting is the Biggest Polluter in Berkeley

  • Of 33 West Berkeley industries required to report toxic emissions to the California Air Resources Board, Pacific Steel IS the biggest polluter by far.
  • With a few exceptions, most of these businesses reported releasing little or no toxic air pollutants.
  • Pacific Steel is the only industrial source of certain highly toxic emissions such as lead.
  • And, no other industries emitted the same complex mix of toxic pollutants as Pacific Steel.
  • Other environmental sources of lead have been eliminated by banning lead additives in gasoline and by phasing out the use of lead in paints.
  • The unique and unmistakable odor of Pacific Steel is due to its unique pollutant mix that no other company releases.

Source: California Air Resources Board

Pacific Steel Casting's Risk Assessment is Inconclusive

  • Required by the Air District.
  • Risk Assessments are based on modeling, not actual air monitoring where people live and work.
  • An expert advisor to the mayor acknowledged that models are easily manipulated to produce the desired results.
  • For example, Pacific Steel utilized questionable assumptions including the near perfect effectiveness of its existing pollution controls.
  • Also, not all pollutants were included.
  • Overall, these assumptions and exclusions can result in an understatement of risk.
  • The exceptionally high number of odor complaints is inconsistent with assumptions the company made about the effectiveness of its pollution controls.
  • -The risks of PM 10 and PM 2.5 particles were not assessed. Pacific Steel accounts for nearly half of all industrial particulate emissions and particulates are a serious health hazard, implicated in premature deaths from respiratory and coronary disease.
  • -Estimates of emissions used in the risk assessment were inconsistent with Pacific Steel's own annual self-reported emissions to the California Air Resources Board.

Sources: West Berkeley Alliance for Clean Air and Safe Jobs, Pacific Steel Risk Assessment, community comments submittal to the Air District

The Air District's Risk Assessment Approach is Flawed

  • To make matters worse, the Air District's Risk Assessment approach is flawed.
  • The Air District accepted the use of an insufficiently protective state reference level for manganese toxicity, a level 4 times less stringent than the existing federal level.
  • Public health protection levels are 10 times less protective than those used in other states.
  • Not surprisingly, the Air District has never in its history used the results of a risk assessment to reduce toxic emissions!
  • Adverse health affects have been noted even at the more stringent federal level.
  • The USA Today article stated Ohio required industries to take action to reduce toxic emissions when the cancer risk was 1 in 100,000 (1 excess death in 100,000 over a lifetime). In California, however, the Air District requires industry to reduce their toxic emissions only if the risk level exceeds 1 in 10,000. In effect, BAAQMD is using a standard 10 times more lenient than Ohio's.
  • When asked if the Air District had ever use a risk assessment to compel an industrial source to reduce its toxic emissions, Scott Lutz, in charge of risk assessments for the District, could not cite an instance.

Sources: Pacific Steel Risk Assessment, USA Today, Air District, City of Berkeley environmental consultant

Community Air Moniting

  • To see what residents were actually exposed to Global Community Monitor requested Air District funding for community air testing.
  • The testing involved good science and the Air District accepted the test results.
  • Over a half-year some 64 samples were taken at 23 West Berkeley and Albany locations.
  • Two-thirds of these locations were found to contain toxic metals exceeding health levels.
  • Making matters worse, nearly half of these unsafe samples were taken after Pacific Steel claimed to have installed additional pollution controls.
  • Project was funded by an Air District grant to the environmental group Global Community Monitor. Trained community volunteers did the testing.
  • Only toxic metals were tested. Other pollutants like benzene, formaldehyde, and phenol­substances with serious health consequences and also emitted by Pacific Steel-were not included.
  • The testing involved good science
    • Standard operating practices were developed to ensure testing uniformity and consistency.
    • The monitoring device used was recommended by the Air District because of its accuracy and ease of use.
    • A written monitoring plan was developed with clear site selection criteria.
    • Air District staff actually observed the team's site selection process and use of the monitor.
    • All volunteers were trained in how to properly use the monitor and handle samples.
    • Official meteorological data were used to determine sample validity.
    • Samples not meeting quality control criteria were discarded.
    • Sample chain of custody procedures were followed and documented.
    • An EPA approved analytical lab was used.
    • Sample results were compared with published World Health Organization and EPA health levels
  • Over a half-year period some 64 air samples were taken at 23 West Berkeley and Albany locations Two-thirds of these locations were found to contain toxic metals exceeding health levels For example, manganese levels at the 600 block of Gilman Street and the 1300-block of 3rd Street were 10-20 times the World health Organization's health level; nickel levels were up to 330 times the US EPA health level.

  • Additionally, nearly half of the unsafe samples were taken after September 15, the date by which Pacific Steel claims to have installed additional pollution control

  • Pacific Steel is the only major industrial source of manganese and accounts for 99% of all industrial nickel emissions in West Berkeley. Testing also showed higher concentrations of these toxic metals closer to Pacific Steel

  • To eliminate other possible sources of these pollutants air monitors were placed upwind of Pacific Steel and downwind of the freeway. Monitoring at these locations failed to identify another source

  • Monitoring involved taking multiple 24-hour samples weeks or months apart strongly suggesting these samples are representative of the daily exposures experienced by residents, workers and children in nearby schools and day care centers.

  • Unhealthy metal levels were found over half a mile from Pacific Steel. Berkeley has a population density of 10,000/square mile-potentially thousands are exposed to toxic air emissions. Many schools and childcare centers are within this area.

  • Odors may have abated recently but metals are hard to detect by smell alone.

Source: Global Community Monitor

Pacific Steel Casting's Risk Assessment Compared with Community Air Monitoring

  • Pacific Steel's risk assessment requires that individuals who live or work in the yellow area be notified of health risks; red dots show that community air monitoring locations with high toxic pollutant levels extend considerably beyond this area.

Source: Berkeley Citizen/Berkeley Air Monitors
Pacific Steel Risk Assessment

Air District Monitoring

  • In addition to requiring Pacific Steel to do a risk assessment, the Air District also conducted its own air monitoring in West Berkeley.
  • The Air District has not publicly released these data but a preliminary analysis indicates unhealthy levels of Manganese, Nickel, Formaldehyde and Benzene.
  • The monitor was located a few blocks from Pacific Steel and levels of Manganese, Nickel and Formaldehyde were correlated with iron levels, suggesting Pacific Steel as a likely source of these pollutants.
  • Nickel levels averaged 12 ng/m3, above the level that is a significant cancer risk according to the World Health Organization

  • The EPA Reference Concentration (RfC) for manganese is 0.00005 mg/m3 based on impairment of neurobehavioral function in humans. This is equivalent to a concentration of 0.050 micrograms per cubic meter, or 50 nanograms per cubic meter. The Air District measured 24-hour manganese concentrations on 32 different occasions from 31 December 2007 to 29 June 2008. On 8 occasions, the 24-hour manganese concentration exceeded the EPA RfC of 50 nanograms per cubic mete.r

  • The Air District measured 24-hour formaldehyde concentrations on 56 different occasions from 14 December 2007 to 27 October 2008. The arithmetic mean for ambient levels of formaldehyde was 1.63 micrograms per cubic meter. This concentration is more than twice the concentration that might result in a one-in-a-hundred thousand increased chance of developing cancer. This level of cancer risk is considered a serious regulatory matter by most environmental and public health agencies.

  • According to the data it provided, the Air District measured 24-hour benzene concentrations on 56 different occasions from 1 January 2008 to 8 November 2008. The arithmetic mean for ambient levels of benzene was 0.73 micrograms per cubic meter. This concentration is more than the concentration that might result in a one-in-a-million increased chance of developing cancer. This level of cancer risk should also be a significant regulatory concern.

  • Mn and Ni levels were strongly correlated with iron levels (correlation coefficients > 0.8). Formaldehyde levels were moderately correlated with iron levels (correlation coefficient of 0.69).

Source: Global Community Monitor

USA Today Report Ranks Berkeley Schools Low

  • Using an EPA model and toxic emissions data, USA Today identified Pacific Steel as the chief culprit for why 11 Berkeley schools were in areas with some of the nation's worst toxic air pollution.
  • Pacific Steel's emissions of Manganese and Nickel account for most of this pollution.
  • While the study has been criticized for using a model that isn't detailed enough to provide conclusive evidence of actual toxic exposure, the extent of Berkeley's problem could also be understated because day care centers and some schools were excluded.
  • Also excluded were UC' s University Village and Berkeley's Harrison Street shelter. Both locations have families with children.
  • Day care centers and schools, like Berkeley's Franklin Preschool, were not included.

Source: USA Today

Day Care Children on Recess Two Blocks from Pacific Steel

Criticisms of the USA Today Study

  • The Air District called the study "misleading and false" and stated data used are "not scientifically valid or verified for the purposes of making risk based assessments."
  • The Air District also criticized the study for not mentioning that diesel particulate matter accounts for the largest share of the nation's toxic air pollution.

Source: Air District correspondence released by Mayor Bates and City Council Member Linda Maio


  • USA Today reporter Blake Morrison: "Mr. Broadbent appears to misunderstand how we used (the) TRI." Risk screening is an appropriate use of TRI data.
  • Professor Michael Ash, Political Economy Research Institute: "Mr. Broadbent has inaccurately characterized our discussion of the accuracy of the ... data." On the contrary, the data used in the USA Today study is "unbiased" and a "best-practice screening system for community exposure to airborne industrial toxics."
  • TRI data have been extensively peer reviewed by the EPA's Science Advisory Board.
  • And, nobody is contesting the fact that diesel exhaust has serious adverse health effects.
  • 'USA Today worked closely with EPA official Nick Bowes, who actually developed the model used in the analysis.
  • Although the Air District's Jack Broadbent cited PERI as a critic of the data used, PERI in subsequent correspondence with a concerned Berkeley parent, stated just the opposite.

A Strategy for Moving Forward

  • Demand health agencies look for adverse health effects in the community.
  • Require Pacific Steel to conduct continuous air monitoring with community participation.
  • Require Pacific Steel to enter into a good neighbor agreement involving:
    • plant access --a formal, regular and transparent dialogue
    • targets for continuing emissions reductions and a plan with dates for achieving these reductions
    • a commitment to toxics use reduction Demand the city use its zoning and health authorities to protect the public in the interim.
  • Pressured to use its zoning and health authorities, Berkeley officials instead promised to work informally with Pacific Steel to reduce odors and toxic emissions. This "behind closed doors" approach has produced no results. The lack of accountability is an issue--there needs to be a transparent process that directly involves the community. A "good neighbor" agreement that directly involves citizens provides this transparency.
  • A "good neighbor" agreement needs to be paired with a commitment to toxic use reduction because risk assessment is a seriously flawed approach to regulating air toxics. First, it assumes a certain number of illnesses and deaths are acceptable. Second, it only assesses one source at a time when, in fact, people are exposed to multiple sources of air toxics on a daily basis. Finally, as shown earlier, its results are highly dependent on the assumptions used in the analysis. Conducted by private consultants to industry, the public must rely on regulatory agencies to ensure the integrity of the process. However, there is no formal process for public input. The Air District, in response to community pressure, solicited public comments on Pacific Steel's risk assessment but never formally replied whether any of these comments resulted in changes or improvements.
An Organized Community is the Key to Solving this Problem

  • Progress to date has occurred only because the community made the best of an antiquated complaint process used by the Air District, was persistent, and demanded that something be done. Continued community pressure on elected officials and the Air District is needed to ensure further progress.

By Peter Guerrero

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