Prof. Shmuel Shapira
[stamp: The Director-General's office
Received 13-03-2011]
December 26, 2010
Mr Eyal Gabai
Director-General, the Prime Minister's office
Dear Mr Gabai,
Subject: Medical opinion regarding Sdeh Barir – Prof. Shmuel Shapira
The Prime Minister decided to appoint an external expert in order to examine whether
health aspects exist that are liable to affect the population following the mining in Sdeh
Barir. I hereby attach my opinion in reply to your application to me as an external
medical expert.
For the purpose of preparation of the opinion:
I visited:
1.
The Oron open pit mining site during active operation.
2.
The outskirts of Arad at an observation point overlooking the planned site in Sdeh
Barir.
I examined:
1.
20 scientific publications collected with the aid of general and scientific scanning
sites that address pollution from particles in general and mining in particular, and
international criteria for pollution from particles.
2.
A letter from Dr Moshe Shirav-Schwartz from the Geological Institute in the
Ministry of National Infrastructures.
3.
The Geo-prospect report – The environmental influence survey for program
140/03/24 – the phosphate mining site in Sdeh Barir, parts A-E, and appendices,
7.01.
4.
Geo-prospect – Supplement to the environmental influence survey for program
140/03/24 – the phosphate mining site in Sdeh Barir, 12.03.
5.
Geo-prospect – Analysis of concentrations of particles as a result of mining
activities in Sdeh Barir, 3.04.
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6.
Opinion from the Ministry of the Environment regarding the environmental
influence survey, 8.8.04.
7.
Geo-prospect – Measurements of PM 10 particles in Arad 2004/2005 – analysis of
measurements.
8.
Ya'akov Kimmelman, the Ministry of the Environment – The Sdeh Barir
phosphates mine, 140/03/24, opinion of the Ministry of the Environment regarding
the environmental influence survey, 8.04.
9.
Geo-prospect – Opinion in the subject of health – Sdeh Barir, 08.
10. Dr Barhana and Dr Dubnov – Opinion in the subject of Sdeh Barir, 3.08.
11. Dr Barhana and Dr Dubnov – Opinion in the subject of Sdeh Barir, supplements
and reference to the counter opinion, 5.08.
12. Prof. R. Carel – Reference to the alleged health risks following operation of
phosphate mining in Sdeh Barir – responses to the report of Dr Barhana and Dr
Dubnov submitted to the Director-General of the Arad Municipality on February
25, 2008, 5.08.
13. Prof. Yosef Ribak – Expert opinion.
14. The opinion of Dr Eli Stern – Radiological effects from the operation of phosphate
mining on the Sdeh Barir site.
15. Dr Ya'akov Mimran, the supervisor for mines – Evaluation of alternatives for Sdeh
Barir, 4.08.
16. Geotec – Ronon Amit – Shocks survey, 7.08.
17. Barhana and Dubnov, Health effects of the operation of phosphate open pit mining
near Arad (the Sdeh Barir site), 4,10.
18. Geo-prospect – Reference to the opinion of the Ministry of Health regarding
mining in Sdeh Barir, 8.10.
19. Letter from advocate Ravit Baram-Mazor, 6.10.
It should be noted that most of the reports were written using good scientific
methodology, based on state of the art models and on extended measurements. Warning
should be given that in some of that written the emotional element is liable to harm the
scientific objectivity. It is important to emphasize that the Ministry of the Environment
validates the data of Geo-prospect (the initial report and its supplements until January
2004). The subject of parallelization of the software and validation of the results of the
model for the dispersions was evaluated by an international expert who was chosen by
the Ministry of the Environment (Dr Japita from Canada).
The opinion will not repeat the geographic and economic data involved in operation of
Sdeh Barir, although all these certainly constitute a basis for the opinion. These data
appear in most of the references.
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In order to save the reader's time, I shall not attach my CV. I shall only note that I am a
full professor in the Hebrew University, VP in Hadassah, head of the military medical
track in the Hebrew University. Until about year ago I served for three years as the head
of the school for public health in the Medical School of the Hebrew University and
Hadassah. I also have considerable experience in and exposure to the subjects of
dispersion, environment, health effects of radiation, safety, and risk management.
The health issue and Sdeh Barir
Before I go into details I have seen fit to emphasize that employment and economic
welfare constitute an essential and major element in the welfare and health of the
population.
Potential negative elements from the health aspect in phosphate open pit mining similar
to that planned in Sdeh Barir are:
1.
Various kinds of inhalable suspended particles.
2.
Radiation.
3.
Noise.
4.
Mental stress.
The minimum distances between settlements and Sdeh Barir are: to Kseyfa, 3,750m and
to Arad, 3,880m, regarding the planned western neighborhood. The nearest buildings of
the Nevatim base are at a distance of 6.5 km and consequently I shall not address
Nevatim specifically below.
It has been determined that the boundary of the influence of the plan will be up to a
distance of 1000m. If Bedouin buildings are found in this range they will be shifted
beyond this safety boundary.
Noise – Based on calculations the extent of the noise resulting from the work in the
closest settlements will not exceed the background noise customary and permitted in the
said settlements in accordance with the updated standards of the State of Israel.
The explosions technique (deep explosions, avoidance of use of a detonating cord, and a
delay between the charges) causes the explosions not to be heard at all and virtually not
felt even at extremely close ranges. Consequently the element of noise does not
constitute a problem.
Mental stress – As set forth above it clear that the claim of increased exposure to mental
stress is unsubstantiated even at the most theoretical level. Furthermore, even if we
adopt an extreme attitude regarding stress, the field is not visible from most significant
observance points in the region. Consequently the claim of mental stress associated with
mining has no real basis.
Radiation – The major gas relevant to mining in Sdeh Barir and presenting a potential
risk to the population is radon, known to be a carcinogen. Most of the carcinogenic
effect is not due to radon, that is a noble gas, but to its daughters – radioactive particles
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that result from disintegration, with a lower atomic weight, and generally with a very
short half life.
Without connection with mining, the external radon concentration in Arad is higher than
in other places in Israel, 12 Bq/m3 compared to 9 Bq/m3. The high concentrations result
from the surroundings being rich in radon rich phosphates. Following the mining in
Sdeh Barir the population is not expected to be exposed to radon levels above the
background radiation.
Radon that is emitted during mining will be diluted in the atmosphere that constitutes an
infinitely large reservoir and consequently there is no health significance to radon
diluted in open spaces. Radon that reaches closed spaces can constitute a risk. The fear
was indicated that the transportation of radon in cracks made by explosions is liable to
endanger populated areas. Since it has been demonstrated that cracks produced by
explosions with the techniques to be used in Sdeh Barir can reach a maximum distance
of tens of meters this fear is unsubstantiated.
Phosphates constitute mineral rich in uranium, and consequently a survey of radiation
risks must also address both natural uranium, U238, and its daughters, that are metallic
solids. To estimate the additional potential radiation for the residents of Arad following
the dispersion of U238 (the relevant data also apply to the population of Kseyfa)
conservative safety factors were used in the following components:
1)
Conservative assumptions regarding the secondary dispersion for mining;
2)
Ignoring means of containment of the dust used in some of the stages of mining
and processing;
3)
Conservative assumptions regarding concentrations of U238 in the overburden, and
following this a stringent estimate regarding the value of Sievert/bq in the emitted
radionuclides.
(Sievert/bq is the unit that describes the biological effect of a radiation dose and is
consequently most relevant to health aspects. 1 Baquerel means one radioactive
disintegration per second.)
The permitted value of the additional environmental radiation for the general population
is 0.1 millisievert/year. This value has been specified by the ICRP – the International
Commission on Radiological Protection. The population in Arad and Kseyfa will not be
exposed to anything near the value of this permitted supplement, since arrival at this
dosage of radiation obligates breathing total suspended particulates (TSP – see the
section regarding dust ) at a concentration of 330 microgram/m3 for a year.
This particles threshold will not exist even for 3 hours a year at distances of hundreds of
meters from the borders of the field – remote from Arad and Kseyfa. It is also worth
emphasizing that this theoretical three hourly value will not exist at all in actual
working since the mechanisms for prevention of working in the field will be
implemented during climatic conditions liable to cause this theoretical concentration of
inhalable particles.
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It is also worthwhile emphasizing that the permitted threshold, to which the population
will not be exposed, constitutes about 3% of the general value of exposure permitted for
the population – 3 millisievert/year. This permitted dose results from background values
of environmental radiation and from average medical exposure. Consequently the
radiation safety margins in the operation of Sdeh Barir are very broad, and no risk of
irregular excessive radiation is expected for the residents of Arad and Kseyfa.
Dust – When discussing dust a number of categories of particles, based on their size,
should be distinguished between.
TSP – total suspended particulates – that are all the particles, and the inhalable particles
are also divided into 2 sub-groups:
PM 10 – particle matter 10, and PM 2.5 – particle matter 2.5, particles whose
aerodynamic diameter is less than 10 and 2.5 microns, respectively.
The TSP is the general criterion for suspension of particles, while PM 10 and PM 2.5
are criteria that are directly relevant to health risks, since they include particles that are
of a diameter suitable for inhalation and penetration of the small air ways.
TSP constitutes a rough overall criterion for air quality, and can constitute an
approximate criterion for potential respiratory risks.
The processes of mining, explosions, crushing, as well as biological processes have
mainly produced particles of the PM 10 type, while type PM 2.5 particles are mainly the
products of combustion and chemical processes, and they are the most problematic
constituents from the health risks aspect. Sdeh Barir is expected to mainly produce PM
10 type particles. PM 2.5 particles will be produced in Sdeh Barir mainly from engine
emissions.
It should be remembered that the approach road will pass through the south eastern part
of the field, tending towards south south east, in the opposite direction to Arad and
Kseyfa.
Geo-prospect, that conducted the environmental survey for Sdeh Barir, has made
calculations using two dispersion models, each of which was correct and accepted at its
time by the US EPA.
The first model is ISCST3 that was run in 2001 and was updated up to the time of its
running. In this model 415 receptors were processed (most of the receptors have no
geographic/social significance and were run for the purpose of constructive influence
maps), including grid receptors.
The model included meteorological data for one calendar year. The results of the run of
the model were confirmed by the Israeli Ministry of the Environment and by an
international expert, as mentioned. An additional run was made on the new AERMOD
model that replaced ISCST3 by the USEPA as the accepted regulatory model. This
model was run for 37 receptors having geographic/social significance. The second run
included a meteorological file for 5 calendar years. I should note that the updated model
slightly improves the environmental exposure picture expected relative to the earlier
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model. As input for the models conservative values were used for each of the stages of
the work (drilling, loading, work by bulldozers, crushing, and unloading the trucks).
The runs were compared to the accepted standards in Israel and abroad and address
TSP, PM 10, and PM 2.5 (no standard exists for PM 2.5 and consequently the average
PM 10 standard is used as a comparison criterion). Regarding the standards see Table 1.
Table 1: The existing standard for TSP and PM 10 and the proposed standard for
PM 2.5
Pollutants
Average range of time
Standard (microgram/m3)
TSP
3 hours
300
TSP
1 day
200
TSP
1 year
100
PM 10
1 day
150
PM 10
1 year
60
PM 2.5
1 day
65
PM 2.5
1 year
15
The results of the updated model that is currently accepted improve the values measured
in most of the receptors and consequently improve the safety margins. It should be
noted that in two receptors, 27 and 36, there is a significant deviation from the standard
proposed for PM 2.5 by 10% and 70%, respectively. These deviations are obtained in
accordance with the model during working in the southern part of the field, in the
residential area of the Bedouins, and within the range of influence (as mentioned, up to
1 km), an area designated for evacuation as a condition for working in the field.
In none of the other 35 receptors were values measured in the updated model that
exceeded the existing or proposed standard in the run of two scenarios (working in the
southern or the northern part of the field), regarding each sub group of the three kinds of
particles and in the three period of time required in the standard.
The model demonstrated a range of concentrations lying between 1% and 18% of the
permitted level (18% in one given state in a single receptor out of hundreds of model
data, and even then the distance from the standard was great), where the estimate
median that was not calculated (by the undersigned) was around 2-3% of the standard.
Conclusions
Mining in Sdeh Barir presents no potential health risks regarding the residents of Arad
and Kseyfa from the aspects of inhalable particles, radiation, noise, and mental stress.
Recommendations
Although it is highly probable that operation of Sdeh Barir will not involve excessive
morbidity in Arad and Kseyfa, it is recommended that in the first year of operation
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special safety measures should be taken. The need to continue using them, and the
working methods in the field, should be re-examined at the end of the first working
year.
1.
Strict environmental monitoring shall be conducted for suspended particles.
2.
The level of background radiation in Arad and Kseyfa shall be checked before
commencement of the work, and at the end of 6 months and 12 months from
commencement of the work.
3.
In irregular meteorological conditions to be specified in advance, no work shall be
carried out that involves dispersion in Sdeh Barir. It should be noted that working
in the field can be halted with less than half an hour's notice.
Conclusions
This report addresses all the environmental aspects that refer to working in Sdeh Barir
and that have a theoretical connection with health. In the report I relied on the sources
that I have indicated, while giving weight to all the opinions of the medical experts, to
the connection between their recommendations and the factual basis, and to the
discussions between the medical experts and the other experts.
The models used for the calculations contained broad safety margins and were validated
by professional bodies in Israel and abroad. Based on all these I found no support for an
expected increase in the morbidity rate or the mortality rate amongst the residents of
Arad and Kseyfa. The mining is planned to be carried out while placing great emphasis
on the safety and environmental aspects. The operators have accepted stringent
operational criteria. However, as additional safety means, monitoring and other
measures will be taken in the first year of operation.
Sincerely,
Prof. Shmuel Shapira
Head of the military medicine track
In the Medical Faculty of the Hebrew University
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