Varying limits
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Identifying areas for improvement

The project team conducted an assessment of the odor situation to identify areas for improvement to enable work to resume. Financial and personnel resources were increased, a new remediation company was selected, and communication with authorities and the community was strengthened.

Text by Linda Bergsten, illustration by Ikonaut, photos by Gregory Collavini

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Tolerance limits for air emissions that apply in Switzerland for the different HCH isomers.

Published on 01/07/2021

During an intensive period of re-assessment, project leaders from Novartis identified the following four areas that warranted improvement: further onboarding of Swiss and German authorities to support project resumption; communicating more effectively with the neighboring community; selecting a new remediation company; and boosting health and security measures (such as, e.g., regular air and screening analyses, new, sealed construction tents, improved air filters, etc.).

One key finding was that remediation could only be successfully continued in close cooperation with Swiss and German authorities. Although the French DREAL was the lead authority, the remediation project had the potential to also affect Switzerland and Germany, and alignment with all key stakeholders became a priority.

The team contacted the Office for Environment and Energy (Amt fuer Umwelt und Energie, AUE) of the canton of Basel-City and the Basel Air Hygiene Office (Lufthygieneamt beider Basel, LHA) as well as the Department of Environment of the District Office of Loerrach (Umwelt und Klimaschutz).

The initial joint meetings focused on understanding the different requirements of French and Swiss legislation. As part of its prefectural order of 2012, DREAL had specified emission measures for the remediation project regarding air, dust, surface water and groundwater. For example, maximum air values for HCH emissions were derived from a risk assessment (Évaluation quantitative des risques sanitaires, EQRS). To determine the values, the EQRS identified the hazard, estimated the dose-­response relationship and evaluated the potential exposures.

While the remediation project had to formally comply with the limits defined in the French prefectural order, tolerance values for α-, β- and γ-HCH (150/30/300 ng/m3) were agreed with the Swiss authorities in addition to the existing French regulation. A further objective was to reduce dust emissions by approx. 90 %. DREAL accepted these tolerance values in addition to the EQRS values to ensure that communication to the public was consistent.

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Air measurement points inside and outside the site (Switzerland/France).

Va­ry­ing li­mits

The new continuous monitoring and sampling occurred daily over 24 hours, including weekends. The tolerance limit for the Swiss population was developed in cooperation with the AUE in Basel. The Swiss tolerance limits were stricter than the French ones, as the Swiss monitored nanogram concentrations.

Threshold levels were specified for each of the three main isomers (α-, β- and γ-HCH), based on their different toxicological properties. An action plan was set up to cover events that exceeded the threshold. The plan specified three different levels of action: green (continue work), amber (implement corrective action) and red (stop work, review the situation and implement corrective action). This action plan was applied to the results of daily monitoring as well as to weekly average monitoring and annual monitoring. TCB levels were also monitored.

Some of the isomers have a low odor threshold that is not necessarily consistent with the tolerable daily intake (TDI) and maximum acceptable concentration values for the population. Consequently, odor inspections were implemented by the AUE. The French authorities were kept informed of the results of monitoring and the odor inspections on a monthly basis, as stipulated in the prefectural order. The results were also reviewed during inspection meetings held by the DREAL on the remediation site.

Improved communication

To strengthen communication with the community, Novartis set up a web page that included a real-time webcam showing the work on the site. Frequent informational events for the French and Swiss communities enabled the project team to apprise the public of site upgrades, and a hotline was established for reporting odor complaints.

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