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PUBLIC HEALTH ASSESSMENT

SUNFLOWER ARMY AMMUNITION PLANT
DESOTO, JOHNSON COUNTY, KANSAS


COMMUNITY HEALTH CONCERNS

ATSDR identified the following community health concerns through meetings with concerned citizens; contact with SFAAP, Alliant Techsystems, SpecPro, KDHE, and EPA; and review of site documents.

  1. Concern: Worker Exposure

Excavation workers were concerned about their exposure to brown dust and "green ooze"while working at SFAAP.

In 1992, workers who were subcontracted by the Army Corps of Engineers encountered three buried concrete structures while excavating for the construction of the wastewater treatment plant at SFAAP. They noticed a discoloration of the soil, which was described as marbled green/black bands. When the backhoe broke through the concrete structures brown dust and green ooze were released. Contact of this dust and ooze with workers' skin resulted in a severe burning sensation. By the end of that day, workers were experiencing nausea, violent headaches, dizziness, abdominal pain, and loss of appetite. Two to three weeks later, they noticed blistering on their skin. The workers received care from their personal physicians (ATSDR 1993a, 1993b, 1993c, 1993d).

In March 1993, a meeting was held with EPA, ATSDR, and workers who alleged health effects during the excavation. By that time the subcontractor had already excavated to bedrock and the suspect material had been removed to an on-site landfill and replaced with clean fill. The exact area of disposal could not be located, and hence, no samples of the suspect material could be taken. In an attempt to find a residual of the suspect material, soil samples were taken in March 1993 from the area of exposure. EPA performed a standard priority pollutant scan and sampled for explosives. RDX (1.0 to 1.5 ppm), HMX (1.0 to 1.3 ppm), TNT (1.0 to 1.3 ppm), tetryl (1.0 to 1.3 ppm), nitroglycerine (1.2 to 59.0 ppm), and nitrocellulose (7.66 to 12.0 ppm) were detected in the soil. The Occupational Safety and Health Administration (OSHA) sampled and analyzed soil for metals and organics. Metals were not detected much above background levels and dibenzofurans, dibenzothiophene, and polycyclic aromatic hydrocarbons were detected in trace amounts. ATSDR toxicological evaluations concluded that the contaminant levels found could not explain the adverse health effects reported by the workers. Even though it appears that workers were exposed to a chemical that caused acute adverse health effects, ATSDR could not make a toxicologic conclusion about the exposure due to the change in conditions at the exposure site (ATSDR 1993e).

One of the exposed workers was concerned that mustard gas was used for training purposes at SFAAP sometime in the past.

The Army strongly affirms that mustard gas was never manufactured, stored, or even transported through SFAAP (ATSDR 1993b, 1993e).

  1. Concern: Hazardous Waste Being Treated at Kansas Waste Water Treatment, Inc (KWWI), formerly known as Wastewater Treatment, Inc.

Community members re concerned about what KWWI was discharging into the Kansas River (the public drinking water supply). There were reports of an orange-yellow liquid leaking from the KWWI discharge pipe into the Kansas River.

KWWI is a non-hazardous centralized waste treatment facility that leased the Industrial Wastewater Treatment Facility at SFAAP. KWWI signed a 25 year lease to use the facility in 1996. They began operations in November 1997, and began discharging into the Kansas River in March 1998. KWWI's National Pollutant Discharge Elimination System (NPDES) permit is provided in Appendix E. KWWI received non-hazardous wastewater by truck. The facility was equipped to treat wastes falling into three categories: oily, metal-bearing, and organic (Wastewater Treatment, Inc 1999). The definitions for these types of wastes are provided in the Glossary in Appendix C.

KDHE oversaw and monitored KWWI's operations. Within KDHE, four divisions (Bureau of Water, Bureau of Waste Management, Bureau of Air, and Bureau of Laboratories) oversaw different aspects of the waste treatment process. KWWI had a history of noncompliance, violations, and illegal treatment of hazardous waste. In December 1998, EPA began a criminal investigation of the company. In June/July 2000, KDHE Bureau of Water issued an administrative order against KWWI to revoke the NPDES permit. Litigations are ongoing. KWWI chose to terminate their facility use contract as of September 30, 2001. For more information, please contact KDHE at (785) 842-4600.

ATSDR was asked by a concerned citizen to investigate the results from a sample that a trespasser collected in March 1999. He sampled the discharge leaking from a capped valve that emptied into the Kansas River from the KWWI facility. After taking the sample, he was apprehended and the sample was taken from him. ATSDR contacted KDHE's Bureau of Water and Bureau of Waste Management--neither had received the sample. Alliant Techsystems did receive a portion of the sample; however, the liquid was not analyzed because the laboratory was unaware if any sampling protocol had been followed for taking the sample and no chain of custody was provided.

It is ATSDR's understanding that any wastewater generated by KWWI for the last year had been trucked off site to a publically owned treatment works in Kansas City, Kansas. Additionally, KWWI's contract with SFAAP was terminated as of September 30, 2001. Therefore, there are no current and future concerns relating to discharge from SFAAP. Past exposure to wastewater discharged to the Kansas River is difficult to quantify without accurate sampling. The public water being supplied from the Kansas River is presumed to be safe because under the regulatory oversight of KDHE and EPA, water treatment plants select treatment processes that are most appropriate to treat the contaminants found in the water source. However, if the discharge from KWWI was not in compliance with the NPDES permit and the water treatment facility did not treat the water for the illegally discharged chemicals, then the potential existed for untreated chemicals to reach the consumer.

  1. Concern: Local Family Health Concerns

A local family was concerned that there were deformities in their small animals and skin tumors and immune suppression in their horses and themselves that were caused by either contamination from past use of their property by SFAAP or hazardous wastes migrating to their property.

The family lives on a 33-acre farm about ½ mile south of SFAAP. In August 1997, the landowner reported deformities in dogs, cats, and rabbits born on her farm and skin tumors and immune suppression in several horses, her husband, and herself. She also said that trees died after she watered them with groundwater from their private well. The family reported that they do not drink water from their groundwater well. The family, their pets, and their livestock are provided drinking water from a rural water system (Ecology and Environment 1998).

In August 1997, KDHE sampled the groundwater well for pesticides/herbicides, nitrates, and metals. Of the chemicals detected, only nitrate (17.98 ppm) was found at an elevated level. Drinking water with the detected concentration of nitrate could cause oxygen deprivation in young children; however, it is not expected to cause birth defects in small animals or cause healthy trees to die. KDHE also used a Geiger Counter to test for radioactivity; the readings were negative.

In April 1998, EPA sampled surface soil from the farm, water from the well, and surface water and sediment from the intermittent creek in places that people and animals frequent. The samples were analyzed for dioxins, furans, metals, VOCs, SVOCs, PCBs, and explosives. ATSDR carefully reviewed the findings and concluded that none of the chemicals were detected at a level of health concern. EPA and KDHE are in agreement that the types and concentrations of the chemicals detected are not expected to cause birth defects or suppress immune systems.

Even though ATSDR does not know the cause for the birth defects in the small animals or the immune suppression, environmental sampling at the family's farm does not indicate that contamination from SFAAP is causing adverse health effects to the family or their animals.

  1. Concern: Blue Baby Syndrome

Community members are concerned that elevated levels of nitrates are causing blue baby syndrome.

Blue baby syndrome (methemoglobinemia) occurs when a baby does not receive enough oxygen in his/her blood. The condition causes the baby's skin to turn blue (Patterson-Kinsey 1999). Drinking water contaminated with nitrate or nitrite can cause susceptibility to blue baby syndrome because nitrite interferes with oxygen uptake in blood and the body can turn nitrate into nitrite (EPA 1995b). Older children and adults do not convert as much nitrate into nitrite, and therefore, nitrate is of less concern if older children and adults are exposed.

Each public water supplier is required by law to collect water samples at least once a year and test for nitrate/nitrite. If the levels are found to be of concern, the water supplier must treat the water to reduce the amount of nitrate/nitrite. Three methods (ion exchange, reverse osmosis, and electrodialysis) are used to reduce nitrate/nitrite levels and are approved by EPA. With these precautions, ATSDR does not expect an increase in blue baby syndrome from drinking public water. For more information about nitrate/nitrite in drinking water, please visit EPA's website at http://www.epa.gov/OGWDW/dwh/c-ioc/nitrates.html or call EPA's Safe Drinking Water Hotline at 1-800-426-4791 and request the Nitrate/Nitrite Factsheet.

ATSDR evaluated the possibility of blue baby syndrome occurring in children and pregnant women who might drink untreated water from Kill Creek, Spoon Creek, and Captain Creek and concluded that the levels of nitrate/nitrite that were detected in the creeks upstream and downstream of SFAAP were below levels of health concern (Law 1998). For a more complete discussion, please read the Surface Water and Sediment Pathway discussion under the Evaluation of Environmental Contamination and Potential Exposure Pathways section in this public health assessment.

Groundwater at SFAAP does have nitrate/nitrite contamination that would be of health concern if children or pregnant women drank water from the site. However, groundwater at SFAAP is not and has not in the past been used for supplying drinking water. Before people are allowed to install and use groundwater wells at SFAAP (if this is ever planned), additional sampling and remediation would be required. For a more complete discussion, please read the Groundwater Pathway discussion under the Evaluation of Environmental Contamination and Potential Exposure Pathways section in this public health assessment.

  1. Concern: Cattle Grazing

Community members were concerned that beef from cattle grazed at SFAAP could be contaminated with harmful levels of chemicals from past propellant manufacturing activities. There were specific concerns about exposure to dioxins and asbestos.

A large portion of undeveloped land (about 5,500 acres) is leased for cattle grazing and hay production (Burns & McDonnell 1997b, 2002). About 3,000 heads of cattle are grazed at SFAAP each year. Cattle arrive at SFAAP when they weigh 450 to 500 pounds. While at SFAAP the cattle are allowed to roam freely throughout the leasing areas, except where fences prevent their access to some of the SWMUs and forested areas. They graze for approximately 3 months and gain an additional 200 to 300 pounds. After which, the cattle are moved to finish pastures or feed lots in Nebraska and Colorado until they weigh between 1,100 to 1,200 pounds. Once the cattle reach their optimum weight, they are sold to processing plants. (ATSDR 1996a, Burns & McDonnell 2002).

ATSDR addressed a community concern regarding nitroguanidine and other chemicals uptake in beef cattle in a February 1996 public health consultation. After reviewing investigations completed at other munitions plants, examining laboratory research found in scientific literature, and assessing the extent of contamination at SFAAP; ATSDR concluded that uptake of nitroguanidine by cattle grazed at SFAAP is unlikely. For more information, please read the public health consultation provided in Appendix A.

In addition, the Department of Defense initiated a study of the grazing practices at SFAAP in May 1995 (Burns & McDonnell 2002). Soil, surface water, sediment, and vegetation samples were collected from three sampling areas to evaluate the potential for contaminant uptake by the cattle grazed at SFAAP. The samples were analyzed for explosives, metals, PCBs, pesticides, polyaromatic hydrocarbons (PAHs), and dioxins/furans. The study concluded that there is no appreciable concern for human health due to consumption of beef from cattle grazed at SFAAP.

Community members were specifically concerned about exposure to dioxins through eating beef from cattle grazed at SFAAP. Dioxins are a group of 75 different compounds with varying degrees of toxicity. They are primarily released to the environment during combustion of fossil fuels and wood, and during incineration processes. The most common way for dioxins to enter the body is through eating foods contaminated with dioxins. The highest amounts are found in the liver and fat tissue, which can store dioxins for many years (ATSDR 1998).

Dioxins were one of many chemicals evaluated by the Department of Defense during the grazing study (Burns & McDonnell 2002). The researchers analyzed surface soil, sediment, and vegetation samples in the West Sampling Area for dioxins. The methods used to evaluate health concern were based on conservative assumptions that would most likely result in an overestimation of actual exposure. ATSDR reviewed the sampling and analysis procedures, the methods used to evaluate exposure, and the results of the grazing study in addition to the toxicologic literature for dioxins and agrees that dioxins are not expected to be at a level that would produce adverse health effects in people consuming beef from cattle grazed at SFAAP.

Community members were specifically concerned about cattle eating the asbestos off the steam pipes. Asbestos is the collective name for a group of six fibrous minerals that occur naturally in soil and rocks. It is resistant to heat and most chemicals and is used in a variety of manufactured goods (e.g., roofing shingles, ceiling tiles, and car brakes). Most asbestos fibers that are ingested (e.g., by cattle) are not absorbed, but rather are excreted in feces and urine. The few fibers that are absorbed can distribute to other tissues such as the lymphatic system or blood stream, which can carry the fibers to various organs (e.g., lungs, kidneys, liver, spleen, heart, and brain) [ATSDR 1996b, Faust 1995].

Because deposition is not in edible muscle, consumers of beef from cattle grazed at SFAAP would not ingest asbestos via this pathway. Even consuming the organs would probably not result in adverse health effects in humans because for a second time, most of the fibers would not be absorbed by people; resulting in an even lower amount potentially absorbed by the consumer. Long-term studies in rats and hamsters indicate that eating high concentrations (i.e., 1% in the diet or 500 to 800 milligrams per kilogram per day [mg/kg/day]) does not cause systemic health effects. Some histological and biochemical alterations of the gastrointestinal tract were reported for rats eating 50 mg/kg/day of one form of asbestos (Faust 1995). These doses are much higher than what a person could possibly consume from beef with potential asbestos contamination. Average beef consumption for people who live in the Midwest is only about 0.0065 mg/kg/day (EPA 1997), which is well below the levels of pure asbestos that would need to be consumed for adverse health effects to be observed.

  1. Concern: Transfer of Property

Community members expressed concern over the proposed sale of SFAAP to Oz Entertainment Company.

The Kansas Statewide Projects Development Corporation had expressed interest in buying SFAAP and planned on selling it to Oz Entertainment Company, who intended to build a theme park on 1,700 acres in the northeast corner of SFAAP. However, in October 2001, the Johnson County Commission voted to rescind and cancel the financial review and feasibility study and to decline further study or review of the redevelopment proposed by Oz Entertainment Company. Therefore, this issue is no longer of concern.

If any future sales are proposed, ATSDR can assist with evaluating the potential health effects at locations where people may come in contact with contaminated soils. ATSDR recommends that sampling and, if required, remediation at the SWMUs and AOCs be conducted before people come in contact with the soils.

The community is concerned about the sale of the land from federal to private owners. What happens to the cleanup efforts if the new owner goes bankrupt?

If the new owner of SFAAP goes bankrupt and is ununable to complete remediation in a safe and protective manner, the Army is ultimately responsible for making sure all currently known sources of contamination are remediated. EPA and the state of Kansas will maintain oversight of remediation, regardless of ownership of SFAAP.

  1. Concern: Asbestos

Community members are concerned that there is asbestos contamination in the soil underneath the asbestos-insulated steam pipes.

There are many miles of asbestos-insulated steam pipes throughout SFAAP. In many places the outer wrap is in disrepair, allowing the asbestos to detach and fall to the ground beneath the pipeline. Short-term inhalation exposure to high levels of asbestos or long-term inhalation exposure to low levels of asbestos can result in lung disease (e.g., asbestosis and mesothelioma) and/or cancer. Currently, there is no data on asbestos contamination in the soil; however, because there is no public access to SFAAP and even though trespassing has been known to occur, any exposure to asbestos in the soil would have been in low doses and too infrequent to cause adverse health effects. However, because of the adverse health effects known to result from exposure to asbestos, before people are allowed open access to the site, the asbestos in the soil and remaining on the steam pipes should be properly remediated.

For a discussion of the potential ingestion of asbestos via cattle, please read the Cattle Grazing Concern in this section of the public health assessment.

  1. Concern: Burning Buildings

The community is concerned that hazardous air pollutants were released during the open burnings at SFAAP.

ATSDR expects that when proper burning procedures are followed, SFAAP's neighbors were not exposed to harmful levels of airborne contaminants (e.g., asbestos and lead) that were generated during the open burnings. For a more complete discussion, please read the Air Pathway discussion under the Evaluation of Environmental Contamination and Potential Exposure Pathways section in this public health assessment.

It is ATSDR's understanding that an additional 200 to 300 buildings are planned to be demolished sometime in the future. However, because the explosive contamination that is present in the buildings is not friction sensitive, the asbestos shingles and siding will be removed before the buildings are burned (KDHE 2001c).

Community members are concerned that ash landing on their properties contains asbestos.

To address this concern, KDHE proposed to sample residential yards near SFAAP for asbestos (and lead) contamination as a result of the open burning (KDHE 2001d). However, the residents have so far declined the offer (personal communication with KDHE representative, 12/01).

During demolition of buildings that do not pose an unacceptably high safety risk, asbestos siding and shingles are removed prior to burning. When this is done, asbestos materials will not migrate into private property. When burning buildings with asbestos-containing materials is unavoidable, control systems such as the use of water curtains, with close monitoring by trained personnel, are implemented to help contain the asbestos material. During the 2000 visit, ATSDR had the opportunity to witness the meteorological monitoring procedures used prior to burning activities. Burning is only done under conditions of low wind speed and moderate to stable atmospheric conditions to minimize dispersal of asbestos-containing ash (Stutz 1997).

However, there were incidences where debris from the open burning was transported off site (e.g., when buildings not slated to be burned caught fire as a result of an explosion at the controlled burn and when the water curtain pump failed). In both instances SFAAP and Alliant Techsystems met with KDHE to discuss the issue of potential asbestos (and lead) releases and implemented measures to prevent these kinds of events from occurring again (e.g., the wind speed and air stability criteria were adjusted to be more conservative and a backup pump system was installed) [KDHE 2001a, 2001b].

At a January 2000 meeting ATSDR conducted with the community group TOTO, a member brought a piece of ash collected after a burn to ATSDR's attention. The next day, Mr. Tim Davis from Alliant Techsystems looked at the ash and verified that it did not contain asbestos. The ash did not contain the characteristic fiber layer that would denote the presence of asbestos.

A former employee of a subcontractor was concerned that burning was done during inappropriate weather conditions.

There are no records that such activities occurred under inappropriate weather conditions. ATSDR has no knowledge either to support or deny this concern. However, as stated above, ATSDR has witnessed the meteorological monitoring that takes place during burning activities. When burning is conducted under appropriate weather conditions, particulate matter will settle out of the emission plume and gaseous compounds will be diluted to acceptable concentrations before reaching SFAAP borders. The following are factors that represent acceptable burning conditions (CHPPM 1997).

  • The wind direction is determined by the location of the building to be burned relative to the plant boundary. The plant boundary that is the greatest distance from the proposed burn is the same direction the wind is to be blowing, to allow the plume to travel the greatest distance before leaving the site.

  • Calculated stability ensures conditions in which airborne particles are not carried high into the atmosphere.

  • Low to mild wind speeds are advantageous because they ensure that the airborne particles do not travel far before settling out.

  • A light precipitation or early morning light ground-based fog represent stability conditions that would also be acceptable for burning.
  1. Concern: Nitrocellulose

SFAAP personnel requested that ATSDR specifically evaluate the health effects expected from exposure to nitrocellulose.

Nitrocellulose is a cotton-like white solid that does not easily biologically degrade in the environment. The available studies indicate that ingestion of nitrocellulose does not result in adverse health effects unless ingested in enormous quantities (e.g., 10% of the total diet), in which case the animals died from intestinal obstruction (EPA 1992).


ATSDR CHILD HEALTH INITIATIVE

ATSDR recognizes that infants and children may be more sensitive to environmental exposure than adults in communities faced with contamination of their water, soil, or air. 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 outdoors; (2) children are shorter than adults and therefore 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. ATSDR is committed to evaluating children's special interests as part of the its Child Health Initiative in evaluating sites such as SFAAP.

ATSDR did not identify any situations where children were being exposed to harmful levels of contamination originating from SFAAP. Although not confirmed, the potential does exist for children to be exposed to drinking water from nine off-site groundwater wells. ATSDR based this conclusion on the following factors:

  • ATSDR does not expect harmful levels of asbestos or lead to migrate off site when burning is conducted during appropriate conditions and control measures are implemented. However, due to the potential for the airborne lead to deposit in residential soils, ATSDR suggests that SFAAP provide assurance through soil surveys that levels are not and will not exceed those of health concern for children.

  • Contamination from SFAAP is not negatively affecting the public drinking water source, the Kansas River and Kansas River Valley alluvium. The water is treated prior to its use and is not expected to contain harmful levels of contamination.

  • Children may be incidentally exposed to contaminants in the surface water and sediment if they play in Kill Creek, Spoon Creek, or Captain Creek; however, the levels of chemicals detected in the creeks were too low to be of health concern for children.

  • Children are not coming in contact with contaminated soil. It is highly unlikely that small children would be able to trespass onto SFAAP property because access to the site is restricted. Even if children were to access the site, many of the SWMUs are fenced and the type of incidental and infrequent exposure expected to result from trespassing would not cause adverse health effects.

  • There is no evidence that contamination at off-site groundwater wells has occurred. However, nine off-site wells have the potential to be influenced by site-related groundwater contaminants because data from four SWMUs and one AOC and sampling from these wells are not currently available.

CONCLUSIONS

ATSDR has drawn the following conclusions from the available environmental data and information concerning SFAAP:

  • ATSDR does not expect that people who live around SFAAP were exposed to harmful levels of airborne asbestos or lead generated during the open burning when proper burning procedures were followed. Asbestos was not detected during any of the test burns and the levels that could be present, if more sensitive methods of detection were used, would not be expected to produce adverse health effects. Sampling and modeling of lead levels indicate that the concentrations would not be at levels of health concern by the time the plume reaches SFAAP's fenceline.

  • Kill Creek, Spoon Creek, and Captain Creek drain several contaminated areas at SFAAP. Some of the concentrations of chemicals detected in the surface water and sediment exceeded comparison values, however, after further analyses, the resulting exposure doses were determined to be below levels of health concern. Therefore, recreational exposure to the surface water and sediment in Kill Creek, Spoon Creek, and Captain Creek are not expected to cause adverse health effects in children who may play in the creeks.

  • Contamination from SFAAP is not negatively affecting the public drinking water source (i.e., the Kansas River and Kansas River Valley alluvium). Even though Kill Creek, Spoon Creek, and Captain Creek flow into the Kansas River, the chemicals that were detected are not likely to influence the public water supply three miles away because of the type of contamination detected and the resulting doses from the concentrations detected were below levels of health concern.

  • Access to SFAAP has always been and still is restricted by fences and an armed guard. No adverse health effects are expected since no one is coming in contact with contaminated soil on a regular basis. Even the occasional trespasser is not contacting potentially contaminated soil often enough or in high enough doses to be a cause for health concern. At this time, no definitive plans for the future use of SFAAP have been made. Continued soil sampling and appropriate remediation is necessary before people are allowed access to the soil at SFAAP.

  • The groundwater at SFAAP is contaminated, however, no on-site exposures are occurring because no one is drinking groundwater from on-site sources. There are 22 off-site private groundwater wells being used to supply water to households within 1 mile of SFAAP. Hydrogeologic and sampling data suggests that groundwater contamination at SFAAP is not negatively affecting the quality of drinking water at 13 of these private wells. ATSDR cannot determine the impact to nine of the private drinking water wells because data that dismisses the potential does not exist at this time. This does not imply that these wells are being negatively affected, simply that additional sampling is necessary before a determination can be made.

  • The workers who came in contact with brown dust and "green ooze" while excavating at SFAAP in 1992 were allegedly experiencing short-term exposure to a chemical that caused them to experience adverse health effects. However, because no sampling of the suspect material could be done, ATSDR could not make a toxicologic conclusion about their exposure.

  • The community concern regarding the discharge from KWWI into the Kansas River appears to have merit. Given KWWI's history and ongoing litigations, the potential existed for unknown chemicals to have been discharged into the Kansas River. Even though water treatment plants are regulated by KDHE and EPA to provide safe drinking water to the public, they could have inadvertently not used the appropriate treatment if unknown chemicals were discharged to the Kansas River by KWWI. However, since KWWI has not discharged into the Kansas River for the past year and their contract with SFAAP was terminated as of September 30, 2001, the potential threat is no longer occurring.

  • A local family expressed a concern that certain health effects seen in their animals and themselves were the result of their property being contaminated. KDHE and EPA sampled various media at their farm and did not detect any chemicals that would cause the health effects mentioned. ATSDR evaluated the information and concurs with KDHE and EPA's conclusion.

  • Drinking water with elevated levels of nitrate or nitrite can cause a depletion of oxygen in the blood and result in what is commonly known as blue baby syndrome. The public water supply is closely monitored and regulated for nitrate and nitrite; therefore, it is not expected that drinking this water would cause blue baby syndrome. ATSDR evaluated the levels of nitrate and nitrite detected in Kill Creek, Spoon Creek and Captain Creek; the concentrations detected were too low to be of health concern for children and pregnant women. Groundwater at SFAAP is not being used for drinking and there is no evidence of any off-site migration of elevated levels of nitrate or nitrite into private wells.

  • Eating beef from cattle grazed at SFAAP is not expected to cause any adverse health effects. Specifically, nitroguanidine and asbestos are not expected to accumulate in the parts of the cattle that are eaten and dioxins are not expected to be at a level that would produce adverse health effects in people consuming beef from cattle grazed at SFAAP.

  • The proposed sale of SFAAP property to private ownership before the cleanup is complete has raised some concerns by the community. Regardless of ownership of SFAAP, EPA and the state of Kansas will maintain oversight of remediation.

  • Miles of asbestos-covered steam pipes are located throughout SFAAP. Given the known health effects from exposure to asbestos, ATSDR recommends that the soils be remediated to appropriate standards before people are allowed open access to the site.

  • Based on the available studies, nitrocellulose in the environment does not pose a health concern to humans because it is not hazardous unless ingested in very large quantities, at which point it may block the digestive tract.

PUBLIC HEALTH ACTION PLAN

The Public Health Action Plan for SFAAP contains a description of actions taken and those to be taken by ATSDR, the Army, EPA, and KDHE at and in the vicinity of the site after 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 public health hazards, but also provides a plan of action designed to mitigate and prevent adverse human health effects resulting from exposure to hazardous substances in the environment. The public health actions that are completed, ongoing, planned, or recommended are as follows:

Actions Completed:

  • The Army has identified 65 SWMUs that may affect human or environmental health. Of these, two SWMUs (28 and 29) received clean closure from EPA and KDHE and the RCRA response is complete at SWMU 23. The Army conducted interim measures at SWMUs 50 and 54 and a corrective measure study is complete for SWMU 22.

  • In 1995, EPA proposed SFAAP for the National Priorities List, however, it was never listed.

  • Through the Environmental Stabilization Program 1,463 accounts that previously manufactured nitrocellulose, nitroglycerine, multi-based propellant, or were support facilities for propellant manufacture were disposed of through open burning. In addition, asbestos-containing material was removed from 455 accounts.

Actions Ongoing:

  • RCRA Facility Investigations are being conducted on 44 SWMUs to identify the type of contaminants present. At 12 SWMUs (14, 19, 20, 33, 34, 35, 37, 39, 44, 46, 48, and 52), the contaminants have been identified and various cleanup options for the sites are being assessed. Two sites (SWMUs 10 and 11) have remediation plans and the Army is implementing corrective measures at them. Two SWMUs (41 and 42) have additional investigative work planned. Three sites (SWMUs 13, 27, and 41) are undergoing long-term monitoring.

Actions Planned:

  • The Army is planning to resample at 18 of the 26 SWMUs determined to have unusable data (7, 8, 9, 15, 16, 17, 20, 25, 26, 30, 38, 40, 43, 44, 45, 46, 49, and 52). Additional sampling is planned for 10 SWMUs (2, 4, 6, 12, 14, 18, 19, 24, 31, and 36). Long-term monitoring is planned for seven SWMUs (10, 11, 12, 22, 24, 32, and 48). The Army is planning interim remedial actions at six SWMUs (18, 19, 21, 33, 34, and 35). RCRA field investigations are planned for SWMUs 39 and 53. The Army plans to close the ponds or lagoons at seven SWMUs (4, 5, 6, 12, 13, 31, and 40). Excavation and/or remedial activities are expected at 13 SWMUs (10, 11, 13, 24, 31, 32, 36, 37, 40, 46, 47, 51, and 54).

  • The Army is planning to being investigations at the 22 AOCs in 2003.

  • If SFAAP is sold prior to the completion of the required remediation, deed restrictions will be imposed to limit exposure to contaminated soil, groundwater, and facilities that may adversely affect human health. KDHE, the Governor of Kansas, Johnson County Environmental Department, and EPA will all provide oversight to different aspects of the process.

Recommendations for Further Action:

  • Currently many of the SWMUs do not have usable soil data upon which to make a health decision concerning the potential future use of SFAAP. ATSDR agrees that the planned sampling should continue and recommends that the soil contamination be properly remediated before people have access to the site. If plans are made for SFAAP to be opened to the public and sampling data are available, ATSDR can provide assistance in determining appropriate health-based cleanup levels specific to proposed future uses.

  • ATSDR cannot determine the potential impact from SFAAP to nine off-site, private groundwater wells. In order to provide the data needed for the evaluation, ATSDR agrees that the planned sampling at SWMUs 44, 45, and 49 should continue and encourages plans be made to sample SWMUs 57 and 59 and AOCs 14 and 17. Because sources other than SFAAP have the potential to affect the water quality at private groundwater wells, ATSDR suggests that private well owners regularly test the water from their wells to ensure that the water is safe to drink.

  • When the building burns do begin again, SFAAP should continue to notify residents, especially sensitive populations, when the open burnings are scheduled, so that they can take measures to reduce their exposure.

REFERENCES

Department of the Army (Army). 2000. Letter to Ralph Burns from Dennis Karns concerning updates to the FY 2001 Installation Action Plan. Kansas City, MO. March 9, 2000.

Aguirre Engineers, Inc. (Aguirre). 1998. U.S. Army Industrial Operations Command. Environmental Baseline Survey Report. Sunflower Army Ammunition Plant (SFAAP). Englewood, CO. August 1998.

Agency for Toxic Substances and Disease Registry (ATSDR). 1993a. ATSDR record of activity for communication with an EPA representative. Atlanta, GA. February 9, 1993.

ATSDR. 1993b. ATSDR record of activity for communication with Army and ATSDR representatives. Atlanta, GA. February 12, 1993.

ATSDR. 1993c. ATSDR record of activity for communication with an EPA representative. Atlanta, GA. March 11, 1993.

ATSDR. 1993d. ATSDR record of activity for a meeting with EPA and ATSDR representatives and workers from Metropolitan Excavating Company on March 10, 1993. Atlanta, GA. March 12, 1993.

ATSDR. 1993e. ATSDR record of activity for communication with EPA and ATSDR representatives. Atlanta, GA. June 14, 1993.

ATSDR, 1994. Preliminary Public Health Assessment, U.S. Smelter and Lead Refinery, Inc.
(a/k/a USS Lead Refinery Inc.) East Chicago, Lake County, Indiana, Indiana State Department of Health. August 24, 1994.

ATSDR. 1995. Site Summary: SFAAP. Atlanta: U.S. Department of Health and Human Services. December 1995.

ATSDR. 1996a. Health Consultation concerning SFAAP. Atlanta: U.S. Department of Health and Human Services. February 27, 1996.

ATSDR. 1996b. Asbestos ToxFAQ. Atlanta: U.S. Department of Health and Human Services. September 1996.

ATSDR. 1997. Public Health Assessment, Murray Smelter, Murray, Salt Lake County, Utah. January 3, 1997.

ATSDR. 1998. Toxicological Profile for Chlorinated Dibenzo-p-dioxins. December 1998.

ATSDR. 1999a. Toxicological Profile for Lead. July 1999.

ATSDR. 1999b. Toxicological Profile for Asbestos. August 1999.

Burns & McDonnell. 1997a. U.S. Army Corps of Engineers. Community Relations Plan and Addenda. SFAAP. Kansas City, MO. January 27, 1997.

Burns & McDonnell. 1997b. U.S. Army Corps of Engineers. Geology, Hydrogeology, and Groundwater Quality. SFAAP. Kansas City, MO. May 1997.

Burns & McDonnell. 1999. U.S. Army Corps of Engineers. Off-site Well Inventory Report at SFAAP. Kansas City, MO. August 1999.

Burns & McDonnell. 2002. U.S. Army Corps of Engineers. Final Grazing Study Report. SFAAP. Kansas City, MO. January 2002.

Burns RC. 2000. Installation Action Plan. SFAAP.

United States Army Center for Health Promotion and Preventative Medicine (CHPPM). 1997. Open Burning Air Sampling Plan for Possible Lead and Asbestos. SFAAP. February 11, 1997.

City of DeSoto. 2000. Letter to Ben Puesta from Doug Smith concerning the well field and water plant at SFAAP. DeSoto, KS. Letter faxed on February 7, 2000.

DeSoto, Kansas Website. October 26, 1999. Available from URL: http://www.desotoks.com/index.html.

Ecology and Environment, Inc. 1998. Memorandum to Paul Doherty, EPA from Lynn Parman, E&E concerning the Superfund pre-CERCLIS Site Screening Assessment. Overland Park, KS. August 11, 1998.

EnviroVisions, Inc. 1997. Alliant Techsystems. Aerial Plume Emissions Measurement Report. SFAAP. McLean, VA. April 15, 1997.

United States Environmental Protection Agency (EPA). Region 7. 1989-1996. Data from the STORET Legacy Data Center. Organization Code/ Station ID: 1117MBR /008268. Available from URL: http://www.epa.gov/storet/index.html .

EPA. 1992. Drinking Water Health Advisory: Munitions. eds. Roberts WC and Hartley WR . Boca Raton, FL: Lewis Publishers. p. 181-199.

EPA.1995a. NPL Site Narrative at Listing. SFAAP. Available from URL: http://www.epa.gov/superfund/sites/npl/nar1451.htm .

EPA. 1995b. National primary drinking water regulations: Nitrates and nitrites. Washington, DC: October 1995.

EPA. 1997. Exposure Factors Handbook. August 1997. Available from URL: http://www.epa.gov/ncea/exposfac.htm .

EPA. 1999. Letter to Thomas Stutz from Kenneth Herstowski concerning RCRA Facility Investigation. Kansas City, KS. November 12, 1999.

EPA. 2000a. National Priorities List Sites in Kansas, Sunflower Army Ammunition Plant. Last updated on November 6, 2000. Available from URL: http://www.epa.gov/region07/superfund/npl_files/sunflower_army_ammun.pdf .

EPA. 2000b. Final Permit Modification: Part II of the Hazardous Waste Management Permit at SFAAP. 2000.

Faust RA.1995. Oak Ridge Reservation Environmental Restoration Program. Toxicity Summary for Asbestos. Oak Ridge, TN. August 1995.

General Services Administration (GSA). 1999. Environmental Assessment. SFAAP. Fort Worth, TX. December 1999.

Johnson County Planning Department. 1998. Conceptual Land Use Plan. SFAAP. Olathe, KS. July 23, 1998.

Kansas Department of Health and Environment (KDHE). 2001a. Letter to Penny Severtson from Russ Brichacek concerning the burned debris found on neighboring properties in late January and early February 2001. Topeka, KS. May 10, 2001.

KDHE. 2001b. Letter to Jeff Kellam from Randall Carlson concerning the Draft Public Health Assessment for SFAAP. Topeka, KS. June 7, 2001.

KDHE. 2001c. Letter to Rick Bean from Randy Carlson concerning potential asbestos and lead releases to residences adjacent to Sunflower Army Ammunition Plant. Topeka, KS. July 17, 2001.

KDHE. 2001d. Letter to Penny Severtson from Randolph Brown concerning Sunflower residential yards site. Topeka, KS. August 10, 2001.

The University of Kansas (KU). 2001. Letter to Gayla Fraser from Dr. Glen Marotz concerning comments on ATSDR's Public Health Assessment for Sunflower Army Ammunition Plant. Lawrence, KS. June 21, 2001.

Law Engineering and Environmental Services, Inc. (LAW). 1997. U.S. Army Corps of Engineers. Final General RCRA Facility Investigation Report. SFAAP. Kennesaw, GA. February 1997.

Law. 1998. U.S. Army Corps of Engineers. Final Ecological Risk Assessment RCRA Facility Investigation. SFAAP. Kennesaw, GA. August 1998.

Patterson-Kinsey L. 1999. Blue-Baby Syndrome and Nitrogen Compounds. July 1, 1999.

Stutz TG. 1997. Action Memorandum. SFAAP. February 12, 1997.

Sunflower Army Ammunition Plant (SFAAP). Draft Finding of Suitability for Early Transfer (FOSET). DeSoto, KS. July 23, 1999.

Wastewater Treatment, Inc. 1999. Facility Operations.



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