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PUBLIC HEALTH ASSESSMENT

US DOE PORTSMOUTH GASEOUS DIFFUSION PLANT
PIKETON, PIKE COUNTY, OHIO


APPENDIX A: NON-HEALTH RELATED COMMUNITY CONCERNS FOR THE PORTSMOUTH GASEOUS DIFFUSION PLANT (PORTS)

Concerns were collected from site visits, public meetings, public availability sessions, newspaper articles, letters from residents, and phone calls and meetings with residents. When several people expressed the same or similar health concerns, they have been combined. This summary covers concerns that were not related to public health and are listed as a courtesy.

Procedural Concerns

  1. One citizen commented that all the agencies are feeling a lot of pressure to "look the other way" because of economic considerations.


  2. During past strikes at PORTS, the use of non-striking management personnel to run PORTS was considered dangerous by residents and workers. Were employees with limited training being used to fill in for striking workers thereby endangering the community and the environment?

A. DOE/Contractors

  1. Residents point to a number of reasons to distrust the DOE:


    1. Residents have alledged that, DOE has admitted to past illegal activities at PORTS:
      1. incinerating spent fuel rods
      2. burying radioactive equipment underground.
    2. Residents point out that the plant initially lied about the magnitude of the 1978 uranium spill.
    3. Residents have expressed anger and frustration over past practices, alleged cover-ups at the plant, and alleged conspiracies of silence among A-plant employees. What are they really doing at the plant? Why don't they tell the truth and give all of the facts?


  2. Residents refer to concerns about SAIC compiled in a letter from the National Association of Radiation Survivors (NARS) in January 1994. NARS compiled evidence that SAIC altered dose-reconstruction studies such that VA claims were denied to veterans. SAIC was also fined $1.3 million for falsifying sample results to U.S. EPA.


  3. Many residents have no confidence in environmental data collected by DOE or DOE contractors.


    1. DOE has acknowledged that it has kept poor records n the past.
    2. The presence of plutonium at PORTS, although reportedly discussed in DOE documents, has been denied by a spokesperson for Martin Marietta. Given this discrepancy, many residents have no confidence that ATSDR will get complete and accurate environmental data from DOE.
    3. Residents feel that the data provided by DOE to ATSDR don't make any sense.
    4. Residents do not trust DOE with the task of reading the proposed additional air monitors.
    5. Residents request that independent environmental monitoring data be generated for the site by an independent group.


  4. Some residents think that DOE and Martin Marietta are slowing down the process by their control over ATSDR, pointing to the fact that the money for ATSDR's budget comes in large part from DOE.


  5. Residents report that some doctors in the area have been discredited by DOE because they reportedly found PORTS-related health problems in plant workers.


  6. Residents think that DOE has had media control in Pike County for the past 45 years, and have prevented accurate reporting. They think the local newspaper is connected to the plant.


  7. One citizen said that his organization had nominated people for a DOE citizen task force several times in the past and had not been successful in gaining representation in this group.


  8. Workers have voiced concerns about the DOE and DOE contractors.


    1. Workers have reported that the radiation measurements in workers are too low. They are suspicious that measuring equipment is set to read below the actual radiation levels.
    2. One past worker expressed concern at what appeared to be an organized effort between contractors, DOE, and the Industrial Commission of Ohio to deny worker compensation claims resulting from contamination.
    3. A couple of former workers claim that their medical records from PORTS have disappeared.
    4. One former worker commented that the toxicology information sheets for uranium was inaccurate.
  1. Residents are concerned that there are thousands of drums at PORTS that contain enriched uranium by-product. They report that these drums are stored outside and many are visibly rusting. They are concerned that the stored waste at PORTS will leak. What is going to be done with these drums? Won't there be problems if this waste is not removed? What is being done to prevent leaks?


  2. Residents are concerned about the continued production of mixed waste at the plant. They have said that the government should have a solution to the disposal problem before producing the waste. Are there any proposed disposal solutions for mixed waste? When will a disposal solution be implemented at PORTS? Will future generations be forced to deal with disposal of the mixed waste presently generated?


  3. Residents have commented that the accumulation of radioactive waste is a big problem for everyone. Is radioactive waste stockpiled at the plant? What is the waste made of and where does it come from? Is it being consolidated? Shouldn't an environmental impact statement be prepared on all storage at the site? Should the waste be kept at the site and monitor until a treatment technology is developed?


  4. Residents were concerned about a proposal to incinerate radioactive waste at PORTS. They commented that the resulting ash would still be radioactive and expected that there would be some air emissions. Are there plans to build an incinerator at PORTS?


  5. Residents are concerned that the government is going to make a dump out of PORTS. They are concerned that, if PORTS is closed, it will become one of the top proposed waste sites. The issue regarding the citing of a low-level radioactive waste dump somewhere in Ohio is only peripherally related to PORTS, but very much affects how the residents view PORTS. One citizen reports that there has already been discussion of shipping waste into PORTS for treatment, and that PORTS has already recycled fuel from Hanford and West Valley, NY.

B. ATSDR

  1. Residents have repeatedly commented that as long as DOE provides ATSDR's data, data that many residents find questionable, they will not trust ATSDR's studies.


  2. Some residents feel that ATSDR is just another arm of DOE. Residents point out that DOE pays a portion of ATSDR's budget and, thus, refer to ATSDR evaluating DOE emissions as "the fox guarding the hen house".


  3. With all of the available information, some residents think ATSDR is trying to slow down the process with meetings. Residents have commented that ATSDR has all the data it needs because it has access to tissue bank data, DOE's CEDR data, a plutonium registry, and DOE's uranium and transuranium registries. They think that ATSDR is disingenuous when they approach each site as "new", as if they are just beginning the process, when they years of information generated from DOE sites across the nation. Why doesn't ATSDR act on this available information? Was the PORTS health consultation on the 1986 hydrogen fluoride concentration a stalling tactic?


  4. Residents want a health study for PORTS. They have found it frustrating to request a health study only to get a health assessment which could be used to show that they shouldn't have the health study (health survey) they originally requested.


  5. Residents have expressed concerns about various ATSDR officials.


    1. After one public meeting, residents commented that ATSDR's regional representative was argumentative and disrespectful of community members. They commented that she was too curt, made "smart" remarks, and controlled the meeting like an elementary school class. They felt her comments were insensitive and showed that she either knew little about the community or did not care about insulting community members. They feel she dominates public meetings, and prevents discussion of more essential issues with the health assessor.
    2. Residents have commented that ATSDR personnel have had very little meaningful contact with the community.
    3. Residents commented that ATSDR officials assigned to PORTS consistently contradict themselves, and that they have behaved defensively at public meetings, as if they were trying to cover something up.
    4. One citizen commented that ATSDR wastes residents' time with terminology they really don't understand or care about. Why do ATSDR officials use so much "tongue twisting double talk"?


  6. Some residents are concerned that by participating in ATSDR's public meetings, they have validated ATSDR's ineffective and insulting process, allowing ATSDR to say that there was "public participation". It is also insulting to some residents, that at the end of this process they will again be told what they were told years ago - "the data are not sufficient to draw any conclusions". They feel that if ATSDR were to listen to residents instead of talking at them they might have collected enough anecdotal data to draw some conclusions.


  7. Residents have commented that ATSDR shows a bias toward agencies (EPA, ODH, OEPA, and DOE) by having them review health documents first, making "necessary" changes, then releasing them to the public. Many residents commented that residents should have a chance to comment on assessments at the same time as the agencies. Would ATSDR change their document release policy so that residents could comment when agencies comment?


  8. Citizen activists expressed concern over the insinuation that they want to close PORTS. Activists feel they are being set up as scapegoats in the event that PORTS is closed.


  9. Residents commented that community members are not respected by ATSDR, their knowledge and feelings are degraded and made fun of by members of ATSDR, and they are "shot down" by educated experts. They feel their tax money is being spent in a manner that is against their interests, given ATSDR's antagonistic approach to the community.


  10. Two other groups (other than those who petitioned for the fluoride release study) had reportedly not heard from ATSDR regarding their requests for additional health consultations. Has ATSDR ever discussed these requests with these groups? Why has ATSDR focused on a typographical error when there are important exposures to study?


  11. A number of residents requested a Community Assistance Panel (CAP) so that they could have input into the health assessment. They feel a CAP could assist ATSDR in identifying and collecting data as well as generate contacts between ATSDR and the residents. A CAP would also allow fewer residents to meet more efficiently. Is there DOE money to sponsor a CAP? Why hasn't ATSDR sponsored a CAP?


  12. Residents commented that if the recommendations for further health studies, site-specific surveillance, and environmental health education programs were not implemented, ATSDR would continue to say that there was no indication there was a problem, when there was no indication there was no problem either.


  13. Residents had asked that ATSDR give them a list of the documents used in the health assessment or consultations before it was released by the agency. Residents could then be sure that ATSDR looked at everything they thought necessary and that ATSDR had access to all information the residents had. Instead, the list was sent with the health consultation. Will ATSDR provide residents with a list of documents used in the health assessment or consultations in the future?


  14. One citizen commented that if the problems at PORTS were closer to ATSDR's home or regional offices, in Atlanta or Chicago, ATSDR officials would work more conscientiously.


  15. Residents feel that ATSDR does not include residents in information gathering and does not appreciate the value of residents' anecdotal experiences.


    1. Residents are concerned that ATSDR has relied on only "peer-reviewed" information and one brief discussion with a limited number of residents as their basis of information. They feel that ATSDR should read fewer articles written by other scientists and instead talk with more of the people involved.
    2. In the health consultation, ATSDR says that the mortality data are not accurate enough to address health problems. Has ATSDR considered ways to go beyond papers and data to find the necessary information?
    3. One citizen suggested that ATSDR speak with people at the Native American reservation in New York state who have had fluoride exposure problems with the fish, water, and cattle similar to those found around PORTS. He commented that if ATSDR spoke with these affected people, they would have a better idea of the problems found around PORTS.
    4. Residents commented that no document should be released until ATSDR has all the documents available and the community has had input. Residents commented that the Health Assessment should not be released until the agency reviews data from PRESS, one of Senator Glenn's aides, and plant production records requested from DOE for a lawsuit. A citizen commented that until ATSDR gets every document the plant has, none of ATSDR's conclusions and reports are going to be of use to the community. How could ATSDR release the hydrogen fluoride health consultation with incomplete data and no input from the community?
    5. Residents think it is premature for ATSDR to conclude there is no problem in the community when all they have is DOE data. One citizen commented that there are a number of studies, some by Lawrence Livermore National Laboratory, which ATSDR did not use in their health consultation. Also, this citizen provided ATSDR with fluoride reports which were not used in the health consultation.
    6. Why was the paper by Joel Griffiths not considered by ATSDR (showing that, based on evidence of bone fracture, arthritis, malignancies, and other, that fluoride is a carcinogen)?


  16. Residents have made many comments about ATSDR's methods for announcing meetings, holding meetings, and maintaining accessibility to the community. They are as follows:


    1. Some residents have found ATSDR methods to inform and involve the community ineffective, and note that ATSDR seems unable to make any adjustment. Residents have made suggestions to ATSDR on how meetings would better serve the community, but ATSDR has not adopted any suggestions. Why doesn't ATSDR use any of the residents' suggestions?
    2. Residents feel they should be contacted regarding where and how to advertise meetings, so ATSDR coverage will be complete and residents won't have to cover locations missed by ATSDR. Would ATSDR supply a list of advertising locations to residents?
    3. Residents have commented that ATSDR does not announce meetings well. They have made a number of suggestions for improvement:


    4. Some residents have commented that the meeting locations and timing have not been good. They suggest that ATSDR consider holding public meetings at the following facilities: American Legions, Elks Club, VFW in Waverly, elementary school cafeterias, or other public locations. One public meeting was held during the Pike County fair, a very busy time for most residents. Additionally, ATSDR only contacted two activists about this meeting, not other activists or the union.
    5. Residents commented that ATSDR has refused to use the cable local access channel to get public meeting information to residents. The cable local access channel is reportedly more popular than the national news in Pike County. Residents point out that those people who didn't want to, or couldn't, come to the meeting (shut-ins, people afraid for their jobs at the plant, people who don't read or don't read the paper, etc.) would also be able to get information also. Residents report that most people have cable in Pike County.
    6. Residents commented that the "800" number hasn't been very helpful because the majority of people in Pike County don't have touch tone for their phones. They found that the process necessary to use the phone mail system was too complicated, and some people felt uncomfortable talking to a machine.
    7. Residents commented that ATSDR should make some effort to contact people living at Dawson Mobile Home Park.


  17. Some residents are distrustful of ATSDR. This is reflected in the following concerns:


    1. A number of residents felt that the PORTS health assessor lied to a reporter to keep her from coming to a public meeting and seeing how residents really felt about the fluoride health consultation. One citizen suggested that ATSDR has control over the media.
    2. One citizen requested that the Ohio Department of Health duplicate ATSDR's studies, because they do not trust that ATSDR will collect all of the information.


  18. A number of residents comments focused on what appears to them to be inaction on the part of ATSDR.


    1. Why is ATSDR looking at teeth were there is so clearly environmental contamination? Given the environmental contamination, why won't ATSDR go to the next step?
    2. Why doesn't ATSDR issue a recommendation to DOE to stop emitting hydrogen fluoride now, before the pollution gets worse?
    3. One citizen wants ATSDR to start treating people in the community. Why doesn't ATSDR help ill community people rather than holding unproductive meetings?
    4. Why does it take so long for ATSDR to recognize that there's a lot of cancer in this area and do something about it?


  19. Residents commented that ATSDR has been unable to address community concerns in any meaningful way.


  20. Can the community have ATSDR's responses to their questions in writing?


  21. Residents commented that if a dental fluorosis study is proposed, use of dental records from dentists would not give a complete picture. Dental care is not always a priority for low income people, many of whom do not have health insurance and can't afford to see a dentist.


  22. One citizen commented that they would like to see health education programs implemented in Pike County. Will ATSDR provide any health education to the residents?


  23. If more air monitors are installed at PORTS, and if DOE is found to be out of compliance with air standards, how long would it be before ATSDR took action and what would ATSDR do?

C. Ohio EPA

  1. There is distrust of the Ohio EPA by some residents who put data from OEPA and DOE in the same category - suspect. Local environmental groups expressed concern that the OEPA may be biased in favor of DOE interests. One citizen said that even though OEPA reported some contamination in nearby creeks, he thought that OEPA was not sharing all they know about site contamination.


  2. Residents commented that neither workers nor the public have had any input into Ohio EPA's decision to allow storage of mixed waste at PORTS.

D. Ohio Department of Health

  1. A number of residents had information about people who died of brain cancer between 1988 and 1991, refuting an ODH official's statement that there were no brain cancer deaths in Pike County between 1988 and 1991.


  2. Residents are concerned that the state's mortality figures don't include people who lived in Pike County but died elsewhere. Residents have asked why are there no health records/death records by place of residence v. place of death in Ohio?


  3. Should the state health department be involved with posting Little Beaver Creek and the Scioto River "no fishing"?


  4. Citizen organizers reflected distrust of their state and local health departments in the wording of their petition: "we the people of Pike County and Scioto County ... do desire a health survey done on it's 'residents' on radiation related diseases by Center for Disease Control and any organization, except Ohio or local health departments."

E. Local Government

  1. Citizen organizers reflected distrust of their state and local health departments in the wording of their petition: "we the people of Pike County and Scioto County ... do desire a health survey done on it's 'residents' on radiation related diseases by Center for Disease Control and any organization, except Ohio or local health departments." (See also Section III.D.)


  2. Residents reported that when the delivery room at Pike Community Hospital closed in 1976, the manager of the Pike County Board of Health was a manager at Atomic Nuclear also. Residents report that since 1976, no maternity services have been available in Pike County. Some citizen suspect the delivery room closed so that all records of children born with abnormalities would be in other counties. Why aren't babies delivered at the Pike Community Hospital? Who owns the Pike Community Hospital?


  3. Residents requested the numbers of mentally retarded children and those born deformed from the Pike County Board of Mental Retardation. Their request for information was denied. They found out that at that time, the second person in charge at Martin Marietta was the chairman of the Board of Mental Retardation.


  4. One citizen commented that radon testing kits were not available from the health department but were needed because of concern over radon emissions from PORTS.

F. Other or Unspecified

  1. The accuracy of past articles in a local paper has been questioned by some residents. Some residents have commented that the paper intentionally mislead the public. Some are concerned that the paper is controlled by DOE and Martin Marietta.


  2. A former worker commented that the Industrial Commission of Ohio has denied legitimate workers compensation claims. Another former worker commented that contaminated workers have to fight Worker's Compensation, which uses taxpayers' money to fight these claims.


  3. One citizen reported that his fishing license does not warn against eating the fish from Little Beaver Creek or the Scioto River. PRESS reports trying to get "no fishing" signs posted along the waterways for a few years now, but has gotten no response to date. If the fish and game people and the government know that the fish are contaminated, why don't they do something about it?


  4. People voiced concern that if PORTS is closed, the state would make a radioactive waste dump out of the site and nothing would get cleaned up.


  5. Residents report that property values are down, and if PORTS becomes a waste site, they expect they will go down even more.


  6. One child asked why adults produce hazardous materials that they don't know how to safely dispose of.


  7. Some say the land is not as productive as it used to be. Is this a result of contamination from PORTS?

Non-Site Related Concerns

  1. A citizen had heard that over 800 sites across Ohio are contaminated or potentially contaminated with radioactive material. Is this true? What are the implications for public health?


  2. One citizen would like to know more about the Southernwood Piedmont site soil remediation.


  3. How do contaminants from other sources on the Ohio River fit into the ATSDR assessment?


  4. Wayne County, WV mortality rate for minority females from breast cancer is high. (ranked #16 nationally)

APPENDIX B. COMMENTS TO PUBLIC COMMENT RELEASE

Reference Comment Response
  An improper assumption by you that the environmental monitoring reports prepared by the operators of the plant accurately reflect the releases from the plant. ATSDR also reviewed State of Ohio EPA reports. ATSDR also reviewed the raw data that went into writing and compiling environmental reports. A bibliography has been added to indicate documents reviewed, but not referenced.
  An improper assumption by you that the monitoring data that is reported by the plant is valid data and properly reflects the off-site releases of all radioactive and hazardous material. The quality of data reviewed is discussed in the Quality Assurance and Quality Control Section. A statement has been added to indicate that ATSDR will review additional data.
pg. 33-35 An improper and incomplete review of county-wide health statistics without any effort to determine whether the persons reported lived near or far from the plant, how long they lived in the community or what their exposures were. No change. ATSDR reviewed the data provided to the Centers for Disease Control and Prevention (CDC) through its WONDER database and State of Ohio's Mortality data through 1991, the last year that has available data and found no excessive adverse outcomes consistent with exposures to any materials held on-site.
  Failure to review and analyze off-site contamination data resulting in an incorrect conclusion that no off-site contamination occurred Wording has been clarified to indicate that ATSDR found off-site contamination that was not at levels that could cause adverse health effects, not that ATSDR concluded that no off-site contamination occurred. A bibliography has been added to indicate documents reviewed, but not referenced.
  Analyses of the community complaints are based on your erroneous conclusion that no off site contamination occurred Wording has been clarified to indicate that ATSDR found off-site contamination was not at levels that could cause adverse health effects, not that ATSDR concluded that no off-site contamination occurred.
  Failure to review and analyze available data resulting in misleading and inaccurate statements that infer that the operations, exposures, monitoring and releases remained constant over the past 41 years. Wording clarified to indicate that releases were not constant over the life of the plant.
  Your report contains many ambiguous statements concerning time. While we assume that your mission is to address only current exposures from the plant and not historic exposures, your report never clearly delineates the time period analyzed. We will clarify that ATSDR is charged with evaluating current exposures, to assess whether people are currently at risk from site releases. We also evaluate past release data to determine whether there is indication of past exposure that could result in adverse health outcomes that would be seen in health outcome data, and show a pattern of continued exposure.
page 25
figures 6, 7		 It is extraordinarily misleading to give the impression that the monitoring, exposures, operations and releases have remained constant over time. For example, you state at page 25 that the plant "since 1964, PORTS has maintained a network of permanent on-site and off-site stations to collect ambient air samples continuously." That statement is wrong. Continuous off-site air monitoring was not begun for several more years, for air monitoring station A28. You obviously did not even review the publicly available environmental monitoring reports very carefully for there to be such inaccurate statements. The statements have been corrected and clarified to indicate time frames.
page 25
figures 6, 7		 You go on to state that "figures 6 and 7 show the location of the stations in the monitoring network." Again, a wrong statement. For example, during several years, the pub reports did NOT report any results. The statement has been clarified to indicate that these are the current sampling locations.
  In the foreword to your report, you state that your legal requirement is to conduct a public health assessment and to consider environmental information provided by EPA, other governmental agencies, businesses, and the public. Yet your report does not reference any environmental information provided by the public nor does it reference the voluminous evidence of offsite releases of numerous radioactive and hazardous materials, including but not limited to, TCEs, hexavalent-chromium, transuranics, uranium, technetium, fluorides, and acids. These materials have been released over the past 41 years into the water and air and many of these materials have been measured in soils offsite. A bibliography has been added to indicate documents reviewed, but not referenced.
  Another example of a misleading statement concerning monitoring at the plant occurs in your report at page 18 where you state that the top and side purge cascades are continuously monitored without mentioning that those monitors did not exist for at least the first 24 years that the plant operated. In 1979 the plant wrote that space records were the only means of continuously monitoring the top purge vent stream from the cascade and, the space recorder had been out of service for over one year. Changed to read "...purge cascades are currently monitored continuously..." ATSDR not only looked at environmental reports, but also the raw data that went into writing and compiling said reports. A bibliography has been added to indicate documents reviewed, but not referenced.
page 27 Your report makes broad statements with no references, many of which tend to indicate a lack of familiarity with the available data on the plant. For example, you state at page 27 that surface water is not considered to be a completed pathway because surface water streams on-site are too small to support subsistence fishing and sampling data did not show sufficient contamination in surface water or fish samples to represent any threat to public health. In 1976, Battelle Columbus Laboratories issued a "Final Report on Research and Evaluation of Selected Environmental Aspects of the Portsmouth Gaseous Diffusion Facility." This report found, among other things, concentrations of chromium, copper, manganese, and zinc in excess of water quality standards in Ohio, beta emitters in excess of recommended Ohio criteria in Little Beaver Creek, gross emissions higher than background levels in the sediments or Big Beaver Creek, and fish downstream from the plant outfall with increased body burdens of chromium/ mercury, and uranium. In another report, "Third Report of the Technical Division Technetium Committee" dated December 14, 1976 (partially released in deleted form on January 18, 1993), plant personnel wrote that peak concentrations of technetium in the East Drainage Ditch were estimated to be 20 times the ERDA standard for beta radiation and six million times the limit for the state of Ohio. It is not possible from your report to determine (a) if you disagree with these reports, (b) do not think that these findings are evidence of sufficient contamination to represent any threat to public health, (c) simply never reviewed these reports or (d) ignored these reports because they describe historical conditions, not current conditions. Wording has been clarified to indicate that ATSDR found off-site contamination, there does not appear to have been a pathway for exposure to the public at levels of concern, and therefore does not alter conclusions or recommendations. Documents are listed in bibliography of documents reviewed.
  Your report makes no mention of the presence of plutonium and neptunium at the plant. In 1977 the plant wrote that trace quantities of transuranics were probably being released to Little Beaver Creek without any monitoring of these materials. No Change. The release of trace quantities of transuranics into Little Beaver Creek, does not pose any public health hazard.
page 78 Reference is made on page 78 to what appears to be our law firm, Your statement that we were contacted and report no additional information is at best misleading. We have had No input in this process even though we have thousands of documents relating to this plant. At no time did anyone involved with this report ask to meet with us or review our documents. At no time were we asked to give input on what our data shows about the historic releases or illnesses in the community Boston University's School of Public Health in a Cooperative Agreement with ATSDR, performed a survey of health outcome data and community concerns and contacted your law firm. The statement that the law firm reported no additional information at that time is correct. However, the paragraph discussing contact with the law firm has been removed.
page 7 You state that you visited the plant for two days, which presumably included the review of classified documents and the tour of the plant. There is no way in two days, that you could even touch the surface of the thousands of classified documents that exist at that plant. Unless you have read all documents relating to releases, you have no basis to make the statement at page 7 that "no unreported release of hazardous substances to the environment from the Site" occurred. Further, there is no clarification of what is meant by "unreported releases of hazardous substances." Clearly, there have many releases of hazardous substances that are not referenced in the environmental monitoring reports. Wording changed to clarify that ATSDR reviewed classified incident reports and release information, and found no incidents not reported in environmental monitoring reports.
  ATSDR has previously been criticized for not making assessments that are comprehensive or scientifically sound. A shortage of funding has been cited as a reason for the problems in your studies. However, even a shortage of resources cannot justify or explain why you have released a report with so many errors and misleading statements. Your report is a disservice to the public and the government. If, in the final draft of this report you choose to make an effort to accurately report to the public, please feel free to contact our office for whatever assistance concerning the history of this plant we can provide. ATSDR has contacted your office and reviewed the information provided; namely "Third Report of the Technical Division Technetium Committee" dated December 14, 1976 (partially released in deleted form on January 18, 1993) and "Final Report on Research and Evaluation of Selected Environmental Aspects of the Portsmouth Gaseous Diffusion Facility."
  In the year of 1992, Pike and Scioto County residents petitioned the Centers for Disease Control (CDC) to do a health study. The petition read; "We the people of Pike and Scioto county ( of voting age ) do desire a health survey done on its residents on radiation related disease." We did not ask for a Health Assessment. It seems clear to us now that (ATSDR) Agency for Toxic Substance & Disease Registry was sent in here too only confuse the issues and, could it be to down play the all ready certified 300, 000, 000 dollar lawsuit? On review of the petition, ATSDR agreed to perform a public health assessment, which if concluded necessary would then recommend a further health study. ATSDR, through its public health assessment process has not found sufficient data to warrant a health study of your community.
  Why wasn't information taken from the Tiger Team Report, where in they stated that the air monitors were facing the wrong directions and it was inadequate monitoring? ATSDR reviewed data from the Tiger Team Report, but did not find sufficient information relevant to environmental releases to reference it. A bibliography has been added to indicate documents reviewed, but not referenced.
  Why wasn't information taken from the General Accounting Office (GAO) report, where in 1985 Senator John Glenn asked the GAO to conduct several investigations into the situation? The final findings were widespread contamination of the air, soil and groundwater? Are you making a United States Senator out a liar? ATSDR has not been able to identify what GAO report you are referring to.
page 27 (A-3) States Sampling data did not show sufficient contamination, in surface water or fish samples, to represent any threat to public health. Why wasn't information taken from the 1991-1992 fish study which was released in 1993 by the Ohio Environmental Protection Agency (OEPA) where they found high levels of Technetium 99, elevated levels of radiation in the fish samples? The sediments in the creeks had radiation, Lead, arsenic, technetium 99 and too many chemicals to name. Reference added, but since they were 1,000 times below health comparison values, they were not added to the data section. They were not at levels of public health concern.
pg. 28 Why wasn't information taken from OEPA, John Rochotte tested the well on Big Run Road, Piketon, Ohio and in a Letter dated 1/19/93, stated the well-contained Alpha, Beta, U-238, U-235, U-234 and Tc-99 which you know is strictly manmade. In 1992 this well was also tested by a private Lab, they also found elevated levels of alpha, beta and Tc-99. The well referred to showed a false hit for technetium. When the water sample was retested, technetium was not detected. The first test of the water sample showed technetium just at the lower limit of detection, and was most likely detecting natural radon.
pg. 28 According to your report you stated one-third of the households in Pike County do not have public water, we feel ATSDR should have tested at least some of these wells. We have been told the Scioto buried valley Aquifer is only 20 feet below us. No change. ATSDR could not identify any residents with drinking water wells that are in the same geologic formations or, could be hydrologically downgradient from contaminated groundwater plumes at PORTS
page 32
Table 11		 page 32 (Table 11) States; Age Adjusted Mortality Rates by County for the years 1979 to 1991. You state Pike County for All Cancers is 181.5 and Scioto County is 215.0 per 100,000 people. You should have also stated that Pike County has absolutely no hospital or facility for Cancer patients and since Portsmouth (Scioto County) has, most of them have gone to Scioto County. Your source states it was taken from the years of 1979-1991 WONDER Database. What happened to the years 1992, 1993, 1994 and 1995 after the cancer registration event into effect? Data for the years 1992 through 1995, are not yet available.
Appendix A Simply rewriting the residents questions, and twisting the words and then charging taxpayers, such a big price was awesome. The Community Concerns Summary in Appendix A, is only a listing of non-health related concerns. ATSDR has attempted to address the health related concerns in the section of the public health assessment titled "Community Concerns".
pg. 47 The well switch was a masterpiece. There were two wells not one well. One well did actually disappear, one day before the Health Dept. was scheduled to test the water the other well contained Technetium. Since one-well was already gone, a clever ruse of words was used to describe the existing well as the well that disappeared. Now both wells are gone. Paragraph rewritten. The well referred to, showed a false hit for technetium. When the same sample was retested, the technetium was not detected. The sample originally showed just at the lower detection limit, and was most likely from radon progeny.
pg. 40 Disregarding all the documented evidence of contamination to Little Beaver and Big Run Creek that residents presented to ATSDR and Boston University you concluded "Furthermore there are no completed pathways to contaminants from the site." Since Little Beaver Creek water can travel all the way to the ocean. Conclusion rewritten to clarify that no contaminants were found in any accessible media at levels that would be of health concern.
page 34 Tooth discoloration could be related to exposure to HF released from the site (a Conclusion?) This is not a conclusion; it is a concern expressed by the community.
page 34 ATSDR recommended a dental fluorosis study in the previous health consultation (a recommendation? PHAP item? Does ATSDR still intend to do this?) No. There was not a completed pathway for HF at levels necessary to cause this health outcome, so the Division for Health Studies decided not to proceed.
page 32 Increased kidney and bladder cancers in the 1950s and 1960s could be related to worker exposures to uranium at PORTS (another conclusion about health impacts?) This statement was in error, and has been removed. There is no relationship between bladder or kidney cancer and uranium exposure. Acute uranium exposure can lead to renal failure, not cancer.
page 37 ATSDR has referred worker concerns about exposures to hazardous substances to NIOSH ( response to a Community health concern?) Yes. This was a work related exposure concern and NIOSH has a worker study under way at the PORTS site.
page 25 Some on-site and off-site HF concentrations appear to have exceeded Tennessee state air quality standards. If so, should ATSDR mention that & discuss the relevance to public health in the Public Health Implications sections? No Change. The Tennessee State air quality standard is for annualized averages, for those values next to the far right column of Table 9 .
page 32 "Increases in brain and nervous system cancers are attributed to other DOE facilities as stated in Dead Reckonings a 1992 report by physicians for Social Responsibility." Is this statement relevant to the PORTS site? Does it address a community health concern? We were unable to determine how it is connected to the PORTS assessment. Statement removed. The reference has been added to the bibliography.
page 34 "It is not possible to link any one cause to the respiratory impairment without a medical evaluation by a competent specialist and is generally not possible even with such an evaluation." (emphasis added). Should an ATSDR physician review this statement? Would a pulmonary medicine specialist in private practice take issue with the last phrase (underlined)? Is it necessary to include that last phrase? It is not possible to show cause and effect when there are many potential causes for a particular health outcome. No Change.
Hazards
(Summary)
page 34		 "Site-related contamination and hydrogen fluoride releases pose no apparent public health hazard." "There appears to be no threat to public health from any site activity or release." If hydrogen fluoride releases pose no hazard, why would ATSDR state that children's teeth may have been mottled by exposure to HF released from the site in the past, and why did ATSDR propose a dental fluorosis study in the health consultation ? No public health hazards associated with site activities or releases were identified. Access to classified process information modified the assumptions used in the public health consultation. The original assumptions were in error.
page 32 If site activities were not a hazard, why would ATSDR say that increased bladder and kidney cancer incidence could be related to worker exposure to uranium at PORTS ? Statement was in error and has been corrected. No public health hazards associated with site activities or releases were identified.
page 37 If there were no hazards, why did we refer workers' Concerns to NIOSH ? Previous NIOSH studies at the site were inconclusive, and NIOSH is continuing worker health Studies. Why would NIOSH continue worker studies if there were also threat to public health from any site activity or release? In other public health assessments, public health hazards are specified as past presents on-site or off-site, workers v. communities, etc. Shouldn't we clarify hazards at PORTS as we do in the other assessments? No off-site public health hazards associated with site activities or releases were identified. Worker exposure concerns are not within ATSDR's purview and must be forwarded to NIOSH, per agency policy.
  NIOSH Studies Should we mention NIOSH's ongoing studies at PORTS in response to workers health concerns in the Community Health Concerns section? Yes, now mentions ongoing NIOSH studies.
  A glossary of scientific terms would be very useful. No Change. A list of abbreviations is provided.
page 3 How can you conclude that "No contaminants were accessible (what does this mean) on or off-site at any level of concern". There is no information in the health assessment that supports this statement from a groundwater perspective. If additional data are needed, how can it be said that no risk exists. No contaminants were accessible at any level of concern, means that they were not in drinking water supplies, or any other off-site media at levels that would cause adverse health effects in humans. Additional data has been referenced to support this statement.
page 3
paragraph 4		 The health consultation regarding the fluoride releases should be included as an appendix to this document. The original document was largely in error, due to false assumptions made about specific processes at PORTS. Document has been superseded and additional data resulted in changes to the conclusions and recommendations.
page 4
paragraph 3		 The second sentence contains too much information for one sentence. No Change.
page 5
last sentence		 Where was the information obtained about the "relatively unpolluted" statement? See references 17 and 18.
page 6 I believe that ATSDR requires a more recent site visit. No Change.
pages 7-12 The entire section on demographics seems to be rather confusing and somewhat pointless. There are too many numbers presented. There is no comparison to the stats from Ohio. References are made to census tracts which are going to be very confusing to the public. The Tables should be put in an appendix. No Change.
Natural
Resource
Section		 General comments about natural resources. What about surface waters?
Are there any fish consumption advisories in place?
How deep are area wells?
What aquifer are the wells drilled in?
Are private wells upgradient or downgradient?
How many private wells are in the area?
This information is extremely important in trying to determine what exposure pathways exist for the site.		 No Change. Fish consumption advisories are in place on the Scioto River, because of contamination upstream of Piketon. DOE's Annual Environmental Reports for the Portsmouth Gaseous Diffusion Plant, list USGS data on aquifers and well survey data for the region. Shallow drinking water wells are 20 to 40 feet in depth and tend to be intermittent and seasonal.
page 16 Recommend the word complaints be changed to concerns. Changed.
  What additional information is available about the waste burial areas and the settling ponds? A more exhaustive description can be found in EPA's RFI reports for Quadrants I, II, III, IV, dated August 1993.
  It was stated that "No contaminants were identified in surface soils, accessible sediment, or surface water at levels that would cause concern". We generally find that you have a better chance of convincing the public if the data are still presented. Especially when there are trust issues to consider. There is insufficient space to copy all available data in a single document, so ATSDR has attempted to only list highest detected levels in any affected media.
  The MCL for TCE is 5 ppb and not 7,000 ppb. It would seem that the presence of these EXTREMELY HIGH amounts of TCE would be a concern to the public and yet no data was presented previously about the number, location, depth, of area private wells. How many people depend on private wells? WHERE ARE THE SAMPLING DATA? This is an ATSDR EMEG (Environmental Media Evaluation Guideline) used to evaluate human health impact. MCLs are not health based guidelines. Groundwater data is from reference 22. Furthermore, the aquifer was isolated and seeps out above surface streams on-site. There are no points of exposure and therefore no members of the community exposed to this contaminant. Private well data is included in the Demographics section of this document.
page 17
last paragraph		 Is there any hydrogeological connection between the aquifers?

We have found that cross contamination of different aquifers occurs regularly. Also surface water bodies are not barriers to groundwater migration. A good example is what has occurred at one of our sites where groundwater contamination has migrated under the Great Miami River.

 This is a perched aquifer that seeps out above the surface streams. Presently the TCE is being pumped out of this aquifer and has not gone off-site. No off-site well data has shown any TCE.
pages 18-21 I found this section to be very confusing, difficult to follow and understand. There is no way the public will be able to understand this very technical discussion. I would suggest that the health assessor work with the community education staff to simplify these discussions. No Change. It is included in the public health assessment as a technical discussion. This section provides a listing of materials that are emitted from the site and where they are used.
pages 22 and 23 Why are there empty spaces on the Tables? If there is no information available for some chemicals during a particular year it should be stated. Corrected to show no release for blank spaces.
page 24 I would strongly recommend that ATSDR should present the information obtained about the 1978 release before any statements are made about the risks associated with the site. The information presented later in the document is for the years 1986-1992. It gives the impression that there is something to hide. If this was classified information, get it released or tell the public that it was/is classified and it is not available for public review. No Change. Information related to this accident have been made publicly available. The accident posed a risk to workers on-site, but was not detected at sufficient concentrations off-site to pose a public heath hazard. Only those working in the direct area of the accident appear to have been injured by the gas leak.
page 25,
third paragraph		 Table 11 is cancer mortality data and not weekly ambient fluoride data. In the same paragraph references are made to Tables 9-13. Other than Table 9, Tables 9-13 are health outcome data. Corrected.
  In the Pink Cover Draft, it was stated that PORTS measures vegetation fluoride levels. This has disappeared from this draft. WHERE ARE THE DATA? Not included because vegetation fluoride levels did not show any levels above background. The data are presented in reference 7.
page 27,
first paragraph.		 It was stated in the first paragraph that processes at the plant have caused accumulation of materials in media. Where are the data on surface water, soil, off-site groundwater, and sediment? The public health assessment lists data that show levels in media that are significantly elevated. The data can be found in references 2, 3, 4, 5, 6, 7, 14, 15, 16, 17, 18, 19, 21, and 22.
  Completed Exposure Pathways. I fail to see how releases of materials into the air and groundwater are not a source of contamination. Where did the TCE come from and where is it going. Also no information was presented about the 1978 release. What about workers? Also, it is stated that "No completed exposure pathways were identified in the areas for which there is sufficient sampling information to make an exposure determination." Air is now listed as a completed pathway, but below levels of public health concern and groundwater are listed as potential pathways. A completed exposure pathway at levels of public health concern requires that individuals are being exposed to levels of contamination that are considered to be of health concern. Even if a pathway is complete, that does not mean that there is sufficient exposure to cause adverse health effects.
  If there is insufficient information how can the site not be a problem. The public will interpret the conclusion that the site poses no apparent public health problem as that the site is safe. Wording clarified; the conclusions state that the site poses no hazard to those living near it. ATSDR does not assert that it would be safe to live on an active industrial site.
  Air pathway. It was stated that measured levels of fluoride are below health standards. What about the release in 1978. Also what about the pathway associated with local farms. Excessive fluoride can cause fluorosis in cattle. Has this happened? Does it in any way pose a risk for people eating the cows or vegetables? If not this should be clearly stated. The 1978 accident posed a risk to workers on-site, but was not detected at sufficient concentrations off-site to pose a public heath hazard. Only those working in the direct area of the accident appear to have been injured by the gas leak.
page 28,
first paragraph.		 It is stated that all fluoride levels are below standards, while the information in Table 9 shows that there are off-site levels that exceeded Tenn. and Kentucky standards. Wording clarified to indicate that the Kentucky and Tennessee standards referred to are not health based and apply to only annual averages (the far right column of Table 9). Off-site levels have not exceeded these standards, which are well below health guidelines that are about 1000 times higher.
page 28, second paragraph A statement is made that says that there are no private wells in the same geological formations. WHERE ARE THE DATA? The only type of information that can provide this type of data are well logs. Where they reviewed? Reference added to show that data reviewed came from the U.S. Geological Survey's (USGS) 1986, Water Resource Data for Ohio.
page 28,
Table 10		 Why is not TCE listed as a potential exposure pathway. Rivers are not barriers to groundwater migration. The source of contamination has been confined to on-site and the contaminant is being removed by a pump and treat facility.
  MCLs are not always the most stringent. Some risk derived numbers are less than the MCLs. What about ATSDR's cancer risk numbers and cancer policy? Sufficient data has not been supported to state that groundwater is not a risk. There was no discussion about the plume size, what data have been collected, private well information and data. I question the basis for stating that there is no pathway for exposure to TCE. What about workers? Where did the plant get its drinking water. What is the basis for this conclusion? TCE is no longer believed to be a human carcinogen. DOE has tested wells of people living adjacent to the site to determine whether any site contaminants have migrated off-site. Most recent private well data (1993), have not shown any migration to off-site wells. Drinking water on-site comes from the public water supply out of Piketon.
pages 29-30 The discussions included under the Introduction heading are very good. No Change.
page 30,
last paragraph.		 Previous standards were listed as much lower. No Change. The Tennessee and Kentucky standards were used as screening values to determine potential contaminants of concern. This section discussed toxicological implications.
page 36 The use of March of Dimes data is not appropriate for comparison to a local population. No comparison is even made. How do these data relate to the site? Also it sounds as though because webbed fingers and toes is not life threatening it is dismissed as not important or not worth looking into. ATSDR listed the table of birth defect rates in response to a public health concern. Webbed fingers and toes are not considered birth defects, which is why they do not appear in the table, but are discussed in the text section.
page 32 I question the comparability of county data to a small or localized population. How does this relate to the site? ATSDR public health assessments include an evaluation of health outcome data at the county level, in response to community health concerns about excessive cancer rates in Scioto County, Ohio. Further health studies were not initiated because there was no indication that exposure had occurred above levels of health concern.
  We strongly disagree that worker exposures should not be addressed. These workers live in the community and therefore are part of the exposed population. ATSDR agrees that worker exposures should be addressed and have referred worker health concerns to NIOSH , because ATSDR does not have the authority to investigate worker health issues.
  I would like to know why all of the community concerns presented in the appendices were not addressed. The public perception will be that you do not feel that it is necessary to respond to these concerns. How can you expect the public to trust the Agency when no attempts are made to address the concerns. The community concerns section has been expanded to more fully summarize and address the health related concerns.

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