Hudson Mohawk Group

P.O. Box 8447

Albany, NY 12208
February 22, 2013
Honorable Judith Enck, Administrator
Environmental Protection Agency
Region 2
290 Broadway
New York, NY 1007-1866
Honorable Joseph Martens, Commissioner
New York State Department of Environmental Conservation
625 Broadway
Albany, New York 12233-0001
RE: Dangerous Health Impacts from Air Emissions in Rensselaer, NY
Dear Ms. Enck and Mr. Martens:
For almost a year and a half now, the Hudson Mohawk Group has worked
alongside the Concerned Citizens of Rensselaer to begin to determine the
human health impacts related to air emissions in and around the City of
Rensselaer. As will be detailed below, we have become aware of what some
of those impacts are and are attempting to determine how to best address
them. Because of our current air monitoring work with scientific analysis
professionals we have collected data which indicates that at least certain
portions of the airshed in the City is unhealthy and actually hazardous to
human health. Therefore, we are asking for an immediate assessment of the
air shed in the City of Rensselaer by the EPA in consultation with the New

York State Department of Environmental Conservation and, an evaluation of

the potential human health impacts of the air shed.
It is well known that there is an inordinately high number of industrial
facilities that impact air quality in the City of Rensselaer. First and probably
foremost is the Amtrak Station in Rensselaer. For many years, the residents
who live in close proximity to the Amtrak Station have had to deal with the
noxious and unhealthy fumes. The fumes emanate from the train
maintenance facility as well as the passenger trains which idle. We now
have solid, scientific evidence of how harmful breathing those fumes can be.
Through its participation as an official party in the siting under Article X of
the Public Service Law, of the new combined cycle gas plant in Rensselaer,
the Sierra Club Hudson Mohawk Group was chosen as the recipient of
$250,000 deposited into a Local Clean Air Fund under an agreement
between the Sierra Club Hudson Mohawk Group and Empire Development.
The purpose of the funding is to improve ambient air quality in areas
surrounding and near the Projects in New York State. 1 With a portion of this
funding, the Sierra Club, in consultation with the Concerned Citizens of
Rensselaer (identified as the Local Committee as per the above reference),
undertook air quality monitoring to determine locations where air quality was
of special concern. One of the first locations chosen was behind a residence
located at 1100 Broadway in Rensselaer whose backyard was approximately
100 yards from the Amtrak Station. Locomotives waiting for crew changes,
new passengers and other activities idle for long periods in which diesel fuel
is burned. Using professional and calibrated air quality monitoring devices 2,
1Appendix A, Exhibit 8 of New York State Board on Electric Generation Siting and the
Environment, Opinion and Order Granting Certificate of Environmental Compatibility and
Public Need; Issued and Effective, September 24, 2004, p. 2.
2The Air MetricsTM MiniVolTM Tactical Air Sampler, manufactured by Air Metrics was utilized in
each of the samples taken. This sampling equipment is a portable ambient air sampler for
particulate matter that can also be used for sampling various air toxics. Its patented flow
technology was developed jointly with the U.S. Environmental Protection Agency in an effort

the Sierra Club/Local Committee took 21 separate samples during 2011 and
2012. Five of those samples were of particular concern due to the high
readings of elemental carbon (EC), such as those found in emissions from
diesel fumes.
As is typically utilized, EC measurements were the metric used to determine
the potential health affects of exposure to diesel engine emissions. As
referenced above, a number of citizens currently live behind the Amtrak Train
station in Rensselaer and are certain that the odor given off is of a gasoline
type and a number of them have stated they believe it is a diesel type
gasoline odor. We would have no problem in obtaining residents willing to
sign affidavits stating that they believe that the very strong odor drifting
toward their residence is in fact a diesel type odor.
Specifically, between June 20, 2011 and March 21, 2012, there were five air
sampling results of particular concern. To understand these sampling results,
a level of human health significance is associated with varying level of EC.
These levels are:
When regular EC levels at a location are above 1.0 micrograms per

cubic liter, then one can conclude that this location is an area impacted
by diesel engine emissions.

to address the need for portable air pollution sampling. While not a reference method
sampler, the mass concentrations of the MiniVol TM TAS gives results that closely agree with
reference method concentrations. In these samples, it was used as a sampler for particulate
matter.
3As reported by Mark Cherniak, Ph.D. Based in part on work in 2008, scientists from the
California Office of Environmental Health Hazard Assessment (OEHHA) published a study
about the relationship between cardiovascular mortality and the chemical composition of
pollutant levels in ambient air in California. These scientists examined the relationship
between cardiovascular mortality and the interquartile range (IQR = the difference between
the third and first quartiles) of EC levels. The scientists found strongly significant
associations between excess risk of cardiovascular mortality two and three-days post
exposure and the IQR for EC. The average level of EC in ambient air samples in the study
was 0.966 g/m3. The IQR for EC was 0.795 g/m3. In this study, the 4th quartile level of EC

 When the 24-hour EC levels at a location are above .838 micrograms

per cubic liter, then they are high enough to be associated with an
excess risk of cardiovascular and respiratory hospitalizations on the
day of exposure.4
When 24-hour EC levels at a location are above 1.36 micrograms per

cubic liter, then they are high enough to be associated with an excess
risk of cardiovascular mortality two and three-days post exposure.

The five most significant readings from locations behind Broadway in

Rensselaer, all downwind of the Amtrak Train station were:
6/20 6/21/2011:

.94 micrograms per cubic liter

7/15 7/16/2011:

1.18

3/11 - 3/12/2012:

1.43

3/18 3/19/2012:

1.30

3/21 3/22/2012:

1.02

The health impacts of human exposure to these levels of EC is

alarming. According to Dr. Cherniak (see references above and below), on
March 11-12 from 1100 Broadway in Rensselaer, persons spending time
outdoors at this location would be subject to an elevated risk of
cardiovascular mortality two and three-days post exposure: and an elevated
risk of cardiovascular and respiratory hospitalizations on the day of exposure.
was 1.36 (0.966 + [0.795/2]) g/m3. Ostro, et al. (2008) The impact of components of fine
particulate matter on cardiovascular mortality in susceptible subpopulations, Occup.
Environ. Med., 65;750-756.

4Ibid
5Ibid

To put it more directly, the above results from March 11-12 are just one days
worth of exposure, in an unusually warm day in March when the wind was
blowing from the south. The impacts of an entire summers worth of
exposure, when windows are open and the breeze is from the south, can only
be categorized as alarming, in our opinion. We have no doubt that the
weather records would indicate that these conditions have frequently
occurred in the past, putting the residents of Rensselaer at risk, to say the
least.
Because of the alarming diesel emission issues, the Sierra Club Hudson
Mohawk Group and the Rensselaer Concerned Citizens believe there may
well be other emission issues that should be addressed also. Toward that
end, we are in the process of completing the second phase of air monitoring
in the City of Rensselaer. This second phase of monitoring will consist of
short grab samples of air taken when there are strong odors present.
Unfortunately, upon talking with residents of Rensselaer, this is an all too
common occurrence. The number of industrial facilities emitting various
pollutants including volatile organic compounds (VOCs), nitrous oxides, sulfur
dioxides and many others is well documented. VOCs typically include
hazardous air pollutants such as benzene, formaldehyde and toluene, among
others, as listed in the DEC permits. VOCs are potential cancer causing
compounds and are associated with respiratory and other health problems
including allergic, or immune effects in infants or children. This phase of our
monitoring will continue throughout the summer in locations where strong
industrial type odors are know to occur including South Street and locations
within the Port of Rensselaer. We will keep you apprised of these efforts as
we obtain results.
The nearby emitting facilities include the Hess Oil Terminal, Empire
Development Power Plant, Petroleum Fuel and Terminal Co., Albany Molecular
Research Inc., (a chemistry-based drug development company), Rensselaer
5

Iron and Steel, Rensselaer Cogeneration facility and the Bennington

Paperboard facility. According to New York State DEC and EPA records, these
facilities combined typically emit over 100 tons of VOCs per year. In addition
to these facilities and as highlighted above, the Rensselaer Amtrak station is
a major emitter of diesel fuel related fumes from its passenger trains which
idle at least 12 hours per day. In addition to these emitting facilities, in close
proximity are also found Surpass Chemicals, Passano Paints, Gorman
Brothers Asphalt Plant (in the Albany Port) and C & F Plating.
Additionally, in its application to the New York State DEC for an air quality
permit, the developer of the New Castle asphalt plant stated that the
proposed plant would have the capacity to produce 400 tons of asphalt per
hour and would limit production to 350,000 tons per year. During this
process, the plant would produce over 11,000 pounds (an additional 5.5
tons) of VOCs.
We believe we have presented a very accurate picture of the air emission
problems in the City of Rensselaer. These air emission issues are not limited
just to City residents, but affect residents and others beyond the City. We
believe that additional monitoring and enforcement actions undertaken by
the EPA and the NYS DEC are warranted as requested above. We would like
first to have the EPA and DEC determine if the above-referenced facilities
(and others in close proximity but not specifically mentioned) are in
compliance with National Ambient Air Quality Standards. Those not in
compliance should be dealt with accordingly under the corresponding
regulations. We would like to request a full and complete report of the
outcome of these efforts by the EPA/DEC.
We also believe that the Sierra Club Hudson Mohawk Group and Concerned
Citizens of Rensselaer should make an effort in concert with EPA/DEC efforts
to combat unhealthy emissions. One of the options we have become aware
of to deal with the diesel emissions from the maintenance facility and

passenger trains at the Amtrak Train station in Rensselaer is to reduce the

locomotive idling. This would be accomplished by utilizing Auxillary Power
Units (APUs). As you may know, APUs have been identified on the EPA
Smartway site as a verified RR Idle reduction technology. One of our
potential options is to utilize some of our grant money to engage the New
York State Energy Research and Development Authority in this endeavor.
However, it is believed by residents of Rensselaer who have complained in
the past to Amtrak about the odors and received little response or help, that
outside assistance, such as that provided by the EPA would help convince
Amtrak to participate in this endeavor. Our other colleagues (copied below)
will be counted on for assistance also.
Thank you for considering this very important and crucial request. The
citizens of Rensselaer have suffered enough from poor air quality and the
time to address the situation is now. We look forward to working with the
EPA, the NYS DEC, NYSERDA and other agencies and organizations to start
turning around this situation.
Sincerely,
Susan Lawrence, Conservation Chair, Hudson Mohawk Group

Michelle Peart, Concerned Citizens of Rensselaer

Michelle Peart

cc: Honorable Charles Schumer, U.S. Senate

Honorable Kirsten Gillibrand, U. S. Senate
Honorable Paul Tonko, U. S. House of Representatives
Commissioner Nirav R. Shah, M.D., M.P.H., New York State Department of
Health
7

Honorable Daniel Dwyer, Mayor of Rensselaer

Dr. David Carpenter, SUNY School of Public Health
Denny Larson, Global Community Monitor
Frank Murray, President, New York State Energy Research and
Development Authority