RICHARD O. BRAJER

 

DANIEL STALEY

Public Health

HLAI 

August 10, 2016
Dear Secretary Brajer,

Today I resign from my position as Epidemiology Section Chief and State Epidemiologist in the
Division of Public Health (DPH), North Carolina Department of Health and Human Services
It has been an honor to serve in this role for the past seven years.

I am resigning because the open editorial issued by this Department on August 9, 2016,
misrepresents the process used by NC DHHS to set health screening levels and provide public
health recommendations to well owners whose wells were tested under the Coal Ash
Management Act. The editorial signed by Randall Williams and Tom Reeder presents a false
narrative of a lone scientist in acting independently to set health screening levels and
make water use recommendations to well owners. In fact, and as briefed you in August 2015,
followed a process that engaged DPH and DHHS leadership in all decisions.

The health screening levels used by in evaluating constituent values from well water
tested under the Coal Ash Management Act (CAMA) were all established with reference to
North Carolina Administrative Code 15A NCAC 02L. This rule was specified in CAMA.
used published 15A NCAC 02L standards where those existed. For constituents with
no published standard in the rule, used the Interim Maximal Allowable Concentration
(IMAC) where available. A screening level calculated per directions in 15A NCAC 02L was
used for constituents, such as hexavalent chromium, that did not have a published standard or


The health screening level for hexavalent chromium was calculated by two toxicologists in the
North Carolina Department of Environmental Quality (NCDEQ, then called NCDENR) using their
standard operating procedure. Two toxicologists in DPH (including Dr. Rudo) reviewed the
calculations and agreed with them. My staff presented the levels and the rationale for them to
me and we briefed Division and Department leadership extensively, including the Department
counsel. The course of action followed was fully vetted and approved through to the Secretary
of Health and Human Services at that time, Dr. Wos.

When Dr. Randall Williams started working at in July 2015, afterthis process was
complete and the Department had begun providing Health Risk Evaluations to NCDEQ to send
to well owners, I fully briefed him with some of my staff and Division leadership on the above
described process. We provided extensive information on the discussions and decisions made.
On August 19, 2015, we briefed you with Dr Williams present on all of this, and provided you
with a summary document of the basis in law and usual practice for the approach the
Department was taking.

Upon reading the open editorial yesterday evening, I can only conclude that the Department?s
leadership is fully aware that this document misinforms the public. I cannot work for a
Department and an Administration that deliberately misleads the public.

-- (.iol'npar'e 



Resigning from this job that I love is a terrible loss to me professionally and personally. Working
in the public health system in North Carolina and nationally brings meaning to my life. It has
been a privilege to work with the superb public health professionals in the Division of Public
Health and all our colleagues across this state. It has been a joy to work with the extraordinary
public servants in the Epidemiology Section.

ln resigning this position, I must also take on the additional sadness of giving up the opportunity
to serve on the Executive Board of the Counsel of State and Territorial Epidemiologists (CSTE),
including this year as President of CSTE, a professional honor equaled only by that of serving
as State Epidemiologist of North Carolina.

My resignation is effective immediately.

Sincerely,

Megan Davies, MD