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PETITIONED PUBLIC HEALTH ASSESSMENT ADDENDUM

SOUTHERN WOOD PIEDMONT
AUGUSTA, RICHMOND COUNTY, GEORGIA



APPENDIX 4 - REPONSES TO PUBLIC COMMENTS

COMMUNITY CONCERNS
OVERVIEW

I. CURRENT EXPOSURE

  1. Safety
    1. Current Contamination
      1. Ditches
      2. Other Questions About Sampling
    2. Health Effects From Current Situation
    3. Relocation and Other Protective Actions
  2. Completeness and Quality of Data
    1. Competing Interests
    2. Specific Studies
      1. Dever/Mercer Report
      2. Extension Service Report
      3. Geraghty and Miller Report
      4. Cox-Manning Report
    3. Health Assessment Process
      1. Standard Procedures
      2. SWP as Source of Contamination

II. PAST EXPOSURE

  1. Extent of Past Contamination
  2. Exposure Pathways
  3. Assumptions and Predictions About Health Effects
  4. Health Effects

III. FUTURE PUBLIC HEALTH ACTIONS

OVERVIEW

The questions from the community fall into three major areas of health concern: current exposure, health effects of past exposure, and future public health actions. Our reassessment of the Southern Wood Piedmont (SWP) site has led to these main conclusions concerning the public health impact of the site:

CURRENT EXPOSURE: The community is probably not being currently exposed to contamination from the site. Although community members continue to have concerns about exposure, current data do not indicate that air quality, soil contamination, or flooding pose health problems for the public. Now that SWP is no longer in operation and alternative water supplies have been provided, there is no longer a public health hazard for neighborhoods surrounding this site.

PAST EXPOSURE: People in the surrounding community were exposed to contamination from the site in the past. Although we will not be able to assess exact levels of exposure, it is possible that people could have been exposed at doses that could cause adverse health effects.

However, we would like to emphasize the following point about the health implications of past exposure: Skin is the target organ for most of the contaminant exposures we have identified. Skin is fairly easily monitored, either by self-monitoring or by physician monitoring, so early detection of disease is possible.

FUTURE PUBLIC HEALTH ACTIVITIES: Health problems that may have been caused by past exposure are the focus of our future health actions as an agency. In particular, a program has been identified to help the Richmond County Health Department educate local health care providers and provide medical testing and physicals to concerned residents. Implementation will depend on further clarification from Congress.

I.    CURRENT EXPOSURE

A.    SAFETY

ATSDR staff members think that no exposure is likely to occur in the area around the site and that community members are safe in their houses, yards, and schools. However, because past exposure to contamination from the site was at a level that could cause adverse health effects, community members have many valid concerns about the current safety of their environment. We address their specific concerns about their current situation below.

1.    CURRENT CONTAMINATION

Now that SWP is no longer in operation and alternative water supplies have been provided, there is no longer a public health hazard for neighborhoods surrounding the site. The area around SWP has been thoroughly tested. The nature and extent of contamination on and around the site are now well described. The levels of contamination detected in the 1993 Environmental Protection Agency (EPA) sampling indicate that contamination around the site is no longer at a level to pose a health concern except in sediments in two ditches. Of the two remaining ditches, only one poses any health concern. State workers are cleaning this lead-contaminated ditch. Posted signs warn residents to keep away. The ditch is downgrade of Goldberg Recycling in the Hyde Park area near Clara Jenkins Elementary School. The second ditch, contaminated with arsenic, is in a location where people will not come into contact with it. Therefore it does not pose a health concern.

Citizens living around the site remain concerned that they may get sick from current exposure to contaminants. However, we do not think this is likely. People become sick from contamination only if they come into contact with it and absorb a high enough dose of it. Therefore, people, not the contamination itself, are the focus of our analyses. Again, ATSDR would like to alleviate these concerns by stating that citizens living around the site are currently not likely to be exposed to contaminants.

1)    "Will these chemicals go away? How long do they stay?"

Chemicals do tend to dissipate from the environment gradually once the source of contamination has been removed. Chemicals such as pentachlorophenol (PCP) have a half-life of 10-70 days in soil. Other chemicals, such as arsenic, lead and dioxin, tend to be more persistent and may be present at elevated levels for several years. Situations such as flooding or heavy rainfall accelerate the dissipation of chemicals in soil. For this area, there are now no widespread elevations of chemicals in soil. In addition, monitoring data indicate a gradual decrease in contaminant levels since the early 1990s.

2)    "What about the adequacy of environmental data in characterizing contamination of the surrounding community?"

ATSDR staff members realize that some of the earlier environmental monitoring conducted by different agencies has produced inconsistent results, especially for residential soil. ATSDR representatives in 1993 requested further sampling and monitoring from EPA to allow better characterization of the amount and extent of contamination in the residential areas surrounding SWP. The results of that sampling and monitoring data were sufficient to allow ATSDR scientists to conclude that residential exposures are no longer a public health concern for residents living around SWP. Refer to the Conclusions in the addendum (page 42) and the introduction on page 4-3 in this appendix.

3)    "We have provided some documentation to explain to you that arsenic, lead, chromium, and mercury originate in (monitoring wells) MWs on SWP and spread out north to Hyde Park MW67 A, B, and C and east E8 and E9. Please do not try to fool us."

Data from monitoring wells in the entire area, including Hyde Park and Virginia Subdivision, show that groundwater contains elevated levels of heavy metals,including lead, chromium, and arsenic, and should not be used as a water supply. Everyone should be using the municipal water supply. The health assessments and several health consultations have included that recommendation.

a.    Ditches

4)    "What about the chemical hazards of ditches in residential areas?"

The only ditches that now pose a chemical hazard are those mentioned on page 4-3 in this appendix; however, they are not of public health concern. One is being remediated and the other is inaccessible. The soil in ditches in residential areas near SWP contained elevated levels of arsenic, polycyclic aromatic hydrocarbons (PAHs), heavy metals, polychlorinated biphenyls (PCBs), and dioxins/furans in the past. The most elevated levels of contamination occurred primarily in those ditches north of and adjacent to SWP, those southeast of SWP, and those south of Clara Jenkins Elementary School. Those ditches have all been cleaned.

5)    "Why do we see strange things floating down the ditches in our community?... How can you explain how and why permits for chemical cleanup are not being enforced when it comes to Southern Wood? There is stuff oozing out of ditches during and after supposed cleanup. Why? ...the permit says no oozing should be present in the ditch from Winter to Gravel Pit road... If the ditch on Winter Road has oozing and chemicals so does Hyde Park because the same ditch runs to Hyde Park."

It is very difficult to answer this question without more information. There are several other industrial sites, junkyards, and more than a thousand people in the area, so it is understandable that occasionally there will be debris floating down the ditches, especially during floods. Data from 1993 environmental monitoring do not indicate that contacting the ditches--except the two ditches previously described--would present a chemical hazard. Given the types of industry in the area, we would not expect that contaminant levels in the ditches would change dramatically.

6)    "Are you aware that the Storm Drain Water Plan has not been implemented? . . .arsenic is running off the site with rain water. Can you tell us how arsenic passes by Hyde Park in water? Does the water get to Dan Bowles Road and say 'Oh no! This is Hyde Park and I can't go over there?' Please be real. Water, ditches and all run across the road into Hyde Park."

Past monitoring data from ditches downgrade of the SWP site do show that levels of contamination decrease with distance from the site. This is common with releases of hazardous substances. Therefore, it is understandable that Hyde Park, being about a half-mile from the site, may have had nondetectable levels of contamination or levels lower than those of areas immediately adjacent to the site. Even areas immediately adjacent to the SWP do not now have hazardous levels of soil contamination.

7)    "On page 16, you stated, 'Generally, contamination was present in ditches bordering the Virginia Subdivision but did not extend into Hyde Park....' Please check the Law Environment Report Job Number 55-5270.431." ALSO, THIS CORRESPONDENT NOTES THAT THERE IS SAMPLING DATA ON ROCKY CREEK.

We reevaluated the Law Environmental report noted above. The report identified trace amounts of copper, nickel and zinc in the ditches in Hyde Park. These are naturally occurring elements and probably not connected with activities at SWP. The report did not identify elevated levels of arsenic and PAHs in Hyde Park, such as those found in Virginia Subdivision.

The public health assessment addendum contains a review of the monitoring data from Rocky Creek. (See page 20 and Table 8 on page 21 of the addendum).

8)    "EPA did not take soil samples in the ditches west of SWP."

EPA took soil samples from ditches in the Virginia Subdivision, which is west of SWP.

9)    "Are you aware that Thermal Ceramics is dumping illegally in our neighborhood?... Thermal Ceramics has been permitted over the years to discharge surface water with a Ph level below 6. Why did this happen? How can the State of Georgia permit an illegal dump into our neighborhood and right in front of our elementary school?"

EPA scientists tested the ditch in front of the Clara Jenkins Elementary School in 1993. The ditch does not present a public health hazard. Ph determines whether a substance is acidic or basic. A Ph level below 6 means that the water is acidic. The Ph level below 6 does not indicate a public health hazard. Many foods and drinks we consume have Ph levels below 6.

10)    "The ditch near the Jenkins School has been contaminated as you can see from this memo of 1990."

The ditch is no longer a public health hazard, since the Georgia Environmental Protection Division (GA EPD) is cleaning the ditch.

11)    "Are you aware that there is a landfill dump in front of Clara E. Jenkins Elementary School?"

ATSDR staff members visiting the SWP site verified with officials from the Richmond County Department of Public Works that they commonly dredge ditches near SWP after heavy rainfall to relieve flooding. They usually stockpile the dredged soil and debris alongside the ditches. ATSDR staff members believe residents may be referring to the stockpile as the landfill dump in front of the Clara E. Jenkins School. ATSDR staff members know of no previous or current landfill dump in front of the Clara E. Jenkins School. Also, officials from the GA EPD said they know of no previous or current landfill dump in front of the Clara E. Jenkins School.

12)    "You do not have any data from regulatory files on air. Why are there no references?"

Very little ambient air monitoring data was available when the plant was operational. Some air monitoring was conducted during remediation and after closure. These data are reviewed on pages 23 and 25 of the addendum and are cited as references number 16, 25, and 27.

13)    "What about air quality during cleanup of the ditches?"

Air monitoring conducted during ditch remediation indicated levels of benzene that, at times, exceeded health comparison values. However, the detected levels were similar to those found in many urban areas. Residents were exposed for less than 1 year while SWP was cleaning up the ditches.

14)    "What about odors and air quality during ditch remediation?"

During cleanup, air monitors measure the level of contamination to make sure people aren't exposed to levels that could pose a health hazard. The contaminant we would be concerned about is benzene, but prior air monitoring indicates the level during cleanup is no higher than the levels found in other urban areas.

b.    Other Questions about Sampling

15)    "It does not seem possible that workers wearing rubber gloves could contaminate surface soil results with (bis-2-ethylhexyl-phthalate) BEHP."

BEHP is in the powder used to make latex gloves easy to slip on and off. The powder used on the gloves is very fine, and it is not uncommon for it to fall out of the glove during sampling.

16)    "What is the HNu? Why do all reports have that piece of equipment for safety at and around SWP?"

HNu is a piece of equipment used as a precaution during remedial activities at any site. It measures total levels of hydrocarbons. This monitor does not measure specific chemicals. It is used to alert workers about an unexpected or sudden release of a volatile compound before the compound affects the health of workers in the immediate area.

17)    "Please define PCB.... Can PCBs come from the spill at Georgia Power Station on Dan Bowles Road? Did you compare the test results?"

PCB stands for polychlorinated biphenyls. PCBs are a group of related compounds (209 of them) once widely used in industry because they are excellent insulators of electrical devices or equipment. They were used as coolants, lubricants, hydraulic fluids, and plasticizers and especially in electrical capacitors and transformers. They were manufactured from 1929 until 1977, when production and sale of PCBs was banned in the United States. However, equipment containing PCBs remains in use, and they have been found at numerous waste sites, former electrical equipment repair sites, and a variety of other manufacturing sites.

One ditch down grade from Goldberg Recycling had elevated levels of PCBs. Given the above information, which is provided on page 3-5 in Appendix 3), it is plausible that PCB contamination may have resulted from a spill at a power station. However, we have not compared test results or determined the source of PCB contamination, except to say that it is unlikely that it came from SWP. More importantly, the amount of PCB contamination in the ditch is unlikely to present a public health hazard. However, to be extra safe, people should avoid contact with this ditch until it is cleaned.

18)    "Did any of your researchers remember the EPA file material on the cyanide surface impoundment? Cyanide was found off site but was not a part of your assessment."

Cyanide was not noted or detected in the off-site sampling and monitoring data; thus, cyanide does not present a public health hazard at this site.

19)    "You missed mercury and cyanide. You must list all chemicals. Who decided that these (listed chemicals) were the only ones to discuss?"

Our assessment has taken into account all these chemicals. We did not include mercury and cyanide in our discussion because they were not detected and/or measured in the available sampling data. Available environmental data have never shown the presence of off-site mercury and cyanide in amounts that would pose a public health hazard.

20)    "While the addendum identifies contaminants of concern not related to Southern Wood Piedmont ... other dangerous compounds such as mercury, trichloroethylene, methylene chloride are omitted altogether.... ATSDR appears to ignore...dangerous compounds."

We did not ignore other dangerous compounds such as mercury, TCE, or methylene chloride. Sampling simply did not detect them at levels of health concern. These chemicals are only dangerous if people are exposed to them in large amounts. This was not the case in areas surrounding SWP.

21)    "You will also find reference to the 205J toxic stream monitoring report which shows the SWP monitoring station. Once again I have submitted the same test results, which are not part of your last assessment or this addendum."

ATSDR received a very large amount of data and information to determine whether or not there is a public health hazard related to off-site contamination near SWP. We reviewed all the data. We can say confidently that there is no widespread contamination and it is safe for people to live in the area. It is extremely unlikely that reevaluating this piece of data would change our conclusions about this site.

2.    HEALTH EFFECTS FROM PRESENT SITUATION

As we stated in the previous section, we do not think people living around the SWP site are coming into contact with contamination at doses that will cause adverse health effects.

1)    "The Hyde Park area and the area to the west of the railroad tracks of the plant site have not been evacuated, and it is well known in the literature that long-term exposure to these toxins and solvents causes a variety of serious and debilitating health effects."

Understanding that "dose makes the poison" is a key to environmental health. It is true that, at large doses, long-term exposure to toxins such as arsenic, PCP, and dioxin can cause adverse health effects. The levels of contamination around SWP are currently not high enough to cause any adverse health effects whatsoever. That is why we have not recommended evacuating residents from their homes in any area around the site.

2)    "Residents as well as children are at risk because of contamination. When residents cut their grass nine months out of the year, they also cut in the ditches causing contamination to stick to shoes, clothing, and your body. When walking in your home its tracked in from shoes and clothing."

The levels of contamination are not high enough to make any of these exposures a public health concern.

3)    "Why did Georgia Power employees develop rashes while working in Hyde Park?"

We have no documentation or direct reports that workers developed rashes, so we cannot address this question directly. However, current testing indicates that people are not coming into contact with contamination at levels that would cause adverse health effects.

4)    "A backhoe worker was exposed to creosote fumes in the ditches southeast of the SWP facility in September of 1992...tests indicate breathing irregularities. The worker has symptoms associated with toxic exposures."

We have no documentation or direct reports about the incident. But we emphasize again that current testing indicates that people are not coming into contact with contamination at levels that would cause adverse health effects.

5)    "If you had made some recommendations from the information presented to you in the last assessment maybe the (Department of Transportation) DOT worker would not have stepped in Rocky Creek and gone to the Emergency Room.

We have received no direct reports about this incident, so we cannot address it specifically. Again, we emphasize that there is currently no contamination at levels that would cause a worker to be so sick that he had to go to the emergency room.

3.    RELOCATION AND OTHER PROTECTIVE ACTIONS

We do not recommend relocation. We understand that community members are afraid that exposure is continuing or that it might recur during clean-up activities. However, we do not think that exposure is taking place now. We also believe that adequate monitoring and precautions during cleanup can ensure the safety of residents without relocation.

1)    "Warning signs and education are of no value when residents are living in a contaminated area and will be living in the area for a long period of time during the cleanup."

There are some isolated areas in two ditches that do have unsafe levels of lead and arsenic; however, one ditch is currently being cleaned and the other ditch is inaccessible. The inaccessible ditch is in a heavily wooded area that prohibits contact by nearby residents (refer to page 4-3 in this appendix). Before cleanup began, signs were posted to warn parents and children where contaminated areas existed so that they could avoid coming into contact with contaminated sediment. Again, at the time of this writing, this sediment either has been removed, is being removed, or is inaccessible for residents to contact, so there is no longer any danger of exposure.

2)    "ATSDR should request that monitoring wells be placed in the Hyde Park area as well as the area to the west of the railroad tracks of the plant site."

Groundwater monitoring has been conducted in the Hyde Park areas and west of the site. The results indicate that the groundwater should not be used as a drinking water source. As long as people do not use or do not plan to use groundwater as a drinking water source, we have no need to install permanent groundwater monitoring wells.

3)    "Air monitors are not sufficient to protect residents (during remediation). The only solution is to relocate residents and clean the entire area from contamination."

Air monitors are essential during remediation, since they warn workers when ambient air conditions become unsafe. Ambient air conditions are usually safe during remediation activities; however, if they become unsafe and present a public emergency, residents will be evacuated to a safe zone designated in the remediation contractor's health and safety plan. We believe that air monitors provide a sufficient method of protection for both residents and workers.

4)    "With all the contamination in the area, it's time to make a decision and apply for Superfund and relocate residents. This is the only way to protect residents' health."

There are ways other than relocation to protect residents' health. EPA results indicate that there is no contamination now that poses a health concern except for sediment in two ditches. Currently, one ditch, near the Clara Jenkins Elementary School, is being cleaned and the other is located where people won't come into contact with it (refer to page 4-3 in this appendix). Cleaning the ditch near the Clara Jenkins School will complete the elimination of all areas where people could come into contact with past contamination. It is not contamination but contact with contamination that poses a health threat. Consequently, it will not be necessary to relocate people to protect the health of residents.

5)    "The residents to the west should have been relocated before any cleanup was started and before any future cleanup because of contamination affecting people's health."

Again, it is not contamination, but coming into contact with contamination, that poses a health hazard. There will be appropriate safeguards to minimize contact with contamination for residents as well as workers during cleanup.

6)    "It is abundantly clear to me that a health hazard exists in the Hyde Park-Argonne area and that anything less than total relocation of the residents NOW would be a miscarriage of justice."

ATSDR can only recommend relocation if a health hazard currently exists and there is an immediate and acute threat to public health. The most recent environmental monitoring data do not indicate that there is currently a public health hazard in neighborhoods surrounding this site.

7)    "How can it be safe for residents to live in the area, but EPD advises new people not to move in because of the contamination?"

We assume that the GA EPD made this comment prior to all the environmental monitoring of the past few years. The 1993 environmental monitoring indicated that it was safe for current residents to live there and for new residents to move into the area.

B.    COMPLETENESS AND QUALITY OF THE DATA

Many of the comments we received concerned the completeness and quality of the data on which ATSDR based its public health conclusions. Public health assessments use currently available data. Thus the data for our analyses regularly come from different sources, often from sources with competing interests. However, we take this fact into account when we evaluate the data and make sure that the data on which our scientists base their conclusions are sufficiently complete and of adequate quality to allow us to decide whether a site poses a public health threat. When the data is insufficient to make a decision about public health issues, ATSDR can request additional data gathering. We have done that for this site.

Because of conflicting findings in the original data sets, ATSDR asked EPA to characterize the area around the site. Using all the data available, EPA developed averages and standard deviations for contamination levels in different areas on the site. EPA then developed a sampling scheme to fill in the data gaps. This sampling scheme was designed to make full use of existing data, so it emphasized collecting data on areas that had not been sampled and on areas that had been sampled but where the findings differed significantly among data sources. With this additional sampling by EPA, ATSDR now considers the sampling data on the site sufficient to allow us to draw the following conclusions: 1) the community around the site is not likely to be exposed to contamination currently, and 2) the community around the site was exposed to contamination in the past.

Our responses to specific questions raised by the community about data sufficiency and quality and our own evaluation process follow.

1. DATA SOURCES

We emphasize the fact that our assessment process takes into account the different sources of the data we review. Whatever its source, we look at each set of data carefully and evaluate how well it meets established scientific criteria. Major evaluation criteria include the overall completeness of data, quality of different data sets, and consistency across data sets.

1)    "Where did you get your description of the Southern Wood Piedmont Site? Whose information did you use?"

The GA EPD provided most of the information, including Corrective Action Reports, the Consent Agreement, and a follow-up memo that included site description information.

2)    "A major concern of all persons is the quality of the data ATSDR relies upon in issuing these assessments. As a result of SWP's superior financial resources versus the limited resources of the residents, most of the data generated by non-governmental sources were data prepared by ITT, ITT Rayonier and SWP."

As the introduction to this section indicates, EPA generated the data that was the basis for our conclusion that there is no widespread contamination or public health hazard currently at this site.

3)    "In almost all cases, no quality control information was submitted with the reports. This lack of quality control in the worst case makes the data worthless and in the best case casts doubts upon the reliability of the data."

Some data had no quality control. For this reason and others, we asked EPA to sample the entire off-site area. EPA used good quality control. Therefore, we are confident in our conclusion that there is no current, widespread public health hazard.

4)    "Conclusions (were) reached concerning health hazards based upon inappropriate methodology, 'suspect' data and without any apparent consideration for specific circumstances under which data was generated."

ATSDR reviewed the data that did not include quality assurance and quality control information. There are discussions regarding the quality of data in the addendum. There were some discrepancies among data. Again, we did request that EPA resample the entire area. Based on these results, we have concluded that a public health hazard no longer exists for residents living around SWP. An earlier discussion includes information on the two ditches with elevated levels of lead and arsenic (refer to page 4-3 in this appendix).

5)    "The addendum relies exclusively upon representations from area residents without any scientific investigation."

Part of the public health assessment process is discussion of health concerns with the community, and the assessment cites those health concerns. We have also taken a further step and conducted a medical records review to assess some of the reported health concerns more thoroughly. We do not rely exclusively upon the representations of the area residents, nor do we rely exclusively upon the reports of the private businesses such as SWP. Please see the introductory note to this section in this appendix.

6)    "...residents are either former or current participants in multi-million dollar litigation against Southern Wood Piedmont. In fact, it is apparent from a number of unsupported allegations made by area residents that certain information is being provided in support of litigation against the company (rather) than based on any accurate scientific evidence."

The purpose of the Community Health Concerns section of the addendum is to provide an opportunity for ATSDR to discuss the health concerns of the community in writing. We try to provide the best public health guidance possible to address those concerns. Our agency has no role in assessing legal liability.

We discussed area residents' concerns with them to make a better evaluation of the area's public health needs. Our purpose was to conduct a thorough evaluation and to recommend the most responsible public health actions possible. We have determined that, while a public health hazard no longer exists, one may have existed in the past; therefore, we are still working on proposing viable public health alternatives and/or actions so that there is appropriate long-term follow-up care and evaluation within the community.

7)    "Accordingly, reports generated by Drs. Harlage, Varma, Kite and Pancorbo should be scrutinized in view of their adversarial and pecuniary interests."

One important criterion is that findings across data sets be consistent. Whatever the source, we assess each data set or report according to the general scientific criteria described in the introduction to this section of this appendix.

8)    "ATSDR should investigate rumors [such as the Georgia power crew member incident] and dismiss them if they have no scientific significance rather than including them in an official publication."

Again, we will provide the most appropriate public health guidance possible to address the health concerns of residents.

9)    "ATSDR gave a million plus to Emory University. Emory hired Howard Frumpkin. ITT hired Howard Frumpkin to be their defense. Does ATSDR fund the defense of the industries...? What other money have you given and to whom to develop your program?"

We have not provided funds to or contracted with outside contractors during the public health assessment process for this site. We are funded entirely by Congress. We have used environmental monitoring data provided by SWP for this site, as well as monitoring data from EPA and other agencies and contractors.

2.    SPECIFIC STUDIES

We emphasize the fact that we did not base our conclusions on the review of any single report but on a review of all the available data plus the extensive sampling carried out by EPA to fill in data gaps and resolve inconsistencies in the data.

a.    Dever/Mercer Study

1)    "The health status assessment from Mercer University, ATSDR found uninterpretable. Richmond County paid $18,000 for this report. Richmond County Task Force had no problem interpreting the report, and the writer was well qualified."

ATSDR did not find the study uninterpretable. The statement about interpretability was a quote from other reviewers from the University of Alabama and Emory University. We will consider the information in this study as we prepare the Medical Assistance Plan.

2)    "The health status assessment was prepared by Dr. Alan Dever, a Professor at Mercer University, not by Mercer University. In fact, the health status assessment is so seriously flawed that it should not be used as a basis for any health-related decisions."

We realize that a professor at Mercer University prepared the study. We will consider whether the information in this study is useful in preparing the Medical Assistance Plan.

b.    Extension Service Report

1)    "The Georgia Extension Service is a well qualified agency and run by the State of Georgia. It is an insult to the state Georgia to disqualify their report. ATSDR has not questioned other agencies how tests were taken."

Whatever its source, we look at each set of data carefully and evaluate how well it meets established scientific criteria. Major evaluation criteria include consistency across data sets. The University of Georgia Cooperative Extension Service (Extension service) data was inconsistent with many other data sets. We did not disqualify the report but rather asked EPA to resample to evaluate this inconsistency. The EPA sampling found that there is no widespread contamination in off-site areas. The EPA collaborated with the Extension service on this sampling.

2)    "All material received for this assessment should be used if it has been prepared by a qualified representative, especially the Georgia Extension Service Report and the report from Mercer University."

Again, whatever the source, we look at each set of data carefully and evaluate how well it meets established scientific criteria. We looked at the Extension service report in exactly that manner. We will consider the study by Dr. Dever from Mercer University in exactly the same manner.

3)    "ATSDR's reliance upon such 'suspect' data [in reference to the Georgia Extension Service data] is inappropriate and such data should not be considered in any health assessment."

ATSDR did not rely on the Extension service data. We questioned the data because of its inconsistency with other data sets. That is the reason we asked EPA to resample the entire area. Again, this additional EPA data indicated that a public health hazard no longer exists for residents living around SWP. The data did indicate that two ditches contained unsafe levels of lead and arsenic; however, they are of no public health concern since one is being remediated and the other is in an inaccessible location (refer to page 4-3 in this appendix).

4)    "The Georgia Extension Service value of 343 (milligrams/kilogram in soil) was used. These data are 10-15 times higher than the data produced by any other group and cannot be verified. This value should not be used."

EPA resampled to resolve the inconsistency between data sets. (See previous question.)

c.    Geraghty and Miller Report

1)    "You have cleverly tried to compare the Geraghty and Miller report. The teenagers of Hyde Park helped Geraghty and Miller do their testing for the SWP attorneys. They used a sampling method that no one has ever seen before. They would core 30 holes in the same small area for soil samples."

We did not rely entirely on the Geraghty and Miller report for the conclusions. We feel there is sufficient data now, along with the Geraghty and Miller report, to conclude that there is no widespread off-site contamination or public health hazard.

d.    Cox-Manning

1)    "...you think you are being very clever using the Cox-Manning report which the Governor's Task Force noted null and void for the conclusions."

ATSDR did not use the Cox-Manning report conclusions. ATSDR did use the data summary within the report, after verifying that it was a complete and accurate summary of the available surface soil data.

2)    "Dr. Cox and the GA EPD are just fronting for the SWP attorneys."

One of the challenges of environmental public health is to come to a carefully considered scientific opinion in a highly charged social context. Our major concern and responsibility as an agency is to protect the health of the public. As we said earlier, we look at all the available data and come to our own conclusions about what needs to be done to protect the community around a site. Again, ATSDR did not use the conclusions of the Cox-Manning report, just the data summarized within the report.

3)    "We see that the Cox and Manning document was listed as a reference for EPA and for your agency. Are you aware that this document was asked to be null and void by some Task Force members? ...the reasons this was requested were that the report was one sided and that the information contained was given by Southern Wood Piedmont attorneys."

Again, ATSDR did not use the Cox-Manning conclusions. However, the body of the report is simply a summary of all the available data. ATSDR verified that it was a complete and accurate summary of the available surface soil data before including it in the public health assessment addendum.

3.    PUBLIC HEALTH ASSESSMENT PROCESS

One reader asked several times whether information presented in this public health assessment addendum complies with the guidelines outlined in the Public Health Assessment Guidance Manual. In general, these comments may be addressed as they are in the Foreword to the manual:

    The Public Health Assessment Guidance Manual is not intended to supplant the professional judgement and discretion of the health assessor in compiling and analyzing data, drawing conclusions, and making public health recommendations. Instead, the manual provides a logical approach to evaluating the public health implications of hazardous waste sites, while still allowing the health assessors to develop new approaches to the process and apply the most current and appropriate science and methodology. That is an important concept; just as environmental health science is rapidly developing, the public health assessment must also adapt to changing scientific technology and procedures in order to remain a dynamic process.

In addition, although health assessors' professional judgement and discretion are encouraged, experts within ATSDR review all public health assessments before release. The purpose of the review is to ensure that the document supports all conclusions and recommendations appropriately. This public health assessment addendum has undergone thorough review.

a.    Standard Procedures

1)    "The addendum reached conclusions that are inappropriate and not clearly supportable based on current ATSDR guidance...ATSDR concluded that the SWP site is a public health hazard. This conclusion cannot be substantiated since the ATSDR 1992 criteria for reaching this conclusion were not met."

It is our conclusion that SWP posed a public health hazard in the past. Our conclusion category is appropriate given our categorization scheme. ATSDR defines health hazards as situations meeting the following criteria: 1) evidence exists that exposures have occurred, are occurring, or are likely to occur in the future; and 2) the estimated exposures are to a substance or substances at concentrations in the environment that, upon long-term exposures (greater than 1 year), can cause adverse health effects to any segment of the receptor population.

It is our opinion that there have been exposures to contaminated groundwater, residential soil, ditch sediment, and air. Further, it is our opinion that levels of arsenic, PAHs, and dioxin were present in surface soil and ditch sediments in sufficient concentrations to present a health risk for long-term exposure, especially for pica children. With these two criteria met, in our opinion the site posed a public health hazard in the past to residents living near the site. However, EPA's monitoring data from 1993 indicate that SWP no longer poses a health hazard. The monitoring data from 1993 did indicate that two ditches contained unsafe levels of lead and arsenic; however, the ditches are of no public health concern since one is being remediated and the other is in an inaccessible location (refer to page 4-3 in this appendix).

2)    "ATSDR has inappropriately determined that certain health hazards exist by comparing the highest concentrations detected to EMEGs (environmental media evaluation guides) in direct violation of the guidance document."

We did use health guidelines as part of the toxicological analysis. However, we estimated dose and compared the estimated dose to the appropriate health guideline. Please note the discussion on pages 33 and 34 in the Public Health Implications section of the addendum. An estimate of the dose people are likely to receive from contaminants at the site is based on the exposure discussion in the Pathway Analyses section of the addendum, and this value is compared to the health guideline to determine whether there might be sufficient exposure to cause harmful health effects. Our Public Health Assessment Guidance Manual recommends this methodology.

3)    "I am shocked that a federally funded agency can publish a document that so blatantly ignores all accepted rules of good statistical scientific methodology. This document is so poor that it needs to be withdrawn and completely redone."

The purpose of this document is to assess the public health needs of communities affected by a release of hazardous substances. It results from an early evaluation process using existing data, not from a controlled health study. Strict statistical methodology may be employed in a follow-up health study; however, our immediate responsibility is to use existing information from the site as a basis for deciding what needs to be done to protect public health. Generally, our assessments are conservative and may overestimate possible risks because this approach is the one most likely to protect the health of the public.

4)    "ATSDR's own Guidance Manual indicates that such models [referring to the air model] should only be used as guidelines to help develop public health decisions and should not replace decisions based on environmental sampling or to draw health conclusions.

This is correct. Unfortunately, we do not have historic air monitoring available for the assessment. If we did, we would use it in lieu of this modeling data. However, the modeling data is all that was available to address community members' concern about past air exposures while the plant was operational.

5)    "Please provide the new analytical method background document and other supporting documents so that a team of chemists and professors can try to interpret your talk and conclusions."

We explain our analytical method and the basis for our conclusions within the document. We encourage any chemists and/or professors who have questions about the document to call us directly.

6)    "Who determined the comparison values? Which doctor on your staff can tell me what level of a chemical will burn me?"

Both ATSDR and EPA scientists determine comparison values. None of the chemicals on- or off-site were found in sufficient concentrations to cause burns. Generally, chemicals must be in or close to their pure form to cause burns. The dose required for a burn varies from chemical to chemical. We suggest calling the poison control center with specific questions about individual chemicals and their ability to cause burns.

7)    "Please give over in writing that ATSDR does not look at the required tests of pesticide registration and manufacturing tests, as required by (Federal Insecticide, Fungicide, and Rodenticide Act) FIFRA, law in telling the community about the dangers and risks of the pesticides in the community. Are any of these chemicals neurotoxins?"

The last round of sampling found no pesticides at levels of health concern. Pesticides have not been a contaminant of concern at this site (aside from those such as arsenic that are used in the wood-treating process).

8)    "The chemical manufacturers have put warnings on the chemicals they sold to SWP. Perhaps your listing is not the same type of chemical that was sold to the company?"

These warnings apply for exposure to chemicals in a more concentrated, pure form, like the form used on industrial or wood-treating sites. They are designed to protect people who may be accidentally exposed to very large doses of those chemicals at the work sites. These warnings do not apply to the long-term, low-dose exposures that may have happened off site at SWP.

b.    SWP as Source of Contamination

The major concern of a public health assessment is to use existing data to analyze whether a health threat exists and, if so, to determine the actions needed to protect the public health. Determining the source of contamination is important if it will affect our recommendations about how to reduce or stop exposure, but establishing the responsibility for contamination is not part of ATSDR's mandate. Once we are investigating a site, we consider the public health effect of any contamination we identify, not just contamination that we can directly link to the site.

1)    "The agency has neglected to determine the nature and extent of the activities occurring at any one property which would explain the [source] of the contamination."

Explaining the source of the contamination is not our goal. If the activities at any one property are posing a threat to the community, we will identify that property. There is currently no widespread public health threat to the community around SWP. The only activity that may have led to elevated lead contamination in one ditch in Hyde Park is runoff from the Goldberg Recycling Facility. A berm is being installed, and the ditch will be remediated.

2)    "ATSDR clearly indicates that it has failed to consider the activities conducted on various properties including vehicular repair, junk and scrap salvage, disposal of waste oil, etc."

Again, it is not our goal to identify all types of activities that may add to contamination of a residential area. If activities at any one property are posing a threat to the community, we will identify that property. With the possible exception of Goldberg Recycling, that is not the case here.

3)    "There does not appear to be any attempt by ATSDR to distinguish known alternative sources of contamination from SWP."

Our responsibility is to determine whether people are coming into contact with contamination and what, if any, public health actions may be needed. It was not necessary to determine all possible sources of contamination for this community to protect public health in this area.

4)    "Why haven't you looked into the (Georgia Bureau of Investigation) GBI report on Southern Wood Piedmont? Why haven't you looked into the file on Southern Wood Piedmont in the attorney general office on enforcement action for the site?"

This information would probably have no influence on the public health decisions made at this site.

II.    HEALTH EFFECTS OF PAST EXPOSURE

Community members have raised other questions about the sufficiency of the information on past exposures and on past and current health effects. We agree that the data on past exposure is inadequate, but present and future medical followup will improve it. Education being provided to local health care professionals will help them take adequate exposure histories and diagnose and treat diseases related to past exposures. A proposed Medical Assistance Plan for the community would help provide these services.

A.    PAST CONTAMINATION

We are aware that in the past the level of contamination around the site was worse than it is now. Although it is not possible to determine actual exposure levels for past exposures , we do think that residents were exposed to contaminants at levels that could cause adverse health effects.

1)    "EPA inspected the area in 1985 and stated this area should have already been on Superfund. There were other areas on Superfund that were not as bad as this area."

We recognize that the SWP property was more contaminated in the past than it is now. Off-site areas around SWP are safe now. Two aforementioned ditches, as indicated on page 4-3 in this appendix, have unsafe levels of lead and arsenic; however, they are of no public health concern since one ditch is being remediated and the other is in an inaccessible location. The 1993 EPA sampling results indicated that there was no public health hazard in soils and sediment in areas surrounding SWP.

2)    "There were only a few tests on the west side of SWP and no test wells to determine if contamination was widespread in this area."

We believe that the data provided by EPA is sufficient for ATSDR to conclude that it is safe to live in areas surrounding SWP.

3)    What effect has flooding had in transporting on-site contamination off site and out of ditches?

Flooding may have helped transport SWP contamination off site and into residential areas. Data from monitoring before 1993 substantiate this theory, especially in the case of arsenic. However, the latest sampling data indicate concentrations are not at a level to pose a health concern.

4)    "Are you aware that we had years and years of flooding? ...we had a terrible flood in October of 1990 and contaminated soil left Southern Wood Piedmont and came into our area."

We recognize your concern about the spread of contamination. However, off-site sampling EPA conducted in 1993 indicates that there is no public health hazard in soils and sediment in areas around SWP.

5)    "...the main engineer and/or environmental person for SWP... (admitted that) the facility was releasing 30,000 to 40,000 gallons of waste water per day in the ditches, sometimes as many as 6 days a week."

We realize that contamination from SWP was worse in the past while the plant was operating. Our focus now is on preventing present and future exposure and addressing possible health concerns based on past exposure. The last EPA sampling indicates that it is safe to live in areas surrounding SWP. We will continue following the community for possible health effects of past exposure.

6)    "Ditches in the Virginia Subdivision have been dug several times, and the water has drained in different directions. Past, present they drained through the Virginia Subdivision, bringing contaminated water in this area."

Again, all these ditches have been tested. These ditches and the water draining through them no longer present a public health hazard. Results from 1993 EPA sampling did indicate that two ditches contained unsafe levels of lead and arsenic; however, neither ditch is in the Virginia Subdivision (refer to page 4-3 in this appendix).

7)    "Are you aware that Southern Wood Piedmont used PCP in its pole processing...? Did you hear workers talking about the staining of the poles, the use of mercury and fenta?"

We cannot reconstruct what doses workers and others may have received while the plant was operational. We are aware of all the chemicals used in processes at SWP. We are concerned about past exposure and plan to follow up on these health concerns now and in the future through the Medical Assistance Plan.

8)    "SWP is one of the few facilities in the United states where all three major wood treating pesticides were used: creosote, (Chromated Copper Arsenate) CCA, and pentachlorophenol. It was known in the late 1970s that there were dioxin releases on site at the SWP facility."

Our assessment has taken all these chemicals into account. These chemicals do not currently pose a public health threat for people living around SWP.

B.    EXPOSURE PATHWAYS

We do think that exposure took place in the past, but we do not think that families who occasionally went on site or who helped wash clothes for family members who worked at SWP experienced exposure to contaminants at levels that would cause adverse health effects.

1)    "The addendum fails to perform the proper exposure assessment, as described by the guidance manual in Appendix D necessary to determine the exposure to the receptor population...it is impossible to accurately conclude that evidence exists for exposure."

Five elements must be present for a completed exposure pathway to contaminants to exist: source, environmental media, exposure point, exposure route, and receptor population. If all these elements exist, then it is our opinion that exposures have happened. We identify all the completed exposure pathways in Table 13 on page 28 of the addendum.

2)    "Individuals playing or working in ditches does not guarantee exposure. While there is a potential for exposure to both ditch and residential soils, this potential has not been quantified or substantiated with medical or scientific evidence."

It is not prudent public health practice to await indisputable proof of this exposure. We intend to mitigate these exposures as soon as the exposure pathway assessment identifies them and to take proper actions to protect public health. Again, in the case of SWP, it is our opinion that there was a completed exposure pathway for residents who came into contact with contaminated ditch sediment and residential soils in the past. This was the basis for past public health actions encouraging residents to minimize their exposure to ditch sediments (until the extent of contamination was reevaluated in 1993) and for the Medical Assistance Plan.

3)    "A census map should not have been used in this report. The area marked off is in error and one community is completely left off, regarding the area in this study."

We apologize for the confusion and have removed the map. We used the census tract identified on the map only to estimate a population number. We did not mean for it to delineate the exposed population. We understand that there may be people who were exposed in the past who are not included in that census tract. Likewise, some people in the census tract were not exposed to the site contaminants.

4)    "While there may be some very limited recreation around Rocky Creek, there is no evidence that any children or adults have ever been exposed to any chemicals either in sediment or in water. Unless ATSDR conducts a thorough risk assessment for potential exposure to contaminants in Rocky Creek, conclusions...amount to nothing more than speculation and are without factual support."

We are glad to hear that there is very limited recreation around Rocky Creek, since past environmental data indicated elevated levels of contamination. However, we still consider Rocky Creek a potential exposure pathway and encourage residents to minimize their exposure to this creek.

5)    "Insofar as ATSDR has no evidence of children in the area exhibiting pica behavior, this pathway should be omitted altogether."

Studies show that about 8% of children will practice pica. Unless we learn otherwise, we will continue to believe that this population is no different and about 8% of children living in the area are potentially practicing pica.

6)    "...ATSDR has no evidence of children exhibiting pica behavior...ATSDR guidance clearly specifies that 'suspected pathways can be ruled out if...the pathway (is) extremely unlikely'. The addendum fails to eliminate unlikely pathways...."

It is our opinion that pica behavior remains a potential pathway. However, there is no widespread soil contamination around SWP at this time.

7)    "ATSDR appears to analyze all possible exposure pathways, however remote. This serves no scientific purpose...."

Community members want to know all exposure possibilities so that they may protect themselves from even the most unlikely exposure scenarios. We do try to put each exposure pathway in perspective by highlighting those that are completed, those that are potential, and those that may be eliminated.

8)    "Are you aware that Southern Wood Piedmont held family barbecues on the site? Are you aware that this was reported in the newspaper, so it is documented? Are you aware that many of the workers were from Hyde Park and their families attended many functions on the site? Are you aware that many residents drank water from the Southern Wood Piedmont fountains?"

We realize this question represents a big concern for people who worked at the site and who are concerned that they may have put their families at risk when they brought their families to visit the site. We do not think that going to the annual picnic or drinking water occasionally from the fountains on site would have caused adverse health effects.

9)    "Are you aware that workers brought their work clothes home to be washed... many wives boiled the clothing after the man wore them trying to get the creosote out of the clothing. "

Again, we do not think that this relatively infrequent exposure would cause adverse health effects.

10)    "Are you aware that when people washed their clothing and hung them on the line that small droplets of substances would collect on the clothing? These droplets came from the direction of Southern Wood Piedmont."

Again, we recognize that residents are very concerned about past exposure. However, we do not think that any exposures to contamination on clothing would result in an adverse health effect.

11)    "Are you aware that Southern Wood Piedmont was warned that workers should not take their clothing home...[but] did not share this information with them? ...these workers carried their clothes home day after day spreading poison throughout their homes?"

We do not think people will experience adverse health effects from this limited exposure.

12)    "Are you aware that many women and children were exposed to chemicals when they brought lunches to husbands and fathers on the site?"

Again, we do not believe families of workers will suffer adverse health effects from visiting workers on site.

13)    "Are you aware that there were several big chemical spills at Southern Wood Piedmont? Are you aware that workers reported these spills to EPD, ATSDR, etc.? Why didn't these agencies address these problems?"

We know there was past exposure to contaminants while the plant was operating. Chemicals were both on and off site. However, the people we think are at greatest risk for adverse health effects are the workers. The most important health action was to stop the exposure for workers. The plant is now closed, so workers' exposure has stopped. For past exposures, because there will never be enough information to develop exposure estimates, our discussion concentrates on the health effects we think might be likely for different chemicals. As stated on the first page of this appendix we are most concerned about effects on the skin.

C.    ASSUMPTIONS AND PREDICTIONS ABOUT HEALTH EFFECTS

To determine whether we think adverse health effects might result from a given exposure, we first consider whether people came into contact with contaminants. If they did, then we consider whether they could have absorbed a high enough dose of the contaminant (by breathing, swallowing, or skin contact) to cause adverse health effects. Exposure assumptions are conservative. This means we will generally base our conclusions on an overestimate rather than an underestimate of risk. Overestimating risk ensures that we will make decisions that are highly protective of public health.

1)    "Conclusions regarding health implications are drawn from a comparison of the highest measured value of a given contaminant in the vicinity of the SWP facility to ATSDR's media evaluation and/or health guidelines...it often results in unrealistic interpretations of the data."

There is much we do not know about the levels of contaminants people have been exposed to and the duration of exposure. We make the best effort possible to estimate the health implications of exposure in order to guide public health interventions. In our opinion, our interpretations are conservative but not unrealistic, and they provide an appropriate basis for current and future public health decisions.

2)    "ATSDR repeatedly uses overgeneralized, inaccurate statements which are not supported by credible scientific data."

ATSDR uses environmental data, health outcome data, and community concerns in the public health assessment process. Collecting community concerns provides an opportunity for ATSDR representatives to discuss concerns with community members. We do not downgrade this process by judging whether the concerns are overgeneralized, inaccurate, or supported by scientific data. We simply address the concerns as responsibly as possible, emphasizing what we have identified as the major public health concerns at the site.

3)    "Incomplete data including health outcome data, the EPA data and data submitted herewithin by SWP render the Addendum premature."

It is not responsible public health practice to continue to wait for more and more data before taking public health actions. The assessment process is a continuing one. We issue our reports when we determine that we have enough new information to affect our public health recommendations. These reports become our basis for further public health actions. In our opinion, we had enough data to release the addendum.

4)    "Since it is unknown whether any resident consumed water containing cresol, it is inappropriate to speculate as to whether there was such an exposure and whether there are any related health effects."

We have told local health officials that this exposure may have happened and advised them of the appropriate followup for residents who may have been exposed. If the exposure did not happen, then we have erred on the side of public health. It is our opinion that taking public health actions to address the potential exposure pathway of cresol in private well water was not inappropriate but was instead prudent public health practice.

5)    "What about past exposure to xylene? The manufacturer (Material Safety Data Sheet) MSDS says it is a neurotoxin."

Xylene is a neurotoxin at very high doses, much higher than those seen in residential exposure situations. There is no indication that exposure to xylene in areas around SWP would present a public health threat.

6)    "PAHs have a great deal of literature. Please give the database for your conclusions. Are they special ones or universal data bases? Our literature and yours don't match."

We used the ATSDR Toxicological Profiles and the Hazardous Substance Database. Both are compendiums of available toxicological literature on PAHs.

7)    "What happened to the health effects of the previous consultation? Please include all previous data for naphthalene."

The addendum discusses data received after the previous health assessment and consultations. The previous analysis regarding naphthalene has not changed. This discussion appears on page 2-14 of the original public health assessment (Appendix 2).

8)    "When will the dose reconstruction process begin that you promised us?"

ATSDR initiated the exposure-dose reconstruction evaluation during the calendar year of 1994. The intent of the evaluation was to determine the best reasonable estimate of chemical doses experienced by private well users, who drank contaminated groundwater in the past and were exposed to elevated levels of arsenic and chromium.

In June, 1994, ATSDR staff decided to discontinue the reconstruction effort. Their decision was based on data set limitations and scientific uncertainties created by hydrogeologic features and a slurry wall constructed in 1988. ATSDR staff felt that without more information to accurately define preferential groundwater flow paths, exposure-dose reconstruction at the SWP Site would not give meaningful results.

D.    HEALTH EFFECTS

The adverse health effects we would expect to see among people who have been exposed to contamination at this site affect the skin. The Medical Assistance Plan includes actions to empower the local medical community to diagnose and follow affected citizens on a long-term basis.

ATSDR has requested reprogramming of funds in fiscal year (FY) 1995 in support of the Medical Assistance Plan. Pending clarification from Congress, ATSDR has decided to suspend funding in FY 1995. Other public health follow-up actions such as the community health investigation will be conducted as resources permit.

1)    What about instances of skin disorders, burns, and other illnesses that are believed to be the result of contaminants associated with the site?

ATSDR is conducting a community health investigation to determine whether this community's trends in skin disorders and other illnesses are unusual. We have already reviewed more than 500 medical records. We will report the results of the investigation to the community as soon as we are finished. The compounds detected off site in completed and potential exposure pathways can cause skin disorders and possibly other illnesses.

2)    "I have shortness of breath, skin rashes, and burning eyes in the area. Have two small grandchildren who could have been affected by the area. My first husband died of cancer. The responsibility of ATSDR is to protect people from hazards in the environment."

ATSDR is concerned about possible health implications from past exposure. We recommend followup through participation in the Medical Assistance Plan that is planned to be implemented in the future. You should report detailed exposure information like that provided in this statement to your own physician and/or the physicians participating in the plan.

3)    "I personally have had so many burns. Please list skin burn, not rash--burn. The kind of burn that there is no skin just raw red tissue. The MSDS for creosote I believe says burns."

Currently, there are no chemicals off site in amounts that pose a public health threat--including the threat of burns. We will take into account your complaints of burns from past exposure as part of the medical assistance follow-up activity.

4)    "Which chemical is causing people to pour sweat?'

None of the chemicals found in any of the sampling were at high enough levels to produce profuse sweating.

5)    What about the effect of off-site contamination on the health of children?

We are investigating medical records of residents to help identify trends in health problems, such as skin rashes. This investigation may provide insight into what effect the environment has had on children. We are also planning to provide medical followup for residents as part of the Medical Assistance Plan.

6)    What health effects should be watched for in children and what methods can residents use to reduce health risks?

Cleanup of the site and adjacent contaminated areas has already reduced health risk. All residents should be on municipal water. We don't think there is any other problem with current exposure.

Past exposure could have included exposure to arsenic, dioxins, and other chemicals used in wood treating. The skin is the target organ for most of the possible health effects of exposure. Participating in the Medical Assistance Plan is a good method to help residents monitor for possible health effects and identify effects at an early stage.

7)    "We, as a community feel that we were not clearly covered in your new assessment.... We want you to know that children, the elderly, former workers are suffering tremendously at this point from contamination problems that date back to many years. We had a teenagers dying from cancer as far back as the 60s and 70s. This is a problem and it is not going away."

We can assure you that environmental sampling indicates it is safe to live in the area now. We realize that there are many concerns about potential health affects from past exposure. We plan to continue with the Medical Assistance Plan to follow residents' long-term health status.

8)    What about past arsenic exposures from drinking contaminated private well water?

Private wells along New Savannah Road, Gravel Pit Road, and a portion of Nixon Road (between the railroad tracks and Old Savannah Road) may have been intercepted by a plume of contaminated water containing elevated levels of arsenic in the past. However, a 1993 EPA private well survey revealed that no one was using water from those private wells. We cannot reconstruct exposure likelihood before that survey because we cannot reconstruct the groundwater patterns before 1988 (see Figure 4 on page 13 of the addendum).

Ingestion of arsenic-contaminated groundwater for long periods at levels detected in monitoring wells in the 1980s could cause skin irritation and increase the risk for skin cancer.

9)    "Can you explain to us how people in Hyde Park can be diagnosed and documented with arsenical keratosis by licensed and certified dermatologists if there is no contamination in our area from Southern Wood? Can you explain how a 5-year-old child can have arsenical keratosis on both her hands and feet if arsenic is still not present in our area?"

We assure you there is no current public health hazard from arsenic in the environment. However, arsenical keratosis can persist for long periods. We will continue with the Medical Assistance Plan to follow residents' long-term health status.

10)    "Are you aware that children who attended or are attending Clara E. Jenkins Elementary School have been documented with neurological problems, learning disabilities, allergies, asthma, behavioral problems and growth problems?"

Yes, those concerns were presented at past meetings. We plan to continue with the Medical Assistance Plan to follow residents' long-term health status.

11)    What are some of the potential health effects of past air exposures to wood treating chemicals?

We cannot estimate the levels of the wood treating chemicals present in the air during the time when the plant was in operation. Health effects from long-term, low-level exposure by breathing wood treatment chemicals could include headaches and weariness and possible adverse effects in the blood, central nervous system, eyes, and respiratory system. The Public Health Implications section of the addendum contains a further description of health implications.

12)    "Which ones of the chemicals found in our neighborhood are neurotoxins?"

There are no chemicals in the environment around SWP that are at levels that would be toxic to the central or peripheral nervous system. Lead is present in one ditch, but it is not likely that exposure to lead at the levels found there would result in a significant neurological effect. However, to be safe, workers are removing this lead contamination from the ditch.

13)    "Are you aware that Southern Wood Piedmont used teenagers during their cleanup process and that there were injuries? Are you aware there is documentation on these matters and that there are examples of some of these young people having mental problems?"

As stated before, ATSDR is concerned about possible health implications from past exposures. A Medical Assistance Plan is planned to be implemented in the future. In the meantime, you may instruct the young people to report their exposure experiences to their own physician.

14)    "Will you please explain to us why wouldn't people be dying with cancer, kidney problems etc. with all this chemical exposure? Will you please explain to us exactly what is this plague that all of these agencies are allowing us to suffer through?"

An individual's risk for adverse health effects depends on the dose the individual receives. It is virtually impossible to determine whether a certain cancer or kidney disease is directly related to a chemical exposure, especially since there are so many other causes of these diseases. As a public health agency, we can offer a mechanism for long-term followup from physicians who specialize in assessing health effects related to chemical exposures. We emphasize again that there is no current public health hazard for residents currently living around SWP.

III.    FUTURE PUBLIC HEALTH ACTIVITIES

Residents remain concerned about their health and safety. As we have emphasized throughout the responses to these questions, we believe people are not currently being exposed to contamination and so are safe in their houses and neighborhood. However, we do think that people were exposed to contaminants in the past. Therefore, we have recommended that local physicians be educated on the health effects related to these exposures and that exposure histories and medical monitoring take place as appropriate.

1)    "Many of the residents have not ever been examined by a physician for complaints likely to be related to their environmental exposure.... What is needed is a thorough and complete physical and medical examination of all of the residents of this community."

We agree. The Medical Assistance Plan under development includes a proposal for medical testing, which may include measuring exposure and/or clinical evaluations. Please see the discussions related to the Medical Assistance Plan in the Recommendations section of the addendum.

2)    "The SWP site as it exists today represents an ideal location from which to collect data for future epidemiological studies."

We disagree. Epidemiologic studies, to be useful, require a good measure of exposure. We have very little information on what exposures may have been while the plant was operational. Therefore, we have recommended the Medical Assistance Plan, rather than an epidemiologic study. It is our opinion that the Medical Assistance Plan will be more useful to residents.

3)    "I will be very surprised if your agency found any useful data from the medical records review. Most of these people saw physicians who were not trained sufficiently to suspect exposure, take the necessary history, or order the proper test. ATSDR should include taking medical histories and performing health screening."

The medical records review was one method for assessing the general health status of the community. We have used information from the medical records review when drafting the Medical Assistance Plan. We appreciate the time and effort community members devoted to retrieving these records.

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