One objective of this PHA is to respond to specific community concerns about the TSCA Incinerator. This section presents responses to all such concerns that residents have expressed to ATSDR to date. Throughout the health assessment process, ATSDR has compiled a list of community concerns by drawing from ATSDR's database of concerns for the ORR facilities5, TDEC's report addressing community concerns (TDEC 1997), and the summary report issued by a group of independent experts chartered by the Governor of Tennessee (Iglar et al. 1998). ATSDR also identified community concerns by talking to local residents, whether at public meetings or through individual communications. The remainder of this section uses a question and answer format to address specific community concerns, which are organized into four topics.
V.A. Community Concerns Regarding Health
Sections III and IV of this PHA present ATSDR's findings regarding the public health implications of exposure to air contaminants released by the TSCA Incinerator. The following questions and answers elaborate on specific health issues of concern to some community members.
Question A-1:
Under certain meteorological conditions, air emissions from the TSCA Incinerator appear to blow directly to ground level at on-site locations. Does this situation present a health hazard to visitors to the property, particularly for exposures to mercury?
Answer A-1:
Many factors determine how contaminants disperse from a stack into the atmosphere. These factors include the stack gas temperature and exit velocity, the stack's dimensions, the stack's proximity to nearby buildings, and local meteorological conditions. Under certain circumstances, stack gas emissions have been observed to blow rapidly to the ground — a phenomenon known as "downwash."
The conditions that cause severe downwash at the TSCA Incinerator typically are short-lived; that is, they likely do not persist for hours on end. ATSDR has received no reports that during downwash conditions, site visitors were ever directly exposed to stack emissions. Further, ATSDR expects that should downwash conditions be observed while visitors are touring the facility, escorts would guide any visitors away from these emissions. Accordingly, ATSDR suspects that visitors' exposures to air emissions during downwash conditions are extremely limited, if they occur at all.
A community member asked ATSDR specifically about whether this scenario could lead to mercury exposures that would cause visitors to get sick. Such an outcome is unlikely for two reasons. First, the TSCA Incinerator has extremely strict Waste Acceptance Criteria for materials that contain mercury to ensure that emissions are safely below levels that would lead to unacceptable air quality impacts. Second, according to ATSDR's Toxicological Profile for Mercury (ATSDR 1999b), the lowest air concentrations of mercury that have been shown to cause adverse health effects following exposures over short time frames (e.g., hours) are more than 20,000 µg/m3. Considering that none of the metals reached concentrations of even 1 µg/m3 at off-site locations, it is highly unlikely that mercury concentrations could reach harmful levels for acute exposures, even when considering direct downwash of the plume.
Question A-2:
Are workers at the TSCA Incinerator at risk for developing adverse health effects, due to their occupational exposures?
Answer A-2:
As noted earlier in this PHA, ATSDR's role at the ORR facilities is to evaluate environmental health issues, not occupational health issues. Nonetheless, ATSDR recognizes that many residents have health concerns specific to occupational exposures.
There are several resources that residents can consult for more information on occupational health issues. Web sites maintained by DOE (http://cedr.lbl.gov) and NIOSH (http://www.cdc.gov/niosh/2001-133.html), for example, describe ongoing worker health studies at several existing and former DOE facilities. One reference available is a NIOSH study that found no evidence of significant occupational exposures to hydrogen cyanide and related compounds at the TSCA Incinerator (Blade and Worthington 1996). Further, the independent panel's summary report (Iglar et al. 1998) and ATSDR's review of thermal treatment technologies (ATSDR 2002) comment on more general occupational health issues observed at incineration facilities.
Question A-3:
Will ATSDR establish a health clinic for residents who live near the TSCA Incinerator?
Answer A-3:
ATSDR does not establish site-specific health clinics. In a February 22, 1999, letter from Donna E. Shalala, Secretary of Health and Human Services, to The Honorable William H. Frist, M.D., United States Senate, Secretary Shalala stated that ATSDR and CDC cannot provide direct primary medical services to communities. ATSDR and CDC can, however, support the existing medical care systems to address public health concerns of communities that are near nuclear plants. ATSDR is working with ORRHES, EPA, TDEC, the Tennessee Department of Health, and DOE to plan appropriate public health follow-up activities to address the concerns of communities regarding the nuclear weapons complexes. In August 2002, the ORRHES recommended that formal consideration of establishment of a clinic, clinical evaluations, medical monitoring, health surveillance, health studies, or biological monitoring be postponed until the ATSDR public health assessment process identified and characterizes an exposure of an off-site population at levels of health concern. As Sections III and IV of this PHA explain, ATSDR found no evidence of local residents being exposed to unhealthful levels of air pollution in the vicinity of the TSCA Incinerator. Accordingly, ATSDR does not believe follow-up public health activities are necessary to address the releases from the TSCA Incinerator.
Question A-4:
Does ATSDR's evaluation consider peak emission rates expected to occur from the TSCA Incinerator, such as those during TRV events?
Answer A-4:
Yes. This PHA examines both routine and peak exposures as characterized by average and maximum concentrations among ambient air monitoring data. It also presents detailed evaluations of TRV events, which are assumed to lead to the highest short-term exposures, given that incinerator gases are released without first passing through air pollution controls. ATSDR's evaluation found that both short-term and long-term exposures did not reach levels expected to cause adverse health effects.
Question A-5:
Does the TSCA Incinerator release beryllium at levels of health concern?
Answer A-5:
No. Ambient air monitoring for beryllium has occurred over nearly the entire history of the TSCA Incinerator's operations at the location predicted to have the greatest air quality impacts. As Table C-3 shows, even the highest concentration of beryllium measured to date did not exceed protective health-based comparison values. Therefore, ATSDR concludes that the air emissions of beryllium from the TSCA Incinerator are not at levels of health concern.
Question A-6:
Several community members expressed concern about the possibility of adverse health effects occurring as a result of exposure to air emissions from the TSCA Incinerator. In one case, for instance, a community member noted that the onset of adverse health effects corresponded with the time the TSCA Incinerator began routine operations. In another case, a community member noted that onset of adverse health effects occurred shortly after a perceived exposure to emissions from the source.
Answer A-6:
ATSDR considered the various community health concerns when preparing this PHA. The analyses in this PHA document the multiple lines of evidence ATSDR evaluated to assess the possibility of air emissions from the TSCA Incinerator causing adverse health effects among nearby community members. Specifically, ATSDR critically reviewed the design and operation of the incinerator, amount and composition of waste treated, emissions data, fate and transport modeling studies, and ambient air sampling and monitoring studies. Every line of evidence considered showed that the TSCA Incinerator's emissions do not lead to exposure levels associated with adverse health effects. Further, continued operation of the TSCA Incinerator is not expected to cause harmful exposures in the future because numerous safeguards, pollution controls, and strict permitting requirements are in place to prevent unsafe operating conditions from occurring.
V.B. Community Concerns Regarding Environmental Contamination
Section III and Appendixes A through C of this PHA present ATSDR's evaluation of the air exposure pathway for the TSCA Incinerator. The following discussion addresses concerns that community members have previously expressed to ATSDR about local air emissions sources, measured environmental contamination levels, and potential ecological effects from the incinerator's emissions.
Question B-1:
Do available monitoring data form a sufficient basis for conclusions on this site?
Answer B-1:
As Appendixes A and C show, multiple parties have conducted numerous sampling and monitoring studies to characterize the TSCA Incinerator's emissions and air quality impacts. These studies considered the contaminants of greatest concern for incineration facilities, focused on locations where air quality impacts are expected to be greatest, and were conducted over almost the entire history of the incinerator's operations. ATSDR believes that the available emissions monitoring data and ambient air monitoring data are generally consistent and provide an adequate basis for scientifically defensible public health conclusions regarding the TSCA Incinerator.
Question B-2:
To what extent do air emissions from sources other than the TSCA Incinerator, particularly the nearby power plants, contribute to local air pollution?
Answer B-2:
The air that local residents breathe contains trace contamination that originates from many different sources, including industrial sources, mobile sources, and natural sources. Section II.E.1 of this PHA identifies several local air emissions sources and describes, in general terms, how they affect local air quality. For additional perspective on power plants, ATSDR examined the most recent TRI data for all electricity-generating facilities within 25 miles of ETTP and found the following:
Facility Name (as listed in TRI)
Total Air Emissions of Toxic Chemicals in 2001 (Pounds)
U.S. DOE East Tennessee Technology Park
83
U.S. TVA Kingston Fossil Plant
5,926,225
U.S. TVA Bull Run Fossil Plant
4,305,815
This previous data compilation shows that the local power plants emit far greater quantities of toxic chemicals into the air than does the TSCA Incinerator. ATSDR strongly cautions about what readers should infer from the data shown above, because comparisons of total TRI emissions does not consider a) releases of all contaminants, b) the toxicity of the individual chemicals emitted, and c) important air dispersion behavior. For instance, because the power plants have such tall stacks, the plants' emissions can travel long distances (and become increasingly less concentrated) before they ever reach ground level. In summary, ATSDR presented the TRI emissions data above to respond to a very specific community concern; however, it is critically important that these data be considered in proper context.
While this PHA does not focus on environmental health issues specific to the local power plants, ATSDR notes that the ambient air monitoring data collected in the vicinity of the TSCA Incinerator reflect potential air quality impacts from the local power plants, the TSCA Incinerator, and other air emissions sources. Therefore, this PHA implicitly considers how air emissions from nearby TVA facilities affect air quality near the TSCA Incinerator.
Question B-3:
Does the TSCA Incinerator contaminate environmental media other than air, whether through direct discharges (e.g., wastewater) or through indirect pathways (e.g., air contaminants depositing onto soils and being taken into the food chain)? If so, does this contamination present a health hazard?
Answer B-3:
The analyses in this PHA focus almost entirely on direct inhalation exposures to airborne contaminants near the TSCA Incinerator, which presents the most likely pathway by which residents might come into contact with site-related contaminants. ATSDR also considered the specific issues raised in the comment, regarding potential contamination of other environmental media:
- Direct discharges. Residuals from the TSCA Incinerator are managed according to applicable permits and waste management regulations; no residuals are released directly into the environment.
The incinerator's liquid residuals, for instance, are pumped to ETTP's wastewater treatment plant, known as the Central Neutralization Facility. The treated water eventually flows into the Clinch River. To fulfill permit requirements, DOE regularly tests the treated water in outfalls to the Clinch River. The testing must measure concentrations of numerous contaminants, including metals, radionuclides, and selected organic compounds. ATSDR reviewed data summaries for these sampling efforts, which show that contaminant levels in the water discharged from ETTP to the Clinch River have been consistently below maximum limits established in the environmental permits (DOE 1991–2002).
ATSDR also considered the fate of the ash and sludge residuals that the TSCA Incinerator generates. Since 1991, DOE has handled these wastes according to EPA's waste management regulations. These regulations require DOE to test the ash and sludge for chemical contamination, and then to handle the materials accordingly. Depending on the testing results, the ash and sludge are either treated further or sent off site (typically to landfills) for waste management. Thus, solid residuals also are not released directly into the environment.
- Indirect contamination pathways. Residents have asked that ATSDR consider the possibility that pollutants released by the TSCA Incinerator might eventually contaminate other media. For example, contaminants in air emissions might deposit on soils or surface waters, and then become available for accumulation into biota. ATSDR is currently preparing a separate PHA on the extent of environmental contamination that has recently been measured in soils, surface water, and biota at locations outside the ORR property line. That "chemical screening" PHA will consider the possibility of indirect contamination caused by the TSCA Incinerator's air emissions. ATSDR expects that the chemical screening PHA will be completed early in 2005.
Question B-4:
Have emissions from the TSCA Incinerator killed pine trees in downwind locations?
Answer B-4:
In the mid-1990s, residents expressed concern that air emissions from the TSCA Incinerator might have killed a group of pine trees located immediately downwind from the facility. The independent panel chartered by the Governor of Tennessee evaluated this issue and concluded that the pine trees were killed primarily by southern pine beetle infestations. These beetle infestations reportedly have caused extensive damage to local trees throughout and beyond ORR (Iglar et al. 1998).
Question B-5:
Has ATSDR considered ambient air monitoring data collected by TVA?
Answer B-5:
During the March 2004 PHAWG meeting when ATSDR presented its preliminary evaluation for the TSCA Incinerator, a community member recommended that ATSDR contact TVA to determine if that agency has collected ambient air monitoring data relevant to this PHA. ATSDR has since obtained data from TVA, which are summarized in Appendix C of this PHA.
Question B-6:
Are the locations chosen for ambient air monitoring and ambient air sampling adequate?
Answer B-6:
Yes. Parties who conduct ambient air monitoring and ambient air sampling studies face difficult decisions when deciding where to place their equipment. On the one hand, there is often a desire to know ambient air concentrations of contaminants at as many places as possible; on the other hand, operating numerous monitoring stations can be prohibitively expensive. To achieve an appropriate balance, scientists typically conduct and carefully review air dispersion modeling studies before deciding where to place monitoring stations. This was done for the TSCA Incinerator, and ambient air concentrations have been measured at locations (both upwind and downwind) believed to have the greatest air quality impacts. Additionally, ambient air monitoring and ambient air sampling takes places at locations between the incinerator and the nearest residential receptors. As a result, it is extremely unlikely that the current monitoring network is grossly underestimating site-related exposures. Consequently, ATSDR believes the monitoring and sampling data are a sufficient basis for reaching public health conclusions, especially when one considers the consistent insights offered by a review of information on emissions and fate and transport.
Question B-7:
Has DOE measured fugitive emissions from the TSCA Incinerator? If fugitive emissions have not been measured, how can ATSDR reach a definitive conclusion on this site, and should DOE be required to measure these emissions?
Answer B-7:
By their very nature, fugitive emissions are extremely difficult, if not impossible, to measure directly. Consequently, DOE has never measured, nor been required to measure, fugitive emissions from the TSCA Incinerator. ATSDR does not view the lack of fugitive emission measurements as a significant data gap for this PHA for two reasons. First, several design and operational features clearly minimize potential fugitive emissions from this source (see Section III.B.3). Second, the ambient air monitoring data that ATSDR reviewed reflects air quality impacts from all local emissions sources, including the fugitive emissions from the TSCA Incinerator. Consequently, ATSDR's evaluation implicitly considered the incinerator's fugitive emissions, even though they have never been directly measured.
Question B-8:
At what location do air emissions from the TSCA Incinerator have their greatest air quality impacts?
Answer B-8:
Local meteorological conditions determine how emissions move from the incinerator stack to off-site locations. As the wind speed and direction change, so does the location with the highest ground-level concentration. As Appendix B describes, the existing dispersion modeling studies have estimated where the incinerator's emissions are expected to have their greatest air quality impacts over the long term. All the studies ATSDR reviewed place the point of maximum impact within ½-mile of the stack base, in areas where no residents live or frequent. It should be noted, however, that ambient air monitoring stations have been placed at the estimated locations of maximum impact.
Question B-9:
Did ATSDR consider air emissions from local medical waste incinerators and municipal solid waste incinerators?
Answer B-9:
To identify nearby medical waste incinerators and municipal waste incinerators, ATSDR consulted with EPA personnel responsible for tracking the permit status of selected facilities in the United States. Through this consultation, ATSDR learned that there currently are no medical waste incinerators or municipal waste incinerators in the Knoxville metropolitan area that process enough material to fall under EPA's most recent regulations on incineration. Thus, if any medical waste incinerators or municipal solid waste incinerators are located in the Knoxville area, they must process very small quantities of waste. Moreover, air quality impacts from such facilities, if they exist, would presumably be captured in the ambient air monitoring data that ATSDR reviewed for this site.
V.C. Community Concerns Regarding Incinerator Operations
ATSDR identified several community concerns regarding the operation of the TSCA Incinerator, with most expressed during the March 2004 PHAWG meeting. ATSDR's responses to these concerns follow. Recognizing that residents have lingering questions about the incinerator's operations and the extent of regulatory oversight, ATSDR has recommended that TDEC issue annual fact sheets to inform the public of the TSCA Incinerator's ongoing operational status (see Section IX for further information on this and other recommendations).
Question C-1:
Why has DOE not implemented continuous emissions monitoring systems for a wider set of pollutants?
Answer C-1:
As Appendix C indicates, DOE currently conducts continuous emissions monitoring for carbon dioxide, carbon monoxide, and oxygen. Additionally, DOE continuously samples stack gases to measure emission rates of metals and radionuclides. Taken together, these continuous emissions monitoring and continuous emissions sampling efforts meet all applicable regulatory requirements for emissions measurements.
While ATSDR can appreciate the desire to have real-time emissions measurements for a broader range of contaminants, reliable continuous measurement devices simply are not available for every contaminant released by incinerators. ATSDR does not view the lack of additional continuous monitoring data as a critical information gap for this site for two reasons. First, ATSDR emphasizes that continuous emissions sampling already occurs for metals and radionuclides — two groups of contaminants that incinerators do not destroy. Second, safeguards are in place to ensure that air emissions of other contaminants do not exceed levels of health concern. For instance, maintaining operating parameters within limits established during the trial burns should ensure that organic compounds and PCBs in wastes are thoroughly destroyed. Therefore, ATSDR believes that DOE's current emissions monitoring and emissions sampling strategies are appropriate.
Question C-2:
If continuous emissions monitoring for PCBs does not occur, how does DOE know that the DRE for PCBs is consistently greater than 99.9999%?
Answer C-2:
No continuous emissions monitoring systems are currently available for PCBs in incinerator exhaust. However, EPA's permitting process for incinerators includes several measures that help ensure that facilities consistently meet required DREs. For instance, through the trial burn process, EPA requires facility operators to demonstrate that their incinerators can adequately destroy wastes, even under unfavorable operating conditions. Further, environmental permits are prepared that establish strict waste acceptance criteria and specify limits on several critical operating parameters in the interest of ensuring that adequate waste destruction occurs. Finally, continuous emissions monitoring is required for carbon dioxide, carbon monoxide, and oxygen; results from this monitoring can characterize incineration efficiency. Thus, even though continuous monitoring of DREs for PCBs is currently not feasible, multiple safeguards are in place to help ensure (though not necessarily prove) that the required DREs are met.
Question C-3:
How can stack tests conducted every 5 years characterize how air emission rates at the TSCA Incinerator vary from day to day?
Answer C-3:
This question addresses a key issue often debated in connection to regulatory strategies for air emissions sources. Given the costs of conducting stack tests, environmental regulators have long recognized that frequent stack testing can be prohibitively expensive for incinerator operators. Regulators have instead focused on an alternate approach to ensuring safe operation of incineration facilities: carefully establishing waste acceptance criteria and limits on critical operating parameters to ensure (with an adequate margin of safety) that incinerator emissions are not harmful. Periodic stack tests are then used to confirm that the permit conditions are indeed appropriate. ATSDR believes that this is a sensible approach and avoids placing an undue financial burden on incinerator operators to demonstrate regulatory compliance.
Question C-4:
Is all waste material being characterized before being treated at the TSCA Incinerator?
Answer C-4:
Wastes must be thoroughly characterized, whether through testing or demonstrated process knowledge, before they can be treated at the TSCA Incinerator. DOE must retain records of waste characterization efforts, and TDEC periodically reviews records to verify compliance with permit conditions. Failure to perform waste characterization carries serious consequences. For instance, the DOE contractors who operate the incinerator can be subject to expensive fines (and, in extreme cases, criminal investigation) if waste characterization is not adequately performed. Overall, ATSDR has no reason to believe that DOE is treating improperly characterized wastes at the TSCA Incinerator.
Question C-5:
Given that incinerators do not destroy metals or radionuclides, why is incineration used to treat wastes containing these contaminants?
Answer C-5:
It is ATSDR's understanding that DOE is not using incineration to treat wastes heavily contaminated with radionuclides. Rather, the wastes of concern predominately contain toxic organic constituents (like PCBs) that need to be destroyed. Incineration has been shown to safely destroy these toxic constituents without generating and emitting harmful levels of by-products.
The toxic organic wastes that DOE treats at the TSCA Incinerator also happen to contain small amounts of metals or radionuclides. Recognizing this, DOE designed the incinerator with extensive air pollution controls to remove metals, radionuclides, and other inorganic materials that are not destroyed in the process. Stack testing has shown that the air pollution control devices at the TSCA Incinerator efficiently remove metals or radionuclides from gases leaving the afterburner. Some estimates place these removal efficiencies well over 90%, depending on the metal or radionuclide of concern. Regardless of the actual removal efficiencies, trace amounts of metals and radionuclides undoubtedly pass through the incinerator untreated. However, an extremely large volume of ambient air monitoring data show that these emissions have only marginal impacts on local air contamination levels and the measured air concentrations of metals and radionuclides are below levels of health concern.
Question C-6:
Does DOE operate the TSCA Incinerator outside of the bounds established in the environmental permits?
Answer C-6:
The incinerator automatically shut downs whenever one of several critical operating parameters (see Table 3) falls outside acceptable ranges specified in the environmental permits. These critical operating parameters are continuously measured using automated sensors. Therefore, ATSDR has no reason to believe that DOE or its contractors can or would intentionally operate the incinerator beyond its permitted bounds.
Question C-7:
Given that the TRV remains open when the TSCA Incinerator is not operating, do emissions routinely occur through the TRV during typical process startups and shutdowns?
Answer C-7:
The question correctly notes that the TRV at the TSCA Incinerator is in the open position when the incinerator is not operating. During startup, a process interlock prevents the incinerator from operating until the TRV is in the closed position. Therefore, all combustion gases generated after process startup cannot pass through the TRV. Similarly, during process shutdown, the TRV remains in the closed position until after all combustion gases have passed through the air pollution controls. Therefore, whether during startup conditions, routine operations, or shutdown conditions, incineration gases pass through the air pollution controls and are not vented through the TRV. Only during the 18 events listed in Table 2 were untreated gases released through the TRV.
The following paragraphs present ATSDR's responses to general community concerns that do not fall under the categories listed above.
Question D-1:
Does trucking hazardous wastes to the TSCA Incinerator present a hazard?
Answer D-1:
As noted previously, the TSCA Incinerator treats wastes generated by multiple DOE facilities, not just the ORR facilities. Selected wastes from other DOE facilities are shipped to the TSCA Incinerator by truck. ATSDR acknowledges that untreated hazardous wastes might be released if any trucks were involved in serious accidents. However, the U.S. Department of Transportation has developed many regulations to prevent such releases or minimize their consequences. For instance, drivers who haul hazardous waste must have special licenses, waste materials must be packaged in containers designed to withstand traumas anticipated in certain accidents, and wastes must be labeled and tracked. ATSDR believes these and other safeguards help minimize any hazards associated with transporting hazardous wastes to the TSCA Incinerator. While none of these regulations can guarantee that no accidents involving waste shipments will ever occur, it is worth noting that the TSCA Incinerator has now operated for 14 years without any accidents involving hazardous waste shipments.
Question D-2:
Has ATSDR evaluated the quality of the monitoring data reported by DOE?
Answer D-2:
ATSDR carefully scrutinized the quality of all sampling results relevant to the TSCA Incinerator, regardless of which party had collected the data. For reasons stated in Appendix C, ATSDR believes the monitoring data provided by DOE are generally of a known and high quality. Moreover, ATSDR sought additional data sources to provide independent verification for the quality of DOE's data. For instance, the consistency between EPA's and DOE's environmental radiation measurements near ETTP provide assurance that the underlying measurements are accurate. Similarly, ATSDR recommends that TDEC conduct similar data comparisons between its metals monitoring data and DOE's or provide some other form of independent verification of DOE's metals data (see Section IX).
Question D-3:
Did ATSDR consider findings from researchers at the University of California at Los Angeles (UCLA) suggesting that metals should not be incinerated?
Answer D-3:
During the PHAWG meeting when ATSDR presented its preliminary evaluation of the TSCA Incinerator, a community member noted that researchers at UCLA published a paper suggesting that metals should never be incinerated. After the meeting, ATSDR asked the individual who made these comments to provide a copy of the publication cited. The information provided was not a peer-reviewed publication, but rather a printed copy of UCLA's Center for Clean Technology Web site. Thus, ATSDR has no knowledge of UCLA researchers making the statements attributed to them. More generally, however, ATSDR has already stated its position on the utility of incineration as a waste management alternative: "Thermal treatment technologies [including incineration] are inherently neither safe nor unsafe; whether they are safe depends on how they are designed and operated" (ATSDR 2002).
Question D-4:
Did ATSDR consider findings from DOE's Lawrence Livermore National Laboratory (LLNL) suggesting that radioactive materials should never be incinerated?
Answer D-4:
During the same PHAWG meeting in March 2004, a community member noted that DOE had previously reported that radioactive materials should never be incinerated. ATSDR obtained a copy of the report that appeared to form the basis for this comment (DOE 1990). The report evaluated whether DOE should install and operate an incinerator at LLNL to treat mixed LLW. After considering many factors, the authors of the report did in fact conclude that a new incinerator should not be constructed. It is important to note that the authors did not conclude that mixed LLW should never be incinerated; rather, the conclusion was that this incineration did not need to take place at LLNL, in part because these wastes could be shipped to other DOE installations that already have permitted incinerators.
Overall, the report that ATSDR obtained suggests that whether incineration is an appropriate waste treatment technology ultimately needs to be decided on a case-by-case basis. As stated earlier, the purpose of this PHA is not to enter into the debate on the utility of incineration, but rather to assess the public health implications of environmental releases specifically from the TSCA Incinerator.
Question D-5:
Is the white smoke in the incineration emissions harmful?
Answer D-5:
A major by-product of incineration processes is water. Because the stack gases at the TSCA Incinerator are typically at least 170 degrees Fahrenheit, some of the water in the air emissions exists as vapor. Once these gases come into contact with cooler ambient air, some water vapor condenses and becomes steam, which is visible. Of course, the incinerator emissions include trace amounts of other contaminants, as Section III of this PHA describes. Still, a large volume of measured and modeled data indicate that residents are not exposed to these chemicals at levels expected to cause adverse health effects.
Question D-6:
If most TRV events are caused by power outages, how does DOE collect air samples during these events?
Answer D-6:
The TSCA Incinerator and the off-site ambient air monitoring networks draw from different power sources. As evidence of this, valid air samples have been collected at the off-site monitoring network during several of the TRV events that were caused by power outages.
Health outcome data, or measures of disease occurrence in a population, can provide information on the general health status of a community. ATSDR scientists evaluate health outcome data in PHAs typically for one of two reasons: 1) to evaluate the possible health effects in a population that is known to have been exposed to enough environmental contamination to experience health effects or 2) to help address community concerns about a particular illness in a community. As the previous sections of this PHA have explained, ATSDR has found no evidence of residents being exposed to the TSCA Incinerator's emissions at levels of health concern. ATSDR found, however, ample evidence of general community health concerns regarding the TSCA Incinerator.
Epidemiological studies show that well-designed and properly operated incinerators generally can destroy wastes without presenting a substantial health risk to nearby residential populations. |
Over the past few decades, government agencies, academic researchers, and other parties have completed several epidemiological studies to evaluate incineration facilities. While none of the studies focused specifically on the TSCA Incinerator, the studies do provide useful perspective on environmental health issues at incineration facilities. The following paragraphs summarize two extensive literature reviews of selected, peer-reviewed environmental health studies on incinerators and related facilities. Occupational health studies are not considered below, but Section V provides some information on occupational health concerns associated with incineration facilities.
In summary, no researchers have conducted epidemiological studies of residents who live in the vicinity of the TSCA Incinerator. However, ATSDR's environmental health evaluations presented earlier in this PHA strongly suggest that such a study is not warranted, given that residents are not exposed to site-related contaminants at levels of health concern. Further supporting this conclusion are health outcome data suggesting that well-designed and properly operated incinerators — such as the TSCA Incinerator — can destroy wastes in a safe manner without compromising the health of local residents.
Because children often are at greater risk than adults of being exposed to toxic chemicals, and because 8% of the residential population within 3 miles of the TSCA Incinerator are children (age 6 year and under), ATSDR specifically considered children's health issues when preparing this PHA. Children are more likely than adults to suffer from adverse health effects due to environmental exposures for several reasons, such as:
Throughout the PHA process, ATSDR considered these and other children's health issues. For instance, when selecting health-based comparison values for the exposure evaluation, ATSDR identified, when available, comparison values protective of children's exposure and of health conditions more common in children, like asthma. As one example, ATSDR used EPA's air quality standards to screen air contamination levels for lead, ozone, and particulate matter. EPA developed these standards to protect the health of sensitive populations, including children.
Ozone and PM2.5 are general air quality issues for the Knoxville metropolitan area. This pollution is caused by numerous air emissions sources, both local and distant. Air emissions from the TSCA Incinerator appear to contribute little to the region's ozone and PM2.5 problems. |
ATSDR identified one environmental health issue of particular concern to children for this site: elevated airborne levels of ozone and fine particulates. Many children who live near the TSCA Incinerator, just like children who live in numerous urban and suburban areas across the country, have a greater risk of suffering from ozone- and particulate-related adverse health effects than do adults.
ATSDR's concern stems partly from the fact that ozone and PM2.5 levels are generally highest during the afternoon hours on sunny summer days, when most children are not in school and are likely to be playing outdoors. Another reason for concern is that people with asthma have been identified as a sensitive population for both ozone and PM2.5 exposure, and asthma is more prevalent among children than among adults (Mannino et al. 2002). Finally, children might not seek or understand information in important air quality forecasts. These factors are of concern because asthmatic children or children who engage in moderate to strenuous exercise (e.g., swimming and running) during poor air quality days are at risk for respiratory problems.
Fortunately, many resources are available to help prevent children from exposure to unhealthful levels of ozone and PM2.5. As noted earlier, TDEC issues air quality forecasts, and the local media usually broadcast them. Parents should encourage their children, especially asthmatic children, to play indoors on days when levels are predicted to be unhealthful. Further, EPA's Web site now includes a tremendous amount of information on ozone, PM2.5, and related air quality issues. Adults are encouraged to access this information, whether from their home computers or those at local libraries, at www.epa.gov/airnow. Additionally, EPA has recently launched a Web site that targets health-related air pollution information to children. The site, Air Quality Index for Kids!, is available in English and Spanish at www.epa.gov/airnow/aqikids.
ATSDR has reached the following conclusions regarding the TSCA Incinerator:
ATSDR recommends the following actions, either to provide greater confidence in this PHA's conclusions or to ensure that residents are not exposed to unhealthful levels of contaminants in the future. The recommendations are classified into two categories:
Public Health Recommendations
DOE, EPA, and TDEC should continue operating their routine ambient air monitoring networks at ETTP to measure metals and radionuclides — two groups of contaminants that the TSCA Incinerator does not destroy.
TDEC should continue to issue air quality warnings on days when ozone or fine particulate concentrations in the Knoxville metropolitan area are expected to reach potentially unhealthful levels.
Local residents should heed air quality warnings issued by TDEC, which typically encourage residents (especially children, the elderly, and those with respiratory conditions) to remain indoors and to avoid any moderate or strenuous exercise. It is especially important for parents to communicate these warnings to their children, who often either do not seek or do not understand information on air quality.
TDEC should independently verify the quality of DOE's ambient air monitoring data for metals. This can be done several ways, such as achieving lower detection limits in its metals monitoring network (particularly for arsenic, cadmium, and chromium), performing critical technical oversight of DOE's sampling and analytical procedures, or sending a small number of "split samples" from DOE's filters to an independent laboratory.
Recommendations to Help Improve Communications on Environmental Health Issues
Even though the TSCA Incinerator does not present a public health hazard, some community members remain very concerned about the site's air emissions. Providing the public with annual fact sheets summarizing environmental conditions at the TSCA Incinerator might help address these concerns. Accordingly, TDEC should issue annual fact sheets that document the environmental status of the TSCA Incinerator. The fact sheets should address issues such as inspection outcomes, regulatory compliance issues, and other important agency oversight activities.
After independently verifying the accuracy of DOE's ambient air monitoring data for metals, TDEC document its findings in its annual environmental monitoring reports. Any notable discrepancies should be documented and explained.
For purposes of transparency, both DOE and TDEC should improve the annual reporting on their environmental monitoring networks. Recommended improvements include identifying the specific sampling and analytical methods used, presenting the method detection limits, and better documenting data quality (e.g., completeness fractions, estimated measurement precision, and comments on measurement accuracy).
This Public Health Action Plan describes specific actions that have been taken, are scheduled to be taken, or should be taken by numerous parties, including ATSDR, DOE, EPA, and TDEC. The purpose of this plan is to document past public health activities and set priorities to ensure that ongoing operation of the TSCA Incinerator will not cause harmful human health effects to occur in the future. This plan addresses issues specific to the TSCA Incinerator — it does not consider the many other public health actions that pertain to the other ORR facilities.
Actions Completed
From 1991 to the present, DOE has completed several tests to measure emissions from the incinerator. ATSDR, an independent panel chartered by the Governor of Tennessee, and DOE have modeled how these emissions move through the air. DOE, EPA, and TDEC have conducted extensive ambient air monitoring to characterize the TSCA Incinerator's potential air quality impacts.
In June 1997, TDEC prepared a report titled Responses to the 101 Questions from Citizens Presented to the Tennessee Department of Environment and Conservation. The report addresses health, environmental, and operational concerns regarding the TSCA Incinerator.
In January 1998, an independent panel chartered by the Governor of Tennessee prepared a report that evaluated community health concerns related to the TSCA Incinerator.
In March 2004, ATSDR conducted a site tour of the TSCA Incinerator and presented preliminary information on this PHA to the Public Health Assessment Working Group.
Actions Ongoing
DOE, EPA, and TDEC continue to conduct ambient air monitoring near the TSCA Incinerator.
ORRHES continues to meet to provide a forum for communication and collaboration between citizens and the agencies that are conducting public health activities at ORR.
To fulfill permit renewal requirements, DOE has plans to prepare a human health risk assessment and ecological risk assessment of selected environmental releases from the TSCA Incinerator. Both risk assessments will be completed after environmental agencies approve DOE's written risk assessment plans.
Recommendations for Further Action
DOE, EPA, and TDEC should continue their routine ambient air monitoring for metals and radionuclides in the vicinity of the TSCA Incinerator.
TDEC should prepare annual fact sheets documenting the environmental status of the TSCA Incinerator. These fact sheets should address inspection outcomes, regulatory compliance issues, and other agency oversight activities. If requested, ATSDR will assist TDEC with preparing a visually appealing fact sheet for the first year, which will then be usable as a template in the future.
TDEC should independently verify the accuracy of DOE's ambient air monitoring data for metals. Once this is done, TDEC should summarize its evaluation in future annual environmental monitoring reports.
TDEC should continue to issue air quality warnings on days when ozone or fine particulate concentrations in the Knoxville metropolitan area are expected to reach potentially unhealthful levels.
Jack Hanley, M.P.H.
Environmental Health Scientist
Division of Health Assessment and Consultation
Agency for Toxic Substances and Disease Registry
Paul A. Charp, Ph.D.
Senior Health Physicist
Division of Health Assessment and Consultation
Agency for Toxic Substances and Disease Registry
John Wilhelmi, M.S.
Senior Chemical Engineer
Eastern Research Group, Inc.
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