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PETITIONED PUBLIC HEALTH ASSESSMENT

LAFARGE CORPORATION - ALPENA PLANT
ALPENA, ALPENA COUNTY, MICHIGAN


RESPONSIVENESS SUMMARY

The MDCH released a draft of this Public Health Assessment for public comment on April 27, 1999. The Public Comment Period lasted until May 27, 1999. The MDCH received extensive comments from an Alpena resident. Our responses to these comments are given below. Page numbers refer to the draft reviewed, and may have changed in this current draft.

General Comments:

Comment: A complete examination and statistical analysis of death certificates of Alpena County would provide a considerable measure of confidence for the health assessment. I have reviewed Alpena County death certificates for 1975, 1989, 1990, and 1991. I am not a statistician.

My review showed that about 42% of cement plant workers, who died in the years 1989, 1990, and 1991 died with cancer of one kind or another. I included leukemia as a cancer. Please note that I counted all WITH cancer at death. Some of these had another cause of death, but listed a cancer also. Most had cancer as the primary cause of death.

Response: In general, one type of cancer is associated with an exposure to a known or suspected carcinogen. For example, an increase in one type of cancer could suggest exposures to certain known or suspected carcinogens that have been associated with the cancer type. Similarly, an exposure to a known or suspected carcinogen could lead to surveillance of certain cancer types that have been associated with the carcinogen. The MDCH statistical analysis did not find obvious elevations in the number of cancer cases and deaths for the 20 major anatomical categories of cancer (cancer categories) for Alpena County and zip code 49707.

Comment: About 7% of all City of Alpena and Township of Alpena residents who died in 1989, 1990, and 1991, died of some form of lung cancer. This included one case of mesothelioma.

Response: Cancer cases and deaths for each of the 20 cancer categories that occurred from 1985 through 1995 were investigated for both Alpena County and the zip code (49707) that contains the City of Alpena. Specific histological cancer types were not investigated. Statistical analyses of specific histological cancer types are conducted when numbers of cases or deaths of specific cancer categories remain elevated over time as compared with the entire State of Michigan. The numbers of lung and bronchus cancer cases and deaths in Alpena County and zip code 49707 were not elevated as compared with the entire State of Michigan.

Comment: I chose 1975 as a date prior to Lafarge, hydrogen chloride and hazardous waste. The unborn and young children had a worse time of it then. For all persons in Alpena Township and the City of Alpena, death with cancer was about 25%. Among cement plant workers, the death with cancer rate was about 25%. From this it appears that the rate of cancer at least among cement plant workers has increased from 1975 to 1990.

`Response: The Michigan Cancer Registry was started in 1985 and accurate time trends for the number of cancer cases and incidence rates cannot be studied before 1985. Consequently, the MDCH conducted statistical analyses of cancer cases and deaths for the 20 major anatomical categories of cancer (cancer categories) for Alpena County and zip code 49707 beginning with 1985 cases. Cancer deaths before 1985 were not included in the analysis because DVRHS conducts paired cancer cases and cancer deaths analyses for each cancer category.

Comment: Based on my amateur statistics, I ask that the MDCH review the last twenty years of Alpena County death certificates on a township and city basis. I ask this so that for each year, every cause of death and any other health conditions are counted and tabulated. Also a break down for each major employer should be given. I chose twenty years, because trends of increase or decrease in a health condition could be seen. We have a small population, so more years of data might be needed to give a complete picture.

Please do not refuse to do this based on ideas that different doctors list causes of death differently, or some death certificates are not explicit about who a person's employer was. I would say that if you do the best you can with the available records, and then let the public have all the tabulated findings, then people would be impressed with the presentation of the information. It is easy to find out where persons in Alpena worked. If the MDCH wants that information complete, all they have to do is make a list of names with residence addresses at death and give the list to our county committee. We can find out fast.

More than anything else the MDCH could do, this kind of complete review of death certificates and fetal deaths would be appreciated. All the possible work that might study contamination levels would cost much more than this statistical analysis of death certificates. Contamination and toxic release studies are quite speculative given our present level of knowledge.

One reason to do a review of death certificates is to compare them with the state health registry to see if they agree. I think that the state registry is missing some information.

Response: The Michigan Resident Death Files (MRDF) have a high degree of reporting completeness. Therefore, manual tabulation of death certificate data is not necessary. Workplace location is not part of the MRDF database. Data quality could be a problem with other sources of workplace location information.

Comment: p. 1. Rather than writing that Lafarge has recently begun using hazardous waste, please put the date in. It has been more than ten years.

Response: The date has been added.

Besides being in consistent violation of a Consent Order regarding hydrogen chloride emissions, Lafarge has hundreds of other environmental violations. Reported violations greatly reduced during 1997 through the present.

Response: Thank you for the information.

Levels of benzene and carbon tetrachloride surprise me. Where do these come from?

Response: Both benzene and carbon tetrachloride are ubiquitous in the environment, from various industrial, commercial, and residential releases. Carbon tetrachloride does not readily degrade, so the environmental load is steadily increasing. Since carbon tetrachloride is also volatile, it can be carried vast distances from its source. The carbon tetrachloride concentrations found in Alpena air were comparable to those found in rural locations (55).

In urban areas benzene might come from gasoline stations, but Alpena has a lower population. So, there are fewer gas stations, and less gas is pumped.

Response: Alpena has the population density of a urban area, by U.S. Census Bureau definition (Help Screen, CensusCD software, Reference 7). The maximum concentration found in Alpena's air is on the low side of the range found in urban areas (Reference 46, Table 5-2).

Could the benzene come from Lafarge's crushing operations? Several years ago, the MDEQ discussed requiring Lafarge to burn off its VOC emissions from its rock crushing operations. Was this ever implemented?

Response: We do not know whether that specific remedy was ever implemented. However, the VOC emissions no longer pose a problem. The high VOC emissions occurred when the company used oil-containing shale as fuel, and some of the organic material within the rock volatilized during the crushing operation. Lafarge has since changed its raw material mix, no longer using the oil-containing shale, and those emissions have been lowered dramatically (97).

Throughout the report levels of contaminants are referred to as being at levels typically found in urban areas. Does this mean that levels found in urban areas are safe or desirable?

Response: If a contaminant is found at levels comparable to those typically found in urban areas, there are likely to be multiple sources for the chemical besides the facility under investigation. In addition, health effects from exposure to that chemical are not likely to occur more often in the target community than in another city.

Also, while perhaps benzene is found at this level in urban areas, do the same urban areas also have the methanol, formaldehyde, toluene, diethanolamine, xylene and other contaminants all in close proximity?

Response: Although the specific chemicals present vary widely, the air in any urban industrialized area contains a mixture of various chemicals. As for the specific chemicals you mention, benzene, toluene, and xylene are components of gasoline, and therefore are frequently found together in urban environments. The toluene and xylene concentrations in the air in Alpena are well within the range found in urban and even some rural areas (98, 99). Many household, industrial, and commercial products contain formaldehyde. Formaldehyde has been found in the ambient air in many cities (100). The U.S. EPA Toxic Chemicals Release Inventory for 1997 contains records of hundreds of facilities nationwide that reported releases of diethanolamine, formaldehyde, methanol, or more than one of the chemicals (12).

Comment: p. 2. The former quarry site is sometimes referred to as "Pike's Peak." It might be good to give it this label. Discussion of the three CKD disposal sites gets a little confused at points in the draft, because two of the sites are quarries.

Response: The text has been revised to cite this name and the name by which the MDEQ refers to the property, the Wessel Road Quarry.

Comment: p. 3. It would be helpful to note that recent health studies have found that metallic particulate matter inflames human lungs and has been linked to some respiratory illnesses.

Response: A paragraph discussing the health effects from airborne particulate matter has been added to the assessment.

Also note that 2.5-micron size particles are absorbed into the blood stream from the lungs during respiration. And note that Lafarge releases metallic particulate matter at 2.5 microns and smaller.

Response: Thank you for the suggestion. The U.S. EPA has proposed new air quality standards for particulate matter less than 2.5 microns in diameter (50). However, in the absence of data on airborne particulate matter in this size range in Alpena, any statement about the possibility of health effects from this cause would be very speculative. The MDEQ is planning to install a monitor to measure particulate matter smaller than 2.5 microns in Alpena.

While some believe that chloride is released from limestone and other raw material, please note that Lafarge has been cited for exceeding its chloride feed limits. Chloride is fed into the mix as an additive to reduce the levels of magnesium and potassium in the cement product. The chemicals are deleterious to cement.

Response: Thank you for the information.

Comment: p. 4. A "physician" should be changed to chiropractor.

Response: The text has been changed to indicate the branch of medicine the petitioner practices.

Comment: p. 6. Note the high level of poverty among the most exposed to pollution population. Because they have less money, they have less access to health care, and so their health problems are less likely to be medically identified and recorded.

Response: MDCH shares your concern about the disproportionate effect of environmental pollution on the less affluent members of the population.

How close is the City of Alpena rain water discharge to the city water intake?

Response: There is a storm sewer discharge within 1,000 feet of the city water intake. The Michigan Department of Transportation recently installed the discharge to take runoff from U.S. 23 south (101). The Alpena city storm sewers discharge into the Thunder Bay River, approximately 1 mile from the city water intake (102).

What does federal law require as a separation between the two?

Response: Federal regulations do not appear to specify such separation. Under the U.S. EPA's National Pollutant Discharge Elimination System (NPDES), which regulates at least some storm sewers (see 40 CFR 122.26):

(b) Impact of discharge on public water supplies.

(1) The applicant's modified discharge must allow for the attainment or maintenance of water quality which assures protection of public water supplies.

(2) The applicant's modified discharge must not:

(I) Prevent a planned or existing public water supply from being used, or from continuing to be used, as a public water supply; or

(ii) Have the effect of requiring treatment over and above that which would be necessary in the absence of such discharge in order to comply with local and EPA drinking water standards.(18)

Comment: p. 12. Why is the source of the dioxin not known? There has been stack testing at Lafarge for dioxins. If dioxins are released from Lafarge, can't the report say that at least some of the dioxin is coming from Lafarge?

Response: There have been several documented other incidents of releases of dioxin into the environment within the watershed of Lake Huron. Large predator fish such as lake trout and whitefish range widely within the lake. The text has been changed to make it clear that Lafarge is also a source of dioxin.

Comment: p. 13. "Reasonably conservative assumptions," is hard to believe. Do these assumptions account for exposure to kiln upsets? Have there ever been any studies of how often kiln upsets occur, and what amounts and kinds of pollution are released during kiln upsets?

Response: MDCH is not aware of any studies of kiln upsets, their frequency, or the nature of the emissions during them. MDCH is working with the available environmental data and is in the process of acquiring additional data on HCl.

Please refer to Internet web site http://www.scorecard.org for Environmental Defense Fund information about the contaminants in Alpena, as to amounts, kinds and health end points. Has the assessment included contaminants that are known to affect some persons more than other persons? What about the most sensitive persons exposed to toluene?

Response: The standards used for selecting chemicals for detailed evaluation were developed to account for and protect the most sensitive human populations.

Comment: p. 15. Releases of pollution are not the same as the chemicals used by industry. For instance, Fletcher Paper releases toluene, even though it buys none, and ABTCO releases formaldehyde even though it does not add it to the product. These are byproducts made in the manufacturing process.

Response: MDCH agrees that the U.S. EPA's Toxic Chemical Release Inventory (TRI) is not necessarily a complete listing of all chemicals released into the environment, one shortcoming being the problem you cite. It is indeed possible that a facility might release a large amount of some toxic chemical while never using, manufacturing, or processing enough of any chemicals on the TRI's list to be required to file reports with the TRI. The passage commented upon was intended to describe one limitation of the TRI.

The Paxton Quarry is no longer used. There are concerns that the water pumped out of the quarry may be diverted into a nearby stream , thus giving it a strong yellow color.

Response: Thank you for the information. MDCH has discussed your concerns with the MDEQ.

Comment: p. 16. I hope the MDCH issues some kind of warning that ground water near Pike's Peak and privately taken water from some places in Thunder Bay should be tested before human consumption. It is conceivable that residences may drill wells near Pike's Peak. That area is developing.

Response: Until now, the MDCH has not seen any data indicating that the groundwater in the "Pike's Peak" a.k.a. Wessel Road Quarry area is contaminated. The MDEQ started an investigation of the area in September 1999. The MDEQ and MDCH share your concern that the CKD in the Wessel Road Quarry probably impacts the groundwater in much the same way as the CKD does under the lakeshore CKD pile. The MDEQ investigation will include investigation of the groundwater as resources permit (4, 5).

Comment: p. 19. "None of the arsenic concentrations was outside the range found in Michigan background soils." It is not clear to me that the levels of arsenic are safe or not safe throughout the draft.

Response: Exposure to background concentrations of arsenic in soil has not caused any documented adverse health effects, or at least, will not cause more adverse effects in one locality more than another. Certain risk calculations do indicate that there is some risk of adverse health effects from exposure to soils containing the background levels of arsenic found in pristine natural soils; however, these calculations include assumptions that are not necessarily realistic. For example, as mentioned in footnote 17 on page 30, a child subject to pica behavior might ingest as much of the metal as has been observed to cause an adverse health effect after chronic exposure. However, pica is a short-lived behavior, and the resultant dose estimates should properly be compared only with exposure doses connected with health effects upon short-term exposure. The documented health effects were from exposures through drinking water; however, experiments indicate that arsenic is from 3.5 to 10 times less readily absorbed from soil than from water. Cancer risks are generally estimated assuming that any exposure results in some finite increase of risk, proportional to the dose, though a very small dose might result in an increased cancer incidence only in a very large population. However, there is evidence that the published proportionality constant might overestimate the actual increased cancer risk, to the point that low doses of arsenic might actually pose no increased cancer risk at all (28).

Comment: p. 24. It is troublesome that the draft indicates that there is a source of dioxin and that in the draft it says that some readings are above levels of concern, and yet there is no recommendation that someone find the source of dioxin. If there is a level of concern, why not address it? (And Page 31).

Response: The appropriate agencies are already investigating to find and eliminate the source of the dioxins in the air and the fish.

Comment: p. 31. Why are there no dioxin advisories for fish in Thunder Bay?

Response: There are advisories due to dioxin in place for lake trout and lake whitefish from Lake Huron, including Thunder Bay.

Comment: p. 32. The first sentence of section D means almost nothing. All it says is that if some other city has the same kind of pile of CKD Alpena has, then the two piles pose the same risk to both cities. This says nothing about what the risk is, or is not. Wherever the risk is, it is the same risk, so what is the point of the sentence? Is the risk acceptable? DO other cities with comparable industrial facilities have something to worry about?

Response: There are physical hazards in any city, including automobile accidents, household accidents, workplace accidents, and tripping and falling on uneven terrain. These hazards are almost completely determined by the population density and surface topography of an area, and nearly independent of the specific industrial or commercial activity within the area. Most residents of a city have implicitly accepted the level of such risks inherent to the area.

Comment: p. 34. Does the fact that many cities have similar concentrations of many (although not all) of these chemicals make these levels safe or desirable?

Response: As mentioned above, if a contaminant is found at levels comparable to those typically found in urban areas, there are likely to be multiple sources for the chemical besides the facility under investigation. In addition, health effects from exposure to that chemical are not likely to occur more often in the target community than in another city.

Comment: p. 35. How can we believe that since these chemicals are found in CKD and the CKD was released without environmental controls for decades, that we do not know where the levels of lead, arsenic, and other metals come from? To the extent that CKD was scattered over Alpena, it has contributed to the existing levels.

Response: The soil throughout Alpena is most likely part CKD because of the historic air transport of the material from what is now the Lafarge plant. However, there is no way to determine how much of the metals in the soil came from the CKD. There have not been any studies on most of the metals similar to the isotope study on lead. It can also be noted that, if you compare the CKD analysis in Table 6 with the concentrations found in the soils in the city in Tables 7, 8, 9, the lead concentration in the CKD is lower than that in the city. On the other hand, the concentrations of arsenic, chromium, zinc, and other metals in the CKD are frequently higher, sometimes much higher, than those in the city. The contribution from the airborne CKD to the soil in the city appears to be small.

The sentences, "The pile presents little to attract trespass. Any access to the pile is not likely to be frequent or prolonged," are questionable statements about human behavior. While the authors of the draft may see little to attract trespass, can the authors point to any studies that demonstrate these sentences reflect human behavior?

Response: The text has been changed to reflect the documented activity that does occur on the pile. We stand by our judgment that there is not likely to be frequent or prolonged access to the pile. There is no evidence that there is a lot of trespassing on the pile.

Comment: p. 36. I think employees and contractors should be mentioned as persons who might be exposed to dust from the pile.

Response: A paragraph has been added addressing this issue.

Comment: p. 37. "There is no available evidence to connect this contamination with the CKD pile." Does this mean it should not be investigated? Does this mean that the existing evidence indicates that there is no connection?

Response: The statement quoted does not say and is not meant to imply anything about investigating the fish or the existence of evidence that there is no connection. The problem of contamination in the fish in Lake Huron is much broader than can be addressed in this Public Health Assessment, and is being addressed by the MDEQ, the Ontario Ministry of Energy and the Environment, the U.S. EPA, and other appropriate agencies.

Might the fish in our bay be better than other Michigan fish were it not for this pile and the other Alpena pollution? It seems dubious to set standards at whatever generally prevails.

Response: Regarding the fish in Thunder Bay, those fish that stay within the bay might contain somewhat less contaminants than other fish in Lake Huron if there was no pollution from Alpena, and other fish in the lake might contain less contaminants than they do now. The problem of contamination in the fish in Lake Huron is much broader than can be addressed in this Public Health Assessment, and is being addressed by the MDEQ, the Ontario Ministry of Energy and the Environment, the U.S. EPA, and other appropriate agencies.

In the groundwater section, naming one pile the lake shore pile and the other Pike's Peak might make this discussion clearer.

Response: See our response to the earlier comment to page 2 (page RS-4).

Do groundwater and well-drilling authorities know about this contamination?

Response: The MDEQ and the District Health Department, the existing groundwater and well- permitting authorities, know very much about this contamination.

[pile misspelled as "plie."]

Response: The error has been corrected.

Comment: p. 41. Does the MDCH know the leukemia rate for Alpena?

Response: The observed numbers of leukemia cases were not significantly elevated in Alpena County and zip code 49707 from 1985 through 1995 for all years combined and for each individual year in comparison with the entire State of Michigan. The observed numbers of leukemia deaths were not significantly elevated in Alpena County from 1985 through 1997 and zip code 49707 from 1989 through 1997 for all years combined and for each individual year in comparison with the entire State of Michigan.

Does the benzene level in Alpena exceed what one might expect from the population size and the number of cars located here?

Response: The data necessary to make any such judgment is not readily available.

Benzene causes leukemia and so does cadmium. We get it twice in Alpena. Here the death certificate study would be helpful.

Response: See our response on page RS-2 to the general comments regarding a manual tabulation of death certificates.

Comment: p. 43. How does the MDCH know that persons in Alpena receive only a brief exposure to dioxins and furans?

Response: That is what the currently available ambient air monitoring data shows. There was a fairly constant low background of certain relatively low-toxicity dioxins and furans, but the more toxic congeners such as 2,3,7,8-TCDD were only detected on a few days during the year.

Can a single exposure to dioxin or furan affect an unborn child?

Response: According to one theory, yes, especially at high doses. However, the chain of events thought to be involved in producing a health effect from an exposure is fairly complex and more likely to occur after a high exposure or a long series of exposures.

Comment: p. 47. Please have a professional sanitarian and a nutritionist review the assessment. Some of the statements on this page and elsewhere in the assessment might be changed based on a review by persons in these areas of study.

Response: Thank you for the suggestion. The assessment has been reviewed by professionals in all appropriate disciplines.

Does the MDCH know how the flow of the river affects the water coming to the city intake? How forceful is the flow of the river, and for what distance into the bay? Might it swirl and bring contaminants to the intake?

Response: According to a manager at the city water plant, the National Oceanic and Atmospheric Administration (NOAA) once attempted to chart the currents in Thunder Bay, but came up with very inconclusive results. The paths of the buoys NOAA used were very dependent on wind direction even though they were designed to be more affected by water currents. The manager said his experience tended to agree with that. When the wind is out of the northeast, the plant will pull river water into the intake. When the wind is from the northwest, water from the bay is pushed into the lake. The latter is the prevailing condition (101).

What are the results of the water testing taken at the intake? Bob Wagner or John Vick can provide water testing for samples taken near the intake.

Response: The water is sampled and tested for metals annually, and nothing indicating contamination from the CKD pile has been seen (101).

Comment: p. 48. "Is not likely to result in any apparent increased risk of contracting cancer." What does apparent mean here? Maybe "appreciable" was meant.

Response: "No Apparent Risk" is ATSDR's preferred designation for a certain level of increased risk of contracting cancer, between their "No Risk" threshold of 1 additional cancer case in one million people exposed and their "Low Risk" range.

The last sentence on page 48 and continuing on to page 49 is confusing. It would be better to separate the ideas in this sentence into at least two sentences. "A child subject to pica behavior would not be likely to ingest or absorb through the skin enough arsenic in a day from soil in some residential areas of Alpena to exceed the amounts that have been observed to cause adverse health effects in documented exposures of less than 10 years." It is the last part of the sentence I cannot make sense of. Does a child subject to pica behavior have an increased chance of changes in the cardiovascular system or skin? Whatever the answer to this question is, I would make a separate sentence.

Response: The passage has been revised to present the message more clearly.

What are the levels of prostate cancer and leukemia in Alpena? I think that a review of death certificates would find more prostate cancer than has been reported to the state registry. This is based on my own review, but I am not a professional statistician.

Response: See above response to the comment on page 41 concerning leukemia. The observed numbers of prostate cancer cases were not significantly elevated in Alpena County and zip code 49707 from 1985 through 1995 for all years combined and for each individual year in comparison with the entire State of Michigan. The observed numbers of prostate cancer deaths were not significantly elevated in Alpena County from 1985 through 1997 for all years combined and for each individual year in comparison with the entire State of Michigan. The observed number of prostate cancer deaths was significantly elevated in zip code 49707 from 1989 through 1997 for all years combined in comparison with the entire State of Michigan. However, the observed numbers of prostate cancer deaths were not significantly elevated in zip code 49707 for any individual year from 1989 through 1997 in comparison with the entire State of Michigan.

Comment: p. 52. "The MDCH and the district health department serving Alpena have programs in place to address the potential health problems from childhood lead exposure." Are these programs receiving adequate funding to meet the needs of Alpena? The health district has had its budget cut in the last several years.

Response: Such questions are best addressed to the relevant sections of the MDCH and the District Health Department.

Comment: p. 53. What about birth defects from mercury compounds? Minamata.

Response: The discussion includes all documented adverse health effects related to exposure to mercury, as listed in ATSDR's Toxicological Profile for the element, including birth defects from prenatal exposure through the mother's diet, at both Minamata, Japan, and another incident in Iraq (73). If a health effect was not mentioned in the toxicological discussion, the estimated exposure was less than that which has been associated with the health effect.

The birth defect survey done so far in the assessment is for only three years. Does this avoid the neural tube defects in the most recent five years? I am not satisfied that a 3-year review is enough to find possible birth defects which are related to pollution.

Response: Since MDCH issued the draft, we have analyzed additional birth defect data for 1995 and 1996. As mentioned in the text, the Michigan Birth Defect Registry was established in 1992, and the most recent data available is that for 1996. The analysis of birth defect data from Alpena County from 1992 through 1996 showed no elevation in the numbers or rates of congenital abnormalities as compared with the entire State of Michigan. Because the overall rates and numbers showed no increase, MDCH did not analyze the birth defect data for specific major congenital anomalies, including spinal abnormalities, for the years 1995 through 1996.

["Lungs" misspelled as "lings"]

Response: The error has been corrected.

The draft's fish advisory table does not include the mercury contamination in Lake Besser.

Response: A discussion of the available Lake Besser fish data and existing advisories has been added to the text.

Comment: p. 54. "No one is likely to spend so much time on the cement kiln dust pile east of Lafarge ..." What about employees and contractors?

Response: No one is working on the CKD pile on the lake shore at the present time.

What about Pike's Peak, which is a large elevated field near a residential area? Pike's Peak has had two grass fires so far this Spring.

Response: To date, there has been no data indicating that "Pike's Peak" posed any health risks beyond the physical risks posed by any equivalent hill. The cover placed over the CKD when the quarry was filled and closed should have protected the population from exposure to the CKD. Unfortunately, a recent MDEQ inspection revealed that the cover has eroded away in places. The MDEQ has collected samples of soil, sediment, and surface water from the area, however, the data on the analysis of these samples is not available as of this writing (4, 5). MDCH is very interested in evaluating this data for possible health hazards when it is available.

Comment: p. 58. I am not satisfied that a 3-year review is enough to find possible birth defects which are related to pollution.

Response: See the response to the similar comment to page 53.

There is nothing about PCB's and the studies linking PCBs to Attention Deficit Disorder and similar conditions.

Response: Neither the ATSDR in the Toxicological Profile for PCBs (82) or the National Attention Deficit Disorder Association (88) mention any link between PCB exposure and Attention Deficit Hyperactivity Disorder. The hypothesis has been made that since a genetic syndrome called Resistance to Thyroid Hormones (RTH) has been linked to ADHD and that Dioxin-Like Chemicals (DLCs) (including Dioxins and PCBs) can interfere with the actions of thyroid hormones, exposure to DLCs might be linked to ADHD. The available evidence is equivocal. Studies of the children of Great Lakes fisheaters found hypoactivity, while studies of Taiwanese who ate rice oil tainted with a mixture of dioxins, PCBs, and other DLCs found hyperactivity. More research is required before the hypothesis can be even provisionally accepted (103).

What of a child who eats PCB tainted fish and then has lead and mercury in his body? [and pages 62 and 63]

Response: PCBs, lead, and mercury, although their effects are similar, act on the body through different mechanisms. The effects of exposure to one of these chemicals are not likely to be affected by the child's exposure to another, although each could have its own separate health effects.

Comment: p. 61. How does the MDCH know that Alpena colon and rectal, and cervical cancers were [mis]diagnosed? Because the rates were elevated is it assumed that it was due to misdiagnosis? Or is there another reason?

Response: The Division for Vital Records and Health Statistics (DVRHS) compiled cancer cases from the Michigan Cancer Registry and cancer deaths from the Michigan Resident Death Files for Alpena County and the zip code (49707) that contains the City of Alpena. In addition, DVRHS conducted a records review and determined that rectal cancers were falsely elevated due to misdiagnosis in 1986 and 1987, which were the two individual years with the highest SIRs for rectal cancer. DVRHS is currently conducting a records review of rectal cancers for the other nine years in the 11-year period. Colon cancers are commonly misdiagnosed as rectal cancers and the two cancers are often combined into one category for investigation and cancer monitoring purposes. DVRHS also conducted a records review for cervix uteri cancers and determined that the number of cases was falsely elevated due to misdiagnosis in 1985 and 1988. Pre-invasive cervix uteri disease is frequently misdiagnosed a cervix uteri cancer. If you would like a more detailed explanation of how DVRHS determined that errors in reporting occurred, please contact Brendan Boyle of MDCH at 1-800-647-6942.

We in Alpena can even supply some lifestyle information on persons who died years ago; things like whether they smoked or were overweight. We can make these records very good. Time trends and incidence can be determined if the MDCH wants to do it.

Response: Demographic, lifestyle and mortality information for the City of Alpena and zip code 49707 residents would be helpful if demographic, lifestyle and mortality information is also collected from a comparison population to identify differences.

Comment: p. 63. What about miscarriages and still births? Were they as expected?

Response: The incidence of miscarriages is unknown because most miscarriages occur before the woman recognizes her pregnancy. An analysis of stillbirths in Alpena County was not conducted.

Comment: p. 70. Melody Jaskolski reported that several dogs, including her own, in her State Street neighborhood had seizures.

Response: We have considered that report, in consultation with veterinarians, and came to no conclusion regarding environmental hazards and seizures in dogs.

Comment: p. 72. What is the other known source of dioxin in the Lake Huron watershed?

Response: There have been many documented dioxin contamination events in the Lake Huron watershed, associated with chemical and automotive plants along the Saginaw and Tittabawassee Rivers and paper mills along the Escanaba River and the Menominee River.

Also the way this sentence is worded it sounds like Lafarge is a source of dioxin and there is another one. Is Lafarge a source of dioxin or not?

Response: Monitoring data shows that Lafarge's stack gas has contained some dioxins, although not in excess of the limits in their discharge permit from the MDEQ.

Comment: In a few places it seems to say that a finding of a contaminant in soil, water, or air is explainable in some way. For instance, that the lead in the soil is from leaded gasoline, or that the benzene in the air is from gasoline stations. If it is the case that this is what the report is saying, that nationwide benzene levels in the air are elevated from gasoline stations or that nationwide elevated levels of lead tend to be from leaded gasoline, then the draft should say that.

The way these are worded now, it seems to imply that in Alpena, the MDCH has done a study and determined that the levels of lead and benzene found in Alpena can be fully explained by these sources. I do not believe that the MDCH has done such a study. Someone on your staff would have had to estimate the level of benzene attributable to the number of gas stations, and the frequency of activities at the gas stations, and then determined if this level represents the level found in Alpena. And so forth for lead in the soil.

Response: Our mentioning of some specific alternate sources, other than emissions from the Lafarge plant, was not meant to exclude other potential sources, such as leaded paint and home use of benzene-containing solvents. We did not and cannot describe the proportional contribution from all possible sources.

During the MDCH Availability Session on May 4, 1999, several Alpena residents made comments about the draft Public Health Assessment to the MDCH. These comments and the MDCH responses are summarized below.

Comment: How is the classification "urban" (vs. rural) made? Why is Alpena considered urban?

Response: The urban/rural classification in Table 1 was made by the CensusCD software which analyzed the data, using the U.S. Census Bureau definitions, which include, "The Census Bureau defines 'urban' for the 1990 census as comprising all territory, population, and housing units in urbanized areas and in places of 2,500 or more persons outside urbanized areas." (Help Screen, CensusCD software, Reference 7.) An "urbanized area" according to the Census Bureau definition has a minimum population density of 1,000 per square mile and a total population of at least 50,000. Alpena has the density (1,335 per square mile overall) but not the total population to be classified as an "urbanized area." However, it is a "place of 2,500 or more persons," and it is therefore considered urban.

Comment: If Alpena has the same rates of cancer as the rest of the state, why is the hospital building a $6 million cancer center?

Response: Any questions about the decision-making process and the exact criteria used are best directed to the hospital administration. One consideration is that cancer of all sorts occurs more commonly in older people, and the average age of Alpena area residents has been rising (39 years), compared to the state (34.8). An older population will have more cancer cases than a younger one, even with the same "age-adjusted" rates in both. In addition, if there is to be a cancer center within a reasonable driving distance of people in northeast Michigan, Alpena's central location, Alpena General Hospital itself, and the infrastructure of the largest city in the area would make the city a logical site for it.

Comment: Why are there no dioxin advisories for fish in Thunder Bay?

Response: See the above response to the comment to page 31.


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