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PETITIONED PUBLIC HEALTH ASSESSMENT

EGLIN AIR FORCE BASE
(a/k/a USAF EGLIN AIR FORCE BASE ARMAMENT DIVISION)
EGLIN AIR FORCE BASE, OKALOOSA COUNTY, FLORIDA


EVALUATION OF ENVIRONMENTAL CONTAMINATION, EXPOSURE PATHWAYS, AND PUBLIC HEALTH IMPLICATIONS (Cont.)

C. Concern: Groundwater Contamination at the C-6 Radar Facility

As stated previously, the C-6 Radar Facility was built in the mid-1960s and is located approximately 3 miles north of the town of Portland in an undeveloped section of Eglin AFB (Earth Tech 2000a; Eglin AFB 2000c). This area of Eglin Reservation is closed to the public and all recreational activities are prohibited (Eglin AFB 2000b). In addition, a barbed-wire fence and a locked gate restrict access to the site. The main facility is surrounded by a chain-link fence and is closely guarded (Earth Tech 2000a).

Monitoring wells were installed at the C-6 Radar Facility and the surficial aquifer was sampled several times between 1995 and 2000 (Earth Tech 2000a; Rust International 1996). While other volatile organic compounds and inorganics were detected, TCE is the primary contaminant of concern in the groundwater. During a 2000 site investigation (Earth Tech 2000a), the extent of the TCE contamination was defined to be entirely on Eglin AFB property. The nearest down- gradient drinking water wells are located off base, 3 miles south of the C-6 Radar Facility in the town of Portland, Florida. To ensure that the contamination does not migrate to areas where people are using groundwater wells, the Air Force is conducting annual long-term monitoring of the groundwater for chlorinated solvents (Earth Tech 2000a). Eglin will continue to sample at the C-6 Radar Facility until the Florida Maximum Contaminant Level for TCE (3 ppb) or lower is achieved. Eglin anticipates that long-term monitoring will continue for about five more years because current sampling results show TCE levels to be in the 4-5 ppb range (personal communication with Eglin AFB personnel, July 2002). Because access to the site is restricted and the groundwater contamination is closely monitored and does not extend into the nearest residential area, it is not expected that past, present, or future public health hazards occurred, are occurring, or will occur.

D. Concern: Herbicide Contamination

To address whether contact with herbicides is a health concern, ATSDR obtained information that characterizes the nature and extent of contamination and the potential for human exposure at areas with herbicide contamination. See Figure 2 for site locations. ATSDR evaluated the potential for the herbicides to move off-base via fires, spraying, and surface waters in previous sections. See also Section III. Community Concerns for additional information specific to Herbicide Orange and exposure at Eglin AFB.

In 1992, the Air Force conducted a base-wide investigation into all known and suspected Herbicide Orange locations at Eglin AFB (Engineering-Science 1993). Eleven sites were identified for further investigation: C-52A Test Grid (SS-25), Mullet Creek Drum Disposal Site (DP-09), C-52A Aerial Overspray Area (AOC-24), Hardstand 7 (SS-26), Receiver Landfill (LF-08), Upper Memorial Lake (LF-51), 3 sites at Lower Memorial Lake (AOC-81), Field No. 2 Drum Disposal (DP-11), and Field No. 2 Helicopter Loading Area (AOC-55). Of these, seven sites (Mullet Creek Drum Disposal Site, Receiver Landfill, 3 sites at Lower Memorial Lake, Field No. 2 Drum Disposal, and Field No. 2 Helicopter Loading Area) required No Further Action because herbicide contamination was not detected. Further investigation was recommended for three sites (C-52A Test Grid, C-52A Aerial Overspray Area, and Upper Memorial Lake), and remedial actions were recommended for Hardstand 7 (Engineering-Science 1993). See Figure 2 for site locations.

Access to the Herbicide Exposure Unit, the C-52A Aerial Overspray Area, and Hardstand 7 has been, is, and will continue to be restricted by locked gates, fences, security personnel, topography, or all these combined. Therefore, human exposure is unlikely to occur. In addition, in 1988, 1996, and 2001, Eglin AFB conducted remedial activities to remove, contain, or both, the contamination that was formerly present at the Mullet Creek Drum Disposal Site (included within the Herbicide Exposure Unit) and Hardstand 7. Thus, if people had been exposed, the levels would be very low. These sites pose no public health hazard.

Even though trace concentrations of TCDD were detected in the subsurface soil at Upper Memorial Lake, people who have access to the area would have minimal contact with subsurface soils, since Eglin AFB has implemented land use controls to minimize exposure. Therefore, this site also poses no public health hazard.

Together, the C-52A Herbicide Test Grid and the Mullet Creek Drum Disposal Site are known as the Herbicide Exposure Unit. The sites are located in a rural area in the southeastern section of the Eglin Reservation, about 3 miles north of Choctawhatchee Bay and 8 miles east of Niceville, Florida, see Figure 2 (Eglin AFB 2001a). The C-52A Herbicide Test Grid is located about 10,930 feet from the nearest base boundary. The Mullet Creek Drum Disposal Site is located about ½ mile west of the C-52A Herbicide Test Grid (about 10,230 feet from the nearest [i.e., southern] base boundary).

Access to the Herbicide Exposure Unit is extremely limited due to steep topography, dense vegetation, and locked gates. In addition, the area is highly controlled by security personnel who patrol the area (Eglin AFB 2001a). Therefore, there is, has been, and will continue to be minimal contact with contamination at the Herbicide Exposure Unit. The Air Force recommended No Further Investigation Required with land use controls to restrict exposure to the area (e.g., signs are posted to not disturb the surface soil).

The C-52A Aerial Overspray Area is in the vicinity of the Herbicide Exposure Unit. According to witnesses, when climatic conditions were not appropriate for aerial spraying at the Herbicide Exposure Unit, aircraft would spray the already-loaded herbicides in this area (Hutto 1990; Ray 1990 as cited in Engineering-Science 1993). How often this occurred and what amount of herbicides were sprayed is not known (Eglin AFB 2000c). Based upon evaluations of the soil, sediment, biota, and groundwater, TCDD and arsenic in the soil are the primary contaminants (Engineering-Science 1993). Like the Herbicide Exposure Unit, access to this area is also controlled and well patrolled by security personnel (Engineering-Science 1993). Therefore, there is, has been, and will continue to be minimal contact with contamination at this site. In 1998 and 1999, No Further Action was approved by FDEP and EPA, respectively (Eglin AFB 2000c).

Upper Memorial Lake is located on Eglin Main Base south of the east-west runway. A site north of the lake was identified as a former burial area used to dispose of herbicide drums, many of which were empty (Engineering-Science 1993). However, trace concentrations of TCDD were detected in the subsurface soil (Engineering-Science 1993). Recreational facilities are located nearby and base personnel and their families have easy access to the area (ES 1990b as cited in Engineering-Science 1993). However, herbicides were not detected in the surface soil and Eglin AFB has implemented land use controls (e.g., signs are posted and a layer of clean soil was placed over the site) and erosion control measures to lessen any potential for exposure to herbicides (personal communication with Eglin AFB personnel, October 2002). Therefore, there is, has been, and will continue to be minimal contact with contamination at this site.

Hardstand 7 is a concrete and asphalt aircraft parking and loading area located west of the north-south runway on Eglin Main Base, see Figure 2 (Eglin AFB 2000c; Engineering & Services Laboratory 1987). About 7,300 feet separate the site from the nearest non-base residence (on the southern side of Tom's Bayou). The site is about 130 feet in diameter with a 15-foot deep pit near the center of the concrete pad. Hardstand 7 was used to store herbicide drums and to transfer herbicides to the aircraft used to evaluate the effectiveness of different aerial spray patterns and spray equipment on the C-52A Herbicide Test Grid (Eglin AFB 2000c). Since 1970, the Air Force has conducted several site investigations to characterize the soil, water quality, and biota in the vicinity of Hardstand 7. Herbicides and dioxins in the soil, sediment, surface water, and groundwater are the primary contaminants at this site (Eglin AFB 2000c).

In 1985, the site was secured with a chain-link fence and locked gates, and signs were posted to prevent trespassing and fishing (Eglin AFB 2000c). In addition, because of its close proximity to active runways, the area is closely guarded (Earth Tech 2001c). In 1996, the Air Force conducted interim corrective measures at Hardstand 7, including embankment stabilization, drum excavation, and drain pit excavation. In 2001, the Air Force installed three erosion control structures to reduce erosion around the hardstand and to minimize storm water run-off into Hardstand Pond. In addition, an asphalt cap was installed over contaminated areas of Handstand 7 and the existing storm water pipe was checked for blockage and integrity (Eglin AFB 2002). Therefore, there was, is, and will continue to be minimal contact with contamination at Hardstand 7.

The current status of Hardstand 7 is that a Statement of Basis is in draft form. A Statement of Basis is the RCRA version of the Record Decision Document required in CERCLA clean ups. The Statement of Basis proposes that the site be maintained in its present condition with land use controls maintained permanently (personal communication with Eglin AFB personnel, July 2002).

E. Concern: Radioactive Contamination

To address this concern, ATSDR reviewed information characterizing the nature and extent of contamination and the potential for human exposure at four areas with past and/or present radioactive contamination: the Isotope Burial Area (AOC-63)/C-74 Sled Track Burial Area (AOC-67), Test Area C-64 (RW-40), Test Area C-74L (RW-41), and the Low-level Radioactive Waste Site/Drum Burial (RW-42). See Figure 2 for site locations.

ATSDR determined that human exposure to radioactive contamination at levels of health concern is unlikely at the Isotope Burial Area/C-74 Sled Track Burial Area, Test Area C-64, and Test Area C-74L. This is because access to the sites is restricted by locked gates, fences or barbed wire, security guards, or all of these. Moreover, remedial activities have removed or lessened radiation that was once present. Therefore, no past, present, or future public health hazard exists.

ATSDR determined that the Low-level Radioactive Waste Site/Drum Burial site poses no public health hazard. There was no indication of radioactive contamination or levels of radiation in excess of local and regional background levels. Although access is restricted, the Low-level Radioactive Waste Site is not fenced and trespassing by boat from the Gulf of Mexico or Santa Rosa Sound could occur. However, trespassers would not be expected to be exposed to levels of radioactive contamination that would cause harmful health effects.

AOC-63 and AOC-67 are considered one site. This inactive burial area is located north of the C-74 Complex, near a 2,000-foot sled track in an isolated area of the base where access was, is, and will continue to be restricted (see Figure 2). The site is fenced and locked with a sign posted to warn people that this is a controlled area. It is located about 15,200 feet (roughly 2¾ miles) from the nearest base boundary (Eglin AFB 2001b). Because this site is in a remote location and is not accessible to people, human exposure is minimal.

The amount of time required for ½ of the atoms of a radionuclide to decay is called its radioactive half-life.The burial area was created in 1960 to dispose of Zinc 65, which was used on bullets during a test project. Reportedly, a small quantity of Zinc 65 was buried at the site as late as the early 1970s (Eglin AFB 2000c). Zinc 65 has a half-life (see text box for definition) of 244 days and decays to a non-radioactive form of copper. Over 30 years has passed since Zinc 65 was disposed of in the burial area; therefore, Zinc 65 would have decayed through approximately 45 half-lives and would no longer be detectable in the burial site. Even if migration from the burial pit occurred, the Zinc 65 would no longer be present. An investigation in the early 1990s monitored for radiation and concluded that there was no radiation hazard (Eglin AFB 2000c). The AOC files are closed and a determination of No Further Action has been approved by the regulatory authorities.

Because there is minimal human exposure, no detectable radiation present above background levels, and the Zinc 65 has totally decayed, ATSDR does not expect that past, present, or future public health hazards occurred, are occurring, or will occur from exposure to radiation at the Isotope Burial Area/C-74 Sled Track Burial Area.

Test Area C-64 is about 14 miles northeast of Eglin Main Base in the northeastern section of the Eglin Reservation, see Figure 2 (Earth Tech 2001d). The nearest base boundary is about 16,700 feet (roughly 3 miles) from the site (Eglin AFB 2001b). Since 1968 the site has been used for small-scale explosive tests, drop tests, bullet impact tests, and DU ammunition tests (Earth Tech 2001d; Eglin AFB 2000c). The site is currently fenced and locked to prevent access, with a sign posted to warn people that this is a controlled area. Therefore, people were not and are not expected to come in contact with radioactive contamination present at this site.

Test Area C-64 is part of an ongoing base-wide radiological survey with quarterly monitoring of the groundwater, soil, and runoff. This has been done since operations began (Eglin AFB 2000c). Uranium in soil and surface water has been the primary radiological material detected at this area (Eglin AFB 2000c). Several samples showed levels of uranium exceeding background levels; but, the overall trend in Test Area 64 has shown the uranium in soils to be below regulatory concern. The Air Force removed depleted uranium fragments in 1999, and 24 cubic feet of depleted uranium-contaminated soil in 2000 (Earth Tech 2001d; Eglin AFB 2000c). No Further Investigative Action is recommended for the site. Land use controls will, however, be implemented to limit the future use of Test Area C-64 to industrial activities (Earth Tech 2000b).

Public access is and has been restricted and remedial activities recently removed contamination. Therefore, it is not expected that past, present, or future public health hazards occurred, are occurring, or will occur from exposure to DU at Test Area C-64.

Test Area C-74L is in the northeastern section of Eglin AFB in an isolated area where access is restricted, see Figure 2. The test area is fenced and locked with a sign posted to warn people that this is a controlled area. The site is located about 18,000 feet (roughly 3½ miles) from the nearest base boundary (North to I-10 boundary). From the mid to late 1970s, a 3-acre area within Test Area C-74L was used to test penetrating munitions containing DU, resulting in contaminated soil and surface water (Eglin AFB 2000c).

Test Area C-74L is part of an ongoing base-wide radiological survey with regular radionuclide monitoring in the soil and runoff. The results of the analyses have been below regulatory concern (Eglin AFB 2000c). In 1980, the Air Force removed soil contaminated with DU and, in 1999, removed and disposed of uranium penetrator fragments off site (Eglin AFB 2000c). Because some soils are still contaminated with DU, additional excavation has been recommended.

Because DU-contaminated soil remains at the site, public access has been and continues to be restricted; hence, people are not coming in contact with the remaining contamination. Therefore, it is not expected that past, present, or future public health hazards occurred, are occurring, or will occur from exposure to DU at Test Area C-74L.

The Low-level Radioactive Waste Site is located near the center of Santa Rosa Island, west of the A-15 compound, see Figure 2 (CH2MHILL 2000). The site is located about 7,000 feet (across the Santa Rosa Sound) from the nearest base boundary. The site was used to dispose of missile fragments, metallic wastes, 55-gallon drums, and batteries (Eglin AFB 2000c). Inorganic compounds and dieldrin are the primary contaminants detected at the site. In 1993, 1995, and 1999 surface and radioactive debris, missile fragments, drums, and petroleum-contaminated soils were removed from the site, and the site has been recommended for No Further Action (CH2MHILL 2000; Eglin AFB 2000c).

Access to the site is highly restricted–it is located on Santa Rosa Island about 12 miles west of the main access road where an armed guard and barbed wire prohibit entrance to unauthorized personnel (Eglin AFB 2000b). Nevertheless, although no trespassing signs are posted on the property, there are no fences to prevent people from entering the area by boat from the Gulf of Mexico or the Santa Rosa Sound (O'Brien & Gere Engineers 1997).

The site also contains wastes associated with a BOMARC missile which contained a magnesium-thorium alloy. Thorium is a naturally occurring radioactive element; but, the radiation levels associated with thorium are very low and the health threat is only from ingestion or inhalation of thorium. After an intensive search and retrieval program in 1993, the Air Force located many of the magnesium-thorium components, packaged them in approved shipping containers, and shipped them off site (Rust Remedial Services 1993). Although not all the components were found, radiological sampling indicates that migration of the radiological components did not occur, nor is it expected to occur in the future.

Even though this site is not fenced and people could trespass onto the property by boat from the Gulf of Mexico or the Santa Rosa Sound, trespassers would not be expected to be exposed to levels of contamination for a long time nor on a regular basis. Therefore, because exposure is possible, but the frequency and duration is minimal, exposure to radioactive contamination at the Low-level Radioactive Waste site poses no past, present, or future public health hazard.


III. COMMUNITY CONCERNS

A. Community Concerns Regarding Herbicide Orange

What is Herbicide Orange?

Herbicide Orange (also known as Agent Orange) is a 50:50 mixture of 2,4-dichlorophenoxyacetic acid (2,4-D) and 2,4,5-trichlorophenoxyacetic acid (2,4,5-T) (HSDB 2002a, 2002b). It is a reddish-brown to tan colored liquid, and was named after the orange stripe on the 55-gallon drum in which it was stored. Herbicide Orange was sprayed from airplanes, helicopters, trucks, and backpacks in Vietnam from 1965 to 1970 to kill unwanted plants and remove leaves from trees (VA 2001, 2002). Use of 2, 4, 5-T is currently restricted in the United States (ATSDR 1998).

During the manufacturing process of 2,4,5-T, a contaminant 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD) was produced in small quantities (ATSDR 1998). Many of the health effects resulting from exposure to Herbicide Orange are attributed to the presence of this contaminant. Many effects have been observed in animals following exposure to TCDD, and this contaminant is considered more toxic than the pure components of the herbicides used in Vietnam (NAS 2000).

How are people exposed to Herbicide Orange?

Workers who were involved with the manufacture of Herbicide Orange were exposed through breathing contaminated air or through skin contact. To a lesser extent, workers who handled and applied Herbicide Orange were also exposed (ATSDR 1998). Vietnam veterans who were directly involved in the aerial spraying of Herbicide Orange as part of Operation Ranch Hand and veterans in the Army Chemical Corps (responsible for mixing, storing, and applying Herbicide Orange) are the two primary groups with increased Herbicide Orange exposure. However, despite many years of effort, researchers have been frustrated by a lack of useful exposure data (VA 2002). In other words, they do not know how much Herbicide Orange the veterans were exposed to and how long the exposure lasted.

What health effects could result from exposure to Herbicide Orange?

The National Academy of Science's Institute of Medicine concluded that there is sufficient evidence(9) of an association between the following health outcomes and exposure to herbicides (not specifically Herbicide Orange): chloracne, soft tissue sarcoma, non-Hodgkin's Lymphoma, and Hodgkin's Disease (NAS 2000 as cited in VA 2002). The Department of Veterans Affairs recognizes the following conditions as associated with (but not necessary caused by) Herbicide Orange exposure: chloracne, porphyria cutanea tarda, acute or subacute peripheral neuropathy, type 2 diabetes, and certain cancers (VA 2001).

How was Herbicide Orange used at Eglin AFB?

Several locations on Eglin AFB were used for the distribution, loading, storage, and disposal of herbicides; primarily to test different applications and the effectiveness of herbicides used as defoliants during the Vietnam Conflict (Engineering-Science 1993):

In 1992, the Air Force conducted a base-wide investigation into all known and suspected Herbicide Orange locations at Eglin AFB (Engineering-Science 1993). Eleven sites were identified for further investigation: C-52A Test Grid (SS-25), Mullet Creek Drum Disposal Site (DP-09), C-52A Aerial Overspray Area (AOC-24), Hardstand 7 (SS-26), Receiver Landfill (LF-08), Upper Memorial Lake (LF-51), 3 sites at Lower Memorial Lake (AOC-81), Field No. 2 Drum Disposal (DP-11), and Field No. 2 Helicopter Loading Area (AOC-55). At seven sites (Mullet Creek Drum Disposal Site, Receiver Area Landfill, 3 sites at Lower Memorial Lake, Field No. 2 Drum Disposal, and Field No. 2 Helicopter Loading Area) herbicide contamination was not detected. Further investigation was recommended for three sites (C-52A Test Grid, C-52A Aerial Overspray Area, and Upper Memorial Lake), and remedial actions were recommended for Hardstand 7 (Engineering-Science 1993). These four sites are described in more detail in the Herbicide Concern discussion, within Section II of the PHA.

Have community members been exposed to Herbicide Orange from Eglin AFB?

No, community members do not have access to areas on Eglin AFB where Herbicide Orange was tested or stored. Therefore, the only way for community members to be exposed to Herbicide Orange would be if it were transported through the air or through surface waters to places where people live or engage in recreational activities.

In conclusion, even though Herbicide Orange was, and still is, present at Eglin AFB, community members were not in the past, are not currently, and are not expected to be in the future exposed to levels of Herbicide Orange that would cause harmful health effects.

B. General Community Concerns

Could chemicals from Eglin AFB cause cancer in community members living near and using Tom's Bayou for recreational activities?

No. ATSDR did not find contaminant levels in the exposure situations evaluated that would be associated with high cancer rates or any other adverse health effect. To provide some perspective on the actual incidence rate for the county, ATSDR contacted the Florida Cancer Data System and requested cancer statistics (specifically, Hodgkin's Lymphoma) for the entire state of Florida and Okaloosa County, the county in which Tom's Bayou is located. The age-adjusted cancer incidence for Okaloosa County (2.1) was lower than that for the state of Florida (2.6).

Should I be concerned about exposure to radionuclides if I consume venison caught in the vicinity of the Eglin Reservation?

No. Although 65% of the base is open to the public for various recreational activities such as hunting, information about the levels of radionuclide contamination in deer or other game animals has not been collected in the area of Eglin. The DU used at the base is generally in the form of an oxide, which is not readily soluble in water nor easily absorbed by plants, animals, or humans. The DU could, however, adhere to soil particles and thus move through the environment. Nonetheless, plants do not readily absorb uranium. Studies suggest that the typical uptake is on the order of 1% or less (Eisenbud and Gesell 1997). If deer ate plants that contained DU, ATSDR estimates that the deer would absorb about 2% of the ingested uranium through their gastrointestinal system. The DU absorbed would be stored in the organs (kidney, liver, and bone) with little (based on laboratory animal studies) in the soft tissues a few days after intake. Similarly, if humans ingested venison that had previously ingested DU, the humans would only absorb 2% of the DU in the venison (less than 0.04% of the amount in the plants and less than 0.0004% of the concentration in soils). Therefore, ATSDR considers the venison caught in the vicinity of the Eglin Reservation safe to eat.

Could biological agents tested or researched at Eglin still be active given the treatment and disposal conditions and could a release of agents have occurred given the abrupt termination of that project?

ATSDR accompanied a biological agent expert from the Centers for Disease Control and Prevention to Eglin on December 17, 2002 to review documents classified and unclassified documents and to provide an opinion on some biological events that occurred intermittently from the 1950s through the 1960s on the airbase. This review was to determine the extent to which any purported release of biological agents would have impacted the surrounding community and if a health threat remained from early test activities. The review consisted of both classified and unclassified documents indicating that biological agents had, indeed, been evaluated on site in the mid-1950's and 1960's.

The classified documents reviewed showed that biological agents tested or researched at Eglin were not released and were destroyed after use so the potential for adverse health impacts on any surrounding communities resulting from the biological work at Eglin is negligible. Agents present at Eglin during this period were not developed or manufactured on base, nor did manipulation or research into whether the biological agents could cause disease take place. Any tests using human biological agents were done in sealed containers and those containers were adequately disinfected and sterilized to destroy all agents. Any tests using non-human biological agents were conducted in a localized area on base that was thoroughly disinfected at the end of the tests.

Biological agent - "Living organisms, or the materials derived from them, that cause disease in, or harm, humans, animals, or plants, or cause deterioration of material."

Simulant - "A chemical that appears and acts like an agent."

C. Public Comments Received During the Public Comment Period

Comment 1

Such vocabulary as "might, should, assumptions, and not expected" leads the reader to question the validity of the conclusions. It makes the reader feel that the degree of confidence with regard to the study's conclusions is rather low.

ATSDR has used the most recent up-to-date body of scientific evidence on which to make conclusions about the contaminants found at Eglin and the off-base vicinity. This information is used to discuss the public health implications of coming in contact with those chemical at the levels detected.

Our knowledge about how hazardous substances interact with the human body is science-based, and it has been obtained from a variety of sources. Such sources include (a) studies of populations who have been exposed to a substance or substances to define and understand short- and long-term health effects and (b) drawing conclusions, on the basis of animal studies and other research, about the possible effects of human exposure to hazardous substances. The medical and scientific communities use this information to identify the general levels of exposure at which a health effect might be seen.

It is important, however, to keep in mind that a number of factors are involved in human health. For example, each individual has a unique genetic makeup, a different overall health status, and different levels and lengths of exposure to the substance over a lifetime. Therefore, we cannot be 100% certain that a given person exposed to a certain substance will have a specific health outcome. Consequently, we must qualify our language to account for the unique characteristics of each human being and the unknown factors associated with exposures.

Also, our scientific judgments are influenced by the number of human and animal studies available on any specific toxicant, which varies, as well as by the quality of such studies, which also varies. We are more definitive when we have many studies that are well designed. We are more tentative when we have fewer and/or poorer quality studies.

With regards to Agent Orange - or Herbicide Orange, there have been many studies on the health effects since the Vietnam war. Human exposure to levels much greater than was possible at Eglin have not been shown to cause lymphomas (Hodgkin's or non-Hodgkin's).

Comment 2

The age-adjusted cancer incidence for Okaloosa County (2.1) was lower than that for the state of Florida (2.6). The question is not about the incidence of cancer for Okaloosa County, but rather, the incidence of cancer for Tom's Bayou residents.

A review of the cancer incidence for any given area is an epidemiological evaluation involving statistics. Because of this limitation, conclusions are more definitive when there are larger numbers of people included. The state of Florida maintains the cancer registry information. Because of the low population of the area around Eglin, the people living in Tom's Bayou are included in the cancer information for the whole county. The information is not available for the street or even the block level at this time. Therefore, we are limited by the information that is available. In this case, the information is based on people living near Eglin who may be exposed mixed with information of people who do not live near Eglin and are not exposed.

After our review of the areas that are contaminated on and off the Eglin AFB, and the ways in which people could come in contact with possible contaminants, ATSDR determined that levels of contaminants from Eglin that could have impacted the Tom's Bayou residents are not at levels that have been shown in scientific studies to cause adverse health effects.

Communities that are interested in collecting their own epidemiological information based on acceptable scientific protocol can use a survey designed for such a purpose. In this way, citizens can go door to door to survey all the residents in a particular area of concern. Information collected can then be evaluated. ATSDR will provide information about such an approach to the person who made this comment.

Comment 3

Herbicide Orange is extremely dangerous. The wording [below] sounds as if the author is dismissing the eye witness account of the community member in favor of the lack of Air Force documentation.

Not at all. The comments made by community members help ATSDR investigate areas often times not included in the military's environmental program, as is the case with this pond. However, the lack of documentation and inclusion in the environmental program limits the ability of ATSDR to evaluate laboratory data on contaminants and levels detected. Therefore, ATSDR must pull scientific information of environmental and human health impacts based on other areas that have been studied. Because this pond is not an area where people would have easy access and constant contact with possible contaminants present, any exposure to adults and children would be intermittent and infrequent. Thus, infrequent contact would mean that exposure would be less than people who worked with the chemicals on a daily basis. ATSDR used information based on worker exposures and accidental exposures to the highly concentrated chemical mixture. We determined that exposures to the off-base residents who visited this pond would be much lower and infrequent than exposures of workers and thus not expected cause adverse health effects.

From the body of the public health assessment: "An unnamed pond near the North Gate of Eglin Main Base is in a remote area with limited accessibility (e.g., access roads are not maintained), about 2,000 feet from the nearest non-base resident (Eglin AFB 2001b). A community member was concerned that Herbicide Orange was present in the pond. About 20 years ago, the community member would ride a horse from the stable to the pond and reported seeing a sign that warned of Herbicide Orange contamination. The Air Force has no records of ever placing a sign at this unnamed pond and the sign is no longer present. There are no historical Air Force documents that indicate Herbicide Orange was ever present at this pond (personal communication with Eglin AFB personnel, April 2002).

If Herbicide Orange was present, people would need to have contact with either the surface water or sediment in the pond to be exposed (e.g., either through touching the water or sediment or drinking water from the pond). If people are not being exposed, no harmful health effects can occur. Currently, there is no fence surrounding the pond or preventing access to the pond. A private off-base riding stable in Valparaiso, Florida is about 450 to 600 feet from the unnamed pond. The area between the stable and the pond is currently filled with building rubble, which severely limits access to the pond.

This unnamed pond is not an ideal location for recreational activities (e.g., swimming). Therefore, it is unlikely that anyone actually had contact with potential contamination in the pond, even in the past when people reportedly rode their horses to it. Because access to the pond is currently limited, there is a low chance that anyone is or will be exposed to high levels of contamination for a long time and on a regular basis. Consequently, harmful health effects are not expected to occur."


IV. CHILDREN'S HEALTH CONSIDERATIONS

ATSDR recognizes that infants and children can be more sensitive to environmental exposure than adults in communities faced with contamination of their water, soil, air, or food. This sensitivity is a result of the following factors: 1) children are more likely to be exposed to certain media (e.g., soil or surface water) because they play and eat outdoors; 2) children are shorter than adults, which means that they can breathe dust, soil, and vapors close to the ground; and 3) children are smaller; therefore, childhood exposure results in higher doses of chemical exposure per body weight. Children can sustain permanent damage if these factors lead to toxic exposure during critical growth stages. As part of the ATSDR Child Health Initiative, ATSDR is committed to evaluating the special interests of children at sites such as Eglin AFB.

ATSDR evaluated the likelihood that children living near Eglin AFB could have been or could be exposed to contaminants at levels of health concern. ATSDR did not identify long-term situations in which children were expected to be or have been exposed to chemical contaminants at levels that pose a health concern. Short-term health effects are possible on rare occasions when winds blow smoke plumes from prescribed burns and wildfires directly toward residential neighborhoods. If, however, harmful health effects occur, they are typically reversible and subside after the fires are extinguished.


V. CONCLUSIONS

Based on an evaluation of environmental information, ATSDR has reached the following conclusions:

  1. Air Contamination Concern: It is not expected that in the past, present, or future, off-base residents could be exposed to air contaminants emitted from Eglin AFB often enough or in high enough doses to be of health concern from previous herbicide and pesticide spraying activities, current OB/OD operations, and a past structural fire at the C-6 Radar Facility. These exposures pose no apparent public health hazard. 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 (see Appendix A for ATSDR's Conclusion Categories).
  2. Prescribed burning and wildfires could pose a past, present, and future public health hazard. Our findings indicate that the contaminants in soils (herbicides, including Herbicide Orange) would not reach off-base areas at levels associated with harmful health effects. Therefore, off-base residents would not come in contact with those contaminants. However, the burning of plant material causes a release of particles and natural chemicals (smoke) that could cause some short-term adverse health effects in those people exposed. Health effects could include burning, itching or watery eyes and sinuses, headache, nausea, breathing difficulty and asthma-like symptoms. Individuals highly sensitive to the effects would be anyone with previous respiratory conditions such as asthma or emphysema, children, and the elderly. But any health effects would only be of short duration, developing within a few days of exposure and lasting no more than 2 or 3 weeks after exposure stopped.

    ATSDR does not consider the presence of depleted uranium in soils to be a concern during either wildfires or prescribed burning in the area. Depleted uranium would not be an airborne contaminant from the burning of plant material since plants have a minimal uptake of uranium from soil.

  3. Surface Water Contamination Concern: It is not expected that in the past, present, or future, people could be exposed to contamination in surface water, sediment, or fish in Tom's Bayou; Weekly Pond; Pocosin Pond; Mullet, Trout, and Basin Creeks; and an unnamed pond near the North Gate of Eglin Main Base often enough or at high enough doses to be of health concern. These surface water bodies pose no apparent public health hazard. Information on the unnamed pond near the North Gate could not confirm whether it might have contained Herbicide Orange.


  4. Groundwater Contamination Concern: It is not expected that in the past, present, or future, people could be exposed to groundwater contamination originating from the C-6 Radar Facility on Eglin AFB. To ensure that the contamination from the C-6 Radar Facility does not migrate to areas where people are using groundwater wells, the Air Force conducts long-term monitoring of the groundwater at the site on an annual basis. This site poses no public health hazard.


  5. Herbicide Contamination Concern: It is not expected that in the past, present, or future, people could be exposed to herbicide contamination on Eglin AFB often enough or in high enough doses to be of health concern. Human exposure is minimal because access to the Herbicide Exposure Unit (DP-09 and SS-25), the C-52A Aerial Overspray Area (AOC-24), and Hardstand 7 (SS-26) is restricted by locked gates, fences, security personnel, and topography. Therefore, there is a low chance that anyone would be exposed to herbicide contamination present at these sites. In addition, remedial activities have removed or contained, or both, the contamination that was formerly at Mullet Creek Drum Disposal Site (DP-09) and Hardstand 7. Therefore, these sites pose no past, present, or future public health hazards.
  6. Even though people have access to Upper Memorial Lake (LF-51), the nearby herbicide contamination was detected in the subsurface soil, and contact with subsurface soil would be minimal since Eglin AFB has implemented land use controls to minimize exposure. Therefore, this site poses no apparent public health hazard.

  7. Radioactive contamination Concern: It is not expected that in the past, present, or future, people could be exposed to radioactive contamination on Eglin AFB often enough or in high enough doses to be of health concern. Human exposure is minimal because access to the Isotope Burial Area (AOC-63/AOC-67), Test Area C-64 (RW-40), and Test Area C-74L (RW-41) is restricted by locked gates, fences, and/or security guards. Therefore, it is not expected that community members would be exposed to radioactive contamination present at these sites. In addition, remedial activities have removed or reduced radioactive contamination that was once present. Thus, these sites pose no public health hazard.
  8. Although trespassing can occur at the Low-level Radioactive Waste Site (RW-42), the levels of radioactive contamination present are too low to be of health concern for this type of exposure (i.e., of short duration). Thus, this site poses no apparent public health hazard.



VI. PUBLIC HEALTH ACTION PLAN

The public health action plan for Eglin AFB contains a description of actions taken at the base and those to be taken at the base subsequent to the completion of this public health assessment. The purpose of the public health action plan is to ensure that this public health assessment not only identifies potential and ongoing public health hazards, but also provides a plan of action designed to mitigate and prevent adverse human health effects resulting from exposure to harmful substances in the environment. The following public health actions at Eglin AFB are completed, ongoing, planned, or recommended:

Completed Actions

Ongoing Actions

Planned Actions

Recommended Actions

  1. Despite the low risk of long-term health effects from exposure to smoke from prescribed burns, Eglin AFB should continue to notify residents, especially sensitive populations, when the prescribed burns are scheduled, so these individuals can take measures to reduce their short-term exposure.

PREPARERS OF REPORT

Monica Booker, MPH
Environmental Health Scientist
Federal Facilities Assessment Branch
Division of Health Assessment and Consultation

Carole D. Hossom
Environmental Health Scientist
Federal Facilities Assessment Branch
Division of Health Assessment and Consultation


CONTRIBUTORS

J. Michael Miller, Ph.D., (D) ABMM
Chief, Laboratory Response Branch
Bioterrorism Prepardness and Response Program, National Center for Infectious Disease
Centers for Disease Control

Amanda Dunnick, MPH
Health and Safety Officer
Office of the Assistant Administrator
Program Operations and Management
Program Analysis Branch

Paul A. Charp, Ph.D.
Senior Health Physicist
Federal Facilities Assessment Branch
Division of Health Assessment and Consultation

Michelle Arbogast, MS
Environmental Scientist
Eastern Research Group


REVIEWER

Wallace Sagendorph
Writer-Editor
Office of Policy and External Affairs


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9 Sufficient evidence means that the evidence is sufficient to conclude that there is a positive association (i.e., a positive association has been observed between herbicides and the outcome in studies in which chance, bias, and confounding could be ruled out with reasonable confidence).
10 The estimated exposure doses were calculated using the maximum soil concentration for the sum of all dioxin compounds using the formula D = [C x IR x EF]/[BW] (see Appendix B for more details).

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