Public Health Assessment Work Group
Meeting Minutes
October 20, 2003
Attendance
ORRHES Members:
Bob Craig (Chair), Tony Malinauskas, David Johnson, James Lewis, LC
Manley, Pete Malmquist, Susan Kaplan, Charles Washington, George Gartseff,
Kowetha Davidson, and Peggy Adkins
Public Members and Others:
Tim Joseph, Gordon Blaylock, Roger Macklin, and Al Brooks
ATSDR Staff:
Jack Hanley, Paul Charp, Bill Taylor, Lorine Spencer, Marilyn Palmer,
Melissa Fish, Terrie Sterling, Libby Howze, Theresa NeSmith, Subha Chandar,
and Michael Hatcher
ERG Contractor:
Michelle Arbogast
Purpose
There were four items on the agenda for discussion.
- Review October 6, 2003 meeting minutes
- ATSDR responses to Y-12 Uranium PHA public comments by Jack Hanley
and Paul Charp
- ATSDR proposed plan for Iodine-131 Public Health Assessment by Paul
Charp
- Other business as necessary
Previous Meeting Minutes
Tony Malinauskas made the motion to approve the Draft minutes for the
October 6, 2003 PHAWG meeting. LC Manley seconded the motion. The
meeting minutes for October 6, 2003 were approved unanimously.
ATSDR Responses to Y-12 Uranium PHA Public Comments
Overhead One
Jack Hanley presented the Presentation Outline to the group. Jack read
aloud the seven components of the presentation. Jack Hanley also provided
a review of the process that ATSDR and ORRHES went through for the Y-12
Uranium Public Health Assessment.
Overhead Two
Jack Hanley provided an overview of the public comments that ATSDR received
regarding the Y-12 Uranium PHA. Jack explained that the public comment
period was from May 5, 2003 through June 20, 2003. Comments were received
from 12 parties including 5 organizations and agencies and 7 individuals.
ATSDR received and responded to over 150 comments (not including comments
relating to spelling or sentence syntax). For comments that questioned
the validity of statements made in the PHA, ATSDR verified or corrected
the statements.
Bob Craig asked if of the 150 comments, if EPA Headquarters comments
and EPA Region 4 comments would be separated and identified. Jack Hanley
responded that the mailing that the PHAWG members received had all of
the comments mixed together without specific agencies or organizations
being identified. However, Jack Hanley told the group that there has been
a request to identify the comments of each federal agency. Thus, in the
final version, ATSDR will identify the specific comments made by the various
federal agencies. As clarification, Jack Hanley told the group that ATSDR
would not identify the specific comments made by various organizations—only
comments made by federal agencies.
EPA Headquarters Summary Comment 1: ATSDR should provide concise
summaries of primary data sources and more detailed discussions of its
own assessments and conclusions.
Jack Hanley explained that the Summary Comment 1 relates to the original
comments 14, 33, 38, 43, 50, 52, 56, 143, and 144 in the draft Appendix
XXX that PHAWG members received prior to the meeting.
Jack Hanley told the group that the ATSDR response to EPA Summary Comment
1 is that it is not ATSDR’s policy to provide raw data from primary
sources that are publicly available. Jack Hanley listed the primary sources
used for evaluation of past exposures as well as the primary sources used
for the evaluation of current exposures. Jack told the group that page
36 of the Y-12 Uranium PHA provides short summaries of the FAMU and EPA
sampling and that ATSDR will add summary briefs of the ChemRisk, FAMU,
and EPA reports in an appendix.
In response to the second portion of the EPA Summary Comment 1, Jack
Hanley said that ATSDR provided detailed summaries of the data and discussions
of ATSDR’s own evaluations throughout the PHA and in the Appendices.
Two examples that Jack pointed out were the uranium enrichment discussion
on pages 85-88 and the linear regression analysis in Appendix E of the
Y-12 Uranium PHA.
Al Brooks and Tony Malinauskas suggested that ATSDR’s response
could be better stated and more accurate if it were similar to the following:
It is not ATSDR’s policy to provide copies
of raw data from primary sources that are publicly available. But
ATSDR does supply references to the data used; which is usual technical
practice.
EPA Headquarter Summary Comment 2- ATSDR should change the title
of the PHA to reflect the principal subject (i.e., Scarboro) or expand
the scope of the assessment to include other Oak Ridge communities.
The Summary Comment 2 relates to the original comments 65 and 66 in the
draft Appendix XXX that PHAWG members received prior to the meeting.
After some discussion about K-25 and uranium hexafluoride, Jack Hanley
reminded the group that ATSDR will conduct a separate PHA that is concerned
with K-25 and fluorides.
Peggy Adkins asked that someone explain how ATSDR could say that the
area between Kingston and Oak Ridge was not affected by the Y-12 Uranium
releases. Jack Hanley told the group that ATSDR believes the city of Oak
Ridge is the only established community adjacent to the Oak Ridge Reservation
that could have been impacted by Y-12 uranium releases and that Scarboro
is a representative community for the city of Oak Ridge and therefore
the conclusions are valid for the people living near the Y-12 Plant, including
the city of Oak Ridge.
Jack Hanley pointed out that the Task 6 team identified Scarboro as the
reference location using air dispersion modeling and Scarboro was considered
the most suitable for screening both a maximally and typically exposed
individual.
Jack Hanley told the group that the predominant wind direction at the
Y-12 facility is southwest or northeast, up and down Bear Creek and Union
Valley between Pine Ridge and Chestnut Ridge. Therefore, most of the uranium
would deposit up and down the valley near the Y-12 facility. No one lives
in Bear Creek or Union Valley. Paul Charp said that the wind would be
blowing away from the city of Oak Ridge.
Peggy Adkins added that the wind blowing away from Oak Ridge would be
blowing toward Kingston—to the area between Oak Ridge and Kingston.
Peggy also added that the ridges do not completely stop the wind.
Jack Hanley said that based on the flat terrain model, most of the uranium
falls near the facility, thus, ChemRisk and Oak Ridge Health Agreement
Steering Panel (ORHASP) decided that doses to the Scarboro community are
most likely the highest of any other Oak Ridge community.
Tim Joseph asked if ChemRisk created a deposition map which showed uranium
fallout. Jack Hanley responded that it is likely that ChemRisk did create
such a map. If so, Tim Joseph suggests that ATSDR locate the map and use
it.
Paul Charp pointed out that even if uranium did get out of the stacks
and ejected into the atmosphere—because of slow wind speed—most
of the uranium would likely settle out before it even reached Pine Ridge.
Al Brooks added that in the valley, the winds tend to stay in the valley
until the wind velocity gets very high—then the wind goes over the
hills.
LC Manley commented about flyover patterns. LC Manley stated that uranium
should give some evidence of a pattern and the pattern should be able
to be followed.
Al Brooks stated that there is evidence that flyovers are sensitive enough
to detect any significant uranium contamination in the area studied.
Peggy Adkins asked if anyone had a topographical map that shows terrain.
Peggy would like the group to have a raised map when approaching this
issue.
Michelle Arbogast told the group that there are maps like Peggy Adkins
is referring to available in the field office.
Jack Hanley told the group that ATSDR presented data from other locations
when the data was available. The evaluation of current exposure via the
air, surface water, and vegetables include other locations surrounding
the Y-12 plant (see Figures 19, 20, and 23 in the PHA).
Jack Hanley told the group that an issue had been brought up about the
Woodland community possibly receiving higher uranium emissions than the
Scarboro community. To evaluate this potential, ATSDR compared the ambient
air monitoring data for Station 46 (Scarboro) to Station 40 (located on
the Y-12 plant near Bear Creek Road and Scarboro Road, near the gap in
Pine Ridge). The average air concentrations at Station 40 were, on average,
20% higher than Station 46 and for one year almost twice those at Station
46. Assuming, therefore, that the Woodland community was exposed to the
uranium concentrations at Station 40 in Bear Creek valley (which is unlikely),
they could have received up to twice the amount of uranium emissions as
Scarboro. However, even if the Woodland community were to have received
double the emissions and dose of Scarboro, the exposures would be way
below ATSDR’s comparison value and still be too low to be of health
concern.
In response to a question about Station 41, Michelle Arbogast stated
that the uranium air concentrations at Scarboro were on average, 2.7 times
higher than Station 41.
Jack Hanley reminded the group that after receiving comments, ATSDR looked
at the water samples at Bear Creek, Lower East Fork Poplar Creek, and
Upper East Fork Poplar Creek—on site and off site—rather than
just focusing on Scarboro. ATSDR also looked at the vegetable data from
various locations, some of which included monitoring stations, private
gardens in Scarboro, private gardens near Station 40, and private gardens
near Claxton.
Al Brooks asked if ATSDR had looked at the screening data that came from
the lower East Fork Poplar Creek sediment. Al said that the sediment contained
elements other than mercury.
Jack Hanley responded that ATSDR has looked at the Remedial Investigation/Feasibility
Study at East Fork Poplar Creek.
In response to an issue that Al Brooks raised about sampling data for
vegetables in the floodplain, Jack Hanley said that he did not find data
for vegetables in the floodplain.
Paul Charp said that Task 6 used East Fork Poplar Creek floodplain soil
data as a replacement for not having any historical Scarboro soil data.
Al Brooks stated that there have been complaints about not having comparison
data—is there comparison data? Jack Hanley replied that yes, there
is comparison data and that Task 6 used higher levels from the floodplain
in their analysis when evaluating Scarboro.
EPA Headquarters Summary Comment 6- For current uranium exposures,
ATSDR should present missing data sources, provide explicit calculations
of intakes and doses, modify selected exposure parameter values, include
additional exposure pathways, and present cancer risk estimates.
The Summary Comment 6 relates to the original comments 32-58 in the draft
Appendix XXX that PHAWG members received prior to the meeting.
Jack Hanley explained that the portion of the summary comment relating
to providing missing data sources could be referred back to ATSDR’s
response to EPA summary comment 1 for a discussion of data sources.
In regards to providing explicit calculations of intakes and doses, Jack
Hanley explained that ATSDR would add an appendix to the final PHA, which
will provide the equations and parameters used in the exposure evaluation.
Jack Hanley told the group that it was suggested that ATSDR use default
consumption parameters out of the EPA Exposure Factor handbook. Jack Hanley
told the group that ATSDR has responded by stating that ChemRisk was very
familiar with the EPA Exposure Factor handbook. However, ChemRisk worked
with and talked with local community members along the floodplain and
used site-specific parameters and tried to be more realistic in the level
2 than in the level 1 where they used default parameters.
Jack Hanley said that it was also suggested that ATSDR look at other
pathways. However, some of the pathways suggested are not realistic to
current exposure scenarios (i.e., air-to-pasture, grass-to-meat/milk pathway,
homegrown fruit, and irrigation). Jack Hanley explained that EPA, when
writing risk assessments, has to look at all pathways as part of their
methodology and guidelines. Looking at all the pathways is appropriate
for EPA’s purpose. But ATSDR’s purpose is to find out where
people are actually being exposed.
Charles Washington said that it is important to include the years because
the operating capacity differed during various years. Charles asked if
ATSDR would be including the years the analyses were done. Jack Hanley
said yes and added that the years at various operating capacities were
evaluated.
In explaining cancer risk estimates, Jack Hanley read through a table
comparing the ATSDR Public Health Assessment to the EPA Risk Assessment.
Jack Hanley felt that it was important that the group understand that
there are deliberate differences between the EPA’s Risk Assessment
and ATSDR’s Public Health Assessment. Jack provided a summary of
the description, the purpose, the goal, exposures and pathways evaluated,
the result, and methods for both the ATSDR Public Health Assessment and
the EPA Risk Assessment.
Al Brooks felt that the environmental standards for many contaminants
and situations are more stringent than for public health work. Al Brooks
also said that animals in the wild need better conditions to survive than
humans.
Gordon Blaylock disagreed with Al and said that animals living in the
soil get higher doses/concentrations than humans.
Al Brooks said that the drinking water standard might be higher than
the comparable environmental standard for water because of food chain
enrichment. Gordon Blaylock asked Al to provide an example. Al Brooks
said that he feels mercury in East Fork Poplar Creek is an example. Jack
Hanley added that one reason for keeping the clean-up level low in East
Fork Poplar Creek was because of effects on the shrews and wrens. [There
was additional conversation about concentration values between Al Brooks
and Gordon Blaylock that was inaudible.]
Tony Malinauskas asked if the screening levels are consistent with risk
analysis, which would show that the hazard presents an acceptable risk.
Paul Charp said that in some cases the minimal risk level (MRL) is set
on a no-observed-adverse-effect level divided by a series of uncertainty
factors.
Kowetha Davidson said that if using an animal study, a safety factor
of 10 is used. To account for sensitivity in the human population, another
factor of 10 is used. [Kowetha went on to discuss animal studies and EPA
values but the details of her discussion were largely inaudible].
Jack Hanley briefly discussed Reference Dose and MRL. Jack said that
ATSDR uses the Reference Dose and MRL for screening and EPA uses Reference
Dose for policy and regulation. After screening, if a dose was found to
be above the Reference Dose, ATSDR would look into the situation further.
EPA would not; they would use their Reference Dose and come up with a
guideline or regulation based on the Reference Dose level.
Jack Hanley told the group that ATSDR is trying to arrange for DHAC’s
Associate Director for Science, Allan Susten, to present detailed material
regarding toxicology to the group.
Jack Hanley reminded the group that ATSDR is not involved with compensation.
James Lewis asked if there had ever been a purchase of land due to the
land being contaminated by a federal facility. Some group members replied
that it was possible that at some point and at some place that a land
purchase had been made due to contamination. Susan Kaplan made reference
to the government’s settlement of the lawsuit filed by Wayne Clark
and Mel Sturm regarding EFPC land.
Jack Hanley said that the PHA report presents conclusions about the actual
existence and level of health threat, if any, posed by a site, and recommends
ways to stop or reduce exposures. However, because of uncertainties, a
definitive answer on whether health effects actually will or will not
occur is not possible. There are no certainties; ATSDR is providing its
best professional judgment.
Al Brooks provided his view of the EPA approach versus the ATSDR approach.
Al provided an example of the EPA approach at East Fork Poplar Creek.
Al Brooks said that when EPA is missing data EPA takes what is “convenient”
or “handy”. When EPA is involved in remediation efforts, they
try to make the situation unquestionably safe for the most sensitive individual.
If this philosophy is not controlled, it leads to safety factors ranging
from one thousand to one million. Public health people try to be more
realistic than EPA because there are other places to spend public health
money. Al Brooks feels that the group should not expect EPA and ATSDR
to agree.
James Lewis said that ATSDR’s PHA Guidance Manual states that ATSDR
evaluates health outcome data. Does EPA use health outcome data in any
of their evaluations?
Jack Hanley said that EPA does not use health outcome data at site-specific
locations. Jack provided an example of the Cancer Incidence Review that
ATSDR is currently working on. Instead, EPA evaluates epidemiological
studies but does not typically perform its own epidemiological work in
site-specific locations.
Kowetha Davidson added that it is EPA’s policy to error on the
side of conservatism, which is why EPA uses conservative assumptions.
One example is that EPA assumes that humans are always 10 times more sensitive
than animals, but that is not always the case.
James Lewis asked if ATSDR was the agency that evaluates health outcome
data. Jack Hanley replied, primarily yes.
James Lewis said that it is important that people understand which agency
“makes the call” regarding health outcome data.
Paul Charp and Jack Hanley discussed some key points involved in the
way that the CERCLA Legislation is written. Paul added that ATSDR was
established to address the public health issues associated with Superfund
sites.
EPA Headquarters Summary Comment 3- For past uranium exposures, we
believe that ATSDR has underestimated the radiation dose for the inhalation
pathway.
The Summary Comment 3 relates to the original comment 19 in the draft
Appendix XXX that PHAWG members received prior to the meeting.
Paul Charp told the group that even if ATSDR had used the specific recommendations
from the EPA comments, the dose calculated would still be well below the
level of health concern. Paul added that instead of relying solely on
EPA’s Exposure Factors Handbook, ATSDR looks at site-specific exposure
information and actual inhalation rates for the South Eastern United States.
Paul Charp added that the comment regarding default exposure assumptions
used in the Task 6 report should have been provided to the Task 6 team
during the 1998 public comment period for the Task 6 report because ATSDR
was not the author.
EPA Headquarters Summary Comment 4- For past uranium exposures, ATSDR’s
assertion that estimated doses are overestimated due to “conservative
and overly protective assumptions and approaches” is not based on
a quantitative sensitivity and uncertainty analysis, and is largely unsubstantiated.
ATSDR should conduct a formal uncertainty analysis to determine the distribution
of possible doses and risks to Scarboro residents.
The Summary Comment 4 relates to the original comments 20-30 and 141
in the draft Appendix XXX that PHAWG members received prior to the meeting.
Paul Charp explained that the issue of conducting an uncertainty analysis
was raised by an ORRHES member at the April 22, 2003 meeting and addressed
by ATSDR in a written response provided to ORRHES at the June 2, 2003
meeting. Paul told the group that ATSDR defended its position using A
Guide for Uncertainty Analysis in Dose and Risk Assessments Related To
Environmental Contamination, issued in 1996 which stated that if
a conservatively based screening calculation is performed and this screening
calculation indicates the risk is “clearly below regulatory or risk
levels of concern,” and the possibility of exposure is low, then
a quantitative uncertainty analysis may not be necessary. Paul added that
the dose to Scarboro was well below the EPA CERCLA Guidance for clean
up as well as other federal regulations for radiation exposure.
Paul Charp stated that since the Task 6 screening evaluation of air,
soil, and surface water pathways resulted in a total past uranium radiation
well below the ATSDR radiogenic cancer comparison value, ATSDR does not
believe the evaluation of Y-12 uranium releases requires a further nonconservative
screening or a refined evaluation with uncertainty and sensitivity analysis.
EPA Headquarters Summary Comment 5- For past uranium exposures, ATSDR
should address the recommendations of several previous reviewers and incorporate
improvements, especially formal sensitivity and uncertainty analyses and
additional core sampling data.
The Summary Comment 5 relates to the original comments 6, 16, 17, and
141 in the draft Appendix XXX that PHAWG members received prior to the
meeting.
Paul Charp explained that independent internationally recognized technical
experts hired by ATSDR concluded that the Task 6 report was technically
sound and applicable to decision-making; supported by and developed on
the basis of information in the reports; had no major or significant problems
with respect to the study design or the scientific approaches used; and
was adequate for public health decision-making.
Paul Charp also told the group that in 2001, EPA Region IV collected
uranium core samples from two locations in Scarboro. The EPA Region IV
report stated that (1.) none of the results of the uranium analysis, including
those for the uranium soil cores, were elevated above background, (2.)
the results of the EPA and FAMU sampling efforts are consistent in their
findings, and (3.) EPA “does not propose to conduct any further
environmental sampling in the Scarboro community. Based on EPA’s
results, the Scarboro community is safe. Therefore, additional sampling
to determine current exposure is not warranted.”
Susan Kaplan asked if the samples collected in 2001 by EPA Region IV
were homogenized. Jack Hanley said that EPA took two core samples and
most likely both samples were homogenized.
Paul Charp said that he agreed with Susan Kaplan. Paul said that he would
not want to take a deep core sample (where the contamination has not gone
deep into the soil) and homogenize it because the sample would be diluted.
Paul provided an example in California where if the 130 cm soil sample
had been homogenized, nothing would have been found. But because the sampling
was done in intervals, ATSDR proved that the plutonium came from the sewage
plant and not from air dispersion.
Paul Charp said that when ATSDR requests soil samples, ATSDR always requests
the top two inches of soil because that is the area where children will
dig into the soil and ingest soil.
Charles Washington asked if uranium migration was affected by pH level.
Paul Charp said that typically, uranium does not migrate in clay very
much.
James Lewis asked if ATSDR actually knows what EPA did as far as the
evaluation of the soil samples. Paul Charp replied that he did not remember
seeing an explanation in the results of the Scarboro sampling. James Lewis
suggested that ATSDR actually find out what EPA did concerning the samples
so that ATSDR has a definite answer to Susan Kaplan’s question.
Al Brooks said that he believed that EPA said that they homogenized the
sample. Jack Hanley said that it is most likely that the soil samples
were homogenized. James Lewis would like to know—for sure—whether
or not EPA’s soil samples were homogenized.
Al Brooks asked if there is any evidence to show that regarding radiation,
twice the background level would demonstrate a hazard. Paul Charp provided
an example of Denver, Colorado having a high background radiation level
and a lower incidence of cancer rates than other states.
Gordon Blaylock said that nothing is usually found at levels one or two
times background, but that does not mean that it does not happen. [There
was continued discussion between Gordon Blaylock and Al Brooks but most
of the conversation was inaudible].
Kowetha Davidson said that there are many examples in ATSDR’s responses
where ATSDR has stated a technical reviewer’s comment but did not
state whether ATSDR agreed with the technical reviewer or not. It has
been Kowetha’s experience, that when ORNL agrees or disagrees with
a technical reviewer, there is usually an explanation provided stating
why there is agreement or disagreement.
Jack Hanley provided an example of uranium and clay that had very little
migration except where large quantities of acidic material had been dumped.
Tony Malinauskas said that the EPA data is not necessarily suspect because
the FAMU data is consistent with the EPA data.
LC Manley said that one reason that EPA came to verify FAMU soil data
was because some people felt that FAMU was not competent. LC feels that
it is a positive event that EPA came back and that its data verified the
FAMU data.
In response to James Lewis’s question about the reason that EPA
took the soil samples, Al Brooks said that EPA’s reasons for taking
the soil samples changed over time.
EPA Headquarters Summary Comment 7- ATSDR’s health evaluation
criteria are less protective than current international, national, and
federal radiation protection standards, and the bases for these criteria
are inconsistent with widely accepted radiation protection guidance.
The Summary Comment 7 relates to the original comments 67-73 in the draft
Appendix XXX that PHAWG members received prior to the meeting.
Paul Charp reminded the group that ATSDR had presented its screening
value to the PHAWG and ORRHES numerous times. During those presentations,
ATSDR explained its process and its procedures concerning the ATSDR screening
value.
Paul Charp discussed a table, which showed how ATSDR’s comparison
value compared on an annual basis to other organizations. With the exception
of EPA’s cleanup level (15 mrem/year), ATSDR’s radiogenic
cancer comparison value (71 mrem/year) is not extremely different from
ATSDR’s MRL (100 mrem/year), ICRP’s guidance (100 mrem/year),
and NCRP’s guidance (100 mrem/year). Paul Charp explained that the
comment from EPA is a misunderstanding of what ATSDR stated in the Y-12
Uranium PHA. Paul stressed that it is 5000 mrem over 70 years and not
5000 mrem over one year.
Kowetha Davidson said that EPA’s values are based on science policy
and not science. Paul Charp said that that is one way of putting it.
EPA Headquarters Summary Comment 8- At this time, we do not agree
with ATSDR’s final conclusions regarding past uranium exposures.
The Summary Comment 8 relates to the original comment 5 in the draft
Appendix XXX that PHAWG members received prior to the meeting.
Paul Charp explained that ATSDR has categorized this site as having no
apparent public health hazard from exposure to uranium. ATSDR’s
category of no apparent public health hazard means that people could be
or were exposed, but the level of exposure would not likely result in
adverse health effects.
Paul Charp also pointed out that this particular comment by the EPA Office
of Radiation and Indoor Air in Washington, DC contradicts EPA Region IV’s
overall conclusion on ATSDR’s PHA. In the March 27, 2003 cover letter
to ATSDR, EPA Region IV stated the following: “EPA concurs with
the assessment’s conclusion that the available data does not indicate
the presence of uranium releases that constitute a past, current or future
health threat for the Scarboro community.”
Susan Kaplan asked who is considered more of an expert—Headquarters
or Region IV? Jack Hanley said that Region IV knows the site and the community
much better than Headquarters. Jack provided an example of Headquarters
using default data or standard methodology concerning fish consumption
rather than site -specific data, which would have had a tremendous impact
on the estimated doses.
Peggy Adkins told the group that she remembered a tornado that caused
a barn to be torn down as well as causing huge waves in the water. Peggy
wondered if anyone had taken into consideration the bizarre weather conditions
and how those conditions could have impacted the soil, water, and air.
Peggy added that unless a person was a resident, they would not know about
those particular situations.
Jack Hanley said that the Dose Reconstruction estimated annual average
doses and in a few situations looked at specific events and specific releases.
However, the Dose Reconstruction primarily focused on average doses, thus,
short term, acute exposures would not have been evaluated. Al Brooks added
that the doses are not necessarily always average; they are cumulative
and could perhaps show bizarre events.
Susan Kaplan passed around a copy of her comments (available in the field
office with these minutes) concerning the ATSDR response document. Susan
would not have passed her comments around, but after listening to the
presentation Susan felt that all of her comments and issues were not addressed
in the ATSDR comments, especially the issue of homogenization of soil
samples. Susan wanted her comments to go into the record as important
issues. Susan Kaplan feels that it is very important to clearly explain
the issue of the apparent discrepancy between EPA Headquarters and Region
IV.
Susan Kaplan also stated that she found two examples of Agency/institutional
arrogance in ATSDR’s responses. One example was with comment number
19 in which ATSDR responded that the “comment should have been provided
to the Task 6 team during the 1998 public comment period for the Task
6 report”. Susan felt that in this context the comment does not
make sense because that was back in 1998. Jack Hanley and Al Brooks responded
that EPA had staff that attended those early meetings. Susan’s second
concern was ATSDR’s use of “nice academic exercise”
in comment number 22. Susan said that there are other things involved
besides the very technical issues. ATSDR should be careful so as not to
be perceived as extremely arrogant when responding to comments and responses.
James Lewis told the group that he feels there are objective comments
and concerns as well as subjective comments and concerns. James Lewis
feels that ATSDR does not do as good of a job addressing the subjective
issues as they do addressing the objective issues. James feels it is important
to critique how ATSDR is addressing and marketing the subjective issues
and concerns—not just the objective comments and concerns.
Overhead Three
Jack Hanley explained the changes that were made to the Y-12 Uranium
PHA as a result of reviewing and evaluating the public comments. However,
ATSDR has not changed its conclusion that past and current off-site exposures
to uranium released from the Y-12 pose no apparent public health hazard
because the estimated doses are not at levels expected to cause adverse
health effects. So, after evaluating all of the comments, this site remains
in the conclusion category of “no apparent public health hazard”.
Kowetha Davidson said that it is often stated that levels are below what
is expected to cause adverse health concerns. Could that statement be
quantified so that people have an idea of where they are in relation to
what would be considered a health concern?
Jack Hanley responded that Paul Charp would get to Kowetha’s question.
Jack went on to explain that ATSDR’s screening level and total past
exposure is about 32 times less than the screening value so there is no
reason to perform further analysis or additional sampling because the
screening analysis shows that it is 32 times less than the screening value.
Overhead Four
Jack Hanley presented and explained the five different conclusion categories
and follow-up public health actions that ATSDR uses when writing Public
Health Assessments. Jack Hanley explained the details associated with
the categories of Urgent Public Health Hazard, Public Health Hazard, Indeterminate
Public Health Hazard, No Apparent Public Health Hazard, and No Public
Health Hazard.
Susan Kaplan asked about the residents tracking system listed under Potential
ATSDR Actions for the category of No Apparent Public Health Hazard. Jack
Hanley and other ATSDR staff commented that they were not sure exactly
what a resident tracking system refers to.
James Lewis showed the group a poster created by ATSDR, which was titled
a “Summary of Public Health Implications from ATSDR’s Evaluation
of Past and Current Uranium Exposure to Off-Site Populations”. James
Lewis explained that under the column of “Is there a public health
concern?” the poster says, no. It is important that ATSDR remain
consistent with its terminology and provide enough information so that
the public will understand what ATSDR/ORRHES is identifying. James Lewis
would like to see the Y-12 Uranium brief revised to include “health
hazard” instead of “health concern” and would like to
see the explanation of the conclusion categories included in the packet.
Jack Hanley, Paul Charp, and James Lewis agreed that instead of saying,
“Is there a public health concern?” the statement should read
as “Is there a public health hazard?”
Peggy Adkins asked—under the column of “Potential ATSDR Actions”—why
ATSDR is only performing health education and not the health investigation
or the residents tracking system. Are the other two actions still an option?
Jack Hanley said that he would follow-up on Peggy’s question.
Overhead Five
Jack Hanley provided a brief overview of the conclusion and recommendation
process by explaining Figure 9-1 from the Public Comment Version of the
PHA Guidance Manual.
Overhead Six
Paul Charp presented and explained the specifics involved in deciding
on a conclusion category for the Y-12 Uranium Public Health Assessment.
Paul discussed the process involved in deciding that there was “no
apparent public health hazard” for both past and current uranium
exposures.
Kowetha Davidson said that the inhalation and ingestion doses of uranium
should be added together because ATSDR is speaking about an internal dose
to the kidneys. [Kowetha Davidson included additional feedback but her
comments were inaudible.]
Paul Charp told Kowetha Davidson that because time was running short,
he would give her a call or talk to her more in depth about this issue
at a later date.
Bob Craig asked what is the next stage involved with the comments. It
was decided that the comments would be revisited at a future PHAWG meeting.
Jack Hanley told the group that he planned to come back to the PHAWG
with the final comments and then go to ORRHES with the Final Y-12 Uranium
PHA during the December Subcommittee meeting.
James Lewis commented ATSDR for doing a good job of explaining and presenting
the EPA comments. However, James feels that there are other outstanding
issues that need to be looked at collectively for the next PHAWG meeting.
James feels that the outstanding issue is the subjective comments that
were included in the Appendix XXX Responses to Public Comments on
Y-12 Uranium Releases Public Health Assessment.
*Like the rest of the overheads used in this presentation, copies will
be made available in the field office upon request.
ATSDR proposed plan for Iodine-131 Public Health Assessment
Paul Charp presented the proposed plan for the Iodine-131 Public Health
Assessment. Paul explained the general steps in the process and the estimated
time frame for the literature reviews, data acquisition, data review,
and the possible need for an expert panel. Paul explained that ATSDR and
others are also currently in the process of looking for missing Iodine
data.
New Business
Bill Taylor told the group that when the Y-12 Uranium final PHA is presented,
ATSDR is interested in ORRHES having some type of recommendation to the
agency. The resolution would need to be discussed and developed within
the PHAWG.
The group decided that all comments on ATSDR responses should be submitted
to the PHAWG for discussion at the next PHAWG meeting on November 6, 2003.
Action Items
Regarding EPA Summary Comment number one, it was suggested that ATSDR’s
response could be better stated and more accurate if it were similar to
the following: It is not ATSDR’s policy to provide copies of
raw data from primary sources that are publicly available. But ATSDR does
supply references to the data used; which is good technical practice.
ATSDR will find out what EPA did concerning the evaluation of soil samples
so that ATSDR has a definite answer to the question regarding whether
or not the Scarboro soil samples were homogenized.
If ChemRisk created a deposition map that showed uranium fallout, ATSDR
should locate the map and use it.
ATSDR should consider revising the Y-12 Uranium brief to include the
term “health hazard” instead of “health concern”
and include additional information such as an explanation of the conclusion
categories.
Regarding the potential ATSDR actions, Jack Hanley will follow-up to
see why ATSDR is only performing the health education and not the health
investigation or the residents tracking system.
The comments regarding the ATSDR responses will be revisited at the November
6th PHAWG meeting.
The meeting was adjourned at 8:15 PM.
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